An agency worker can do a safe shift in your care home if three things happen before they start: a short structured induction, access to only the records they need for that shift, and a clear way to write their notes so they land in the right file under their own name. Get those right and agency stops being a risk you tolerate and becomes cover you can trust. Get them wrong and every agency shift is a gap in your evidence and a risk to the people you support.
The short answer
You are responsible for everyone who delivers care in your home, whoever employs them. Under CQC Regulation 19 you must be satisfied that each agency worker is fit, which means checking the agency's profile before the shift, not after. Under Regulation 18 you must make sure they are competent for what you ask them to do and that they receive an induction. Under Regulation 17 your records must show who did what, which rules out shared logins. The practical routine is a profile check the day before, a signed 20-minute induction at the start, record access limited to the people they support and expiring when the shift ends, clear boundaries on what they do and do not do, a check-in during the shift, and feedback both ways at the end. This article sets out each step, with a checklist, a procedure and the questions an inspector will ask.
What CQC expects of you with agency staff
Inspectors do not treat agency workers as somebody else's problem. When they walk the floor at 8am they will ask the agency worker who they are, what induction they had, how they know what each person needs, and how they would report a concern. Then they will ask you for the evidence behind those answers.
Regulation 19 is the fit and proper persons requirement. It applies to agency workers as much as to your own staff: you must have assurance that the person has a satisfactory DBS check, right to work, references, training and, for nurses, current NMC registration. The agency does the checks; you must see and record that they were done. Regulation 18 is about sufficient numbers of suitably qualified, competent, skilled and experienced staff, and it requires that staff receive the support, training and supervision they need. An agency worker on their first shift with no induction fails that test. Regulation 17 requires accurate, complete and contemporaneous records that identify who provided the care. A note written under a permanent worker's login by an agency worker fails that one.
The evidence inspectors look for is simple: a file for each agency worker holding the profile, the signed induction and any feedback, and records that show what they did under their own name.
Before the shift: the agency profile
Every agency should send a worker profile before the first shift. If they do not, ask, and if they still do not, use a different agency. The profile should show, at minimum:
- Full name and a photograph, so you can check the person who arrives is the person on the profile.
- Enhanced DBS with adult barred list check, the date and the certificate number, and whether it is on the update service.
- Right to work confirmation and the date checked.
- Two references and the dates obtained.
- Mandatory training with dates: moving and handling, safeguarding, infection control, fire, basic life support, medication if they will administer, and any specialist training you need such as PBS or restrictive intervention.
- Care Certificate status or equivalent experience.
- For nurses, NMC PIN and expiry, which you should check on the register yourself.
- Occupational health clearance and any restrictions.
Check the profile against your own minimum standards and record that you did, with the date and your initials. Keep it. The profile is your Regulation 19 evidence, and a profile received after the shift is no evidence at all.
Choosing agencies: fewer, better, known
Homes with the worst agency experiences usually use six agencies and ring whichever answers. Homes with the best use one or two, with a written agreement about profiles, minimum notice, cancellation, the training they guarantee, and the right to refuse a worker. The most valuable thing an agency can offer is the same workers coming back, because a returning agency worker knows the building and the people and needs only a short update rather than a full induction.
Ask the agency how they verify training, whether they observe competence or just collect certificates, how they handle a complaint about a worker, and how quickly they can send a replacement profile. Ask for the names of workers who have done shifts in homes like yours. Put the agreement in writing and review it once a year. Check too that the agency is operating within the Conduct of Employment Agencies regulations on transparency of charges and worker terms, because problems there tend to become your problems on the day.
The first 20 minutes: an induction that actually happens
Most homes have an agency induction checklist. Most agency workers have never seen it. The difference is whether the senior on shift owns the first 20 minutes. Here is the procedure that works.
- Check identity against the profile photograph and confirm the name on the rota.
- Walk the building: fire exits, assembly point, the fire panel, call bell system, where the office is, where the medicines are kept and who holds the keys.
- Introduce the senior in charge and say who to go to with any question.
- Explain the shift: which people they are supporting, the routine, break times, handover time.
- Show them the care records: how to log in, how to find each person's summary, how to write a note, how to raise a concern.
- Go through the people they are supporting: the one-page summary for each, including communication, mobility, risks and anything that has changed this week.
- State the boundaries: what they should not do this shift, such as giving medicines, using equipment they have not been shown, or supporting people not on their list alone.
