{{org_field_logo}}

{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Professional Boundaries and Relationships Policy

1. Purpose

The purpose of this policy is to provide clear guidance to all workers, staff, directors, consultants, and representatives engaged by {{org_field_name}} on maintaining appropriate, professional, ethical, and lawful boundaries when working in temporary assignments, client premises, healthcare, care home, supported living, domiciliary care, or similar settings.

{{org_field_name}} operates as an employment business and temporary staffing agency. It does not provide regulated care directly and does not assume responsibility for the regulated activity carried on by a client or hirer. However, workers supplied by {{org_field_name}} may work with patients, residents, service users, vulnerable adults, children, relatives, client staff, and other professionals. It is therefore essential that all workers maintain professional boundaries, protect vulnerable people from abuse or exploitation, and uphold public trust.

This policy supports compliance with applicable legislation and guidance, including the Employment Agencies Act 1973, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, the Agency Workers Regulations 2010, the Safeguarding Vulnerable Groups Act 2006, the Equality Act 2010, the UK GDPR and Data Protection Act 2018, the Health and Safety at Work etc. Act 1974, the Working Time Regulations 1998, the National Minimum Wage legislation, and relevant professional codes such as the NMC Code where applicable.

2. Scope

This policy applies to all individuals engaged, introduced, supplied, managed, or supported by {{org_field_name}}, whether under a zero-hours contract, temporary worker agreement, flexible worker arrangement, PAYE arrangement, umbrella arrangement, personal service company arrangement, consultancy arrangement, or other lawful engagement model. This includes, but is not limited to:

• Registered Nurses
• Healthcare Assistants
• Senior Carers
• Support workers
• Temporary, bank, agency, or flexible workers supplied to clients or hirers
• Candidates and work-seekers during recruitment, vetting, onboarding, and placement
• Directors, managers, supervisors, recruitment consultants, booking coordinators, payroll staff, compliance staff, and administrative staff
• Any person acting on behalf of {{org_field_name}} in relation to recruitment, supply, supervision, support, or client liaison

This policy applies to all professional relationships arising from or connected with the agency’s work-finding services, including relationships with patients, residents, service users, families, representatives, client organisations, hirers, colleagues, other professionals, regulators, safeguarding bodies, and members of the public.

3. Related Policies

This policy should be read alongside the following policies and procedures:

• Code of Conduct
• Recruitment, Selection and Vetting Policy
• Right to Work Policy
• Agency Worker Rights and AWR Compliance Policy
• Key Information Document and Terms of Engagement Procedure
• Safeguarding Adults and Children Policy
• DBS and Barring Referral Policy
• Disciplinary Policy
• Whistleblowing Policy
• Social Media, Confidentiality and Acceptable Use Policy
• Data Protection, Privacy and Records Retention Policy
• Equality, Diversity and Inclusion Policy
• Anti-Harassment and Sexual Harassment Policy
• Health and Safety Policy
• Lone Working Policy, where applicable
• Incident and Accident Reporting Policy
• Complaints Policy
• Modern Slavery and Labour Exploitation Policy
• Gifts, Hospitality and Anti-Bribery Policy

4. Policy Statement

{{org_field_name}} is committed to upholding high standards of professional conduct, integrity, safeguarding, confidentiality, equality, and lawful agency practice. Maintaining professional boundaries is essential to:

• protect patients, residents, service users, and other vulnerable people from harm, abuse, exploitation, grooming, coercion, discrimination, or improper influence;
• protect workers from allegations, conflicts of interest, misunderstandings, and unsafe working practices;
• support clients and hirers in maintaining safe, respectful, and professional environments;
• comply with employment agency legislation, safeguarding duties, data protection law, equality law, health and safety duties, and professional standards;
• maintain public confidence in temporary healthcare staffing.

{{org_field_name}} does not provide regulated care and is not CQC registered. Where workers are supplied to CQC-registered clients, workers must follow the client’s lawful instructions, care plans, safeguarding procedures, confidentiality requirements, professional standards, and site-specific policies. The client remains responsible for the regulated activity it carries on, while {{org_field_name}} remains responsible for its own duties as an employment business and temporary staffing agency.

All workers must maintain professional boundaries at all times, including during recruitment, assignment, handover, breaks, travel connected with an assignment, online activity, communication outside working hours, and any ongoing contact arising from an assignment.

