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Immigration Attendance Monitoring Arrangements

Contents

Scope

1. For the purposes of this policy, "sponsored staff/sponsored worker", refers to those individuals sponsored under the Skilled Worker and Government Authorised Exchange (GAE) routes.

Monitoring Arrangements

2. Under the Skilled Worker and Government Authorised Exchange Visa requirements, and as an A rated sponsor, it is necessary for University College London (UCL) to monitor staff attendance on an on-going basis. As part of our requirements as an A rated sponsor, we have obligations to report certain sponsored worker activities, including but not limited to;

  • If a sponsored staff member fails to commence employment with the University
  • If a sponsored staff member fails to attend work, resigns or has their contract of employment terminated early. 

3. UCL has an obligation to make a report on any of the above situations to UK Visas and Immigration (UKVI), through the Sponsor Management System within 10 working days of the start date, resignation date, non-attendance date, or termination date. Reporting these events late could impact on UCL's sponsor licence. 

4. Sponsored staff members, employing departments/schools, and UCL HR all have joint and separate responsibilities 

Sponsored Staff Responsibilities 

5. Sponsored Staff have a number of responsibilities, which are set out below.  

6. Advising the Departmental Administrator and Human Resources (HR) if they are delayed in arriving to the UK, providing details of the reason and expected date of arrival.

7. Providing evidence of their National Insurance (NI) Number, unless they are exempt from requiring one. For example, a copy of their NI card (or NI number notification letter from Her Majesty’s Revenue and Customs (HMRC) or the Department for Work and Pensions), wage slip, P45, New Starter Checklist, P60, P11 (employers declaration to HMRC), P14 (employers return to HMRC), P35 (employer’s annual return to HMRC). 

8. Maintaining up-to-date contact details either through updating MyHR or through direct communication of any changes to HR. UKVI requires that the following details are kept up to date at all times: 

  • UK residential address
  • UK telephone number
  • Mobile telephone number 

9. Checking their UCL e-mail account regularly to ensure that they are informed of any updates with respect to their employment at UCL, including those related to their visa, and ensuring that they can respond promptly to any requests for information or actions UCL makes in this respect. 

10. Recording absences such as leave and off site meetings/conferences using MyHR and/or recording them in their Outlook calendar. Sponsored staff should ensure that their Departmental Administrator and line manager have access to their Outlook calendar, so that they can be located when UCL is audited by UKVI.

11. Making appropriate contact with their employing department in circumstances of illness or emergencies to clarify the nature of the absence and seek permission as required in accordance with normal UCL procedures. Failure to attend work without such contact/permission may be reported to UKVI via the Sponsorship Management System. 

12. Advising their Departmental Administrator in a timely manner if resigning from their post and/or if they take up employment elsewhere, providing details of any future UK employer, where applicable. 

13. Advising their Departmental Administrator and HR if they have moved into an alternative immigration category which does not require a sponsorship from UCL and providing evidence to confirm this.

14. Applying promptly for further leave to remain where UCL has been granted a further certificate of sponsorship to extend the sponsorship period. 

15. If a sponsored worker is travelling outside the UK, Channel Islands, Isle of Man and Republic of Ireland (the common travel area) they must ensure that they have sufficient clearance to re-enter the UK. Where the leave to remain has been granted for a period of more than six months, this will mean that your leave to remain cannot expire whilst outside the UK and you cannot remain outside the UK for more than two years. Where the leave to remain has been granted for a period of less than six months, your leave to remain will lapse if you leave the common travel area. You should seek advice from the HR Service Compliance team (via MyServices) if you are intending on being outside of the common travel area for an extended period, and this should be approved in advance by your department/line manager. 

16. Ensuring that you do not claim benefits, tax credits or housing assistance that you are not entitled to. For more information please refer to the UK Visas and Immigration guidance. 