- Explain safeguarding and whistleblowing: who to tell, how, and that they can contact CQC directly.
- Both sign the induction record, with the time.
Twenty minutes is realistic if the summaries are ready and the system works. It is not realistic if the senior has to find a folder and photocopy a checklist. Returning workers get a shorter version: what has changed since they were last here, and a signature.
At a glance: what an agency worker should have, see and do
| Stage | Minimum | Better | Evidence |
|---|---|---|---|
| Before the shift | Profile received and checked | Same worker returning, profile on file, NMC checked by you | Profile with your dated check |
| Induction | Checklist signed by both | Person summaries handed over, boundaries stated, returning-worker update | Signed induction with time |
| Record access | Own login, not shared | Today-only access to their people, expiring at shift end | Audit trail under their name |
| Medicines | Not unless competence confirmed | Only after observed competency on your eMAR | Competency record |
| During the shift | Senior available | Check-in at two hours and at handover | Senior's note |
| After the shift | Notes complete under own name | Feedback both ways recorded, worker rated for return | Feedback form |
Access to records: enough, and no more
An agency worker needs to read the plans and risk assessments of the people they are supporting and write notes and charts for them. They do not need the whole home's records, the finance module, HR files or the ability to change a care plan. Give them exactly what the shift needs.
The right model is an account for that worker that exists only for that shift: today-only access to the people on their list, with a password the senior gives them at induction and that stops working when the shift ends. Everything they write is attributed to them by name. If they come back next week, the senior issues access again. This is what a system built for care homes should do out of the box; a home on paper can approximate it with a folder for each unit, but attribution is harder and nothing expires. Read our page on care records for how shift-limited access works in practice.
Why shared logins are the common failure
Shared logins are the most frequent way care homes breach data protection without noticing. They also mean the record shows a permanent worker gave care they did not give, which is a Regulation 17 failure and, if something goes wrong, a serious problem for the permanent worker whose name is on the note. If your system cannot give an agency worker their own access quickly, that is a reason to change the system, not a reason to share a login.
What agency workers should and should not do
Be explicit, at induction, in writing. On a first shift an agency worker should support personal care, meals, activities and mobility for the people on their list, write notes and charts, and report anything unusual to the senior. They should not administer medicines unless you have confirmed competence on your own system, use hoists or other equipment they have not been shown, be the only worker with a person who has a two-to-one plan, take charge of a shift, or make decisions about restrictions or capacity.
For agency nurses the boundaries are different but still needed. Check the PIN yourself, confirm they know your eMAR and controlled drugs process, make sure they know who the on-call manager is, and do not leave an agency nurse as the only nurse in a building where they have never worked before if you can possibly avoid it. If you cannot avoid it, the senior care worker on shift needs to be someone who knows the home well.
Medicines and agency workers
The safest rule is that agency care workers do not give medicines on a first shift. The agency's certificate says they have done a course; it does not say they can use your eMAR, know your PRN protocols or count your controlled drugs. If you need an agency worker to give medicines, observe a round first, record the competency check, and give them access to the eMAR under their own name. Returning workers who have been assessed can be authorised for the shift at induction, with the record showing who authorised them.
Agency nurses will usually give medicines; that is often why they are there. They still need a walk through your system, your CD process and your PRN protocols before the first round, and a second nurse or competent senior for the CD count. Record the walk-through.
Supervision during the shift
An agency worker should never be left to work it out. The senior checks in at around two hours: how is it going, any questions, anything they have noticed. That is when you find out that a person has refused breakfast or that the worker did not understand the hoist sling. A second check at handover confirms that notes and charts are complete. In learning disability and mental health homes, pair the agency worker with a permanent worker who knows the people for at least the first hours, and never leave an agency worker alone with someone whose PBS plan they have not read.
If something goes wrong during the shift, treat it as you would with any worker: deal with the person, complete the incident form with the agency worker's own account, notify who needs notifying, and tell the agency the same day. Do not let an agency worker's error disappear because they are leaving at 8pm.
Notes and handover: making the record land
Agency workers' notes tend to be the weakest in the file, usually because they had no login, no prompts and no time. Fix each. Their own login means the note is attributed. Prompts in the daily log, tied to the person's plan, mean a stranger can still write something useful: what the person ate, their mood, what they did, anything that changed. Fifteen minutes before handover for writing means it does not get done from memory in the car park.
