A busy manufacturing company in the West Midlands was frequently recruiting shop floor workers to meet production demand. The HR team had recently mandated that Right to Work checks were carried out at final interview stage by the interviewing manager and not by HR at offer stage had been the case previously. It became apparent that some managers were accepting copies of right to work documents via email or multimedia message and not physically inspecting the original documents.
Although it was thought that the documents themselves were genuine, the failure to follow the correct checking process meant the company was technically non-compliant and at risk of fines.
HR Intervention
Working with the HR team we implemented a straightforward compliance action plan as follows:
-
- Manager Briefings: All supervisors, managers and anyone like team leaders that may be involved in interview stages received clear guidance on what constitutes a compliant right to work check—including the legal requirement to see and verify the original documents in person, or to use the official online check system where appropriate.
- Process Alignment: A standardised checklist was introduced to the onboarding process for all new hires, ensuring that no employee could start work without a verified and signed right to work record.
- On-site File Audit: All existing employee files were reviewed. Where gaps were found, HR scheduled follow-ups with employees to recheck and document their status appropriately.
- Future-Proofing: A simple tracker using an excel spreadsheet and the HRIS system was created to flag visa expiry dates and recheck deadlines, helping the company stay ahead of compliance issues. All employees were added and adding an new employee to this tracker is also part of the onboarding process.
Outcome
The company achieved full compliance within six weeks. Operationally, the process did not take up too much time of the HR team or the employees that needed rechecking. Any time spent on the audit was worth it as it gave the business peace of mind they did not have any compliance issues and had a robust plan for future proofing them.
HR Takeaway
In fast-paced, high-turnover environments like manufacturing, it’s easy to overlook detail in the name of speed— however right to work checks must follow strict Home Office guidelines. Physically checking documents (or using an approved digital method) protects your business from fines, reputational risk, and potential disruption to your workforce.
Further consideration
This particular client did not utilise agency workers however a further consideration would be to ensure you are aware of what checks a recruitment agency do and what cover they provide for you when supplying you with personnel.
L Weston 21 May 2025