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Question:

I work for a company via an agency. Am I an employee of the end user company?               

 

 

Answer:

The short answer is that people working for an end-user via an agency, may encounter significant difficulty establishing that they are an ‘employee’ of the end user, and therefore have protection from being unfairly dismissed etc. This can be the case, even if the worker has been there for years.

 

In James v Greenwich Council, 2006, the EAT held that Mrs James was supplied by an agency to carry out work for Greenwich Council. She had no express contract with the Council but she contended that there was an implied contract, given in particular that she had worked for the Council for a period of some five years and had been treated in all respects like other permanent employees. There were two express contracts regulating her relationship with Greenwich Council. There was no contract directly between her and the Council. However, she signed a document headed "Temporary Worker Agreement" which set out the terms of the arrangement between her and the agency.  Clause 2 of the Agency contract included:

 

   ‘The temporary worker contracts with BS Social Care in the capacity of a self-employed worker in relation to each assignment’

 

The EAT held that the Tribunal was entitled to conclude that there was no mutuality of obligation and that there was no employment contract. In deciding whether a worker supplied to an end-user client by an employment agency is in law an employee of the agency's end-user client, the passage of time is not by itself sufficient to mean that a contract of employment can or should be implied and this is so even if the arrangement continues for longer than originally expected.

 

If an agency supplied worker wishes to assert that she is an employee of the end user (for example with a view to claiming unfair dismissal) then, assuming the original agency arrangements were genuine, it will be necessary for her to show that there have evolved "..... mutual obligations binding worker and end user which are incompatible with those arrangements".

 

In Muschett v HM Prison Service 2010, where the Court of Appeal considered whether the relationship of Mr Muschett, an agency worker, with HM Prison Service had developed into that of an 'employee' with all the potential rights that that brings.

 

Where contractual terms are clear, as they were in this case, by an analysis of the elements of control, personal performance and mutuality of obligation in the work carried out by the Appellant (applying the Court of Appeal's decision in James v LB Greenwich [2007]), there is no need to imply a contract of employment. Mr Muschett was not an employee.

 

Further, because he had no contractual obligation to HM Prison Service to do any work for them, and because there was no contract between him and HM Prison Service, he had no contract for service under the Race Relations Act.

 

Therefore, as case law currently stands, it appears that it will be much harder for the agency worker to argue that she is an employee of the end user company.

 

New regulations for agency workers in 2011:

The government plans to give more protection to Agency Workers and to implement the EC Temporary Agency Workers Directive are under review.  The plan was that after working for 12 weeks, agency workers should be treated equally compared to permanent workers on basic employment conditions such as pay, working hours and holidays and access to vacancies.

 

Employees can be awarded up to £5,000 if employers take avoidance measures (such as rotation between 11 week assignments in different roles). There is a minimum award of 2 weeks pay for breach of the equal treatment duty.

 

In certain areas, entitlement to rights, including equal treatment, will kick in from day one of the job: for example, the right to receive information about job vacancies; the right to equal access to on-site facilities such as child care and transport services; and improved protection for new and expectant mothers - such as adjustments to working conditions and hours.

 

The planned regulations will now not be introduced before April 2011 at the earliest.   See also time off for agency workers.

 

Last reviewed:   July 2010

 

 

 

 

James Carmody

Employment Solicitor

 

Reculver Solicitors

12-16 Clerkenwell Road

London EC1M 5PQ

 

www.reculversolicitors.co.uk

info@reculversolicitors.co.uk

Tel 0207 324 6271

 

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