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Modern day slavery & recruitment checks

Guidance about modern day slavery and the checks CIW expect providers to make for agency workers.

Published: 21 July 2022
Last updated:
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Warning signs of modern slavery

Signs of modern slavery and exploitation are often hidden. Victims can be any age, gender or ethnicity or nationality. Some common signs:

  • Legal documents (passport, ID, DBS) may be held by someone else. Victims may be forced to use false or forged identity documents
  • The person may look malnourished, unkempt, appear withdrawn or tired. They may not be dressed appropriately for the work.
  • The person may be withdrawn, unable to answer questions about themselves or give inconsistent answers.

The North Wales Safeguarding board has compiled a seven minute briefing on the indicators of modern slavery and what to do should you suspect someone is a victim of this terrible crime (External link).

We encourage you to share this with your managers and staff so that they can familiarise themselves with the signs of modern slavery. You can report concerns to the Modern Slavery & Exploitation Helpline on 0800 0121 700, and you should call 999 in an emergency. You can also report suspected labour abuse and exploitation to the GLAA (External link). The GLAA encourages the reporting of all suspicions.

Checks we expect providers to make for agency workers

Service providers are required to have rigorous selection and vetting systems in place for all staff and volunteers. This includes the information set out in schedule 1 of the Regulations (External link).

The statutory guidance (External link) clarifies agency staff are subject to the same checks as permanently employed staff. It states providers should have evidence to demonstrate the checks have been undertaken. This evidence may include confirmation and checklists supplied by a staffing agency. This could include:

  • a checklist or evidence from the agency confirming the required checks have been completed and are satisfactory for the specific individual, or
  • a portfolio of the required documentation supplied by the agency worker.

The service provider should assure themselves the agency is reliable and robust in carrying out the checks. Generally, this will be where service providers have established over time the agency does the checks robustly and reliably. The service provider should have a process for establishing this. Where providers are working with new agencies it is particularly important to be assured of the agency’s reliability and robustness.

Student Visas

Some people in the UK on a Student Visa may be able to work. How much they are allowed to work depends on what they are studying and whether they work in or out of term time. Individuals studying at degree level on a Student Visas are permitted to work a maximum of 20 hours per week during term time (defined as a period of seven days starting on Monday). This includes both paid and unpaid work.

Those with a Student Visa can prove their right to work via the UK Government’s online ‘view and prove’ service (External link) (this will also state what work the individual is permitted to undertake in accordance with their visa).

You can use this service to check details of a job applicant’s right to work in the UK (External link), including the types of work they’re allowed to do and how long they can work in the UK for.

You’ll need the job applicant’s date of birth and ‘right to work’ share code.