{{org_field_logo}}

{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Communication and Record-Keeping Policy

1. Purpose

The purpose of this policy is to provide clear and robust guidance to all staff and temporary workers of {{org_field_name}} on the principles and expectations relating to communication, information handling, and record-keeping when supplying temporary healthcare workers to care homes, nursing homes, hospitals, and other healthcare or social care settings.

Effective communication and accurate record-keeping are essential to safe working, continuity of care, safeguarding, accountability, legal compliance, and the protection of service users’ rights, wellbeing, dignity, and confidentiality.

{{org_field_name}} operates as a temporary staffing agency/employment business and does not provide regulated care in its own right. Care delivery, care planning, clinical decision-making, and statutory provider records remain the responsibility of the client or hirer. However, all workers supplied by {{org_field_name}} must comply with the client’s local policies, procedures, documentation systems, handover arrangements, confidentiality requirements, and lawful instructions while on assignment.

This policy reflects the requirements and principles of applicable legislation and guidance, including the Employment Agencies Act 1973, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, the Agency Workers Regulations 2010, the Working Time Regulations 1998, the Equality Act 2010, the Health and Safety at Work etc. Act 1974, the Immigration, Asylum and Nationality Act 2006, the Data Protection Act 2018, the UK General Data Protection Regulation, and, where relevant to the role, safeguarding and DBS requirements. Registered professionals must also comply with their own professional codes, including the NMC Code where applicable.

2. Scope

This policy applies to:

• All registered nurses, healthcare assistants, senior carers, support workers, and other temporary workers employed or engaged by {{org_field_name}} under zero-hours, flexible, worker, employee, or contract-for-services arrangements
• All directors, managers, consultants, coordinators, recruiters, payroll staff, compliance staff, and office-based personnel responsible for recruitment, bookings, assignment management, worker records, client records, payroll information, compliance checks, or service delivery
• All temporary assignments in client or hirer premises, including care homes, nursing homes, hospitals, supported living services, domiciliary care providers, and other healthcare or social care settings
• All records created, received, reviewed, or retained by {{org_field_name}}, including recruitment records, work-seeker files, client or hirer records, assignment confirmations, timesheets, right-to-work evidence, DBS and safeguarding information, training and competency records, incident reports, complaints, supervision records, payroll records, communications, emails, messages, and audit records
• All forms of communication and record-keeping, whether verbal, handwritten, electronic, telephone-based, email-based, app-based, text message, messaging-platform based, or paper-based.

3. Related Policies

• Data Protection and Confidentiality Policy
• Safeguarding Adults and Children Policy
• Incident and Accident Reporting Policy
• Complaints Policy
• Whistleblowing Policy
• Code of Conduct
• Professional Boundaries and Relationships Policy
• Recruitment and Selection Policy
• Safer Recruitment Policy
• Right to Work Policy
• DBS and Criminal Records Checks Policy
• Agency Worker Regulations Policy
• Working Time and Rest Breaks Policy
• Equality, Diversity and Inclusion Policy
• Health and Safety Policy
• Information Security Policy
• Records Retention and Disposal Policy
• Staff Suitability and Compliance Checks Policy
• Assignment Booking and Client Communication Procedure
• Payroll and Timesheet Policy
• Modern Slavery and Labour Exploitation Policy

4. Policy Statement

{{org_field_name}} is committed to ensuring that all communication and record-keeping practices carried out by its directors, office staff, and temporary workers are lawful, ethical, accurate, timely, confidential, respectful, accessible, and appropriate to the circumstances.

As a temporary staffing agency/employment business, {{org_field_name}} will maintain records that demonstrate compliance with recruitment, employment agency, employment business, agency worker, working time, right-to-work, safeguarding, DBS, equality, health and safety, payroll, and data protection obligations. Records must be sufficient to evidence the checks completed before workers are introduced or supplied to clients, the information obtained from clients, the information provided to workers and clients, and the steps taken where concerns arise about suitability, conduct, competence, incidents, complaints, safeguarding, confidentiality, or safety.

