About this policy
This policy is issued by Bubble Fresh (Bubblefresh Limited, company number 12691029), a specialist cleaning and clearance company based in Rushden, Northamptonshire. We provide services for vulnerable adults, families, and local council partners across Northamptonshire, Milton Keynes, Bedford, and Norfolk. The Director, Lance James, is responsible for this policy and for all decisions about subcontractor engagement.
Our position
We deliver all services using our own directly employed staff. We do not routinely use subcontractors. This policy sets out the standards that would apply should we engage subcontractors in the future, ensuring that our quality, safety, and safeguarding standards are fully maintained. Because our work involves vulnerable adults in their homes, the standards we apply to any subcontractor are the same high standards we apply to our own team.
When subcontractors may be used
We would only engage subcontractors in exceptional circumstances. Examples include where demand significantly exceeds our capacity, where specialist skills not held by our team are needed (for example, specialist biohazard remediation or structural drying), or where geographic coverage requires local support. The Director would make any decision to use subcontractors and inform the relevant council partners in advance. Where services are delivered under a council contract, we would not engage a subcontractor without the prior written approval of the relevant council partner, as required by our contractual obligations. We keep a written record of the reasons for engaging any subcontractor.
Prohibition on sub-sub-contracting
We do not allow subcontractors to further sub-contract any part of the work they carry out on our behalf. All work must be performed by the subcontractor's own employees or named individuals who have been vetted and approved by us. Any breach of this requirement is grounds for immediate termination of the subcontractor agreement. This ensures we maintain a clear chain of accountability and that every person working on our behalf has been properly checked.
IR35 and employment status
Before engaging any subcontractor, we carry out an employment status assessment to determine whether the engagement falls inside or outside the off-payroll working rules (commonly known as IR35), as required by Chapter 10 of Part 2 of the Income Tax (Earnings and Pensions) Act 2003 (as amended by the Finance Act 2021). We use HMRC's Check Employment Status for Tax (CEST) tool or equivalent to make this determination. We keep a written record of each assessment and its outcome. Where the engagement is determined to fall inside IR35, we apply PAYE deductions and account for employer National Insurance contributions as required by law. We communicate the status determination to the subcontractor in writing. If a subcontractor disagrees with the determination, they may raise this in writing and we will review the assessment. We ensure all engagement terms reflect genuine self-employment where that is the correct status, including the right to send a substitute, control over working arrangements, and no mutuality of obligation.
Selection and vetting
Before engaging any subcontractor, we would require Public Liability Insurance of not less than five million pounds and Employer's Liability Insurance of not less than ten million pounds, Enhanced Disclosure and Barring Service (DBS) checks for all personnel who will work in client-facing roles, processed at the appropriate level for working with vulnerable adults; at least two satisfactory professional references; evidence of relevant training (safeguarding adults, Control of Substances Hazardous to Health (COSHH), manual handling, and lone working at minimum); a valid Upper Tier Waste Carrier Licence registered with the Environment Agency (where the subcontractor will transport waste); provision of risk assessments and method statements (RAMS) for all work to be carried out; where applicable, professional indemnity insurance of not less than one million pounds, evidence of current registration with HMRC for tax purposes; a completed modern slavery and human trafficking declaration (see Modern slavery checks below); and a signed subcontractor agreement covering quality standards, confidentiality, compliance, payment terms, and termination provisions. We verify all documents and certifications directly with the issuing body where possible. Insurance certificates must be current and we require notification of any lapse, cancellation, or material change in cover.
Modern slavery checks
In line with our commitment under the Modern Slavery Act 2015, we carry out checks on all subcontractors before engagement to satisfy ourselves that they are not involved in modern slavery, human trafficking, forced labour, or any form of labour exploitation. We require each subcontractor to provide a signed declaration confirming that they comply with the Modern Slavery Act 2015, that they do not use forced, bonded, or compulsory labour, that their workers are free to leave employment with reasonable notice, that they pay at least the National Living Wage as set under the National Minimum Wage Act 1998, and that they will notify us immediately if they become aware of any modern slavery concerns in their own operations or supply chain. We reserve the right to audit a subcontractor's compliance with these requirements at any time. A breach of these obligations is grounds for immediate termination of the subcontractor agreement. For more detail on our wider approach, see our Modern Slavery Statement.
Standards and compliance
Any subcontractor working on behalf of Bubble Fresh would comply with all our policies and procedures as if they were a directly employed member of staff. This includes our Safeguarding Policy, Code of Conduct, Professional Boundaries Policy, Health and Safety Policy, Lone Working Policy, Equality and Diversity Policy, and Privacy Policy. We provide subcontractors with copies of all relevant policies before work begins and require written confirmation that they have read and understood them. Subcontractor insurance levels must meet or exceed those required by the relevant council contract. Where a council contract specifies additional requirements beyond those in this policy, those additional requirements also apply to any subcontractor engaged on that contract.
Data protection
Where a subcontractor processes personal data on our behalf, we require a Data Processing Agreement compliant with Article 28(3) of the UK General Data Protection Regulation (UK GDPR), including all mandatory terms of Article 28(3)(a)-(h). Where we act as a data processor for a council partner, we will obtain the council's prior written authorisation before engaging a sub-processor, as required by Article 28(2) of UK GDPR. We require confidentiality obligations for all subcontractor personnel who access personal data. Subcontractors must not retain any personal data beyond the period needed to complete the work, and must return or securely destroy all personal data on completion of the engagement. For full details of our approach to data protection, see our Privacy Policy. For information security requirements, see our Information Security Policy.
