Subcontracted cover: whose compliance problem is it?

Subcontracting is normal in this sector — geography, short notice and demand spikes all make it necessary. What it does not do is move the client's expectations onto someone else. The client contracted with you.

The evidence problem

When your own officer works a shift, you hold their licence record, their screening file and their training history. When a subcontractor's officer works it, you typically hold none of those, and you are relying on an assurance.

• –Licence status confirmed verbally, never recorded
• –Screening assumed to meet the standard, never evidenced
• –Site-specific induction skipped because the officer is "only covering"
• –No record of which subcontractor supplied which officer on which shift

That last gap is the one that hurts most in an investigation. If you cannot say who was on site, you cannot begin to answer anything else.

A workable minimum

• –Record the subcontractor and the individual officer against the shift, every time
• –Hold licence details for subcontracted officers as you would your own
• –Agree in writing what screening standard the subcontractor operates to
• –Keep site induction as a requirement, not a courtesy

The client's view of your supply chain

From a client's perspective there is one contractor on their site, and that is you. Where cover has been subcontracted, the client's expectation is generally that the officer standing on their premises has been screened and licensed to the standard your contract promises — and they will look to you, not the subcontractor, to demonstrate it.

Which makes the practical question what you actually hold for each subcontracted individual. A contractual assurance that a supplier screens their people is a commercial protection; it is not evidence about the named person on shift last Tuesday.

What to hold before the shift, not after

The workable arrangement is holding the same evidence for a subcontracted officer as for your own, obtained before they attend. That is more administrative work and it is the only version that survives a client asking about a specific individual on a specific date — which is exactly when it gets asked.

Common mistakes

• –Relying on a contractual assurance rather than evidence for the individual
• –No record of which subcontracted officer worked which shift
• –Evidence obtained after the shift rather than before
• –No check that a subcontractor's standard matches what your client contract promises
• –Different evidence standards for your own and subcontracted officers
• –Assuming the subcontractor will produce records on request, years later

What separates contractors who manage this well

The distinguishing habit is treating subcontracted officers as part of your own compliance population rather than somebody else's. That means the same evidence held, the same checks applied, the same records kept — and a named person who knows, on any given day, which subcontracted individuals are working which of your client sites. Contractors who cannot answer that question are not managing a supply chain; they are hoping about one.

It also means auditing the arrangement occasionally rather than at mobilisation only. Suppliers change their own processes, lose staff who understood the requirement, and take on their own subcontractors. An assurance obtained two years ago describes a supplier that may no longer exist in that form.

One more thing: the client contract may say more than you think

Security contracts frequently contain terms about subcontracting that nobody revisits after mobilisation — a requirement to notify, a right of approval, sometimes a prohibition. Where cover is arranged under pressure, those terms are the last thing anyone checks, and a breach of them is a contractual matter regardless of whether the officer was perfectly competent.

• –Check what the client contract says about subcontracting before you need to rely on it
• –Where notification is required, build it into the cover process rather than remembering it
• –Keep a record of which cover was subcontracted and whether the client was told

One practical test: name last month's subcontracted officers

Ask who, by name, worked your client sites last month through a subcontractor or labour supplier, and produce the evidence you hold for each.

Where officers are logged by supplier and headcount rather than by name, the question cannot be answered — and it is always asked about a named individual on a named date, usually months afterwards when the supplier's own records are no better.

• –Log the named individual, not the supplier and a headcount
• –Hold the same evidence as for your own officers
• –Obtain it before the shift rather than on request
• –Check what the client contract says about subcontracting
• –Re-check the supplier's arrangements periodically