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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

This policy outlines the procedures for issuing, using, and managing staff identification (ID) cards at {{org_field_name}}. The policy ensures compliance with CQC regulations, the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, and Regulation 19 – Fit and Proper Persons Employed. It aims to enhance safety, security, and professionalism within our care home while ensuring that staff can be easily identified by the people we support, visitors, and regulatory bodies.

2. Scope

This policy applies to all staff employed at {{org_field_name}}, including full-time, part-time, temporary, bank, agency staff, volunteers, and contractors. It covers the issuance, replacement, and usage of ID cards and the responsibilities of all staff members regarding identification.

3. Legal and Regulatory Framework

This policy operates within the following legal and regulatory framework:

• Health and Social Care Act 2008: Provides the statutory framework for the regulation of health and adult social care services in England and for the functions and powers of the Care Quality Commission (CQC).
• Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Regulation 19 – Fit and Proper Persons Employed: Requires persons employed for the purposes of carrying on a regulated activity to be of good character; to have the qualifications, competence, skills and experience necessary for the work they perform; and to be able, after reasonable adjustments are made, to properly perform tasks intrinsic to their work. The organisation must establish and operate effective recruitment procedures and must obtain and make available the information required by Regulation 19 and Schedule 3, as applicable.
• Schedule 3 to the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014: Requires the organisation to obtain prescribed information about persons employed for the purposes of a regulated activity. This includes proof of identity incorporating a recent photograph and, as applicable to the individual and the role, appropriate criminal-record information, evidence of conduct in relevant previous employment, verification of the reason why relevant previous employment ended, evidence of relevant qualifications, employment history and explanations for gaps where required, and relevant information concerning the person’s capability to perform tasks intrinsic to their role after reasonable adjustments have been made. The statutory exemption applicable to the full employment-history requirement for volunteers will be applied where relevant.
• Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Regulation 17 – Good Governance: Requires records relating to persons employed in carrying on the regulated activity to be maintained securely. Records relating to identity verification and the administration of staff ID cards will therefore be created, maintained, accessed, retained and disposed of securely.
• Data Protection Act 2018 and UK GDPR: Personal data used to create, issue and manage staff ID cards, including names, photographs, job information and identification numbers, will be processed lawfully, fairly and transparently; limited to information that is adequate, relevant and necessary for the stated purpose; kept accurate; retained only for as long as necessary; and protected by appropriate security measures.
• Equality Act 2010: The organisation will make reasonable adjustments where required for disabled workers. A requirement to wear or display an ID card will therefore be applied in a manner that takes account of any reasonable adjustment required by law.
• Health and Safety at Work etc. Act 1974: ID card arrangements will be implemented in a way that does not create avoidable health and safety risks for staff or other persons within the care home.

The requirement within this policy for workers to wear an organisation-issued ID card is an organisational identification and security measure. It must not be interpreted as a statement that CQC legislation itself requires every care-home worker to wear an ID card.

4. Issuance of ID Cards

• Staff who are required by {{org_field_name}} to use an organisation-issued ID card will be provided with an appropriate ID card when authorised to commence their duties.
• Before a person is permitted to commence employment or deployment, {{org_field_name}} will ensure that the recruitment and pre-employment checks required by Regulation 19 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 and Schedule 3 have been satisfactorily completed and recorded, as applicable to the person and the role.
• Required checks will include proof of identity incorporating a recent photograph and, where applicable:
  • the appropriate criminal-record and barring information where the role is legally eligible for such a check;
  • satisfactory evidence of conduct in relevant previous employment;
  • satisfactory verification, so far as reasonably practicable, of the reason why previous employment involving work with children or adults at risk ended;
  • satisfactory documentary evidence of relevant qualifications;
  • a full employment history together with satisfactory written explanations of gaps in employment where this requirement applies;
  • information relevant to the person’s capability, after reasonable adjustments have been made, to perform tasks intrinsic to the role; and
  • any other information or professional registration required by law for the role.
• The statutory exception relating to the requirement for a full employment history for volunteers will be applied where applicable. Nothing in this policy prevents {{org_field_name}} from obtaining additional information about a volunteer where this is lawful and considered necessary for the role.
• Where recruitment checks have been carried out by an employment agency, contractor or another third party, {{org_field_name}} will obtain sufficient assurance that the required checks have been completed and are satisfactory before the individual is deployed in the service.
• A Disclosure and Barring Service check will only be obtained at the level for which the particular role is legally eligible. The presence of information on a DBS certificate will be considered through the organisation’s safer recruitment and risk-assessment procedures and will not automatically be described as a failure to obtain “DBS clearance”.
• ID cards issued by {{org_field_name}} will contain only information that is necessary for identification, security and legitimate organisational purposes. As applicable, this may include:
  • the staff member’s name;
  • job title or department;
  • photograph;
  • staff identification number where this is necessary for organisational verification;
  • organisation name and logo; and
  • expiry date where the organisation operates a defined ID-card renewal period.
• Information displayed on, and records associated with, ID cards will be processed and protected in accordance with the Data Protection Act 2018 and UK GDPR.