5. Responsibilities

Director

As {{org_field_name}} does not have a registered manager and does not provide regulated care, the Director is responsible for governance of the agency’s conduct, compliance, safeguarding, and professional standards. The Director is responsible for:

• developing, approving, implementing, and reviewing this policy at least annually or sooner where legislation, guidance, incidents, complaints, or audit findings require;
• ensuring the agency operates consistently with the Employment Agencies Act 1973 and the Conduct of Employment Agencies and Employment Businesses Regulations 2003, including appropriate terms, Key Information Documents, assignment information, suitability checks, confidentiality, and record keeping;
• ensuring workers receive appropriate induction, guidance, and refresher training on professional boundaries, safeguarding, confidentiality, equality, health and safety, and reporting concerns;
• ensuring that workers are not knowingly supplied to assignments where required checks, qualifications, experience, right-to-work evidence, DBS checks, registration status, training, or assignment information are incomplete or unsuitable;
• ensuring boundary concerns, safeguarding allegations, complaints, incidents, and whistleblowing reports are recorded, investigated, and escalated appropriately;
• ensuring appropriate referrals are made to relevant bodies where required, including the client, local authority safeguarding team, DBS, police, NMC or other professional regulator, the Fair Work Agency, or other competent authority;
• ensuring that personal data, including safeguarding information, health information, DBS information, and investigation records, is handled securely and lawfully;
• promoting an organisational culture in which workers feel able to report concerns without fear of detriment or retaliation.

All Workers and Staff

All workers and staff are responsible for:

• maintaining clear, appropriate, and professional boundaries in all work-related relationships;
• complying with this policy, the Code of Conduct, client site rules, safeguarding procedures, confidentiality requirements, professional standards, and all lawful instructions relevant to the assignment;
• treating patients, residents, service users, families, colleagues, client staff, and members of the public with dignity, respect, compassion, and fairness;
• avoiding any conduct that may amount to abuse, exploitation, grooming, harassment, bullying, victimisation, discrimination, coercion, neglect, or misuse of professional position;
• refusing and reporting any request to act outside competence, training, assignment instructions, care plans, client policy, professional registration requirements, or the law;
• reporting actual or suspected breaches of professional boundaries, safeguarding concerns, unsafe practice, discrimination, harassment, confidentiality breaches, or conflicts of interest without delay;
• informing {{org_field_name}} and the client immediately where a personal, family, financial, social, romantic, sexual, or other relationship may affect professional boundaries or create a conflict of interest;
• cooperating fully with investigations, safeguarding enquiries, audits, and requests for information from lawful authorities.

6. Employment Business and Agency Worker Compliance

{{org_field_name}} operates as an employment business when it supplies temporary workers to hirers. The agency will comply with the Employment Agencies Act 1973 and the Conduct of Employment Agencies and Employment Businesses Regulations 2003, including requirements relating to work-seeker terms, hirer information, assignment details, suitability checks, confidentiality, records, and restrictions on charging fees to work-seekers.

Before supplying a worker to an assignment, {{org_field_name}} will take reasonable steps to obtain and provide relevant information, including the identity of the hirer, nature of the role, location, hours, pay, health and safety risks known to the agency, required experience, training, qualifications, professional registration, DBS requirements, and any relevant safeguarding or vulnerable-person requirements.

Workers will receive a Key Information Document where required before agreeing terms with the agency. Workers must also receive clear assignment information before starting work, including reporting arrangements, expected duties, rate of pay, payment arrangements, working time expectations, and any known risks or special requirements.

{{org_field_name}} will support compliance with the Agency Workers Regulations 2010. Agency workers must receive applicable day-one rights, including access to relevant client facilities and information about client vacancies where the hirer is responsible for providing these. After the qualifying period, eligible agency workers must receive equal treatment in relation to relevant pay and basic working conditions, subject to the statutory rules.

Any worker who believes their agency worker rights, pay rights, working time rights, or other employment rights have not been respected should report this to {{org_field_name}} promptly. The agency will investigate and take appropriate action, including liaising with the hirer where required.

7. Defining Professional Boundaries

Professional boundaries are the limits that protect the space between a worker’s professional role and the vulnerability, dependency, privacy, dignity, and rights of the people they support or encounter during an assignment. In temporary healthcare and care settings, workers may enter private, sensitive, or high-risk environments and may have access to personal care information, medication information, property, family circumstances, and confidential records. This creates a position of trust and power that must never be misused.

