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This document outlines an immigration compliance exercise conducted from January to March 2014 by Vanessa Howe, David Dongworth, and Anne Morris of Davidson Morris Ltd. The exercise aimed to assure compliance with UKBA requirements for Tier 2 and Tier 5 visas among academic staff at the University of Oxford. It covers the background, risks of non-compliance, aims, and future plans of the exercise. Through a structured audit process, the goal was to provide assurance, improve efficiency, support departments, and plan for continuous compliance moving forward. The document also details the logistics, risks of non-compliance, action plan, and agenda for the compliance audit. This exercise was vital to avoid fines, license downgrades, and reputational damage. The comprehensive approach included reviewing staff files, documenting, and communicating the importance of compliance across departments and colleges. The exercise highlighted opportunities for improvement and good practices in immigration compliance.
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Immigration Compliance Exercise January-March 2014 Vanessa Howe, Head of Recruitment and Employee Development David Dongworth, Head of Work Permits Team Anne Morris, Director, Davidson Morris Ltd
Immigration Compliance Exercise • Introductions • Aims of the compliance exercise • Background • PwC Audit and Audit and Scrutiny Committee • Immigration Compliance Working Group • Future Plans • Logistics of the Audit – Anne Morris • Questions and Discussion
Background – Risks of Non Compliance • Attraction and retention of global academic talent • 32% of academic teaching and research staff from overseas, 16% from outside EEA • 47% of research staff from overseas, 23% from outside EEA • Academic staff from c 100 countries
Background – Risks of Non Compliance • Attraction and retention of global academic talent • 32% of academic teaching and research staff from overseas, 16% from outside EEA • 47% of research staff from overseas, 23% from outside EEA • Academic staff from c 100 countries • Oxford has some 890 sponsored migrants on tier 2 and 5 visas we have to comply with Home Office requirements – or risk: • Fines • Sponsorship licence downgraded , or lost • Reputational damage • Illegal employment can carry prison sentence • One licence for University and Colleges – Musketeer effect
Aims of Immigration Compliance Exercise • Provide Assurance to the Collegiate University of compliance with UKBA requirements for Tier 2 and Tier 5 visas • Check each individual staff file for the c 890 staff in colleges and departments with tier 2 and 5 visas • Work closely to support departments and colleges throughout the exercise • Learn from the experience so that processes can be improved and good practice shared • Report to Audit and Scrutiny Committee in March 2014 • Anne Morris of Davidson Morris will explain logistics today
Working Group – 8 areas for action • On going compliance monitoring • Training for Departments and Colleges • Documentation and Guidance • Record keeping requirements • Recording Absence • Recruitment documentation • Opportunities for centralisation • Communicating the importance of compliance
Draft Aims and Action Plan for 2014 - from the 8 areas for action • Provide assurance of compliance with UKBA • Improve efficiency – people into post more quickly • Support and Communications to Colleges and Departments • Full Service on Immigration
Provide Assurance of compliance with UKBA requirements – both immediately and ongoing • Compliance Exercise – report to Audit and Scrutiny in March • Review our processes and data holding • Identify good practice at Oxford and externally • Use of CORE and review Central/Local locus • Plan continuous / ongoing audits • Plan to reduce other potential risks - students, visitors • Leadership communications
Improve Efficiency – People into Post • System review / best practice from Oxford and outside • Identify time saving/parallel process possibilities • Reduce advertising errors – use CORE to help/training • Engage with candidates/sponsored individuals • Support departments on in country visa process
Support and Communication to Departments and Colleges • User group/working group from Departments and Colleges • Training –Inductions and workshops • Identifying and Sharing good practice • Communications and outreach with departments and colleges • Documentation and Guidance • Leadership communications
Full Service – provide support on full range of immigration matters • Indefinite Leave to Remain, Spouse visas • In country application process • Consider external support in short term
Summary • Thank you for your co-operation in compliance audit – aim to make it supportive and helpful • Will provide a high level of assurance • 2014 Action Plan to support long termcompliance and support to colleges and departments
Agenda • Welcome • Dates for the Audit • Site visits • Drop in sessions • Divisional and Departmental Meetings • Documents to be reviewed • Monitoring & recording absences • Next Steps
13 – 22 January Chemistry (all laboratories) Engineering Science Physics (all sub-departments) Mathematical Institute Physiology, Anatomy and Genetics Materials Zoology Biochemistry Computer Science Earth Sciences Geography Sir William Dunn School of Pathology Plant Sciences Pharmacology Wellcome Trust Centre for Human Genetics
13 – 22 January Nuffield Department of Orthopaedics, Rheumatology and Musculoskeletal Sciences Clinical Neurosciences Oncology NDM Experimental Medicine Oxford Centre for Diabetes, Endocrinology and Metabolism Weatherall Institute of Molecular Medicine Cardiovascular Medicine Clinical Trial Service Unit Said Business School Economics Politics and International Relations Oriental Studies Faculty Philosophy Faculty
File Checking / Surgery Sessions 21 January: 9.30 - 12 Meeting Room, Medical Sciences Divisional Office Level 3 JR Hospital 21 January: 1.30 – 4.30pm Room 4 Wellington Square 22 January: 1.30 – 4.30pm Oriel College Harris Seminar Room
Academic Files Humanities MPLS Social Sciences Medical Sciences
Documents to be reviewed Full list of Tier 2 and Tier 5 visa holders, including leave to enter and expiry dates (word or excel sheet format) Copy of ID section of the passport Copy of entry clearance visas and/or biometric cards Evidence of recording employees contact details inc telephone, address and email
Documents to be reviewed Screen shot of the advert and evidence of recruitment and short listing procedure Contract of employment Job description Salary details Evidence of annual right to work checks If there have been changes to an employee’s status such as visa extension, salary, change of working location or advising the WP team of any other matters, details of the changes reported to the team
Missing documents Don’t panic Advise us when we’re checking Can you locate them or are they missing in action!
Absences To: Anne Morris Subject: RE: Query re Sponsor record-keeping requirements Dear Ms Morris, Thank you for your email. A Sponsor Licensing Unit Compliance Officer would normally expect to see all absences recorded, regardless of whether the absence is authorised or not, as this is standard practice for almost all employers. The sponsor has to be able to demonstrate through their record keeping that they are aware of the whereabouts of their sponsored employees. Regards, Daniel Hartley | Business Helpdesk | Home Office | Vulcan House - Iron | Sheffield | S3 8NS |
Absences How you currently check that all employees arrive on the first day of work How do you monitor absences such as illness Do you have written policy in the contract of employment How do you monitor attendance at conferences, exchange visits