Registration Number: {{org_field_registration_no}}

Handling Service User Belongings and Valuables Policy

1. Purpose

The purpose of this policy is to establish clear guidelines for the handling, safeguarding, and management of service user belongings and valuables within {{org_field_name}}. This policy ensures that service users’ possessions are treated with respect, accountability, and transparency, while minimising the risks of loss, theft, or misplacement.

By implementing this policy, we ensure compliance with Care Quality Commission (CQC) Fundamental Standards, the Care Act 2014, and best practices in safeguarding vulnerable individuals and their property.

2. Scope

This policy applies to:

All employees, including care workers, administrative staff, and management.
Service users and their families, ensuring their belongings and valuables are protected.
Third-party contractors and external service providers working within service users’ homes.
Regulatory bodies and safeguarding teams, ensuring compliance with best practices.

It covers:

Principles for handling belongings and valuables.
Inventory and record-keeping procedures.
Safe storage and security measures.
Staff responsibilities and conduct.
Reporting and resolving issues.
Preventing financial and property abuse.

3. Legal and Regulatory Framework

This policy aligns with the following current legislation, regulations and statutory guidance, as amended:

Care Act 2014 and Care and Support Statutory Guidance – including safeguarding requirements relating to financial and material abuse. Financial or material abuse may include theft, fraud, exploitation, coercion in relation to financial affairs, property, wills or inheritance, and misuse or misappropriation of property, possessions or benefits.
Mental Capacity Act 2005 and current Code of Practice – governing decision-making where a person may lack capacity to make a particular decision concerning their belongings, property or finances, including supported decision-making, best-interests decisions and the least restrictive principle.
Health and Social Care Act 2008 and Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, including:
- Regulation 9 – Person-centred care.
- Regulation 10 – Dignity and respect.
- Regulation 11 – Need for consent.
- Regulation 13 – Safeguarding service users from abuse and improper treatment.
- Regulation 17 – Good governance.
- Regulation 18 – Staffing.
- Regulation 20 – Duty of Candour.
Regulation 13 – Safeguarding service users from abuse and improper treatment – including protection against theft, misuse or misappropriation of money or property belonging to a service user.
Care Quality Commission (Registration) Regulations 2009, including Regulation 18 concerning statutory notification of abuse, allegations of abuse and relevant police involvement.
Equality Act 2010 – protecting people from unlawful discrimination and requiring appropriate reasonable adjustments.
UK General Data Protection Regulation and Data Protection Act 2018, as amended by the Data (Use and Access) Act 2025 – governing the lawful, fair and secure processing of information concerning service users’ belongings, property, financial transactions and valuables.
Applicable local Safeguarding Adults Board procedures relating to financial or material abuse.

{{org_field_name}} will ensure that service users’ belongings, money and valuables are handled only where this is necessary, agreed or lawfully authorised, properly recorded and subject to appropriate safeguards.

4. Principles for Handling Belongings and Valuables

Our approach to managing service user belongings and valuables is based on:

Respect for personal property – Ensuring that all items are handled with care.
Transparency and accountability – Keeping accurate records of valuables under our care.
Security and safeguarding – Preventing unauthorised access to belongings.
Non-intrusive handling – Avoiding unnecessary interference with personal possessions.
Prompt reporting – Addressing any incidents of lost or missing items immediately.

5. Inventory and Record-Keeping Procedures

To ensure accountability and transparency, {{org_field_name}} maintains clear, auditable records whenever staff support service users with belongings, valuables or money. We will ensure that:

Initial property inventory – Where a service user requires support with valuables or significant possessions, an inventory of high-value or high-risk items (for example jewellery, electronic devices, cash kept at home) is documented and kept under review.
Care planning link – Any support with belongings, money or valuables is clearly described in the service user’s care plan and risk assessment, and reviewed at least annually or sooner if needs change.
Signed documentation – Service users (or their representative, appointee, attorney or deputy) and staff sign to confirm the accuracy of any inventory and any subsequent changes.
Financial transaction records – Where staff assist with shopping, online purchases, withdrawing cash, paying bills or handling money on behalf of a service user, a financial transaction record is completed each time, showing:
- date and time
- purpose of the transaction
- amount of money involved
- starting and ending balance (where applicable)
- receipt or other evidence attached
- signatures of the staff member and, where possible, the service user.
Receipts – Receipts are obtained and attached for all purchases made by staff using a service user’s money. Where a receipt cannot be obtained, this is clearly recorded with an explanation, and countersigned by a second member of staff or the line manager.
Dual-signatory arrangements – Where practical, balances of cash held on behalf of service users and any reconciliations are checked and signed by two members of staff, or by staff and the service user or their representative.
Regular audits – The Registered Manager or delegated person completes regular audits of inventories, financial transaction records and reconciliations, and promptly follows up any discrepancies.
Secure storage of records – All records relating to belongings, valuables and finances are stored securely and retained in line with {{org_field_name}}’s data protection and records retention policies, in compliance with UK GDPR and the Data Protection Act 2018.