All temporary workers must follow the client’s local communication, handover, reporting, and record-keeping procedures while on assignment. Poor communication, inaccurate records, falsified records, missing records, or inappropriate disclosure of information may place service users, workers, clients, and {{org_field_name}} at risk and may result in corrective action, suspension from assignments, referral to a professional body or safeguarding authority, or disciplinary action.

5. Responsibilities

Director / Responsible Person

The Director or nominated Responsible Person has overall responsibility for the implementation, monitoring, and review of this policy. As {{org_field_name}} does not provide regulated care directly and is not registered with CQC, references to management responsibility in this policy relate to the agency’s internal governance, staffing, compliance, and oversight arrangements.

The Director or Responsible Person will:

• Ensure that this policy is implemented across the agency
• Ensure that staff and temporary workers receive appropriate induction and refresher training on communication, confidentiality, information governance, record-keeping, and assignment documentation
• Ensure that recruitment, suitability, right-to-work, DBS, training, qualification, professional registration, and assignment records are maintained accurately and securely
• Ensure that client and hirer information is obtained and recorded before workers are supplied, including role requirements, location, duties, hours, health and safety risks, required qualifications, training, experience, authorisations, and any safeguarding or vulnerability-related requirements
• Ensure that workers receive appropriate assignment information before commencing work
• Review incidents, complaints, safeguarding concerns, breaches, audits, or feedback that identify communication or record-keeping failings
• Ensure that corrective action is taken where issues are identified, including retraining, supervision, suspension from assignments, disciplinary action, client notification, regulatory referral, or safeguarding referral where appropriate
• Ensure that records are retained, reviewed, archived, deleted, or securely destroyed in accordance with legal requirements and the agency’s retention schedule.

Recruitment, Compliance, Booking, and Office Staff

Recruitment, compliance, booking, payroll, and office-based staff are responsible for:

• Creating and maintaining accurate work-seeker and client records
• Recording all relevant communications with workers, candidates, clients, hirers, referees, training providers, DBS bodies, professional regulators, payroll providers, and other relevant parties
• Ensuring that required checks are completed and recorded before a worker is introduced or supplied to a client
• Ensuring that assignment details are communicated clearly to workers and clients
• Recording client requirements accurately, including duties, dates, times, location, pay and charge arrangements where relevant, required skills, required qualifications, professional registration, DBS level, training requirements, health and safety information, and any known risks
• Escalating any concerns about suitability, conduct, competence, identity, right to work, safeguarding, complaints, incidents, or data protection immediately to the Director or Responsible Person
• Maintaining confidentiality and complying with UK GDPR, the Data Protection Act 2018, and the agency’s information security procedures.

All Staff

All staff are responsible for:

• Communicating clearly, respectfully, and effectively with service users, colleagues, client staff, and families
• Maintaining accurate, complete, and contemporaneous records
• Adhering to the confidentiality requirements of the Data Protection Act 2018 and UK GDPR
• Reporting any communication or documentation concerns immediately
• Complying with client-specific policies when working in external care settings

6. Principles of Effective Communication

Effective communication is essential to maintaining service user safety, dignity, and well-being. All staff must:

• Use language appropriate to the situation and service user’s needs, considering literacy, cognitive ability, cultural background, and sensory impairment
• Listen actively and attentively to service users, families, colleagues, and others
• Provide information in a clear, concise, honest, and respectful manner
• Seek clarification when unsure and avoid making assumptions
• Be open and transparent, especially when communicating about incidents, complaints, or safeguarding concerns
• Avoid jargon and complex language, particularly when speaking with service users and families
• Adapt communication methods for individuals who require alternative forms of communication, such as non-verbal communication or the use of aids
• Document verbal communications, handovers, and discussions that have an impact on care or outcomes within care records
• Ensure that assignment information is communicated to workers before the assignment starts, including the client name, location, shift date and times, role, expected duties, dress code or uniform requirements, reporting arrangements, local induction requirements, required documentation, and any known health and safety risks
• Ensure that workers know who to contact at {{org_field_name}} and at the client site if they are delayed, unable to attend, concerned about safety, unsure about duties, asked to work outside their competence, or involved in an incident
• Ensure that client instructions are recorded accurately and not altered, abbreviated, or passed on in a way that could mislead the worker
• Ensure that communication with clients about worker suitability, performance, complaints, safeguarding, incidents, or concerns is factual, professional, confidential, and recorded
• Avoid using informal messaging platforms for confidential personal data unless authorised by {{org_field_name}} and appropriate security safeguards are in place
• Ensure that urgent concerns are communicated by the fastest appropriate method and followed up with a written record.

