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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Staff Identification and ID Card Policy

1. Purpose

The purpose of this policy is to ensure that staff working on behalf of {{org_field_name}} Supported Living Services can be appropriately identified and that staff identification arrangements support the safety, security, dignity and rights of people using the service.

Staff identification cards are an organisational security and identification measure. The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 do not impose a specific requirement for care staff to wear an employer-issued identification card. However, the organisation must operate effective recruitment and employment procedures and must obtain and retain the information required by Regulation 19 and Schedule 3 of the Regulations, including satisfactory proof of identity incorporating a recent photograph.

This policy aims to:

• Ensure that staff can provide appropriate evidence of their identity when carrying out duties on behalf of {{org_field_name}}.
• Support safe care and safeguarding arrangements by helping people using the service, their representatives and other appropriate persons to establish the identity of workers providing care and support.
• Support compliance with Regulation 12, Safe Care and Treatment, Regulation 13, Safeguarding Service Users from Abuse and Improper Treatment, Regulation 17, Good Governance, and Regulation 19, Fit and Proper Persons Employed, where those Regulations are relevant to staff identification, security and verification.
• Protect the dignity, privacy, autonomy and independence of people using supported living services.
• Ensure that identification information and records are managed securely and in accordance with applicable data protection legislation.
• Establish consistent arrangements for issuing, using, replacing, returning and deactivating staff identification cards.

Nothing in this policy gives {{org_field_name}} control over a person’s home beyond the rights and responsibilities arising from the care and support arrangements, any lawful agreement applying to the premises, and applicable legislation.

2. Scope

This policy applies to persons working for or on behalf of {{org_field_name}} where identification is required in connection with the provision, management or oversight of supported living services, including:

• Employees, including full-time, part-time and bank staff.
• Agency and temporary workers.
• Volunteers where they undertake duties on behalf of the organisation.
• Contractors where they are carrying out work on behalf of the organisation and require identification for that purpose.

External health or social care professionals who are not employed, engaged or contracted by {{org_field_name}} remain responsible for identification arrangements required by their own employing or professional organisation. Where appropriate, staff may verify the identity and purpose of attendance of an external professional before facilitating access to a person receiving support, subject to the person’s wishes, consent and applicable safeguarding requirements.

This policy applies to staff identification arrangements when staff are carrying out duties on behalf of {{org_field_name}}, including when providing regulated personal care in a person’s supported living accommodation.

For the avoidance of doubt, a person’s supported living accommodation is their home and must not be treated as a care home or as premises controlled by {{org_field_name}} merely because the organisation provides care or support there. Where {{org_field_name}} also controls an office, staff base or other non-domestic premises, the organisation’s access-control arrangements may apply to those premises.

The identification requirements in this policy must be implemented in a manner that respects each person’s privacy, dignity, autonomy, independence, tenancy or occupancy rights and choices about their home.

3. Legal and Regulatory Framework

This policy must be implemented in accordance with applicable legislation and regulatory requirements, including the following.

3.1 Health and Social Care Act 2008 and Health and Social Care Act 2008 (Regulated Activities) Regulations 2014

Where {{org_field_name}} carries on a regulated activity, the following Regulations are particularly relevant to this policy:

• Regulation 9 – Person-centred care: identification and security arrangements must not unnecessarily restrict a person’s choices or control over their care and support and must be applied in a way that reflects individual needs and preferences.
• Regulation 10 – Dignity and respect: identification and security procedures must respect people’s privacy, dignity, autonomy and independence, including recognition that supported living accommodation is the person’s home.
• Regulation 11 – Need for consent: where an identification or security procedure forms part of, or directly affects, the provision of care or treatment, the person’s consent must be obtained where required. Where a person lacks capacity to make the relevant decision, staff must act in accordance with the Mental Capacity Act 2005.
• Regulation 12 – Safe care and treatment: the organisation must provide care and treatment safely and must assess and manage relevant risks. Staff identification arrangements may form part of proportionate arrangements for reducing risks associated with unauthorised persons or uncertainty about the identity of a worker.
• Regulation 13 – Safeguarding service users from abuse and improper treatment: appropriate identity verification may support safeguarding arrangements by reducing the risk of unauthorised persons presenting themselves as staff or gaining inappropriate access to people receiving support.
• Regulation 17 – Good governance: the organisation must operate effective systems and processes to assess, monitor and mitigate risks and must maintain secure and accurate records relevant to the management of the regulated activity. Records relating to the issue, loss, return, cancellation or misuse of identification cards must therefore be maintained securely where such records are required for governance and risk-management purposes.
• Regulation 19 – Fit and proper persons employed: effective recruitment procedures must be operated and the information required by Schedule 3 must be available in relation to persons employed for the purposes of carrying on the regulated activity.

