Field notes › Compliance
Keeping compliance records for people you don't employ
The tidy version of labour hire is that you employ the workers and place them on client sites. The real version has a few more parties in it. Some of the crew are subcontractors with their own ABN. Some come from a second-tier supplier you use when you are short. Some are on working visas with conditions attached. All of them walk through the same gate, and to the client they are your people.
That last part is the bit that matters. The site does not care about your contracting arrangements. If the person at the gate does not have the right ticket, it is your name on the incident.
The record has to exist regardless of the relationship
Whether someone is an employee, a contractor or supplied by another firm changes the tax and industrial questions considerably. It changes the compliance question hardly at all. Either the site's required competencies are held, current and verified, or they are not.
So the practical rule is that everyone who can appear on a client site needs a profile with their certificates on it, no matter how they are engaged. The engagement type is a field on the profile, not a reason to keep them out of the system. The moment you keep contractors in a different place because they are contractually different, you have created a second source of truth, and the second source of truth is always the one that is out of date.
Verified means somebody looked
Holding a record is not the same as having checked it. There is a real difference between a certificate a worker uploaded, a certificate someone in your office has opened and confirmed against the document, and a certificate whose number has been checked against the issuing authority where that is possible.
Most systems collapse those into a tick. Keeping them separate is worth the effort: an uploaded but unverified certificate should be visible as exactly that, so nobody assumes a check happened that did not. In Mustr a certificate carries a state the office has set, and only verified, unexpired certificates satisfy a site requirement.
For subcontractors this matters more, not less. You are relying on paperwork provided by someone whose systems you do not control, so the verification step is doing more work.
Second-tier suppliers
When you take crew from another firm, you inherit their record keeping. If they cannot produce current tickets for the people they send, you cannot either, and your client will ask you rather than them.
Two things help. Ask for the same evidence you would ask of your own crew, in the same format, before the person is rostered rather than after. And put those workers in your system as their own profiles, sourced from that supplier, rather than as a line item called agency crew. If a ticket expires mid-placement you want the same reminder machinery pointed at them that is pointed at everyone else.
Work rights and visa conditions
Some workers have conditions on how much or what kind of work they can do. The rules here are the government's, they change, and getting them wrong is expensive, so this is a check-with-the-source area rather than a take-our-word-for-it one. What the system can do is make sure the record exists, carries an expiry where one applies, and behaves like any other expiring requirement: visible on the dashboard well before it lapses, and capable of stopping a booking.
Treating a work-right condition as just another competency with an expiry date is not a legal opinion. It is a filing decision, and it is the one that means the date does not sneak up on you.
The audit question you will actually be asked
When a client audits you, the question is rarely how do you engage your people. It is: for these twelve shifts on these dates, show me who was on site and prove they were compliant at the time.
That is a question about records at a point in time, which is why the record needs to sit against the booking, not just against the person today. A worker whose ticket has since expired was compliant in March if the ticket was current in March. If your evidence is a screenshot of today's certificate list, you cannot answer the question that was asked.
The short version
One system, every person who can reach a site, engagement type as a field rather than a filing cabinet, verification recorded as a state rather than assumed, and a history that can answer questions about the past rather than only the present.
The compliance page covers how requirements are set per site and per role, and the audit preparation post goes through what client auditors tend to ask for.