Memorandum submitted by National Car Parks (NCP) (UKB 7)


1. Company Information


NCP is the leading provider of parking enforcement services in the UK, supplying more than 3,000 parking attendants to more than 40 local authorities.

The Company is also the biggest car park provider, with more than 800 off street sites around the country, and 75 years experience in the planning, design, building and management of car parks.

We currently employ in excess of 6,000 staff, approximately 50% of whom are foreign nationals.


Over the past 3 years NCP has developed highly regarded internal processes to deter, detect and remove illegal immigrants from our workforce and has developed considerable expertise in recognising fraudulent documentation. The size of our business means that we are able to pick up on trends and emerging risks with documentation fraud.


2. Submission Introduction


The purpose of our written submission is to present to the UK Borders Bill Committee our views on specific aspects of the Bill which impact on us and through our experience seek clarification on other aspects of the Bill, raise issues that we feel the Committee need to be aware of and present points for discussion and further analysis.


We have placed particular emphasis on responding from the perspective of what the practicalities of the Bill mean to employers and from our experience what genuine employers can be reasonably expected to do to support the principles of the Bill.


3. Aspects of the Bill that we wish to comment upon


Employee document checks

Biometric Immigration documents

Joined up approach with other agencies







4. Employers Document Checks


We agree that presently there is no easy way for employers to verify a person's right to work. This is an area that we feel passionately about and one that through hard work and determination we have enjoyed some success.


Therefore, we would like to raise a number of points. Firstly, there is a real need for clearer, more focused guidance on what employers need to be checking until such time as biometric identity cards are fully introduced.


Secondly, assuming that proper tools, support and education has been provided to employers, and then there is an argument that any penalties for non compliance should be pro-rated on the size of the business to ensure the appropriate level of deterrent is in place.


Thirdly, and perhaps most importantly, the current guidelines for document checks require that an employer conduct what could be classed as a "reasonable" check. Whilst our view maybe controversial, we believe that this level of checking is insufficient (this view being based on our own daily experience) and that if the business community is to help address illegal working then more rigorous checks are needed, particularly in respect of understanding forged documents.


This will require additional support for employers from either the Home Office or indeed approved commercial concerns but is an important area that could significantly impact on the population of illegal workers who present and gain work using forged or stolen documents.


Vitally such an approach would require much more flexibility and commitment from police forces to get involved in incidents of an illegal worker being identified.


While we note and welcome the introduction of an identity checking service from April 2007 (something that NCP are helping the IND to pilot) we have a number of points that we would like to present to the committee for consideration. In particular, we are concerned that the service is likely to overload by less than diligent employers, who see the service as a reason for them not to conduct any checks.


Given the current level of understanding of what checks are required and what is generally accepted as poor levels of compliance by a significant number of employers the likelihood of the details of a large % of the 29 million people currently in work to be requested is a very real one.


However, this is not our biggest concern. The fact that potential employees will have to give their consent for any check, will we believe, create a situation where the service is only used by genuine employers (i.e. those who use what tools are available) and genuine employees (i.e. those with right to work). Therefore, the checking system does little to address the very real issue of the underclass of workers in the population, those with forged documents who present to less than scrupulous employers.


5. Biometric Immigration Documents


The proposal to introduce biometric immigration documents (BIDs) for all non EEA Nationals is supported in principal by NCP. However, it is noted that there is currently no provision within the Bill for Government to require businesses to make identity checks of foreign nationals using BIDs. In our view this could be a mistake.


As discussed above the current document checks are already complicated, by introducing another document into the equation would only cause more confusion. To optimise the effectiveness of the BIDs it would make sense to make these a compulsory check for employers. The benefits are three fold. Firstly, the checks required could be simplified by removing other document checks; secondly' this could ensure that migrant workers are not employed unless they apply and obtain the relevant BID therefore protecting the employer and thirdly; and probably more importantly this will ensure that all reasonable employers play a part in effective policing of the law by removing the opportunities for illegal migrants to obtain employment.


Whilst we are not privy to the exact details of the production of the BIDs we do have concerns over the fraudulent production of falsified BIDs and would request some clarity around the Governments plans to ensure the integrity of these documents.


6. Joined up approach with other Agencies


We note from the Bill that there is an attempt to make it easier for the various agencies to work together. In our experience there is an immediate need to improve the Police Forces knowledge of immigration issues that directly affect employers.


We have had numerous examples where we have either identified illegal immigrants as a result of our pre employment checks or in a number of cases whilst carrying out checks of TUPE transferred staff. In the majority of these cases the individuals have walked away because either the Police were not interested, too busy or didn't know what to do and in the case of the Immigration Officers due to limited resources it was often difficult in our experience to gain immediate support. This can have a very negative effect on employers many of whom recognise the need to carry out appropriate checks but become disenchanted as they perceive a general lack of joined up thinking from enforcement agencies. This situation coupled to the previous lack of deterrent clearly does little to reduce illegal working.


More importantly, in this age of ever increasing risks from terrorist attacks enforcement agencies are failing to tap into this well of intelligence which could mitigate the risks of attack further through a joined up approach to handling illegal migrant workers.


February 2007