Right to Work Policy
Ashley Cleaning Services is committed to operating as a responsible and legally compliant commercial cleaning company. We recognise our duty as an employer to prevent illegal working in the United Kingdom and to ensure that every person engaged by the company has a valid legal right to work before commencing employment.
Compliance with UK Immigration Legislation, Employment Law and Health & Safety Requirements
Policy Owner: Ashley Cleaning Services
Policy Area: Human Resources / Recruitment Compliance
Applies To: All employees, workers, agency workers, contractors and managers
1. Policy Statement
Ashley Cleaning Services is committed to operating as a responsible and legally compliant commercial cleaning company. We recognise our duty as an employer to prevent illegal working in the United Kingdom and to ensure that every person engaged by the company has a valid legal right to work before commencing employment.
Ashley Cleaning Services will comply with all applicable UK immigration, employment, equality and health and safety legislation. No individual will be permitted to undertake cleaning duties, attend client sites, or represent the company unless the required right to work checks have been completed and recorded.
The company is committed to ensuring that right to work procedures are carried out fairly, consistently and without discrimination.
2. Purpose of This Policy
The purpose of this policy is to:
Ensure compliance with UK immigration legislation.
Prevent illegal working within Ashley Cleaning Services.
Establish clear procedures for checking and recording employees’ right to work status.
Protect the company from civil penalties and enforcement action.
Ensure all employees are treated fairly and equally.
Provide managers with clear responsibilities when recruiting and managing staff.
Support safe working practices by ensuring all workers are properly authorised, trained and documented before entering workplaces and client premises.
3. Legal Framework
Ashley Cleaning Services operates this policy in accordance with:
Immigration, Asylum and Nationality Act 2006.
UK Home Office Right to Work guidance.
Equality Act 2010.
Health and Safety at Work etc. Act 1974.
Management of Health and Safety at Work Regulations 1999.
Control of Substances Hazardous to Health Regulations 2002 (COSHH).
Provision and Use of Work Equipment Regulations 1998 (PUWER), where applicable.
Personal Protective Equipment at Work Regulations 1992 (as amended).
Data Protection Act 2018 and UK GDPR.
The Home Office requires employers to carry out prescribed checks before employment begins to establish a statutory excuse against penalties for illegal working.
4. Scope of Policy
This policy applies to:
Permanent employees.
Temporary employees.
Part-time employees.
Casual workers.
Agency workers.
Apprentices.
Contractors.
Subcontractors.
Self-employed individuals engaged by Ashley Cleaning Services.
All individuals working on behalf of Ashley Cleaning Services must provide evidence that they are legally entitled to work in the UK.
5. Responsibilities
5.1 Directors and Senior Management
Ashley Cleaning Services directors are responsible for:
Ensuring the company maintains lawful recruitment practices.
Providing adequate resources for compliance.
Ensuring managers understand their responsibilities.
Reviewing compliance procedures regularly.
5.2 Managers and Supervisors
Managers are responsible for:
Ensuring no person starts work before right to work checks are completed.
Checking that employees attending cleaning contracts are authorised to work.
Reporting any concerns regarding documentation or employment status.
Ensuring workers receive appropriate health and safety induction before starting duties.
Ensuring cleaning staff are trained in safe use of chemicals, equipment and PPE.
5.3 Employees and Workers
Employees must:
Provide genuine documents or online verification evidence when requested.
Inform Ashley Cleaning Services immediately of any change affecting their right to work.
Follow company health and safety procedures.
Attend required training.
Use cleaning chemicals and equipment safely.
6. Recruitment and Right to Work Procedure
6.1 Before Employment Begins
Ashley Cleaning Services will complete a right to work check before any employee:
Starts employment.
Undertakes cleaning duties.
Accesses client premises.
Receives payment for work performed.
No manager may allow an individual to work before confirmation has been received.
7. Acceptable Right to Work Checks
Ashley Cleaning Services will complete checks using one of the approved methods:
Option 1 – Manual Document Check
Where applicable, the company will:
Obtain original acceptable documents.
Check the documents in the presence of the holder.
Confirm the photograph matches the individual.
Confirm dates and restrictions.
Copy and securely store evidence.
Record:
Date the check was completed.
Who completed the check.
How the check was performed.