6. Safe Storage and Security Measures

To prevent loss or theft:

Service users retain full access and control over their belongings unless support is needed.
Storage guidance is followed, ensuring items are safely secured as per service user preference.
Keys and lockable storage options are available for those needing extra security.
Staff do not hold or manage large sums of money or valuable items unless explicitly authorised.

In relation to money, bank cards and financial information, {{org_field_name}} will also ensure that:

Staff must not use a service user’s bank or building society card, online banking, or contactless payment methods unless this is clearly authorised in the care plan, risk-assessed, and there are agreed written controls in place.
Staff must never record, retain or share a service user’s PIN, online banking password or other security information. If a service user chooses to share such details, staff must explain the risks and record the discussion; staff must not store this information in any written form.
Where a service user cannot safely manage bank cards or cash, we will work with the commissioning authority, family, appointee, attorney or deputy to agree safe arrangements (for example, use of a local authority or appointee scheme).
Staff must not keep a service user’s money, cards or valuables in their own possession, vehicles or homes. Any temporary holding of items (for example, while on an outing) must be clearly recorded and reconciled immediately after use.
Any loss or suspected theft of money, bank cards, benefit books, identification or valuables is treated as a potential safeguarding concern and reported without delay in line with our Safeguarding and Whistleblowing Policies.

Mental Capacity, Consent and Best Interests

{{org_field_name}} recognises that handling belongings, valuables and money can involve significant decisions and potential risk. We will apply the five principles of the Mental Capacity Act 2005 whenever there is doubt about a person’s capacity to make decisions about their property or finances. In particular:

We will assume capacity unless there is clear reason to doubt it, and provide information and support in accessible formats to help the person make their own decision.
Where there is doubt, a decision-specific capacity assessment will be completed and recorded, following the MCA Code of Practice.
If a person lacks capacity for a particular property or finance decision, any action taken by staff must be in the person’s best interests, using a structured best-interests decision process and involving those who know the person well (family, friends, attorney, deputy, appointee or advocate) as appropriate.
Where a person has an appointed attorney, deputy or DWP appointee, staff will work within the limits of that authority and follow any relevant instructions, while continuing to safeguard the person from financial abuse.
Records of capacity assessments and best-interests decisions relating to belongings, valuables or finances will be kept with the care plan and reviewed regularly.

7. Staff Responsibilities and Conduct

All staff must protect service users’ property, privacy, dignity and financial interests.

Staff must:

Obtain the service user’s agreement before handling their belongings, money or valuables where the person has capacity to make the relevant decision.
Where the person lacks capacity for the specific decision, only handle belongings, money or valuables where this is supported by a lawful Mental Capacity Act best-interests decision or other appropriate legal authority.
Follow the person’s care plan, risk assessment and any documented limitations on what staff may handle.
Respect privacy and avoid touching, searching, moving or interfering with personal possessions unnecessarily.
Handle only those belongings or valuables necessary for the agreed care or support activity.
Maintain accurate records whenever organisational procedures require belongings, valuables or money to be documented.
Immediately report unexplained loss, damage, discrepancies or suspected misuse.

Staff must not:

Borrow money from a service user.
Lend money to a service user.
Use service-user money for their own purposes.
Enter into private loans or other personal financial arrangements with service users or their families.
Purchase goods from or sell goods to service users where this creates a conflict of interest or breaches organisational procedures.
Use a service user’s bank card, account or payment method except where this is specifically authorised and controlled under the person’s care arrangements.
Remove service-user property from the home except where this is specifically required and authorised for an agreed purpose.

Gifts and Gratuities

Staff must not solicit money, gifts, tips or other financial benefits from service users or their representatives.

Low-value tokens of appreciation, such as chocolates or flowers, may only be accepted where permitted by {{org_field_name}}’s Gifts and Hospitality Policy.

Where accepted, such gifts must be:

Declared to the appropriate manager.
Recorded where required by organisational procedures.
Free from pressure, expectation or conflict of interest.

High-value gifts, money, loans or other significant benefits must not be accepted.