Key principles of professional boundaries include:

• Avoiding personal, social, sexual, financial, or other inappropriate relationships with service users
• Providing care in a respectful, non-judgemental, and impartial manner
• Maintaining confidentiality and respecting service user privacy
• Avoiding favouritism, gift acceptance, or special treatment
• Ensuring all relationships with colleagues and clients remain professional

For the purposes of this policy, “service user” includes any patient, resident, client, service user, vulnerable adult, child, family member, representative, or other person encountered because of an assignment, even where {{org_field_name}} is not the direct provider of care.

8. Examples of Boundary Violations

Examples of actions considered breaches of professional boundaries include but are not limited to:

• Entering into a personal, romantic, or sexual relationship with a service user or their relative
• Accepting or soliciting gifts, money, loans, or favours from service users or their families
• Disclosing personal contact information (e.g., personal phone number, address, social media accounts)
• Socialising with service users or their relatives outside the work context
• Using social media to communicate with or share personal information about service users or their families
• Discussing personal matters with service users to an extent that may be perceived as unprofessional or manipulative
• Providing care that exceeds authorised or expected limits without prior approval
• Failing to challenge or report inappropriate behaviour or boundary violations by colleagues

• forming or attempting to form an inappropriate emotional dependency with a service user, patient, resident, family member, or representative;
• grooming, coercing, manipulating, threatening, or pressuring any person encountered through work;
• asking for, accepting, borrowing, lending, handling, or misusing money, bank cards, PINs, online banking details, property, keys, medication, or personal possessions except where expressly authorised by the client’s policy and assignment duties;
• becoming involved in a service user’s will, inheritance, financial affairs, tenancy, benefits, banking, legal documents, or personal disputes;
• taking or sharing photographs, videos, audio recordings, screenshots, documents, care records, medication records, handover notes, or personal information without lawful authority and client approval;
• accessing care records, medication records, staff systems, rota systems, or confidential information without a legitimate work-related reason;
• continuing contact with a service user, patient, resident, family member, or representative after an assignment ends unless expressly authorised for a lawful professional reason;
• giving personal opinions, advice, treatment, care, medication, financial guidance, legal guidance, or promises outside the worker’s role, competence, or assignment instructions;
• using the worker’s position to obtain personal advantage, gifts, money, accommodation, employment, references, testimonials, social contact, or future work directly from a service user or family;
• failing to disclose a pre-existing or developing relationship that may compromise professional boundaries.

9. Power and Trust

Workers supplied by {{org_field_name}} may be placed in positions of trust because they may support or work near people who are vulnerable due to age, illness, disability, mental health needs, cognitive impairment, communication needs, dependency, trauma, isolation, or the need for care and support.

Workers must never exploit, misuse, or appear to misuse their position for personal, emotional, sexual, financial, social, political, religious, or other improper gain. Any sexualised behaviour, grooming, harassment, coercion, discriminatory conduct, humiliation, intimidation, neglect, or abuse of power is strictly prohibited.

Workers must act in a way that protects dignity, autonomy, privacy, equality, safety, and wellbeing. Where a worker is unsure whether conduct may cross a boundary, they must stop, seek advice from {{org_field_name}} and the client, and record the concern where appropriate.

10. Gifts, Hospitality, Money and Personal Benefit

Workers must not solicit, request, encourage, or accept gifts, money, loans, tips, vouchers, hospitality, favours, services, accommodation, personal benefits, or preferential treatment from service users, patients, residents, families, representatives, or client staff.

Low-value tokens of thanks, such as a thank-you card or modest shared item such as chocolates, may only be accepted where this is permitted by the client’s policy and where acceptance could not reasonably be seen as influencing care, treatment, support, decision-making, or professional judgement. Any such offer must be reported to both the client and {{org_field_name}}.

Workers must never become involved in a service user’s will, inheritance, financial arrangements, benefits, banking, property, possessions, legal documents, or personal disputes. Workers must not borrow from, lend to, buy from, sell to, or enter into private transactions with service users, patients, residents, families, or representatives.

Any offer of money, a significant gift, a personal benefit, or involvement in financial or legal affairs must be politely declined and reported immediately to the client and {{org_field_name}}. Failure to report such matters may result in disciplinary action, removal from assignment, safeguarding referral, professional regulator referral, or DBS referral where appropriate.