7. Principles of Record-Keeping

Good record-keeping is essential to protect service users and staff, provide continuity of care, and demonstrate professional accountability. In addition to care-related records completed within client systems, {{org_field_name}} must maintain agency records that are sufficient to demonstrate compliance with the Employment Agencies Act 1973, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, the Agency Workers Regulations 2010, right-to-work requirements, working time obligations, safeguarding requirements, DBS requirements, data protection law, payroll obligations, and contractual obligations to clients and workers.

All records must be:

• Accurate, factual, and free from personal opinions or inappropriate language
• Clear, concise, and legible
• Dated, timed, and signed by the person making the entry
• Completed contemporaneously (at the time of or as soon as possible after the event)
• Confidential and only accessible to authorised persons
• Comprehensive and reflective of the care provided, including assessments, interventions, outcomes, and service user responses
• Written in accordance with the client’s documentation standards, as temporary workers are required to comply with local systems, forms, and electronic record-keeping protocols
• Corrected appropriately when errors are made, ensuring the original entry remains visible and signed
• Supported by incident forms when applicable, especially in the case of adverse events
• Created and maintained in a way that demonstrates who made the record, when it was made, what information was relied upon, and what action was taken
• Stored in the correct worker, candidate, client, assignment, incident, complaint, payroll, safeguarding, or compliance file
• Retained only for as long as required by law, regulatory expectation, contractual need, legitimate business need, or the agency’s retention schedule
• Not falsified, backdated, misleadingly amended, deleted, concealed, or destroyed outside the agency’s retention and disposal process
• Capable of being retrieved promptly for audit, investigation, complaint handling, safeguarding, payroll, employment dispute, data subject request, regulator request, or legal claim purposes
• Clearly distinguished between facts, professional opinions, client feedback, allegations, concerns, and decisions.

7.1 Agency Compliance Records

{{org_field_name}} will maintain appropriate records for each work-seeker, temporary worker, client, hirer, and assignment. These records may include, where applicable:

• Candidate application details and date of application
• Identity checks
• Right-to-work checks and follow-up check dates where time-limited permission applies
• Contact details and emergency contact details
• Terms of engagement, contracts, worker status information, and key information documents where required
• Role preferences, availability, restrictions, and agreed working arrangements
• Employment history, references, interview notes, and suitability assessments
• Training, induction, competency, and mandatory training records
• Professional qualifications, authorisations, professional registration checks, PIN checks, revalidation or renewal dates, and restrictions on practice where applicable
• DBS check details, barred list checks where legally permitted and required, risk assessments, and renewal/update service checks where applicable
• Safeguarding declarations and records of concerns or referrals
• Health declarations, occupational health information, reasonable adjustments, and fitness-to-work information where relevant and lawful
• Assignment confirmations and booking records
• Timesheets, pay records, holiday records, working time records, and rest break records
• Client requirements, role descriptions, shift details, health and safety information, and site-specific instructions
• Records of complaints, incidents, accidents, concerns, investigations, outcomes, and learning actions
• Records of communication with workers, clients, regulators, professional bodies, safeguarding authorities, payroll providers, and other relevant third parties.

Records must be accurate, proportionate, secure, up to date, and limited to what is necessary for the purpose for which they are held.

