You do not need a work permit to access the Department of Labour Protection and Welfare. What you need to be able to do is prove you worked for an employer.
In terms of the DLPW, not having a work permit is seen as a deficit of the employer and not of the employee.
If not having a work permit is all it took for an employee not to be covered by labour law then employers would be incentivised not to assist in getting any work permits at all.
My apologies to the OP for sidetracking the discussion.