Wills, Inheritance and Legal Documents

Staff must not:

Encourage or pressure a service user to change a will.
Influence decisions concerning inheritance or property.
Seek to become a beneficiary of a service user’s estate.
Exploit their professional relationship for personal financial benefit.

Any proposal by a service user to leave a significant gift or inheritance to a member of staff must be reported immediately to the Registered Manager and considered as a potential professional-boundary and safeguarding issue.

Staff must not witness wills or other significant legal or financial documents as part of their ordinary care duties.

Any exceptional circumstance must be referred to the Registered Manager and appropriate independent legal advice should be obtained where necessary.

8. Reporting and Resolving Issues

Any missing, lost, damaged, misused or suspected stolen money, belongings or valuables must be taken seriously and dealt with promptly.

8.1. Immediate Reporting

Staff must immediately report to the Registered Manager, on-call manager or designated safeguarding lead:

Missing money.
Missing valuables.
Unexplained discrepancies.
Suspected theft.
Suspected misuse or misappropriation of property.
Damage that may have been caused deliberately or through neglect.
Unauthorised use of bank cards or payment methods.
Suspected financial exploitation.
Concerns involving gifts, wills or inheritance.
Any allegation against a member of staff or another person.

The concern must also be documented through {{org_field_name}}’s incident-reporting system.

Immediate steps must be taken to protect the service user’s remaining property and financial interests where necessary.

8.2. Safeguarding

The Registered Manager or Safeguarding Lead will assess the concern under {{org_field_name}}’s Safeguarding Adults Policy and applicable local Safeguarding Adults Board procedures.

Theft, misuse or misappropriation of money or property belonging to a service user constitutes abuse for the purposes of Regulation 13.

Where financial or material abuse is suspected:

The local authority safeguarding team will be informed where appropriate.
The police will be contacted where a criminal offence may have occurred or where otherwise appropriate.
Relevant commissioners or professionals will be informed where required.
Evidence and records will be preserved.
Appropriate measures will be taken to prevent further access to the person’s money or property while the concern is investigated.

8.3. CQC Statutory Notification

The Registered Manager will consider whether the incident is notifiable to CQC under the Care Quality Commission (Registration) Regulations 2009.

Under Regulation 18, {{org_field_name}} must notify CQC without delay of abuse or an allegation of abuse in relation to a service user where it occurs while services are being provided in carrying on the regulated activity, or as a consequence of carrying on that regulated activity.

For this purpose, abuse includes:

Theft.
Misuse of money or property.
Misappropriation of money or property.

Where an incident involving a service user is reported to or investigated by the police, the separate Regulation 18 police-notification requirement must also be considered.

An internal investigation or safeguarding enquiry must not delay a statutory CQC notification that is required without delay.

8.4. Duty of Candour

{{org_field_name}} will act openly and transparently with people using the service.

Where an incident meets the statutory definition of a notifiable safety incident under Regulation 20, the formal Duty of Candour procedure will be followed.

For {{org_field_name}}, as a registered provider other than an NHS health service body, this means an unintended or unexpected incident occurring during provision of a regulated activity which, in the reasonable opinion of a healthcare professional:

Appears to have resulted in:

The death of the service user where the death relates directly to the incident rather than the natural course of illness or an underlying condition.
An impairment of sensory, motor or intellectual function lasting, or likely to last, continuously for at least 28 days.
Changes to the structure of the person’s body.
Prolonged pain.
Prolonged psychological harm.
A shortening of life expectancy.

Or requires treatment by a healthcare professional to prevent:

Death; or
An injury which, if untreated, would lead to one or more of the statutory outcomes above.

Loss, theft or damage to property does not automatically trigger the formal Duty of Candour procedure merely because the loss is significant or distressing.

The incident must meet the statutory Regulation 20 criteria.

Where the formal Duty of Candour threshold is met, {{org_field_name}} will:

Notify the relevant person as soon as reasonably practicable.
Provide reasonable support.
Provide a truthful factual account of what is known.
Explain further enquiries or investigations considered appropriate.
Provide a sincere apology.
Follow up in writing.
Maintain appropriate records of the process.

The organisation will nevertheless communicate openly and appropriately about property loss, theft or damage even where the statutory Duty of Candour threshold is not met.

8.5. Investigation and Outcome

A proportionate investigation will be undertaken where appropriate to establish:

What happened.
When the item was last accounted for.
Who had access to the item.
Whether relevant care plans and procedures were followed.
Whether records and reconciliations are complete.
Whether a staff conduct or disciplinary concern exists.
Whether a safeguarding concern exists.
Whether criminal activity may have occurred.
Whether additional controls are required.