11. Social Media, Messaging Apps and Personal Contact

Workers must maintain professional boundaries in all forms of communication, including face-to-face contact, telephone calls, text messages, WhatsApp, email, social media, online forums, video calls, messaging apps, photographs, recordings, and any other digital platform.

Workers must never:

• share service user, patient, resident, family, client, colleague, or assignment information on social media or messaging platforms;
• post, upload, forward, or store photographs, videos, audio recordings, screenshots, care records, medication records, rota information, or confidential information unless expressly authorised for a lawful work purpose;
• accept, initiate, or maintain friend requests, follows, private messages, or online contact with service users, patients, residents, families, or representatives;
• use personal phones, personal email addresses, or personal accounts for client records, handover information, care information, medication information, or confidential work communications unless expressly authorised by the client and {{org_field_name}};
• arrange private meetings, social contact, paid work, unpaid support, or contact outside the professional setting with service users, patients, residents, families, or representatives;
• use artificial intelligence tools, translation tools, transcription tools, or cloud services to upload, process, summarise, or share confidential personal data unless expressly approved by {{org_field_name}} and the client and compliant with data protection law.

Any accidental disclosure, misdirected message, lost device, unauthorised photograph, or suspected data breach must be reported immediately to {{org_field_name}} and the client.

12. Maintaining Boundaries with Colleagues, Clients and Hirers

All workers and staff must act professionally in interactions with colleagues, client organisations, hirers, managers, residents’ families, other agencies, healthcare professionals, regulators, and members of the public. Relationships must be based on respect, lawful cooperation, safeguarding, confidentiality, and the safe performance of the assignment.

Bullying, harassment, sexual harassment, victimisation, discrimination, intimidation, retaliation, exploitation, or abusive behaviour will not be tolerated. This applies during assignments, breaks, travel connected to work, online communication, work-related social events, and any communication arising from the assignment.

Workers must not use client relationships to obtain private work, gifts, references, personal favours, social relationships, or commercial advantage without authorisation from {{org_field_name}}. Workers must not bypass {{org_field_name}} to arrange private shifts, direct employment, or alternative payment arrangements where this would breach their terms, client terms, confidentiality, safeguarding requirements, or applicable law.

Concerns about harassment, discrimination, unsafe practice, exploitation, or inappropriate conduct by client staff or colleagues must be reported promptly to {{org_field_name}} and, where appropriate, to the client.

13. Equality, Harassment and Reasonable Adjustments

{{org_field_name}} will not tolerate discrimination, harassment, victimisation, or other unlawful conduct because of age, disability, gender reassignment, marriage or civil partnership, pregnancy or maternity, race, religion or belief, sex, or sexual orientation.

Workers must treat all people fairly and respectfully and must comply with the Equality Act 2010, client equality policies, and professional standards. Workers must not refuse to work with, support, or communicate with a person because of a protected characteristic.

Workers must make reasonable adjustments within their role and competence where instructed by the client or where required to communicate respectfully and safely with disabled people, people with communication needs, or people requiring accessible information. Workers must seek guidance where they are unsure how to meet a person’s needs safely and lawfully.

Any discriminatory request from a client, colleague, service user, family member, or representative must be reported to {{org_field_name}}. {{org_field_name}} will not knowingly comply with discriminatory instructions.

14. Safeguarding, Regulated Activity and DBS Referrals

Workers supplied by {{org_field_name}} may work in environments involving adults at risk, children, patients, residents, or other vulnerable people. Workers must follow the client’s safeguarding procedures and must report any concern about abuse, neglect, exploitation, professional boundary breaches, unsafe practice, or risk of harm immediately to the client and {{org_field_name}}.

Safeguarding concerns may include physical abuse, sexual abuse, emotional or psychological abuse, financial abuse, discriminatory abuse, organisational abuse, neglect, self-neglect, domestic abuse, modern slavery, coercion, grooming, misuse of medication, unlawful restraint, or breach of professional boundaries.

{{org_field_name}} will assess safeguarding concerns promptly and will make referrals to the appropriate body where required. This may include the client organisation, local authority safeguarding team, police, DBS, NMC or other professional regulator, the Fair Work Agency, or another competent authority.

Where the legal conditions for a DBS barring referral are met, {{org_field_name}} will make a referral to DBS. This duty may apply where the agency is acting as a personnel supplier and has withdrawn permission for a worker to engage in regulated activity, or would or might have done so, because the worker has harmed, poses a risk of harm to, or has engaged in relevant conduct towards a child or vulnerable adult.