7.2 Information to be Obtained Before Supplying Workers

Before introducing or supplying a worker to a client or hirer, {{org_field_name}} must obtain and record sufficient information to select a suitable worker for the assignment. This includes, where applicable:

• The identity of the client or hirer and the nature of the client’s business
• The assignment start date and expected duration
• The position to be filled and the type of work required
• The location of the assignment
• The working hours, shift pattern, breaks, and reporting arrangements
• Any known health and safety risks and the steps taken by the client to prevent or control those risks
• The experience, training, qualifications, professional registration, DBS level, barred list requirement, authorisation, or competency required for the role
• Any expenses payable by or to the worker
• Any special requirements relating to vulnerable adults or children
• Any client-specific induction, uniform, documentation, handover, reporting, or record-keeping requirements.

Where the assignment involves working with, caring for, or attending vulnerable persons, {{org_field_name}} must take particular care to confirm identity, suitability, qualifications, experience, training, authorisations, and safeguarding requirements before supply.

7.3 Suitability Concerns and Duty to Inform the Hirer

If {{org_field_name}} receives or obtains information indicating that a worker may be unsuitable for an assignment, this must be escalated immediately to the Director or Responsible Person.

Where the information gives reasonable grounds to believe that the worker may be unsuitable, {{org_field_name}} will, without delay:

• Inform the client or hirer of the relevant concern, where lawful and appropriate
• Make further enquiries as reasonably practicable
• Record the concern, enquiries, evidence, decision, and outcome
• Remove, suspend, or not supply the worker where required to protect service users, workers, clients, or others
• Consider whether safeguarding, professional regulator, DBS, police, local authority, or other external referral is required
• Ensure that any disclosure is factual, proportionate, lawful, and limited to those who need to know.

Where {{org_field_name}} has reasonable grounds to believe that the worker is unsuitable for the position concerned, the worker must not be supplied or must be withdrawn from the assignment where already supplied, subject to lawful and fair process.

8. Confidentiality and Data Protection

Staff and workers must adhere strictly to confidentiality and data protection requirements at all times.

{{org_field_name}} processes personal data relating to candidates, workers, clients, service users, referees, complainants, staff, and other individuals. This may include special category data, such as health information, occupational health information, disability-related information, and safeguarding information. It may also include criminal offence data, including DBS-related information, where lawful and necessary.

All personal data must be handled in accordance with the UK GDPR, Data Protection Act 2018, the agency’s Data Protection and Confidentiality Policy, and any applicable client information governance procedures.

Staff and workers must:

• Only access records where they have a legitimate work-related need
• Only share information with those who are authorised and have a legitimate need to know
• Use the minimum amount of personal data necessary for the purpose
• Avoid discussing confidential information in public areas or where they may be overheard
• Keep paper and electronic records secure
• Use secure systems and approved communication channels wherever possible
• Report any actual or suspected data breach, loss, unauthorised access, misdirected email, missing record, or confidentiality concern immediately
• Not download, photograph, copy, remove, or transmit client care records unless expressly authorised, lawful, and necessary
• Not retain service user information after an assignment unless authorised by the client and lawful.

8.1 DBS and Criminal Record Information

Where DBS checks or criminal record information are required for a role, {{org_field_name}} will ensure that such information is handled lawfully, securely, confidentially, and proportionately.

DBS certificate information must only be used for the specific purpose for which it was requested and only where the role is eligible for the relevant level of check. Access to DBS information must be restricted to authorised staff who need the information to make recruitment, suitability, safeguarding, or compliance decisions.

DBS certificates or certificate information must not be copied, scanned, photographed, emailed, disclosed, or retained unnecessarily. Where certificate information is retained, the reason for retention must be documented and the information must be kept securely for no longer than necessary. Any disclosure to a client, regulator, safeguarding authority, or other third party must be lawful, proportionate, and approved by the Director or Responsible Person.

Where a DBS certificate contains information that may affect suitability, {{org_field_name}} will carry out a documented risk assessment before deciding whether the worker may be supplied. The assessment must consider the nature of the role, the relevance of the information, the seriousness and age of the matter, any pattern of behaviour, the worker’s explanation, safeguarding implications, and any client or legal requirements.