At handover, the agency worker reports on their people to the incoming shift like anyone else. A structured handover that goes person by person with the record on screen catches what a stranger missed. Our article on how to structure a care home handover covers that. The senior reads the agency worker's notes before they leave, and asks for anything missing while they are still in the building.
After the shift: feedback both ways
Two minutes at the end of the shift saves hours later. The senior records whether the worker was on time, followed the induction, wrote their notes, worked well with people and should be asked back. The worker is asked what would have helped: better summaries, a clearer boundary, a quieter place to write notes. Both go on the worker's file and the themes go to the agency.
A rating for return is the most useful thing on that form. Over a few months you build a list of agency workers who know your home, and you ask the agency for them by name. That is how agency becomes safe cover rather than a lottery, and how induction shrinks to a five-minute update.
Agency in learning disability and mental health homes
In services for autistic people, people with a learning disability and people with mental health needs, an unfamiliar worker can itself be the trigger for distress. The induction has to cover each person's communication passport and sensory profile, the PBS plan or risk plan in plain terms, and the specific things to do and not do with that person. A summary that says 'can become anxious' is useless; one that says 'if he starts pacing, offer the garden, do not ask questions' is what the worker needs.
Prefer returning agency workers matched to the same people. Pair first-timers with a permanent worker. Do not use agency workers for one-to-one support of someone with a complex PBS plan unless they have been assessed against that plan. And make sure agency workers know that restrictive interventions are only used by people trained in your approach, which on a first shift will not be them.
Agency nurses in nursing homes
Agency nurses carry the clinical shift, so the checks go further. Verify the NMC PIN on the register yourself and record the date. Confirm the training the agency lists includes what you need: medication competency, syringe driver if relevant, catheter care, wound care, basic life support. Walk them through your clinical governance: who the GP is, how to escalate a deterioration, the on-call manager, the CD process, the eMAR and how to record a wound review. Give them a competent senior care worker who knows the home. Record all of it on the induction. If the same agency nurse comes back, keep their file and the returning-worker update short.
Bank staff: the better answer
A bank worker is someone you have recruited, checked and inducted yourself, who works flexibly for you and no one else. They know the home, the people and the system. They cost less than agency, they write better notes, and they turn up. Most of what this article describes is unnecessary for a good bank worker because it was done once at recruitment. The best long-term answer to agency is a bank of six to ten reliable people with the same training, supervision and record access as permanent staff, and a rota with enough slack that the bank covers absence before agency is considered. Our guide on rota planning to reduce agency use shows how to build that.
Reducing the need in the first place
Agency cover is a rota symptom. A rolling pattern, contracted hours that cover absence, a working bank and a gap-filling order that starts with swaps and ends with agency will cut the number of agency shifts to a handful a month. For the shifts that remain, everything above applies. Track agency hours by unit and by cause, and put the number in front of the provider every month; nothing focuses a recruitment budget like an agency invoice.
Keep agency workers' training records alongside your own staff's in the training matrix, so that when an inspector asks whether everyone on shift tonight is in date for moving and handling, the answer includes the agency worker. Our article on mandatory training for care home staff lists what to look for on the profile.
Confidentiality and data protection with agency workers
An agency worker sees personal and health information about the people they support, and they leave at the end of the shift. Their duty of confidentiality is the same as anyone else's, but the safeguards have to be built in rather than assumed. State at induction that nothing about residents leaves the building, on paper, on a phone or in conversation. Do not let handover sheets or printed summaries go home in a bag; collect them at the end of the shift or, better, keep summaries on the record system so there is nothing to collect. Make sure the worker's access ends when the shift ends, and that they cannot photograph the screen for later. Record the confidentiality briefing on the induction. If a breach happens, treat it as you would with your own staff: record it, assess it against your data protection policy, tell the agency, and report to the ICO if the threshold is met.
Checking the invoice and the agreement
Agency invoices are where money leaks quietly. Check every invoice against the rota: the worker named, the hours worked, the rate agreed, and any uplift for nights, weekends or bank holidays. Query breaks that were not taken but were charged, shifts that ended early, and workers who were sent home. Keep the written agreement to hand so the rate is not a matter of memory. If the agency charges a fee for taking a worker onto your own bank, know what it is before you offer the job, and know when it lapses. Track agency spend by unit and by cause every month alongside the hours, because the provider will ask, and because a clear line between an unfilled vacancy and its agency cost is the strongest argument for a recruitment budget you will ever have.