Option 2 – Home Office Online Check
Where an individual has a digital immigration status, Ashley Cleaning Services will:
Obtain the individual’s share code.
Access the Home Office online checking service.
Confirm the individual’s identity.
Confirm permission to work and any restrictions.
Retain evidence of the online check.
8. Follow-Up Checks
Where a worker has time-limited permission to work:
Ashley Cleaning Services will:
Record the expiry date.
Conduct a follow-up check before permission expires.
Not allow continued work if permission cannot be verified.
Employees must cooperate with follow-up checks.
9. Right to Work Restrictions
Where an individual has limited permission to work, Ashley Cleaning Services will ensure:
Working hours restrictions are followed.
Job restrictions are respected.
Expiry dates are monitored.
Any Home Office conditions are complied with.
Examples may include restrictions on:
Maximum weekly working hours.
Types of employment permitted.
Requirement for additional approval.
10. Recruitment Equality and Non-Discrimination
Ashley Cleaning Services is committed to preventing discrimination.
Right to work checks will:
Be applied consistently to all applicants.
Not be based on appearance, nationality, accent, ethnicity or name.
Not involve unnecessary requests for additional documents.
Follow Home Office prescribed procedures.
The company recognises its obligations under the Equality Act 2010.
11. Agency Workers and Contractors
Where agency workers or subcontractors are used:
Ashley Cleaning Services will require confirmation that:
Right to work checks have been completed.
Records are maintained.
Workers supplied have appropriate authorisation.
Ashley Cleaning Services may request evidence of compliance from suppliers.
No subcontractor may provide workers without appropriate legal checks.
12. Record Keeping Requirements
Ashley Cleaning Services will maintain confidential records including:
Copies of right to work evidence.
Online verification records.
Dates of checks.
Employee details.
Follow-up dates.
Records will be:
Stored securely.
Accessed only by authorised personnel.
Retained in accordance with legal requirements and company retention procedures.
13. Data Protection
Right to work information contains personal data.
Ashley Cleaning Services will:
Store information securely.
Limit access.
Process information only for legitimate employment purposes.
Dispose of records securely when no longer required.
14. Health and Safety Compliance Connection
Ashley Cleaning Services recognises that ensuring workers are legally authorised and properly documented supports safe working practices.
Before employees undertake cleaning duties, the company will ensure:
Suitable induction is provided.
Employees understand workplace hazards.
COSHH training is completed where required.
Appropriate PPE is provided.
Equipment training is completed.
Emergency procedures are explained.
Cleaning employees may work with:
Chemical substances.
Machinery.
Wet surfaces.
Electrical equipment.
Waste materials.
Client-controlled environments.
All workers must follow Ashley Cleaning Services’ Health & Safety procedures.
15. Preventing Unsafe Working Practices
Ashley Cleaning Services will not permit:
Untrained workers to operate specialist equipment.
Workers to use chemicals without appropriate instruction.
Workers to undertake duties without required PPE.
Individuals without confirmed right to work to attend client contracts.
16. Suspicion of Invalid Documents or Illegal Working
If Ashley Cleaning Services has concerns regarding right to work evidence:
The company will:
Not make assumptions based on nationality or appearance.
Seek advice from the appropriate authority where necessary.
Investigate confidentially.
Follow fair employment procedures.
Employees will not automatically be dismissed without appropriate investigation and legal advice.
17. Failure to Provide Evidence
If an individual cannot provide acceptable evidence:
Ashley Cleaning Services may:
Delay commencement of employment.
Suspend work activities.
Seek clarification through appropriate channels.
Take further action in accordance with employment law.
18. Training and Awareness
Managers responsible for recruitment will receive training on:
Right to work requirements.
Document checking procedures.
Equality and discrimination prevention.
Record keeping responsibilities.
Health and safety training will be provided according to job requirements.
19. Auditing and Monitoring
Ashley Cleaning Services will periodically review:
Employee records.
Right to work expiry dates.
Recruitment procedures.
Contractor compliance.
Any failures identified will be corrected promptly.
20. Policy Review
This policy will be reviewed:
Annually.
Following changes in legislation.
Following guidance updates from the Home Office.
Following any compliance concerns.
Ashley Cleaning Services
Committed to lawful employment, safe working practices and professional cleaning standards.
Ashley Cleaning Services Limited ©