9. Electronic Records and Use of Technology

Where client organisations use electronic record-keeping systems, staff must:

• Ensure that they are trained and authorised to use the system
• Use secure logins and passwords which must never be shared
• Log out of systems when leaving workstations unattended
• Record information promptly and ensure data integrity
• Report any technical or access issues without delay

Electronic communication, including emails and messages, must also comply with data protection laws and must not include unnecessary personal information unless using secure systems approved by the client.

Staff and workers must not use personal email accounts, unapproved messaging applications, personal cloud storage, or personal devices to store or transmit confidential agency, worker, client, or service user information unless this has been expressly authorised and appropriate safeguards are in place.

Photographs, screenshots, downloads, or copies of care records, medication records, rotas, service user information, worker documents, DBS information, right-to-work documents, or client documents must not be taken or retained unless there is a lawful and authorised reason.

Where electronic systems are used, staff must ensure that records are entered under their own login and must not allow another person to use their account. Audit trails must not be manipulated or bypassed. Any suspected unauthorised access, cyber incident, misdirected message, loss of device, or system security concern must be reported immediately.

10. Verbal Handover and Shift Reports

All staff must ensure that verbal communication during shift handovers is:

• Structured, comprehensive, and accurate
• Focused on the care provided, ongoing needs, and any incidents or changes in condition
• Documented as appropriate following client procedures
• Confirm at the start of the shift who they must receive handover from and who they must hand over to at the end of the shift
• Ask for clarification if handover information is incomplete, unclear, inconsistent, or raises concerns
• Ensure that any deterioration, medication concern, safeguarding concern, accident, incident, refusal of care, missing record, or significant change is reported to the appropriate client senior staff member immediately
• Ensure that handover information is recorded in the client’s required system where it affects care, risk, safety, or continuity
• Notify {{org_field_name}} where poor handover arrangements create a risk to worker safety, service user safety, or safe care delivery.

Poor handover communication is a known risk factor for incidents and complaints and must be managed diligently.

11. Handling of Records When Working Across Multiple Clients

Due to the nature of agency work, staff and workers may work across different client sites and encounter different documentation systems, record formats, handover arrangements, and reporting procedures.

Staff and workers must:

• Familiarise themselves with the client’s record-keeping and handover procedures at the start of each assignment
• Seek guidance from the client’s manager, nurse in charge, senior carer, or nominated supervisor if unsure of documentation requirements
• Use the client’s approved documentation system only as authorised
• Not remove, alter, destroy, conceal, photograph, copy, or download client records unless expressly authorised, lawful, and necessary
• Not transfer service user information from one client setting to another
• Not retain service user information after the assignment has ended unless expressly authorised and lawful
• Not mix client records with agency records unless there is a lawful and necessary reason, such as incident reporting, safeguarding, complaint investigation, or legal compliance
• Report any missing, incomplete, inaccurate, or inaccessible records to the client’s senior staff and, where appropriate, to {{org_field_name}}
• Ensure that any agency record relating to a client incident, concern, complaint, or safeguarding matter is factual, proportionate, confidential, and stored securely.

12. Reporting Communication and Record-Keeping Errors

Any error, omission, delay, falsification, loss, unauthorised disclosure, or concern relating to communication or record-keeping must be reported immediately in accordance with {{org_field_name}}’s Incident Reporting Policy, Data Protection and Confidentiality Policy, Safeguarding Policy, and any applicable client procedure.

Examples include:

• Incomplete, missing, inaccurate, late, or illegible records
• Incorrect information entered into a client or agency record
• Records completed under another person’s login or signature
• Miscommunication leading to harm, risk, delay, missed care, missed medication, or complaint
• Failure to report deterioration, safeguarding concerns, incidents, or risks
• Breach of confidentiality or data protection
• Misdirected emails, messages, documents, or records
• Lost paperwork, lost devices, or unauthorised access to systems
• Incorrect, misleading, backdated, or falsified records
• Failure to provide required assignment, suitability, or compliance information to a worker or client.