Agency worker induction checklist
- Profile received and checked before the shift, with your dated initials.
- Identity checked against the profile photograph on arrival.
- Fire, call bells, office, keys, senior in charge.
- Login issued for today only, limited to the people on their list.
- One-page summary for each person handed over and discussed.
- Boundaries stated: medicines, equipment, one-to-one, restrictions.
- Safeguarding and whistleblowing routes explained, including CQC.
- Both signatures and the time on the induction record.
- Check-in at two hours recorded by the senior.
- Notes read before the worker leaves; feedback recorded both ways.
Common mistakes
- Accepting a worker without a profile because the shift starts in an hour.
- An induction checklist that exists in a folder and is never signed.
- Sharing a permanent worker's login with the agency worker.
- Letting an agency care worker give medicines on a first shift on the strength of a certificate.
- Leaving an agency worker alone with a person whose PBS plan they have not read.
- No check-in during the shift, so problems surface at handover or the next day.
- Notes written from memory after the shift, or not at all.
- Using six agencies instead of building a relationship with one or two.
What good looks like on inspection day
The inspector arrives at 7.50am and there is an agency worker on the floor. She has a lanyard with her name, she can say who the senior is, and she explains that she is supporting four people today and that she read their summaries at 7.30am on the phone in her hand. She knows where the fire panel is and who to tell if she is worried about someone. The senior shows the inspector her profile with the manager's dated check, the signed induction from this morning with the time on it, and the login that will stop working at 8pm. Her notes from the last hour are on the record under her own name. The manager shows that she has worked here four times, was rated for return each time, and that the induction today was the short returning-worker version. The training matrix shows her moving and handling date next to everyone else's. That is Regulation 18 and 19 evidence in ten minutes, and it is what a system such as Kiwi, with today-only agency access and a shift password, is designed to produce. If you want to see how that works, book a demo.
Final conclusion
Agency staff are safe when the home does three things every time: checks the profile before the shift, runs a real induction that both people sign, and gives the worker their own access to the records they need for the people they support, expiring when they leave. Add clear boundaries, a check-in during the shift, feedback at the end and a preference for the same workers coming back, and agency becomes cover you can trust. Then fix the rota and build a bank so that you need it as rarely as possible.
Frequently asked
Do agency staff need an induction every time they work in a care home?
A full induction the first time, and a short update on what has changed for returning workers. Both should be signed by the worker and the senior with the time and kept on the worker’s file, because inspectors will ask to see them.
Can agency staff share a permanent staff member’s login?
No. Shared logins breach data protection and mean the record shows the wrong person gave the care, which is a Regulation 17 failure. Agency workers need their own time-limited access that lets them read the plans and write notes for the people they are supporting that shift.
What checks does a care home have to do on agency staff under Regulation 19?
You must be satisfied the worker is fit: enhanced DBS with barred list check, right to work, references, training relevant to the role and, for nurses, current NMC registration. The agency carries out the checks and you must see the profile before the shift and record that you checked it.
Can agency care workers give medicines in a care home?
Not on a first shift on the strength of a certificate alone. Observe a round on your own system, record the competency check, and give them their own eMAR access. Returning workers who have been assessed can be authorised at induction with the record showing who authorised them.
Are care homes responsible for agency workers’ conduct?
Yes. You are responsible for everyone who delivers care in your home, whoever employs them. Incidents involving agency workers are recorded, reviewed and notified like any other, and the agency is told the same day. Keep a file for each agency worker with their profile, inductions and feedback.
How do we reduce reliance on agency staff?
Fix the rota first: a rolling pattern, contracted hours that cover absence, a bank of six to ten reliable people with the same training and record access as permanent staff, and a written gap-filling order that starts with swaps and ends with agency. Track agency hours by unit and cause every month.
What should be in a one-page summary for an agency worker?
How the person communicates, mobility and equipment, eating and drinking including any texture or allergy needs, risks and what helps, anything that has changed this week, and the specific things to do and not do. For people with a PBS plan or communication passport, the key points from those in plain words.
Sources
- CQC: Regulation 19 fit and proper persons employed guidance
- CQC: Regulation 18 staffing guidance
- CQC: Regulation 17 good governance guidance
- Skills for Care: Care Certificate standards
- Skills for Care: safe and fair recruitment guidance
- NMC: register search and revalidation
- ICO: UK GDPR guidance for health and social care
- Conduct of Employment Agencies and Employment Businesses Regulations 2003
