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Safeguarding People from the Risk of Closed Cultures in Domiciliary Care (England) Policy

[This template policy needs to be highly personalised with information about local services and the specific steps that your service is taking in response to the identified risk factors in your service, with links to your relevant related polices.]

Policy Statement

This care service is committed to promoting the rights and interests of the people we support in line with national and local policies and strategies. This includes the prevention of a closed culture developing, that is ā€œa poor culture that can lead to harm, including human rights breaches such as abuseā€.

This service is committed to ensuring that a closed culture does not develop but also acknowledges that, as a service that supports vulnerable people, there is an inherent risk even in the absence of any other factors.

[The service recognises that services that support people with learning disabilities and autistic people are especially vulnerable to the development of such cultures.]

This service also recognises that as a domiciliary care service, a closed culture can manifest in isolated parts of the service, such as with staff cliques or around particular people we visit, as well as for the whole service.

[This service also acknowledges that there is a risk of corporate failings in larger chains.]

It therefore expects staff and managers to take the danger of a closed culture seriously, and to recognise the even the most experienced observers can be deceived.


This policy is written in line with the Care Quality Commissionā€™s guidance on closed cultures and with the requirements of Regulation 13: Safeguarding Service Users from Abuse and Improper Treatment of the Health and Social Care Act 2008 (Regulated Activities) 2014.


This service works in line with Positive Approaches: Reducing Restrictive Practices in Social Care, published by Social Care Wales. This refers providers to the Care Quality Commissionā€™s guidance on closed cultures.

This policy should be considered alongside the serviceā€™s other polices on safeguarding, human rights and restraint. [list if appropriate]


The manager with responsibility for oversight of the serviceā€™s prevention of closed cultures is: ______________________.

The manager will keep up to date with the guidance on closed cultures and share learning with the team.

An annual (or more frequently according to peopleā€™s needs/vulnerability) audit of the risks of closed cultures will be carried out and an action plan developed to address identified concerns. The audit will address the CQCā€™s identified inherent risk factors for a closed culture. [attach or link to your audit tool/guidance]

Peopleā€™s Experience and Feedback

This service will ensure that peopleā€™s experience of their care is one that affirms their human rights and dignity. This includes ensuring that people who use services have the information they need and practical means to raise concerns about their care, including escalating concerns externally, and that they have the assurance that their concerns will be dealt with properly. This service will make every effort to receive feedback from everyone who receives services, or at least on their behalf from someone in a position to give a meaningful opinion, to enable this.

[where a service might use restraint]

Restraint and Restrictive Practices

This service considers that physical restraint represents bad practice in care and should be avoided wherever possible. Staff will use physical restraint only as a last resort or in exceptional circumstances and any instance will be immediately reviewed. (See also the servicesā€™ policies on restraint.)

The closed cultures audit will include a full review of all restraint and restrictive practices since the last audit. It will include ensuring that any follow up action has been taken as a result of an incident, such as updated behaviour support plans, staff training and information sharing.


This service recognises that poor management can cause or enable a closed culture. It will ensure that:


This service recognises that domiciliary staff mostly work unsupervised. This can lead to the development of ā€œmicroculturesā€ around specific people or staff. This may include poor practice that would not be displayed in other contexts and so can be difficult to spot. To prevent closed cultures of any scale, this service will ensure that:

External Oversight

This service recognises that external oversight is vital for all care services.

[For larger chains, the first line of oversight is the corporate/provider governance and compliance arrangements, describe them here]

[Describe the local authority/ other commissioners QA arrangements here]

[Describe any private arrangements, such as consultant audits, here]

This service ensure that any action required as a result of external oversight is properly taken and recorded and included in the serviceā€™s overall improvement plan.

In addition, this service will ensure that no oneā€™s care is without oversight between formal quality checks, for example by continuously seeking feedback from professionals also involved in peopleā€™s care. It will support people who are at risk of social isolation to access the community and maintain relationships with friends and families.


All new staff will receive training on the identification and prevention of closed cultures as part of their induction training, in accordance with the needs of their role.

Training should be refreshed on annual review as required by any changes in the serviceā€™s policies or best practice guidance.

Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}

Reviewed on: {{last_update_date}}

Copyright Ā©2024 {{org_field_name}}. All rights reserved

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