The Director or Responsible Person will ensure that incidents are reviewed, investigated where appropriate, recorded, and acted upon. Actions may include correction of records, notification to the client, notification to the data protection lead, safeguarding referral, professional regulator referral, DBS referral, disciplinary action, worker suspension, retraining, supervision, or changes to procedures.

12.1 Right to Work Records

{{org_field_name}} must complete and retain compliant right-to-work checks before employing or engaging any worker and before supplying the worker to a client. Checks must be completed in accordance with current Home Office guidance and must be recorded clearly.

Right-to-work records must show:

• The type of check completed
• The date the check was completed
• The person who completed the check
• The evidence reviewed or online check result obtained
• Any expiry date or follow-up check date where the worker has time-limited permission
• Any restrictions on the type of work, hours, employer, or role
• Any action taken where a check cannot be completed or a concern arises.

Workers must not be supplied to clients unless {{org_field_name}} has confirmed and recorded that the worker has the right to undertake the work in question. Where a worker has time-limited permission to work, a follow-up check must be completed before the statutory excuse expires.

12.2 Agency Worker Regulations and Assignment Records

{{org_field_name}} will maintain records necessary to monitor and evidence compliance with the Agency Workers Regulations 2010.

Records should include, where applicable:

• Assignment start and end dates
• Client or hirer details
• Role and duties
• Working hours and shift patterns
• Pay rates and holiday pay arrangements
• Breaks, rest periods, and annual leave records
• Information received from the client about comparable employees or workers where required
• Records of day-one access to relevant collective facilities and information about relevant vacancies where applicable
• Records required to assess the 12-week qualifying period for equal treatment rights
• Communications with clients and workers about AWR rights, pay, duration of assignment, and working conditions.

Workers must be able to raise concerns about AWR rights without being subjected to detriment. Any AWR concern must be escalated to the Director or Responsible Person and recorded.

12.3 Working Time, Rest Break, and Holiday Records

{{org_field_name}} will maintain records necessary to comply with working time, rest break, night work, and holiday obligations. Records may include shift bookings, timesheets, hours worked, cancelled shifts, rest periods, night work, annual leave, holiday pay, and any working time opt-out or relevant workforce agreement where applicable.

Workers must report accurately the hours they have worked and must not falsify timesheets or working time records. Office staff must review working patterns for potential fatigue, excessive hours, missed rest, or unsafe scheduling, particularly where workers accept shifts across multiple clients or employers.

Where a worker raises concerns about fatigue, missed breaks, excessive hours, unsafe working patterns, or inability to take rest, {{org_field_name}} will review the concern and take appropriate action with the worker and/or client.

12.4 Equality, Accessibility and Reasonable Adjustments

{{org_field_name}} will ensure that communication and record-keeping practices comply with the Equality Act 2010. The agency will not discriminate, harass, or victimise candidates, workers, staff, clients, or others in the way it communicates, provides work-finding services, maintains records, handles complaints, or makes decisions.

Where a candidate, worker, or staff member requires a reasonable adjustment in relation to communication, documentation, training, interviews, induction, assignment information, or record-keeping, {{org_field_name}} will consider and record reasonable adjustments in a timely and lawful manner.

Records relating to disability, health, adjustments, discrimination complaints, or protected characteristics must be handled confidentially and only shared where lawful, necessary, and proportionate.

12.5 Health and Safety Communication and Records

{{org_field_name}} will communicate and record health and safety information relevant to agency assignments. Before supplying a worker, the agency will seek relevant information from the client or hirer about known risks, control measures, role requirements, PPE, infection prevention and control requirements, moving and handling expectations, lone working risks, violence and aggression risks, and any site-specific safety rules.

Workers must:

• Follow client health and safety procedures
• Use PPE and equipment as instructed
• Report hazards, accidents, incidents, near misses, unsafe staffing concerns, or unsafe instructions immediately
• Not undertake tasks outside their competence, training, or authorisation
• Inform {{org_field_name}} if they believe an assignment is unsafe or if they are asked to work in a way that places themselves or others at risk.