Workers must cooperate with safeguarding investigations and must not contact the alleged victim, witnesses, families, client staff, or other parties about the concern unless authorised by the investigating body.

15. Right to Work and Worker Eligibility

{{org_field_name}} will carry out right-to-work checks before a worker starts work and will repeat checks where required by law or Home Office guidance. Workers must provide accurate, genuine, and up-to-date evidence of their right to work and must notify {{org_field_name}} immediately of any change affecting their immigration status, work restrictions, identity documents, professional registration, DBS status, or eligibility for an assignment.

Workers must not accept or continue an assignment where they do not have the legal right to work, where work restrictions would be breached, or where required checks, registration, training, or authorisation are not in place.

Providing false documents, misleading information, or failing to disclose restrictions may result in removal from assignment, disciplinary action, termination of engagement, notification to the client, and referral to relevant authorities.

16. Health and Safety in Temporary Assignments

{{org_field_name}}, workers, and client organisations all have responsibilities for health and safety. {{org_field_name}} will take reasonable steps to obtain relevant assignment information from clients, including known risks, required training, personal protective equipment, moving and handling requirements, lone working arrangements, infection prevention requirements, and any role-specific hazards.

Workers must comply with client health and safety procedures, infection prevention and control requirements, moving and handling rules, medication procedures, fire safety procedures, incident reporting requirements, and any site-specific instructions.

Workers must not carry out tasks where they have not received appropriate training, instruction, supervision, equipment, or authorisation. Workers must report unsafe conditions, accidents, near misses, violence, aggression, exposure incidents, medication errors, moving and handling concerns, and other health and safety issues immediately to the client and {{org_field_name}}.

Where a worker reasonably believes that continuing an assignment would place them or others at serious and imminent risk, they must take immediate steps to protect safety and report the matter to the client and {{org_field_name}}.

17. Pay, Working Time, Holiday and National Minimum Wage Compliance

{{org_field_name}} will take reasonable steps to ensure that workers are paid lawfully and receive clear information about pay, deductions, holiday entitlement, payment intervals, and assignment rates. Workers must be paid at least the applicable National Minimum Wage or National Living Wage for all working time, subject to the statutory rules.

Workers must accurately record hours worked, breaks, sleep-ins, travel time where applicable, cancelled shifts, and any other information required for lawful pay and working time compliance. False timesheets, inflated hours, failure to record breaks accurately, or collusion over working time records may result in disciplinary action and removal from assignments.

{{org_field_name}} will comply with applicable Working Time Regulations requirements, including rest breaks, rest periods, maximum weekly working time rules, night work rules, and paid holiday entitlement. Workers must notify {{org_field_name}} if they believe their hours, rest, or breaks create a health and safety risk or breach legal requirements.

Holiday pay and entitlement records will be kept in accordance with legal requirements and agency policy.

18. Addressing Boundary Challenges

{{org_field_name}} recognises that working in temporary placements may present additional challenges regarding boundary maintenance. Staff may encounter clients where professional and social roles overlap (e.g., local community connections).

In these situations, workers must:

• inform {{org_field_name}} and the client organisation as soon as they become aware of the actual or potential conflict;
• disclose any personal, family, social, romantic, sexual, financial, tenancy, community, online, or previous care relationship that may affect professional boundaries;
• seek guidance before starting or continuing the assignment;
• follow any management plan agreed by {{org_field_name}} and the client;
• decline or withdraw from an assignment where clear professional boundaries cannot reasonably be maintained;
• record the concern and action taken where instructed to do so.

19. Training

All staff will receive mandatory training on professional boundaries as part of induction and through annual refresher training.

Training may include:

• recognising appropriate and inappropriate professional relationships;
• power imbalance, vulnerability, grooming, coercion, financial abuse, sexual misconduct, and exploitation;
• professional boundaries in temporary, unfamiliar, and multi-site assignments;
• safeguarding adults and children, including how to report concerns;
• confidentiality, social media, information governance, and data protection;
• equality, dignity, harassment, discrimination, and reasonable adjustments;
• gifts, gratuities, money, property, and conflicts of interest;
• health and safety responsibilities in temporary assignments;
• incident reporting, whistleblowing, and escalation;
• relevant professional codes, including the NMC Code where applicable;
• agency worker rights, assignment information, and conduct expectations.