5. Use of ID Cards

• Staff who have been issued with an ID card and are required by {{org_field_name}} to wear it must display the card while on duty, unless doing so would create a health, safety, infection prevention or other identified risk, or a reasonable adjustment is required under the Equality Act 2010.
• Where an ID card cannot safely or appropriately be worn or displayed, the Registered Manager or delegated senior person will agree a suitable alternative means of identification. Any disability-related adjustment will be considered individually and will not result in unlawful disadvantage to the member of staff.
• ID cards must be worn or carried in a manner that enables staff to be appropriately identified by people using the service, visitors, colleagues and authorised persons while protecting confidential or unnecessary personal information.
• Staff must not lend, exchange, alter, copy or permit another person to use their ID card.
• Staff ID cards must only be used for authorised organisational purposes.
• Staff must provide appropriate evidence of their identity when reasonably requested by the Registered Manager, an authorised senior member of staff, CQC or another person lawfully entitled to verify their identity. Where CQC requests information or evidence as part of its regulatory functions, staff and managers must co-operate with the request in accordance with the organisation’s regulatory responsibilities.
• The organisation’s own ID card is an internal means of identification and must not be represented as a substitute for the statutory recruitment and identity checks required under Regulation 19 and Schedule 3.

6. Security and Access Control

• ID cards may be integrated with access control systems to regulate entry to specific areas of the care home.
• Lost or stolen ID cards must be reported immediately to the HR Department and Registered Manager.
• ID cards remain the property of {{org_field_name}} and must be returned upon termination of employment.
• Misuse of ID cards, including sharing or tampering, may result in disciplinary action under the Staff Conduct and Code of Ethics Policy.

7. Replacement of ID Cards

• If an ID card is lost, stolen, or damaged, staff must report it immediately to the HR Department.
• A replacement fee may be applicable unless the loss occurred due to circumstances beyond the staff member’s control.
• ID cards that become faded or unreadable must be replaced free of charge.
• Any name changes or job title updates will require reissuance of an updated ID card.

8. Temporary and Visitor ID Cards

• Agency workers, contractors and other temporary workers will be subject to appropriate identity and suitability verification before being permitted to undertake their duties. Where {{org_field_name}} requires temporary workers to use an organisation-issued temporary ID card, the card must be returned at the end of the relevant assignment or shift, unless another authorised arrangement applies.
• Where recruitment or suitability checks for an agency worker or contractor have been undertaken by another organisation, {{org_field_name}} will obtain sufficient assurance that the checks required for the individual’s role have been completed and are satisfactory before deployment.
• Ordinary visitors, including visiting professionals, will follow the care home’s reasonable sign-in, identification, safeguarding and security arrangements. Where a visitor pass is issued, the visitor will be asked to display it as appropriate and return it before leaving the premises.
• Visitor identification and security arrangements must be applied proportionately and must not impose an unnecessary or disproportionate restriction on a person’s right to receive visitors.
• CQC inspectors are not to be treated solely as ordinary visitors when exercising their statutory inspection functions. A CQC inspector attending the premises should show their official CQC identification and warrant card. Where there is genuine uncertainty about an inspector’s identity, staff may verify the person’s identity through CQC before providing access.
• Reasonable local sign-in and security procedures may be applied to a CQC inspection, provided they do not obstruct or unreasonably delay the inspector in exercising statutory powers of entry, inspection, access to records, interviews or other powers under the Health and Social Care Act 2008.
• No member of staff may refuse, obstruct or unnecessarily delay lawful access by an authorised CQC inspector on the basis that the inspector has not been issued with, or is not wearing, {{org_field_name}}’s own visitor pass.
• Visitors and temporary workers must not use another person’s pass or ID card and must report a lost visitor or temporary ID card immediately to the person responsible for the visit or shift.

9. Monitoring and Compliance

• Compliance with ID card usage will be monitored by line managers and senior staff.
• Periodic audits will be conducted to ensure ID cards are being used appropriately.
• Staff failing to comply with ID card policies may face formal warnings or disciplinary actions.

10. Staff Responsibilities

• HR Department: Responsible for issuing and managing ID cards.
• Registered Manager: Oversees compliance and security related to staff identification.
• All Staff: Must wear and take care of their ID cards, report any issues, and ensure proper use at all times.

11. Related Policies

• CH02-Fit and Proper Persons: Employed Staff Policy
• CH16-Health and Safety at Work Policy
• CH23-Lone Working and Staff Safety Policy
• CH27-Staff Supervision, Training, and Development Policy
• CH28-Staff Conduct and Code of Ethics Policy
• CH34-Confidentiality and Data Protection (GDPR) Policy

12. Policy Review

• This policy will be reviewed annually or sooner if changes in CQC regulations or organisational needs arise.
• Amendments will be made to ensure compliance with security and identification best practices.
• Regular staff training and reminders will be provided to reinforce the importance of ID card usage.

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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.