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SL48-Handling Service User Belongings and Valuables Policy

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Handling Service User Belongings and Valuables Policy

1. Purpose

The purpose of this policy is to ensure that the personal belongings, valuables, money and financial items of people we support are respected, safeguarded and managed lawfully, safely and transparently. This policy sets out how {{org_field_name}} will support individuals to retain maximum choice, control and independence over their belongings and valuables while putting in place proportionate safeguards where support is required.

This policy applies a person-centred, least restrictive approach and is intended to prevent loss, theft, financial abuse, misuse, avoidable distress, poor record keeping and conflicts of interest. It also explains the arrangements for consent, mental capacity, recording, secure storage, access, reconciliation, incident management, complaints and audit.

This policy is designed to support compliance with the 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 12 (Safe Care and Treatment), Regulation 13 (Safeguarding Service Users from Abuse and Improper Treatment), Regulation 16 (Receiving and Acting on Complaints) and Regulation 17 (Good Governance), together with the Mental Capacity Act 2005, the Care Act 2014, the Human Rights Act 1998, UK GDPR and the Data Protection Act 2018.

2. Scope

This policy applies to all permanent, temporary, agency and bank staff, volunteers, students, contractors and managers working on behalf of {{org_field_name}} who may come into contact with, record, store, handle, transport or support a person to manage their belongings, valuables, money or financial items.

This policy applies in supported living settings, including when support is delivered in a person’s own home, tenancy, shared accommodation, or any other community-based setting where {{org_field_name}} provides regulated activity. It covers clothing, personal possessions, identity documents, keys, assistive equipment, sentimental items, jewellery, cash, bank cards, payment devices, benefit or pension monies held temporarily, and any other item that a person asks us to help manage.

Nothing in this policy removes the individual’s ownership of their belongings or their right to make day-to-day decisions unless there is a lawful basis, a documented assessment, and a proportionate plan to support or restrict access in their best interests.

3. Related Policies

4. Policy Statement

{{org_field_name}} recognises that personal belongings and valuables are closely linked to identity, dignity, independence, emotional wellbeing and human rights. We will always support people to manage and retain control over their own property wherever possible.

Where a person wants support, or where an assessment identifies a specific risk of loss, misuse, exploitation, self-neglect or harm, staff will provide support in line with the person’s wishes, assessed needs, mental capacity, lawful authority and agreed care and support plan. Any restriction or protective arrangement must be necessary, proportionate, clearly recorded, regularly reviewed, and the least restrictive option available.

Staff must not borrow, use, remove, gift to themselves, or otherwise benefit from a person’s belongings, money or valuables. Staff must never use a person’s bank card, PIN, online banking, payment device or cash except where this is expressly authorised within a documented support plan, supported by consent or lawful authority, and subject to robust recording, receipts, oversight and audit.

Any concern about missing items, financial irregularity, coercion, theft, misuse, pressure, undue influence or potential abuse will be treated seriously and managed under safeguarding, incident reporting and disciplinary procedures as appropriate.

5. Principles

5.1 Person-centred practice

People we support will be involved in decisions about their belongings, valuables and money. Support arrangements must reflect the person’s wishes, preferences, communication needs, cultural requirements and desired level of independence.

5.2 Consent and mental capacity

Consent must be sought before staff handle, store, record or assist with a person’s belongings or valuables, unless immediate action is required to prevent serious harm and this is lawful and documented. Where there is doubt about a person’s capacity to make a particular decision, staff must follow the Mental Capacity Act 2005, including the presumption of capacity, support to make decisions, decision-specific assessment, and best interests processes where required.

5.3 Safeguarding and prevention of financial abuse

Systems must protect people from theft, coercion, exploitation, misuse of possessions, fraud or financial/material abuse. Concerns must be recognised and escalated without delay.

5.4 Least restrictive approach

People should keep belongings in their own possession wherever this is safe and consistent with their wishes. Provider-held storage must only be used where requested by the person or justified by assessment and planning.

5.5 Accurate records and accountability

All support relating to valuables, cash, bank cards, keys and important possessions must be clearly documented, signed, auditable and regularly checked.

5.6 Dignity, privacy and respect

Staff must treat all personal possessions respectfully and avoid intrusive or unnecessary handling of property.

5.7 Accessible complaints and challenge

People we support, families, advocates and representatives must be able to raise concerns or complain about the handling of belongings and valuables, and must know how to do so in an accessible format.

6. Procedures

6.1 Recording Personal Belongings

At the start of support, and whenever {{org_field_name}} takes responsibility for assisting with a person’s belongings or valuables, an inventory must be completed with the person wherever possible. In supported living, this should normally take place at commencement of the service, at transition into the accommodation, after a hospital admission or discharge where relevant, or when a significant change in circumstances means the provider is being asked to assume greater responsibility for property or valuables.

The inventory must be person-centred and proportionate. It should record only the level of detail necessary for safeguarding, accountability and continuity of support. The record should identify items of significant financial, legal, practical or sentimental value, including keys, identity documents, bank cards, cash amounts held by staff, jewellery, mobility aids, communication devices and other items agreed in the support plan.