20. Reporting Concerns

All workers and staff must report the following without delay:

• actual or suspected breaches of professional boundaries;
• safeguarding concerns involving adults or children;
• harassment, sexual harassment, discrimination, bullying, victimisation, or retaliation;
• unsafe practice, neglect, abuse, exploitation, or misuse of authority;
• confidentiality breaches, data breaches, or unauthorised use of records, photographs, or devices;
• inappropriate gifts, financial involvement, personal relationships, or conflicts of interest;
• concerns about a colleague, client staff member, visitor, family member, representative, or other professional.

Reports must be made immediately to {{org_field_name}} using the Incident Reporting Procedure or Whistleblowing Policy. Where the concern arises during an assignment, the worker must also report it to the client organisation in accordance with the client’s safeguarding, incident, or escalation procedure.

{{org_field_name}} will handle reports sensitively, confidentially, and fairly. Confidentiality cannot be guaranteed where information must be shared to protect people from harm, comply with legal duties, investigate concerns, or make referrals to appropriate bodies. Workers who raise concerns in good faith must not be subjected to detriment, retaliation, or victimisation.

21. Investigations

Alleged breaches of professional boundaries will be reviewed and, where appropriate, investigated by the Director or another authorised person appointed by {{org_field_name}}. Investigations will be conducted fairly, promptly, and proportionately, taking into account the seriousness of the allegation, safeguarding risks, client requirements, legal duties, and the rights of the worker.

During an investigation, {{org_field_name}} may remove a worker from an assignment, restrict future placements, suspend access to systems, notify the client, preserve records, obtain statements, review assignment information, and take any other reasonable steps to protect people and evidence.

Where allegations are substantiated, action may include retraining, supervision, written warning, removal from assignment, termination of engagement, notification to the client, referral to the local authority safeguarding team, DBS, police, NMC or other professional regulator, Fair Work Agency, or other relevant authority.

Where the client is CQC registered, {{org_field_name}} will cooperate with the client so that the client can meet its own regulatory and notification duties. {{org_field_name}} will not describe itself as the registered provider unless it is registered with CQC for the relevant regulated activity.

Lessons learned from investigations will be used to improve recruitment, vetting, training, supervision, client communication, assignment information, and policy compliance.

22. Role of the Director in Governance and Oversight

The Director will maintain oversight of professional boundaries, safeguarding, and agency compliance by:

• reviewing this policy at least annually and whenever legislation, guidance, incidents, complaints, audits, or client requirements indicate that changes are needed;
• monitoring themes from incidents, complaints, safeguarding concerns, whistleblowing reports, client feedback, and worker feedback;
• ensuring that appropriate corrective action is taken following substantiated concerns;
• ensuring records are accurate, secure, and retained in accordance with legal and policy requirements;
• ensuring workers receive appropriate information, training, and guidance before and during assignments;
• ensuring compliance concerns are escalated to clients, regulators, safeguarding bodies, DBS, professional bodies, or enforcement bodies where required;
• promoting a culture of openness, professionalism, lawful practice, and safe reporting.

23. Record Keeping, Confidentiality and Data Protection

Records relating to professional boundaries, concerns, complaints, incidents, safeguarding matters, investigations, training, vetting, DBS checks, right-to-work checks, assignment information, working time, pay, and decisions will be kept securely and confidentially in accordance with the UK GDPR, the Data Protection Act 2018, employment agency legislation, safeguarding requirements, and {{org_field_name}}’s Data Protection, Privacy and Records Retention Policy.

Personal data must be accurate, relevant, limited to what is necessary, kept securely, retained only for an appropriate period, and shared only where there is a lawful basis to do so. Special category data, criminal offence data, DBS information, health information, safeguarding information, and investigation records must be handled with particular care.

Information may be shared with clients, safeguarding authorities, DBS, police, professional regulators, legal advisers, insurers, payroll providers, occupational health providers, the Fair Work Agency, or other competent bodies where lawful and necessary.

Workers must not remove, copy, photograph, upload, disclose, or retain client records or confidential information unless expressly authorised for a lawful work purpose.

24. Policy Review

This policy will be reviewed at least every 12 months or sooner where required because of changes to legislation, statutory guidance, professional standards, safeguarding guidance, Fair Work Agency guidance, client requirements, incidents, complaints, audits, or lessons learned. The review will be completed by the Director of {{org_field_name}} and approved before reissue.

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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.