The service user and, where appropriate and lawfully authorised, their representative will be kept informed of relevant findings and actions.

Lessons identified will be used to update:

Care plans.
Risk assessments.
Financial controls.
Staff supervision.
Staff training.
Safeguarding procedures.
Organisational policies.

9. Preventing Financial and Property Abuse

{{org_field_name}} recognises financial and material abuse as a form of abuse under safeguarding legislation and Regulation 13 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. We will:

Ensure all staff receive initial and refresher safeguarding training that includes clear guidance on:
- recognising signs and patterns of financial and material abuse
- professional boundaries in relation to money, gifts and belongings
- how to raise concerns and use whistleblowing channels.
Provide role-specific training for staff who regularly support people with money, shopping or valuables, including practical exercises on record-keeping, receipts, reconciliation and responding to concerns.
Operate clear financial and property handling protocols that set out what staff may and may not do, and which require manager approval for any exceptional arrangements.
Maintain whistleblowing arrangements that enable staff, service users and others to raise concerns anonymously if they wish, without fear of reprisal.
Work collaboratively with local safeguarding adults boards, commissioning authorities and the police to ensure that any suspected financial or material abuse is investigated and addressed quickly and transparently.
Use audits, complaints, incident reports and safeguarding data to identify patterns or emerging risks and take preventative action.

10. Monitoring and Continuous Improvement

To ensure the effectiveness of this policy:

Regular audits and inspections of inventory records and security measures are conducted.
Feedback from service users and families is used to improve handling procedures.
Policy updates are made in response to regulatory changes or incidents

Insurance and Liability

{{org_field_name}} maintains appropriate insurance and indemnity arrangements to cover potential liabilities that may arise in relation to loss of, or damage to, service users’ belongings or valuables where this is due to our negligence or failure to follow agreed procedures.

Service users and their representatives are informed, in accessible formats, of what is and is not covered by our insurance, and are encouraged to arrange their own contents insurance where appropriate.

11. Policy Review and Updates

This policy will be reviewed at least annually, or sooner where necessary, to ensure that arrangements for safeguarding service-user belongings, money and valuables remain lawful, effective and consistent with current CQC and safeguarding requirements.

An earlier review will be undertaken where:

Regulation 13 safeguarding requirements materially change.
CQC statutory notification requirements concerning abuse or police involvement change.
Care Act safeguarding legislation or statutory guidance materially changes.
Mental Capacity Act legislation or guidance relevant to property or financial decisions changes.
Data protection legislation materially affecting records of belongings or financial transactions changes.
A serious financial or material safeguarding incident occurs.
Theft, misuse or misappropriation of service-user property is identified.
Repeated discrepancies occur in financial or property records.
Police involvement identifies weaknesses in organisational controls.
Complaints identify shortcomings in the handling of belongings or valuables.
Audits identify deficiencies in inventories, receipts, reconciliation or storage arrangements.
Professional-boundary concerns involving gifts, wills, property or inheritance arise.
The policy is found to be inaccurate or ineffective.

The Registered Manager is responsible for ensuring that safeguards relating to service users’ property are implemented and monitored.

The review will consider:

Property inventories.
Financial transaction records.
Receipts.
Reconciliation records.
Missing-property incidents.
Theft or fraud concerns.
Safeguarding referrals.
CQC Regulation 18 notifications.
Police involvement.
Duty of Candour cases.
Mental Capacity Act assessments and best-interests decisions.
Attorneys, deputies and appointees where relevant.
Gifts and gratuities.
Wills and inheritance concerns.
Complaints.
Whistleblowing disclosures.
Staff supervision.
Staff training.
Audit findings.
Service-user and representative feedback.
Relevant changes in legislation and CQC guidance.

Where weaknesses are identified, {{org_field_name}} will:

Take immediate steps to protect affected service users.
Review staff access to money, belongings or valuables.
Update care plans and risk assessments.
Strengthen inventory or reconciliation arrangements.
Provide additional staff training or supervision.
Take disciplinary action where appropriate.
Make safeguarding, police or CQC referrals or notifications where required.
Implement corrective and preventative action.

Material amendments to this policy will be documented, approved and communicated to relevant staff.

All staff must follow the current version of this policy and the specific arrangements documented in each service user’s care plan.

{{org_field_name}} will use learning from incidents, safeguarding concerns, complaints, audits and regulatory findings to continuously improve protection of service-user belongings and valuables.

Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.

DC48-Handling Service User Belongings and Valuables Policy