Where possible, the inventory must be checked and signed by the person and the member of staff completing it. If the person does not wish to sign, is unable to sign, or there is a dispute about the record, this must be clearly documented together with the reason and any involvement of a family member, advocate, attorney, deputy or other lawful representative.

Inventories must be reviewed and updated whenever items are added, removed, replaced, damaged, lost, transferred or returned, and at planned review intervals set by the service. Photographic records may be used with consent where this is appropriate and proportionate.

6.2 Handling Valuables

People we support should be encouraged and enabled to manage their own valuables wherever possible. Staff must not routinely take control of valuables simply for organisational convenience.

Where a person asks {{org_field_name}} to hold valuables, or where support is required because of an assessed risk, this must be clearly set out in the person’s support plan and risk assessment. The record must specify what is being held, why support is required, where the item will be stored, who may access it, what consent or lawful authority applies, and how often the arrangement will be reviewed.

Before staff take possession of valuables, the person’s consent must be obtained and recorded, unless the person lacks capacity for that specific decision or there is an immediate and lawful safeguarding reason to act. Where the person lacks capacity, staff must follow the Mental Capacity Act 2005 and record the capacity assessment, best interests decision, who was involved, and the legal status of any attorney, deputy or other authorised representative.

Any cash, jewellery, bank card, payment device, passport, tenancy agreement, benefit letter, cheque book or other valuable held by the service must be entered into a valuables register. The register must include the item description, amount where relevant, date and time received, reason for holding, name of the person, signatures of the staff member and the person supported wherever possible, and the date and time of return.

Stored valuables must be kept securely in a designated locked facility with controlled access. Each occasion of access must be recorded, including date, time, reason, item removed or returned, and the names and signatures of the staff involved. Dual staff witnessing should be used for high-risk items, cash handling, discrepancy checks and returns.

Staff must never use or retain a person’s PIN unless this is exceptionally justified, lawfully authorised, specifically risk assessed, documented in the support plan, and subject to enhanced managerial oversight. Staff must not keep a person’s bank card or payment device in service storage without clear consent or lawful authority and an explicit care-planned reason. Under no circumstances may staff use a person’s property for personal benefit or convenience.

6.3 Managing Finances

Where {{org_field_name}} provides support with day-to-day finances, shopping, bill payments, collection of pensions or benefits, or access to cash, this must be managed under the person’s support plan, risk assessment and the Managing Service User Finances Policy (SL41). This policy must be read alongside that policy and does not replace it.

Any financial transaction carried out by staff on behalf of a person must be transparent, evidenced and capable of audit. Records must include the date, amount, purpose, method of payment, balance where relevant, staff names, and receipts or equivalent proof of purchase. Cash balances held temporarily by the service must be counted and reconciled at agreed intervals and whenever responsibility transfers between staff.

Staff must not act outside the authority granted to them. Where a person has a Lasting Power of Attorney, deputy, appointee or other person lawfully managing finances, the role and limits of staff involvement must be clearly recorded. Any refusal, disagreement, unusual transaction, unexplained shortfall, missing receipt, suspected coercion or sign of financial abuse must be escalated immediately to the line manager and considered under safeguarding procedures.

6.4 Storage and Labelling

In supported living, people should normally keep their belongings in their own rooms, flats or living areas, unless they ask for support or an assessment identifies a clear reason for alternative arrangements. Storage arrangements must respect the person’s home, privacy and tenancy rights.

Items should only be labelled where this is practical, proportionate and in the person’s best interests, for example to reduce the risk of loss, mix-up or incorrect use. Labelling must be done sensitively and in a way that does not undermine dignity or privacy.

Where secure provider-held storage is used, the location, access arrangements and security measures must be documented. Keys, key safes, access codes and any communal storage arrangements must be managed securely and only shared with authorised persons. Medication and medical devices must continue to be managed under the Medication Management Policy, but any overlap with personal valuables, such as controlled access to monitoring equipment or communication aids, should be clearly addressed in the support plan.

6.5 Loss, Theft, or Damage

Any loss, unexplained discrepancy, theft, suspected theft, damage or allegation concerning a person’s belongings or valuables must be reported immediately to the senior person on duty or line manager and recorded in line with the Incident Reporting Policy.

Immediate action must include taking steps to preserve evidence, checking records and storage logs, speaking with the person in a sensitive and accessible way, assessing whether the matter may amount to financial or material abuse, and deciding whether safeguarding, police involvement, landlord notification, insurance processes or commissioner notification are required.

The person supported, and where appropriate their family member, advocate, attorney, deputy or representative, must be kept informed of the concern, the action being taken and the outcome, unless there is a lawful reason not to do so. The person must also be told how to make a complaint and how to seek independent support to do so.

All investigations must be documented, proportionate and concluded with findings, actions, lessons learned and any required service improvements. Reimbursement, repair or replacement will not be automatic and will depend on the facts of the case, contractual arrangements, insurance position, evidence available and whether the provider was at fault. However, any remedy offered must be explained clearly and recorded.