Confidentiality
All subcontractors must sign a confidentiality agreement before starting any work on our behalf. Subcontractor personnel must not share, discuss, or disclose any information about our clients, their homes, their circumstances, or our operations with anyone outside of the direct service delivery team. This obligation continues after the subcontractor agreement ends. A breach of confidentiality is grounds for immediate termination of the subcontractor agreement and may result in legal action. Our clients are vulnerable adults and the protection of their privacy and dignity is of the highest importance.
Liability and indemnity
Each subcontractor must maintain insurance cover at the levels set out in the Selection and vetting section of this policy for the full duration of the engagement. The subcontractor agreement requires the subcontractor to indemnify Bubble Fresh against any loss, damage, cost, or claim arising from the subcontractor's negligence, breach of contract, breach of statutory duty, or wilful misconduct, including any claims from clients, council partners, or third parties. This indemnity covers damage to property, personal injury (to the extent caused by the subcontractor), regulatory fines or penalties arising from the subcontractor's actions, and costs of remedial work needed to correct defective or incomplete work. The indemnity does not limit any other rights or remedies available to Bubble Fresh. Where a council partner suffers loss as a result of a subcontractor's actions, Bubble Fresh remains liable to the council under the primary contract and will pursue recovery from the subcontractor under the subcontractor agreement.
Payment terms
Payment terms are set out in the individual subcontractor agreement. We pay subcontractors within 30 days of receiving a valid invoice for completed and accepted work, unless the subcontractor agreement specifies different terms. Invoices must include a description of the work completed, the dates the work was carried out, any purchase order or reference numbers, and the agreed rate. We may withhold payment where work has not been completed to the required standard, where there is an unresolved complaint or dispute relating to the work, or where the subcontractor has not provided required documentation (such as waste transfer notes or updated insurance certificates). We do not make advance payments. Where we withhold payment, we notify the subcontractor in writing with clear reasons and a reasonable timescale for resolution.
Monitoring and performance
We monitor subcontractor performance through the same quality assurance processes applied to our own staff, including client feedback, quality inspections, and body-worn camera footage review (where consented and in line with our Body-Worn Camera Policy). We carry out regular reviews of subcontractor work, with frequency based on the volume and nature of the work being carried out. We address any concerns about a subcontractor's performance or conduct immediately and keep a written record of all performance discussions. Where performance falls below the required standard, we issue a written improvement notice setting out what needs to change and by when. Continued poor performance after a written improvement notice is grounds for termination of the subcontractor agreement.
Complaints about subcontractors
If a client, council partner, or any other person raises a concern or complaint about the conduct or performance of a subcontractor working on our behalf, we handle it through our standard complaints process. We investigate the complaint promptly and thoroughly. The subcontractor is required to cooperate fully with any investigation, including providing access to their personnel, records, and any other relevant information. We keep the person who raised the complaint informed of progress and outcome. Where the complaint involves a safeguarding concern, we follow the procedures set out in our Safeguarding Policy, including making referrals to the local authority safeguarding team and the Disclosure and Barring Service where appropriate. For details of how we handle complaints generally, see our Complaints Policy.
Suspension and termination
We may suspend a subcontractor from working on our behalf immediately and without notice where there is a safeguarding concern involving the subcontractor or their personnel, where the subcontractor or their personnel are subject to a police investigation or DBS referral, where the subcontractor's insurance has lapsed or been cancelled, or where there is an immediate risk to the health or safety of clients or staff. We may terminate the subcontractor agreement with written notice where the subcontractor fails to meet the required standards after a written improvement notice, where the subcontractor breaches any material term of the subcontractor agreement, where the subcontractor breaches confidentiality or data protection requirements, where the subcontractor sub-contracts work without our approval, where the subcontractor fails a modern slavery compliance check, or where a council partner withdraws approval for the subcontractor. On termination, the subcontractor must return all Bubble Fresh property (including ID badges, keys, and equipment), securely destroy or return all personal data and confidential information, and complete or hand over any work in progress in an orderly manner. The subcontractor's obligations regarding confidentiality, data protection, and indemnity survive termination of the agreement.
Training
Before starting any work on our behalf, all subcontractor personnel receive an induction covering our expectations, safeguarding procedures, health and safety requirements, confidentiality obligations, and the standards set out in this policy. We require evidence that all subcontractor personnel have completed appropriate training in safeguarding adults, COSHH, manual handling, and lone working before they carry out any client-facing work. Where our procedures differ from the subcontractor's own, we provide additional briefing to make sure there is no gap. We keep records of all induction and training provided to subcontractor personnel. For our wider approach to training standards, see our Training and Development Policy.
Contact us
If you have any questions about this policy, contact us by phone on 01933 213045, via Relay UK on 18001 then 01933 213045, or by post at Bubblefresh Limited, 6 Carnegie Street, Rushden, Northamptonshire, NN10 9SN.
Changes to this policy
We may update this policy from time to time to reflect changes in legislation, guidance, or best practice. Where we make material changes, we will notify our council partners and ensure all active subcontractors are briefed on the changes before they take effect.
Review
The Director, Lance James, reviews this policy annually. We would also update it before engaging any subcontractor, to make sure it reflects current requirements. Last reviewed: February 2026. Next review due: February 2027.
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