Schedule 3 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 requires proof of identity, including a recent photograph, to be available in respect of persons employed or appointed for the purposes of a regulated activity.

An employer-issued staff identification card may assist operational identification but does not replace the organisation’s duty to complete and retain the recruitment and employment checks and information required by Regulation 19 and Schedule 3.

3.2 Supported Living and CQC Registration

Where {{org_field_name}} provides the regulated activity of Personal care within supported living, the regulated activity relates to the personal care provided to the person in the place where they live.

Supported living accommodation must remain genuinely separate from the provision of personal care. A person’s home must not be treated as a care home or as premises controlled by the care provider merely because {{org_field_name}} provides care or support there.

Identification and access-control procedures must therefore distinguish between:

• the organisation’s own office, staff base or other premises that it lawfully controls; and
• the private home of a person using the supported living service.

Any restriction affecting access to a person’s home must have a lawful basis and must respect the person’s rights, wishes, consent and decision-making ability. Where the person lacks capacity to make a particular decision, the Mental Capacity Act 2005 must be followed.

3.3 Data Protection

Personal information used to create, administer or monitor staff identification cards must be processed in accordance with:

• the UK General Data Protection Regulation;
• the Data Protection Act 2018; and
• the Data (Use and Access) Act 2025, insofar as it amends the applicable data-protection framework.

{{org_field_name}} must ensure that personal information associated with identification cards and identification records is:

• processed lawfully, fairly and transparently;
• collected and used only for specified and legitimate purposes;
• adequate, relevant and limited to what is necessary for those purposes;
• accurate and kept up to date where necessary;
• retained for no longer than necessary in accordance with the organisation’s retention arrangements; and
• protected by appropriate technical and organisational security measures.

Access to identification-card records must be limited to persons who require access for an authorised purpose.

3.4 Health and Safety at Work etc. Act 1974

{{org_field_name}} must, so far as is reasonably practicable, protect the health, safety and welfare of employees and meet its applicable duties towards other persons who may be affected by its undertaking.

Any method used to display an identification card, including a lanyard, clip or other attachment, must not create an avoidable health or safety risk. Where an individual risk assessment identifies that a particular method of wearing an identification card would be unsafe, an appropriate alternative method of identification must be used.

3.5 Employment Rights Act 1996

Any deduction from wages or other withholding of wages in connection with the loss, non-return or replacement of an identification card must comply with the Employment Rights Act 1996.

No deduction may be made from wages unless the deduction is permitted by law, authorised by a relevant contractual provision of which the worker has been appropriately notified, or the worker has given the required prior written agreement or consent.

4. Staff Identification and ID Card Management

4.1 Issuance of ID Cards

• All staff members are issued an official photo ID card upon commencement of employment.
• ID cards must include:
  • Full name
  • Job title
  • Staff ID number
  • Expiry date
  • Organisation logo and contact details
  • A colour-coded system to differentiate permanent, temporary, and agency staff.
• Agency and temporary staff are issued temporary ID badges that must be returned at the end of each shift.
• Volunteers and contractors must wear visitor ID badges while on-site.

4.2 Wearing and Displaying ID Cards

• Staff must wear their ID cards at all times while on duty.
• ID cards should be clearly visible and worn using a lanyard or clip badge.
• Staff must present their ID card upon request from managers, security personnel, or external professionals.

4.3 Access Control and Security

• ID cards may be integrated with electronic access systems to restrict entry to specific areas.
• Lost or stolen ID cards must be reported immediately to management to deactivate access.
• Staff found loaning or sharing their ID cards will be subject to disciplinary action.

5. ID Card Renewal, Replacement, and Deactivation

5.1 ID Card Renewal

• ID cards are valid for three years or until the staff member’s contract expires.
• Renewals are automatic for existing employees, subject to employment status checks.
• Expired ID cards must be returned to us before a new one is issued.

5.2 Lost or Stolen ID Cards

• Staff must report lost or stolen ID cards immediately.
• A replacement ID card will be issued within 48 hours, and the lost card will be deactivated.
• Repeated loss of ID cards may result in investigation and possible disciplinary action.