6.6 Handling the Property of a Person Who Has Died

Where a person we support dies, staff must act with dignity, sensitivity and in accordance with any end of life, death, tenancy, safeguarding, incident reporting and notification procedures that apply. Staff must not remove, distribute or dispose of the person’s belongings unless authorised to do so through lawful process or clear managerial instruction based on legal advice or agreed procedure.

Where {{org_field_name}} holds any valuables, cash, keys or documents belonging to the deceased person, these must be checked against the relevant inventory and valuables records as soon as practicable. A manager must oversee the check, and a full record must be made of all items held, their condition, and any transfer to the next of kin, executor, administrator, landlord, local authority, police or other authorised person.

In supported living services, staff must recognise that belongings may remain within the person’s own home or tenancy and may not automatically fall under provider control. Staff must therefore liaise appropriately with the person’s next of kin, legal representative, landlord or housing provider, commissioner and any relevant authority before any belongings are moved or released.

Any handover of property must be recorded in writing, signed and dated by the person receiving it wherever possible. Unclaimed items must not be disposed of until the provider has followed the relevant legal, contractual, tenancy, probate, commissioner and organisational requirements and obtained appropriate authorisation.

6.7 Consent, Capacity and Lawful Authority

Before staff support with belongings, valuables or financial items, they must consider whether the person has given valid consent for that specific support. Consent must be assumed absent unless it has been given, can reasonably be implied from the circumstances, or there is another lawful basis for action.

Where there is reason to doubt a person’s capacity to decide about a specific item or arrangement, staff must follow the Mental Capacity Act 2005. Capacity assessments must be decision-specific and recorded. Where the person lacks capacity, any decision to hold, restrict access to, monitor or manage property or valuables must be made in the person’s best interests, with involvement of relevant others and with the least restrictive option chosen.

Where another person is acting on behalf of the individual, staff must verify and record the basis of that authority, for example Lasting Power of Attorney, Court of Protection deputyship, DWP appointeeship, or another lawful arrangement. Staff must remain clear about the limits of each role and must seek management advice where authority is unclear or disputed.

6.8 Audit, Reconciliation and Managerial Oversight

Managers must ensure that all inventories, valuables registers, cash records, access logs, discrepancy reports and return records are subject to regular review and audit. The frequency of checks must reflect the level of risk and the volume of valuables or cash handled by the service.

Any discrepancy, incomplete record, missing signature, unusual transaction, repeated error or pattern of concern must be investigated promptly and escalated where required. Audit findings must be used to improve practice, reduce risks and inform supervision, training, safeguarding action and policy review.

Records created under this policy must be accurate, complete, contemporaneous, securely stored and retained in accordance with legal and organisational requirements.

6.9 Complaints and Disputes

Any person we support, relative, advocate, representative or other interested party may raise a concern or complaint about the handling, loss, storage, recording or return of belongings and valuables. Staff must respond seriously, respectfully and without defensiveness.

People must be given information in an accessible format about how to raise a complaint, who will deal with it, expected timescales, and how they can obtain support or advocacy. Raising a complaint must not adversely affect the person’s support.

Complaints must be handled in line with the Complaints Policy and recorded, investigated and responded to in writing where appropriate. Outcomes, remedies and lessons learned must be documented and fed into governance and service improvement systems.

6.10 Prohibited Staff Practices

Staff must not:

Any breach of this section may be treated as a safeguarding concern, disciplinary matter, potential misconduct or criminal matter.

7. Staff Responsibilities

Registered Manager

The Registered Manager is responsible for ensuring implementation of this policy, maintaining effective systems for inventories and valuables records, ensuring investigations are completed, overseeing audits and reconciliations, ensuring staff receive training and supervision, and taking action where concerns, discrepancies or safeguarding issues arise.

Deputy Manager / Team Leaders / Senior Staff

Senior staff must monitor day-to-day compliance, check that records are complete, countersign high-risk transactions where required, respond promptly to incidents and discrepancies, and escalate concerns without delay.

All Staff

All staff must follow this policy, obtain and record consent where required, respect the person’s property, maintain accurate records, protect confidentiality, report concerns immediately, and never place themselves in a position where their conduct could be perceived as exploitative, secretive or inappropriate.

Key Workers / Named Staff

Key workers must ensure that relevant care plans, risk assessments and property records are up to date and reviewed with the person, and that any changes in need, capacity, risk or legal representation are reflected in current documentation.

8. Legislative and Regulatory Framework

This policy supports compliance with:

In supported living settings, this policy must be applied in a way that recognises the person’s tenancy, home, privacy, autonomy and legal rights over their own property, while ensuring that the provider’s systems are robust where staff support is provided.

9. Policy Review

This policy will be reviewed at least annually and earlier if there is a change in legislation, CQC guidance, local safeguarding requirements, case law, service model, serious incident, complaint trend, audit finding, or learning arising from investigations relating to property, valuables or financial abuse. Lessons learned from incidents, safeguarding enquiries, complaints and audits will be used to update this policy and associated procedures.

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.

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