Labour Inspection: Cross-Checks on a Temp Worker File

In Canada, a temp worker file stands up to an employment standards or immigration inspection when the same facts (legal name, start date, job, employer, work permit end date, hours) agree across the staffing agreement, the employment record, the work authorization, the timesheets and the invoice. Inspectors seldom penalize one missing page. They ask why two records disagree, and the file either answers or does not. This article sets out the cross-checks, what a mismatch looks like and what the reviewer does next.

Employment standards are mostly provincial and territorial, while immigration is federal. Confirm each point below against the linked official source and the rules of the province where the work is done.

Who inspects a temp worker file in Canada?

It depends on the issue. Wages, hours and records are normally the business of the provincial or territorial employment standards office; the right to work for foreign nationals is federal and handled through Immigration, Refugees and Citizenship Canada. Both start from Canada.ca, where federal programs and links to provincial offices are listed. Employers using the Temporary Foreign Worker Program are subject to federal compliance inspections under that program; read the program pages for what you must be able to show.

The arrangement with an agency is triangular: the agency employs, the client directs the work. Which party carries which duty depends on the province, the contract and the facts, so take advice for your case. Each party still needs to produce its own part of the file.

Which six cross-checks matter most?

Six comparisons cover most of what a reviewer can defend. Each sets a field on one document against a field on another document or record.

What should the work authorization record show?

It should show who was checked, against what document, when, and when permission ends. Foreign nationals may work only as their permit allows, including its end date and any conditions on employer or occupation; the rules are on Canada.ca. The cross-check is to compare permit name and expiry with your employment record and the assignment end date.

A Social Insurance Number is a second point of comparison. Canada.ca explains that numbers beginning with 9 are issued to temporary residents and carry an expiry tied to their authorization (Service Canada, Social Insurance Number); confirm current details on that page. If the SIN expiry and the permit expiry disagree, one of the two records is out of date.

A permit copy shows what was presented on a date. It does not establish that a physical document is genuine, and it does not track later status changes. For more on foreign workers, see work permit checks before an assignment.

How do agency and client records have to line up?

They each hold half of the picture and the halves must agree. The client holds attendance, safety orientation and what work was actually done. The agency holds hiring documents, payroll and the invoice. The simplest evidence is a timesheet tying one named person to a set of hours that matches the invoice line.

What to compare on the client side:

1. Assignment start and end dates against timesheets and access logs.
2. Job description against the work seen. A role requiring a ticket or certification filled by someone with no record on file is a gap, even if each document is valid on its own.
3. Legal entity on the invoice against the entity in the agency agreement.
4. Worker identity on timesheets against the name on the permit or passport.

See staffing agency compliance requirements by country for a wider comparison.

Privacy: what may you copy and keep?

Keep what you need for the purpose, protect it and know who can see it. For private-sector organizations, PIPEDA sets the federal rules on collection, use and retention of personal information, and the Office of the Privacy Commissioner publishes guidance. Some provinces have their own private-sector laws. Collecting a SIN or permit copy is a decision to document, with a stated reason and a retention period you can explain.

What do site managers actually ask on forums?

Questions that recur on HR and staffing forums are practical. We summarize them without quoting anyone.

"The agency says it checked the permit. Do I need to see anything?" Ask for the record, not a reassurance, and compare name and expiry with your own site data.

"What if the permit runs out during the assignment?" The follow-up date should already be in the file. If not, take advice before the worker carries on.

"Is a phone photo of the permit enough?" It records what was shown. Whether it meets a rule depends on the rule; check the current guidance for your situation.

What should the reviewer do when documents disagree?

Treat a mismatch as a question first. Three outcomes cover nearly all cases.

• Clerical error: typo, date format. Correct it with supporting evidence and record who changed it and when.
• Missing cover: permit ending, record created late, role not matching training. Pause the affected work and log the reasoning.
• Unexplained: different employer, different identity, hours that cannot be reconciled. Stop, record what you saw, notify the agency's compliance contact and take advice before further payment.

Keep the trail: which field, compared with what, by whom, when, with what decision. A dated file answers an inspector's question. A recollection does not.

Where does automation help, and where does it stop?

Reading six fields across five documents for forty workers on a Monday morning is where errors creep in. A document validation tool extracts names, dates, reference numbers and employers, compares them across documents and flags the rows that disagree. It compares data. It does not establish that a document is genuine, and the decision stays with a person.

CheckFile's temp staffing and recruitment solution is built around those comparisons; see also the industry verification guide and our security page.

Frequently Asked Questions

What is the first cross-check an inspector is likely to run?

Whether the person on site is the person in the file: name and date of birth on the permit or passport against payroll and timesheets.

Does a permit copy prove the document is genuine?

No. It records what was shown on a given date. It does not authenticate the physical document.

Who keeps which records, the agency or the client?

Each keeps the records for its own part of the arrangement. Your agreement should state who holds the work authorization evidence and how you can see it.

How often should the checks be repeated?

At each extension and before the earlier of the permit expiry and the assignment end.

What if the invoice and the timesheet disagree?

Hold the disputed line, ask the agency for source records and compare them with your access data. Record the resolution in the file.