Verifying the people you never put on payroll
Vendors, contractors and incoming directors reach the same things your employees reach. They rarely get the same check, and the gap is usually an assumption nobody wrote down.
- Exposure follows access, not payroll. A contractor with a site pass reaches what an employee with a site pass reaches.
- "The agency checks them" is the most common gap. Ask what they ran, and put the standard in the contract.
- Company checks and people checks are different work. A vendor needs both.
- Directors are the highest-exposure appointment most companies make and often the least checked.
The gap, and why it exists
Most organisations have a verification standard for employees and no equivalent standard for anybody else. The reason is structural rather than careless: employee checks are owned by HR, and vendor onboarding is owned by procurement, and the two processes were built at different times by people solving different problems.
So the housekeeping staff with a key to every floor were checked by whatever the facilities agency does, which nobody has asked about. The vendor engineer with production access was checked by their employer, or was not. The consultant with the commercial model in their inbox was checked by nobody at all, because consultants are contracted rather than hired.
The test to apply is the one from scoping a package by role, and it does not mention employment: what can this person reach? If the answer is the same as for an employee, the check should be the same as for an employee, and who pays their salary is not part of the question.
Three different problems
"Vendor due diligence" gets used for three quite different pieces of work, and running one when you needed another is how gaps appear.
The entity
Is this company real, active and what it claims to be? This is a register question, answered at the MCA and against public filings. It is fast, it is inexpensive, and it is the one most often skipped for a supplier somebody already knows.
The people behind the entity
Who owns and directs it, and does any of that connect back to your own organisation? This is where a supplier owned by a relative of the person approving its invoices becomes visible, and it is a different search from checking the company.
The people who will be on your site
The individuals the vendor actually sends. These are the ones with the badge, the login and the keys, and they are the ones most likely to have been checked by nobody. Individual checks, on individual consent, exactly as for an employee.
The most common single failure is assuming the first one covers the third. A supplier being a legitimate registered company says nothing at all about the person they sent to your data centre on Tuesday.
What an entity check covers
Public company information in India is genuinely good, and an entity check is one of the better returns on money in this whole field.
- Existence and status. Whether the company is registered, active, dormant or struck off.
- Directors, current and past. Who is behind it, and who was behind it when.
- Disqualification. Whether any director carries a disqualification on record.
- Registered office. Which is worth comparing against the address on the invoice, since a mismatch is common and occasionally meaningful.
- Filing history. A company that has not filed for years is telling you something about how it is run.
- Connections. Whether the directors or their addresses link to other entities you already deal with, or to your own people.
The detail on the register itself is in DIN and the MCA register, and the service page is vendor due diligence.
Contractor and agency staff
This is the largest population and the weakest link in most organisations. Housekeeping, security, catering, facilities, logistics, temporary staffing, on-site technical contractors.
The failure mode is always the same sentence: the agency checks them. Sometimes true, frequently partly true, occasionally not true at all, and almost never written down. Four questions turn that assumption into a fact.
- What exactly do you run? Not "we do background checks", but which checks, on whom, and how far back.
- Who runs them? A named provider, or an internal process that consists of collecting photocopies.
- Can we see the evidence for a named individual? Not a certificate that checks were done, but the finding and what sits behind it.
- What happens when somebody is replaced? Agency staff turn over constantly, and a check on the person who started in January says nothing about the person who arrived in June.
Whatever the answers, the standard belongs in the contract, along with the right to see evidence and the obligation to re-check on replacement. An assumption is not a control. Staffing firms that already run verification to a client standard will have no difficulty with any of this; the ones that object are answering the question.
Incoming directors
A director can bind the company. It is the highest-exposure appointment most organisations make, and it is routinely made on the basis of a personal recommendation and a CV.
| Check | What it answers |
|---|---|
| Identity | That the person is who they say, confirmed at the issuing authorities |
| DIN and directorship history | Every company they direct or have directed, and the status of each |
| Disqualification | Whether they are disqualified from acting as a director |
| Court record | Matters on file across the jurisdictions tied to their addresses, criminal and, here, usually civil |
| Global database screen | Sanctions, watchlists, regulatory enforcement and adverse media, where there is international exposure |
| Credit | Financial distress as a pressure, where the role carries financial authority |
The directorship history is the one that most often produces something. Undisclosed directorships, a trail of struck-off companies, or a resignation timed just before a company's problems became public are all visible on a public register and none of them appear on a CV. See leadership verification.
Doing it once is doing it wrong
Employee verification happens at a point in time because hiring happens at a point in time. Vendor relationships continue, and a check at onboarding says nothing about a company three years later.
What works is a cycle for anything with continuing access, plus a set of triggering events that force a re-check regardless of where the cycle sits: a change of directors, a change of registered office, a contract renewal, a significant expansion in what the vendor can reach, or any adverse news. Each of those is a moment when what you verified stopped being what is true.
The same applies to the people. A vendor's staff list at onboarding is a snapshot. Without an obligation to check replacements, the population on your site drifts away from the population you approved, one substitution at a time.
Questions we get asked
Why verify a vendor if we are not employing them?
What is checked on a company rather than a person?
Should contractor staff be checked like employees?
What should be checked before appointing a director?
How often should an existing vendor be re-checked?
Does a vendor have to consent to checks on its people?
Read next
What the public company record shows about a person, and how to read it.
Read the update Scoping by roleThe exposure test, which does not mention who is on the payroll.
Read the guide The service itselfWhat GVS checks on a company, on its owners and on the people it sends.
Vendor due diligenceWho is on your site that you have not checked?
Tell us how your vendors are onboarded and we will point at the gap.
Talk to sales