{{org_field_name}} will record health and safety concerns, accidents, incidents, near misses, client notifications, worker feedback, and actions taken.

13. Training and Supervision

All staff and workers will receive appropriate induction and refresher training relevant to their role. Training may include:

• Effective communication and professional conduct
• Record-keeping and documentation standards
• Confidentiality, data protection, information governance, and information security
• Incident reporting and escalation
• Safeguarding adults and children
• Whistleblowing and raising concerns
• Client handover and local documentation systems
• Use of electronic systems, passwords, and secure communications
• Right-to-work processes for relevant office staff
• DBS handling and safer recruitment for relevant office staff
• Agency Worker Regulations awareness for relevant office staff
• Working time, fatigue, rest breaks, and timesheet accuracy
• Equality, diversity, inclusion, and reasonable adjustments
• Health and safety communication and reporting.

Supervision, audit, and performance review will address communication and record-keeping where relevant, particularly where incidents, complaints, client feedback, safeguarding concerns, data breaches, or documentation errors have been identified.

14. Monitoring and Quality Assurance

The Director or Responsible Person will monitor compliance with this policy through appropriate governance and quality assurance processes. These may include:

• Worker file audits
• Client file audits
• Assignment record audits
• Right-to-work audit checks
• DBS and safeguarding record audits
• Training and competency record audits
• Professional registration and qualification checks
• Timesheet, working time, and holiday record audits
• Incident, complaint, safeguarding, and data breach reviews
• Review of client feedback and worker feedback
• Review of communication records, booking confirmations, and assignment information
• Review of trends, repeated concerns, or recurring documentation errors.

Where concerns are identified, {{org_field_name}} will take proportionate action, which may include corrective recording, retraining, supervision, client discussion, suspension from assignments, disciplinary action, referral, policy review, or procedural change.

15. Governance and Accountability

The Director or Responsible Person has overall accountability for ensuring that communication and record-keeping arrangements support safe staffing, lawful recruitment, safeguarding, continuity of care, worker protection, client confidence, and regulatory compliance.

The Director or Responsible Person will ensure that significant concerns relating to communication, record-keeping, safeguarding, suitability, confidentiality, data protection, right to work, health and safety, or professional conduct are reviewed and acted upon promptly.

15.1 Records Retention and Secure Disposal

{{org_field_name}} will retain records only for as long as necessary for the purpose for which they are held, taking account of legal, regulatory, contractual, safeguarding, employment, tax, payroll, insurance, limitation, and legitimate business requirements.

The agency will maintain a records retention schedule setting out retention periods for different categories of records, including candidate records, worker files, right-to-work checks, DBS information, training records, assignment records, timesheets, payroll records, holiday records, client records, incident records, complaints, safeguarding records, accident records, and data protection records.

Records must be securely destroyed or anonymised when no longer required, unless there is a lawful reason to retain them, such as an ongoing complaint, investigation, safeguarding matter, legal claim, audit, regulator request, or contractual dispute.

Disposal must be secure and appropriate to the format of the record. Paper records must be shredded or disposed of using confidential waste arrangements. Electronic records must be securely deleted or archived in accordance with system controls and retention procedures.

Retention and disposal decisions must be documented where required, particularly where records contain sensitive personal data, DBS information, safeguarding information, health information, or criminal offence data.

16. Policy Review

This policy will be reviewed at least annually by the Director or Responsible Person, or earlier where required due to:

• Changes in legislation, statutory guidance, or regulatory expectations
• Changes in the agency’s services, client base, systems, or operating model
• Serious incidents, complaints, safeguarding concerns, data breaches, audits, or legal claims
• Updated guidance from relevant bodies, including the Home Office, DBS, ICO, HSE, Employment Agency Standards/Fair Work Agency, professional regulators, or government departments.

The review will consider whether the policy remains suitable for a temporary staffing agency/employment business supplying workers to healthcare and social care clients.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.