# Passport custody: keeping a factual record of who holds what

A practical way for recruitment agencies to record where each worker's passport is, who has it, since when and why, so the question can always be answered from a record and not from memory.

By Worker Vault · Published 3 October 2026 · 5 min read

URL: https://workervault.com/blog/passport-custody-record-foreign-workers

**Key points**

- A custody record answers four questions: who holds it, since when, why and when it came back.
- Record every hand-over and return as an entry with a date and a name.
- Review open custody entries on a schedule so none sits unexplained.
- The record states facts. Rules on what is permitted come from the relevant authority and your adviser.

Where is this worker's passport right now? It is a simple question, and in a busy agency it can take several messages to answer. The passport may be with the worker, with a clerk preparing an application, with a courier or with an employer client's office. When nobody can say, the first problem is practical. Later, it can become a larger one.

A custody record turns that question into something you can look up. This article describes what to put in it and how to keep it honest, as one part of [keeping worker records in order](https://workervault.com/blog/keep-worker-records-and-document-expiry-in-order). It is about recording facts. It is not advice on what is permitted. The rules on holding a worker's passport depend on the country and the circumstances, and your legal adviser and the relevant authority are the right source for them.

## What a custody entry holds

Keep an entry for every change of hands, with five facts:

1. **Who has it now:** a named person or organisation, not "the office".
2. **Since when:** the date it was handed over.
3. **Why:** the reason, in one line. For example, "submitted with an application" or "worker asked the office to keep it safe".
4. **Where it is:** the location or the person responsible for it.
5. **When it came back:** the date it was returned to the worker or passed on, with who confirmed.

A free-text note field is useful, but do not let the note replace the structured fields. A date in a note cannot be sorted or counted.

## Record the worker's side too

Where the worker has asked for the passport to be kept, or has asked for it back, record that request with the date. A custody history that only shows the agency's actions tells half the story. If any consent or request is in writing, attach the document to the entry.

## Make hand-overs two-sided

A hand-over has two parties. Whenever a passport changes hands, both people should be named in the record, and the receiving person should confirm. This is the simplest way to avoid the entry that says "with the clerk" when the clerk has already passed it on.

## Set a review rhythm

An open custody entry is not a problem in itself. An open entry with no recent review is. Choose a threshold that suits your workflow, such as the number of days a passport can sit with the agency before someone looks at it, and make the list of entries over that threshold a standing item in your [weekly review](https://workervault.com/blog/weekly-placement-pipeline-review).

For each entry on the list, ask:

- Is the reason still current?
- Does the worker know where the passport is?
- Is there a next step with a date?

If the answer to any is no, fix the record, and the situation behind it, the same day.

## Keep the record apart from judgement

A custody register records what happened. It does not decide whether what happened was appropriate, and it should not be written to look as if it does. Use plain, neutral wording in entries. Describe the action and the date, and leave interpretation out.

If you are unsure whether a practice is permitted for a worker in a particular country or pass type, ask your legal adviser and check the authority's own guidance. Then record the outcome of that advice as an internal note, with the date.

## Handling exceptions

Some cases do not fit the usual pattern. A passport may be held at a clinic or at an embassy for a short period, or a worker may be travelling and carry it. Record these as entries like any other, with the holder, the reason and the date. Do not leave a gap in the history because the situation was unusual.

If a passport cannot be located, record that on the day it is found out, with who was told and what was done. A prompt, honest entry is far more useful later than a tidy history that was written after the fact. The aim of the record is to say what happened and when, in a way that someone else can follow.

## A short weekly check

- Entries open longer than your threshold are listed and reviewed.
- Each open entry has a current reason and a named holder.
- Returns are recorded on the day they happen.
- The worker knows where the passport is.

## Where Worker Vault fits

Worker Vault carries a passport custody register on each placement and worker, with a hold history. The threshold for review is a workspace setting. When a candidate is deployed, the custody history [carries into the worker record](https://workervault.com/blog/worker-record-handover-at-deployment), so the question of who held the passport does not start again from nothing.

The register records facts entered by your team. It does not decide whether holding a passport is lawful. See [worker records](https://workervault.com/solutions/worker-records) for how custody, documents and employment history sit together, and [Book a Demo](https://workervault.com/book-a-demo) to see it on your own placements.

This post provides general information only. It is compiled from information publicly available on the web and is not an official source or legal or professional advice. Rules and requirements change over time, so check the facts with the relevant official authority before acting. Worker Vault accepts no responsibility for how this content is used.