Immigration is mission-critical for many companies, and disruptions hit hard. The time to implement a defensible system is before you need it, not when an inspection lands.

We believe that the six-year document retention obligation needs an owner for all six years. Most employers who cannot produce some documents for an inspection were not hiring or employing a foreign national in bad faith.

For six years beginning on the first day of the work-permit employment period, you have to be able to show that you kept the records covering recruitment, hiring, onboarding and employment of every temporary foreign worker. ESDC now selects individuals and companies for inspection at random and through data, not just from complaints. Even a spotless program can be audited. Here is what we think is likely happening in practice.

  • LMIA decision letter and all annexes, plus the job offer whose terms the employment must continue to match → Immigration files, often with current or former counsel

  • Payroll and pay stubs. Wages must stay substantially the same as, and not less favourable than, the offer (IRPR s. 209.3(1)(a)(iv)) → Payroll

Wages for LMIA-based workers must be reviewed once a year against the prevailing wage for that occupation and region, and raised where needed by January 1. Job Bank publishes the new wages in the fall, usually early November, which leaves about six weeks over year-end. The wage can never fall below the wage in the positive LMIA.

  • Working-conditions records and evidence of a workplace free of abuse (IRPR s. 209.3(1)(a)(v)) → HR, handbooks, training records

  • Private health insurance registration, receipts for disbursements, and housing condition records → Benefits, finance, site management

  • Recruitment records, retained the full six years → Whoever ran the posting, potentially HR, an agency etc.

  • Know Your Rights information provided to the worker → Onboarding

Six of those seven rows sit with a different team. That is why the records go missing: no single person has ever held all of them. This is why we believe that compliance fails in the gaps between people, not because anyone isn't trying.

Callie is the shared system of record — one secure place where HR, global mobility, operations, and counsel each add the piece they hold, and update it on an annual basis, so the responsibility everyone shares stays whole for all six years.