5.3 Staff Leaving the Organisation

• Staff must return all identification cards issued by {{org_field_name}} no later than their final working day, unless another return arrangement has been authorised by management.
• The identification card and any associated electronic access permissions must be cancelled or deactivated as soon as they are no longer required and, in all cases, promptly following termination of the person’s authority to act on behalf of {{org_field_name}}.
• Failure to return an identification card must be reported to the responsible manager so that appropriate security measures can be taken, including cancellation or deactivation of the card where applicable.
• {{org_field_name}} will not withhold or make a deduction from wages, including final wages, because an identification card has not been returned unless the deduction is lawfully authorised in accordance with applicable employment legislation.
• Suspected fraudulent, dishonest or unauthorised use of an identification card after employment or engagement has ended may be investigated and, where appropriate, referred to the police or another relevant authority.

6. Visitors, Contractors and External Professionals

6.1 Visitors to a Person’s Supported Living Home

A person’s supported living accommodation is their home. Personal visitors, including relatives and friends, must not be treated as visitors to a care home or required by {{org_field_name}} to follow a blanket staff-controlled sign-in, identification-badge or escort procedure solely because the person receives care or support from the organisation.

People using the service must be supported to exercise choice and control over who visits their home, subject to any lawful restrictions that apply independently of this policy.

Staff must respect the person’s privacy, dignity, autonomy, independence and wishes in relation to visitors.

Where there is an identified safeguarding or safety concern relating to a particular visitor or proposed visit, staff must follow the organisation’s safeguarding and risk-management procedures. Any restriction must:

• have a lawful basis;
• be necessary and proportionate to the identified risk;
• be specific to the circumstances rather than imposed as a blanket restriction;
• take account of the person’s wishes and rights; and
• be documented and reviewed as appropriate.

Where a person has capacity to decide who may enter or visit their home, their decision must be respected unless there is a separate lawful basis for intervention.

Where a person lacks capacity to make the relevant decision, staff must follow the Mental Capacity Act 2005, including the relevant decision-making and best-interests requirements.

6.2 Communal Areas and Provider-Controlled Premises

Where there are communal areas, offices or staff bases to which {{org_field_name}} has a lawful right or responsibility to control access, proportionate visitor identification or sign-in arrangements may be used where required for safety, security or another legitimate purpose.

Such arrangements must not be applied in a way that improperly converts a person’s private home into premises controlled by the care provider.

6.3 Contractors and Persons Working on Behalf of {{org_field_name}}

Contractors, agency workers and other persons undertaking work on behalf of {{org_field_name}} must provide appropriate evidence of identity where required before they are permitted to undertake duties requiring access to people using the service, confidential information or provider-controlled premises.

Where {{org_field_name}} issues a temporary identification badge, it must be used only for the authorised purpose and must be returned or deactivated when the person’s authorised activity ends.

6.4 External Health and Social Care Professionals

External health and social care professionals may be asked to provide appropriate professional or employer-issued identification where their identity is not already known and verification is reasonably required.

Where access to a person’s home is required, the person’s wishes and consent must be respected. Staff may support the person to verify the identity and purpose of an external professional where appropriate.

Verification must be proportionate to the circumstances and must not unnecessarily delay urgent or emergency care.

7. Compliance and Enforcement

7.1 Staff Responsibilities

• All employees must:
  • Wear their ID card at all times while on duty.
  • Report lost or stolen ID cards immediately.
  • Ensure ID cards are used only for authorised purposes.
  • Never lend or share ID cards with others.

7.2 Management Responsibilities

• Managers must:
  • Ensure all new staff receive their ID card on their first day.
  • Maintain a secure ID card registry and audit records regularly.
  • Investigate and address any breaches of ID card policy.

7.3 Disciplinary Actions for Non-Compliance

• Failure to comply with this policy may result in:
  • Verbal or written warnings.
  • Suspension of access privileges.
  • Formal disciplinary action, up to and including termination of employment.

8. Monitoring and Auditing

• Management conducts monthly audits to verify ID card compliance.
• Spot checks are conducted by managers and security teams to ensure ID cards are worn correctly.
• Incident reports involving lost, stolen, or misused ID cards are reviewed quarterly.

9. Policy Review

This policy will be reviewed annually or sooner if:

• New security measures are introduced.
• Legislation or CQC requirements change.
• Staff or service user feedback indicates improvements are needed.

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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.