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CH222-Safeguarding People at Risk of Financial Abuse Policy

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Registration Number: {{org_field_registration_no}}

Safeguarding People at Risk of Financial Abuse Policy

1. Purpose

The purpose of this policy is to outline how {{org_field_name}} prevents, identifies, and responds to the risk of financial abuse affecting individuals receiving care in their own homes. This policy supports compliance with the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, in particular Regulation 13 (Safeguarding service users from abuse and improper treatment) and related Fundamental Standards, and reflects the Care Act 2014 adult safeguarding duties and principles. It is also underpinned by the Mental Capacity Act 2005 (including lawful decision-making where a person lacks capacity), and aligns with CQC expectations for safeguarding policies, including clear routes for raising concerns and responding without delay.

2. Scope

This policy applies to all staff, contractors, volunteers, and others working on behalf of {{org_field_name}} who may come into contact with individuals’ money, possessions, or financial information during the course of providing care. It also applies to agency workers and third-party services acting under our instruction or in partnership.

3. Definitions and examples of financial abuse

For the purpose of this policy, financial abuse includes (but is not limited to): theft; fraud; scams; pressure, coercion, or intimidation to hand over money or assets; forcing or manipulating someone to change a will or financial arrangements; misuse of bank cards, cash, or PIN entry; misuse of benefits; unauthorised or excessive charges; misappropriation of property or possessions; forced loans; misuse of online shopping accounts, subscriptions, or digital payment methods; and ‘mate crime’ (where a person is exploited by someone they consider a friend).

Financial abuse may be perpetrated by family members, friends, neighbours, strangers, professionals, or staff/volunteers/agency workers. It may occur in person, by telephone, or online.

4. Related Policies

5. Policy Statement

{{org_field_name}} is committed to upholding the rights, dignity, and financial security of all individuals in our care. Financial abuse can include theft, fraud, misuse of funds or property, coercion in relation to wills or financial decisions, or denying access to funds. We operate a zero-tolerance approach and work proactively to safeguard individuals from such risks. Our procedures support the principles of the Care Act 2014, including empowerment, protection, prevention, proportionality, partnership, and accountability.

We maintain effective systems and processes to prevent financial abuse and to investigate immediately any allegation or evidence of abuse. Where abuse is suspected, disclosed, witnessed, or evidenced, we will take action without delay, including internal fact-finding and referral to the Local Authority safeguarding team and/or the police as appropriate. We will support the person affected throughout, and we will take proportionate steps to reduce immediate risk while enquiries are undertaken.

6. Recognising Financial Abuse

Staff are trained to identify signs of financial abuse, which may include: unexplained lack of money or possessions; unpaid bills or missed payments; sudden changes in financial documents; anxiety when finances are mentioned; reports of missing belongings; or unusual interest from others in the person’s finances. Staff are instructed never to ignore or dismiss concerns, and all suspicions must be reported. Additional indicators may include: unexplained new ‘friends’ or frequent callers; sudden changes in shopping patterns or unexpected online deliveries; new or unexplained direct debits/subscriptions; unusual ATM withdrawals; unexplained changes to benefits payments; reluctance to discuss spending; missing bank cards; changes to property deeds/tenancy arrangements; or evidence of scams (for example, requests for gift cards, urgent bank transfers, pressure to share one-time passcodes, or requests to install remote access software).

7. Prevention Measures

a. Professional Boundaries

Staff must not: borrow money from or lend money to individuals; accept gifts or tips without explicit authorisation; involve themselves in an individual’s financial decisions; become a beneficiary in a will; or act as a witness to legal or financial documents. These boundaries are reinforced through induction, training, and supervision. Any offer of a gift, gratuity, loan, or legacy must be declined unless permitted by the Gifts Policy and authorised by a manager. All offers (including refusals) must be recorded in the gifts register with the rationale and any actions taken.

b. Support with Shopping or Petty Cash

Where shopping or financial transactions are part of a care plan, staff must follow the CH41-Managing Service User Finances Policy. Receipts must be kept for all purchases, records must be maintained, and transactions must be signed off by both the staff member and the individual (or representative). Use of cash or bank cards must be pre-approved, with safeguards in place.

Staff must never: use contactless payments without explicit written controls; add a person’s bank card to any digital wallet; make online purchases using a person’s account unless this is clearly authorised, risk assessed, and recorded; or remove a person’s bank card from their home except where this is explicitly agreed in the care plan and recorded.

c. Access to Financial Information

Staff must not access bank statements, PIN numbers, online banking, or financial accounts unless this has been formally authorised in the care plan and supported by a best interest decision (if capacity is lacking). All access must be documented, and staff must only act within their job role and authorisation.

