Sponsor record-keeping duties

Sponsor record-keeping should follow current Appendix D and route-specific requirements for each worker. Retain a coherent file linking identity, permission, role, pay and other required evidence rather than only a certificate reference and start date.

Use a requirement-based file index Organise each sponsored worker's record so that an authorised colleague can identify the evidence supporting their permission, role and employment. Appendix D sets the sponsorship record requirements and should be read with relevant route guidance. [1] Build the file index from those requirements rather than from whatever documents happen to arrive during recruitment.

Give each item a clear description and identify the period it covers. If a record has been replaced, keep the current version distinguishable from the historical one. A folder containing several unnamed scans can appear substantial while remaining difficult to use. The objective is a coherent account that can be retrieved and understood when a question arises.

Preserve the evidence of the right to work check Keep the evidence required for the checking method used and record when the check was completed. Do not assume that possession of a passport copy or a sponsorship reference proves that the appropriate check took place. Appendix D connects sponsor records to the official right to work process and distinguishes the relevant online service from other status-checking services. [1]

Make the checking record easy to locate without exposing it unnecessarily to colleagues who only need to know that onboarding has been cleared. If the worker has time-limited permission, connect the record to the follow-up process. When a discrepancy appears between the permission and proposed work, flag it for assessment before treating the file as complete.

Connect recruitment evidence to the role filled Retain the relevant recruitment material and the account of how the person was selected, in line with the route's requirements. Keep the job description that supported the appointment identifiable. If duties later change, record the new description and the effective date rather than overwriting the earlier document and losing the basis on which sponsorship was arranged.

Use Genuine vacancy evidence for a sponsored role to assess whether the file explains the genuine vacancy. A reader should be able to connect the employee to the role in the organisational structure and understand the actual work. Generic material describing the whole business may provide context, but it does not replace evidence of the particular employment arrangement.

Reconcile salary records with employment terms Create a reliable connection between the contract, payroll information and evidence of payment where required. Check that the records concern the same worker and period. Investigate differences such as changed hours, deductions or an unexpected payment pattern rather than assuming that every discrepancy is harmless. Preserve the explanation and any assessment of its sponsorship consequence with the relevant records.

Do not rely exclusively on a payroll total if it leaves the underlying arrangement unclear. The person reviewing the file should be able to understand what the worker was entitled to receive and what happened in practice. Where finance maintains the evidence separately, give authorised staff a dependable retrieval route and identify the person responsible for supplying it.

Keep contact and employment changes traceable Provide workers with a clear way to update contact details and managers with a clear way to notify changes affecting employment. Record the date information was received and the action taken. Historical details may be needed to explain an earlier event, so avoid replacing information in a way that makes the chronology impossible to reconstruct.

Link significant events to the assessment and any Home Office report. A note saying reported is less useful than a record identifying what was reported, when and by whom. Where no report was required, retain an appropriate explanation of the assessment. This helps a later reviewer distinguish a considered decision from a task that was overlooked.

Apply a considered retention schedule Appendix D permits paper or electronic storage provided records can be made available. Its general worker-record period runs through sponsorship and then until the earlier of one year after sponsorship ends or an officer's earlier examination and approval. Other duties can require longer retention, and licence application evidence must be kept while the licence is held. [1]

Translate these overlapping requirements into a schedule before deleting records. Identify the record type, relevant obligation and trigger date, then consider any other applicable legal or operational requirement. Do not apply a single sponsorship period indiscriminately to payroll, employment and right to work evidence. Record who authorised disposal and how confidential material was securely handled.

Review access and test retrieval Limit access according to responsibilities and review it when staff leave or change roles. Keep a workable backup and recovery arrangement for electronic records. Test retrieval using a real question, such as finding the evidence supporting a particular start date or salary change. The test should show whether the system works for someone other than the colleague who originally created the file.

For assistance through Sponsor compliance readiness review, provide an anonymised description of the filing structure and the specific gaps requiring assessment before sending sensitive documents. A useful review should produce an evidence schedule and prioritised corrective actions. Record completion against actual files so the organisation can show that improvements changed its working records rather than merely creating another policy document.

Illustrative example

An HR team checks a sponsored worker’s file against Appendix D and reconciles the recorded salary with payroll before closing the review.

Preparation checklist

• Use current record requirements
• Link evidence to each worker
• Reconcile HR and payroll
• Control access and retention