Department Responsibilities 

17. Employing departments also have a number of responsibilities, which are normally delegated by the Head of Department to the Departmental Administrator: 

18. Any new sponsored staff members who do not commence employment on the agreed start date must be reported by UCL to UKVI within 10 working days of the anticipated start date. Employing departments must advise HR Services immediately if a sponsored new member of staff does not attend work as expected in order for the situation to be monitored accordingly by both the department and HR Services.  

19. Each department is required to have in place a robust process through which sponsored staff members (along with all other members of staff) are effectively monitored in terms of their attendance. Employing departments must advise HR Services immediately if a sponsored member of staff is absent from work without permission, as this must be reported to UKVI within 10 working days of the 10th day of absence. Where a member of staff is on an agreed period of leave and/or has made appropriate contact to advise that they are absent due to illness etc., this does not need to be reported. Please note that there are certain circumstances in which sponsorship may need to be withdrawn, so it is imperative that departments closely monitor attendance and escalate to HR Services where appropriate. 

20. The Departmental Administrator is required to ensure all staff use MyHR to record sickness absences and to use MyHR and/or Outlook to record other absences such as leave and off site meetings/conferences.

21. Sponsored staff members must be informed of the local procedures for attendance monitoring/reporting by each employing department, highlighting that they must comply with these procedures as a requirement of their visa conditions. 

22. If a sponsored staff member is absent from work without permission, efforts should be made by the department to contact the sponsored staff member to establish their whereabouts and the reason for the absence. 

23. HR Services must be advised in a timely manner of any changes or proposed changes to the sponsored staff members circumstances including: a potential promotion or change in job duties/ responsibilities, a change of salary level, a period of maternity, paternity, adoption and shared parental leave, a change of location of work, a proposed extension to contract or a proposed early termination of contract/resignation. Such changes should not be agreed and put in place before notifying HR Services. Doing so could negatively impact a sponsored workers visa and UCL's standing as an A rated sponsor. 

UCL Human Resources Responsibilities 

24. Human Resources are responsible for the following: 

25. HR Services maintain a list of all Skilled Worker and Government Authorised Exchange Visa sponsored staff members. 

26. Share information, including UKVI updates and changes, with Departmental Administrators at the HR DA User Group on a regular basis to maintain up-to-date knowledge and effect any required amendments to practices. 

27. HR Services will write to sponsored staff annually to remind them of their obligations including how to update their contact details. 

28. HR Services will send Departmental Administrators an annual list of sponsored staff in their area together with a reminder of the monitoring obligations that apply. 

29. HR Services will be responsible for updating the right to work information on MyHR.

30. HR Services will undertake all reporting requirements to UKVI of any matters of concern or changes of circumstances. Circumstances which are required to be reported to UKVI include: 

  • Permitted reductions in salary- these include (but not limited to) where a sponsored staff member has commenced a period of statutory maternity, paternity, parental, shared parental, adoption or neonatal care leave, sick leave, or jury service. Reductions in pay for other reasons are unlikely to be permissible
  • If the sponsored staff member does not commence employment on the agreed first day of employment with UCL.  If the employment contract is terminated earlier than the date of expiry of the CoS e.g. in cases of resignation or dismissal.
  • Cases where the employee wishes to take more than one month’s unpaid leave[1], in which UCL must stop sponsoring the migrant and this must be reported to UKVI. 
  • Cases where the employee has switched immigration categories and no longer requires UCL to sponsor them.
  • Promotions or changes in job title or core duties, other than those requiring a change of employment application.
  • Changes of salary other than those related to annual increments or pay awards and not requiring a change of employment application.
  • Changes to salary as a result of maternity, paternity, adoption and shared parental leave or sickness absence lasting one month or more.
  • Changes to location of work.
  • Changes which mean the employee will be affected by TUPE regulations.
  • Unauthorised absence of more than 10 consecutive days. This must be reported within 10 working days after the 10th day of absence. 

[1] Excluding maternity, paternity, adoption, shared parental leave, or sickness absence. 

 

HR Policy Team

September 2025