Staff must never record, store, photograph, copy, share, or retain a person’s PIN, online banking password, one-time passcodes, security answers, or full card details. Where a transaction requires a PIN, the person (or their authorised representative) should enter it privately wherever possible.

d. Recruitment and Supervision

All staff are vetted through enhanced DBS checks and references before employment. Financial safeguarding forms part of staff supervision, appraisals, and team meetings. Where concerns about conduct arise, these are investigated promptly and transparently.

e. How to raise a concern (people who use the service, families, representatives and the public)

People can raise concerns about financial abuse by:

Information on how to raise a safeguarding concern is provided in the service user guide and can be made available in accessible formats on request.

8. Responding to Financial Abuse

a. Reporting Concerns

Any suspicion or allegation of financial abuse must be reported immediately to the Registered Manager {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}. Concerns must be recorded factually and submitted through our internal incident reporting system.

b. Safeguarding Procedures

On receipt of a financial abuse concern, a safeguarding referral will be made to the local authority {{org_field_local_authority_authority_name}} in line with adult safeguarding protocols. The individual’s safety and wellbeing are prioritised, and measures are taken to prevent further harm. Families, advocates, or the police may be involved depending on the severity and nature of the concern.

c. Confidentiality and Support

All reports are handled with strict confidentiality. The individual affected will be supported emotionally and practically throughout the investigation process. Advocacy services will be offered where appropriate to ensure the individual’s voice is heard.

d. Allegations involving managers or conflicts of interest

Where an allegation concerns the Registered Manager, a senior manager, or there is a conflict of interest, the concern must be escalated immediately to the Nominated Individual (or equivalent governance lead), who will appoint an independent investigating manager and ensure the response is impartial. Staff may also use the Whistleblowing (Speaking Up) procedure to raise concerns outside line management.

e. Consent, mental capacity and involvement of the person

We will involve the person at risk as much as possible and seek their consent to share information and make referrals where it is safe and appropriate. If there is reason to believe the person may lack capacity to make a specific decision (for example, about managing money, allowing access to funds, or reporting to the police), we will follow the Mental Capacity Act 2005, complete and record a decision-specific capacity assessment, and make any necessary decisions in the person’s best interests, considering advocacy and the least restrictive option.

f. Immediate protection and preserving evidence

When financial abuse is suspected we will, where lawful and proportionate:

g. Notifications to the Care Quality Commission (CQC)

We will notify CQC without delay of notifiable events and incidents in line with the Care Quality Commission (Registration) Regulations 2009. The Registered Manager (or delegated senior) is responsible for deciding and documenting whether a CQC notification is required and for submitting it within required timescales.

9. Training and Awareness

All staff receive safeguarding and financial abuse training at induction and through annual refresher programmes. Training covers definitions, signs, reporting procedures, and maintaining professional boundaries. Staff are also trained on GDPR and information handling to ensure financial data is protected. Training is role-appropriate, refreshed at planned intervals, and includes how staff access current safeguarding procedures, how to respond to disclosures, how to escalate concerns (including out-of-hours arrangements), and the prohibition on retaining PINs/passwords or using personal accounts/devices for service user transactions.

10. Audit and Oversight

Financial safeguarding forms part of our internal quality audits and governance reviews. Any incidents or themes are analysed to identify risks and improve controls. The Nominated Individual {{org_field_nominated_individual_first_name}} {{org_field_nominated_individual_last_name}} oversees financial safeguarding compliance and reports annually to the board or responsible governance body. Audits will include (where applicable): spot checks of transaction records and receipts, trend analysis (themes, repeat risks, locations, and patterns), review of gifts register entries, and assurance that safeguarding actions and outcomes are documented and shared with relevant partners. Action plans will be tracked to completion and learning will be shared through supervision and team meetings.

11. Roles and Responsibilities

All staff are responsible for recognising and reporting financial abuse. Managers are responsible for investigating concerns, liaising with safeguarding authorities, and supporting individuals through any necessary actions. The Registered Manager ensures that systems are in place for monitoring and oversight, and that this policy is embedded in daily practice.

12. Policy Review

This policy will be reviewed at least annually and immediately following any relevant changes to legislation/regulations, CQC guidance, local safeguarding arrangements, or after significant incidents and learning. Version control will record the changes made. All staff will be informed of updates and provided with refresher training as necessary.

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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