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Registration Number: {{org_field_registration_no}}

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Fit and Proper Persons: Employed Staff Policy

1. Purpose

The purpose of this policy is to ensure that all individuals employed within our domiciliary care organisation meet the Fit and Proper Person Requirement (FPPR) as outlined by the Care Quality Commission (CQC) Regulations 2014 (Regulation 19). This policy establishes a robust and consistent approach to vetting, assessing, and monitoring employees to ensure they are suitable for their roles and uphold the highest standards of care, integrity, and professionalism.

By implementing stringent recruitment and ongoing monitoring procedures, {{org_field_name}} ensures the safety and well-being of service users while maintaining compliance with legal and regulatory requirements.

2. Scope

This policy applies to:

• All staff employed in any capacity within our domiciliary care service.
• Senior management and leadership roles, including directors and registered managers.
• Temporary and agency staff providing care services.
• Volunteers and external contractors with access to service users or sensitive information.

It covers:

• Recruitment and selection processes.
• Background checks and disclosure requirements.
• Ongoing monitoring and professional development.
• Compliance with regulatory and safeguarding standards.
• Staff training and reporting responsibilities.

3. Legal and Regulatory Framework

This policy is guided by the following regulations:

• Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 – Regulation 19 (Fit and Proper Persons Employed).
• CQC Fundamental Standards – Ensures service providers recruit and employ suitable individuals.
• The Safeguarding Vulnerable Groups Act 2006 – Governs eligibility and barring of individuals.
• The Disclosure and Barring Service (DBS) Regulations – Ensures all employees undergo appropriate background checks.
• Equality Act 2010 – Ensures a non-discriminatory recruitment process.
• General Data Protection Regulation (GDPR) 2018 – Governs secure handling of employment data.

4. Recruitment and Selection Process

To ensure that only suitable individuals are employed, our recruitment process includes:

• Robust Job Descriptions: Clearly defining responsibilities, essential qualifications, and key competencies.
• Application Screening: All candidates undergo a thorough assessment of experience and credentials.
• Face-to-Face Interviews: Conducted by trained interviewers to assess values, attitudes, and competencies.
• Right to Work Checks: Verifying eligibility to work in the UK.
• Reference Verification: Minimum of two professional references, including one from the most recent employer.
• DBS Checks: Enhanced Disclosure and Barring Service (DBS) checks conducted for all care staff.
• Occupational Health Screening: Ensuring physical and mental fitness for the role.
• Probation Period: New employees are subject to a structured probationary review for the first three to six months.

5. Background Checks and Disclosure Requirements

• All employees must undergo:
  • Enhanced DBS checks prior to employment.
  • Regular DBS update service monitoring to ensure continued suitability.
  • Checks against the Adult and Child Barred Lists, where applicable.
  • Verification of professional registrations, such as the Nursing and Midwifery Council (NMC) or Health and Care Professions Council (HCPC).
  • A signed declaration stating they are not disqualified from working in regulated activities.
• Any criminal record disclosures are assessed case-by-case, considering:
  • The nature and severity of the offence.
  • Time elapsed since the conviction.
  • The relevance to the role in question.
  • Evidence of rehabilitation and conduct.

6. Ongoing Monitoring and Professional Development

To maintain compliance and support continuous improvement, {{org_field_name}} implements:

• Annual Performance Reviews: Evaluating employee competency, professionalism, and adherence to policies.
• Regular DBS Renewals: Conducted every three years, with mandatory registration to the DBS update service.
• Mandatory Training Compliance: Employees must complete:
  • Safeguarding Adults and Children training.
  • Infection Prevention and Control training.
  • Mental Capacity Act (MCA) and Deprivation of Liberty Safeguards (DoLS) training.
  • Health and Safety and Fire Safety training.
• Code of Conduct Compliance: Employees must adhere to the CQC Code of Conduct and {{org_field_name}}al Policies.
• Whistleblowing and Reporting Procedures: Encouraging staff to report concerns about colleagues’ fitness to practice.

7. Addressing Fitness to Practice Concerns

If concerns arise about an employee’s suitability, the following steps are taken:

• Internal Investigation: Led by senior management, with HR involvement.
• Immediate Safeguarding Actions: If required, temporary suspension or restricted duties may be implemented.
• Professional Body Notifications: If the staff member is regulated (e.g., NMC or HCPC), concerns are reported to the appropriate body.
• Disciplinary Actions: Depending on the findings, this may result in additional training, reassignment, or dismissal.
• DBS Referral: If there are serious safeguarding concerns, a referral to the DBS may be made to prevent future risk.

8. Compliance and Confidentiality

To ensure compliance and data security:

• All employee records related to vetting, training, and monitoring are stored securely and managed in line with GDPR regulations.
• Confidentiality is maintained, with only authorised personnel having access to sensitive information.
• Regular audits are conducted to ensure continued compliance with CQC and employment law.

9. Monitoring, Evaluation, and Continuous Improvement

To uphold high standards, {{org_field_name}}:

• Conducts quarterly audits of recruitment and vetting processes.
• Reviews staff fitness-to-practice concerns to identify recurring trends.
• Collects employee and service user feedback on staff performance and suitability.
• Ensures annual policy reviews reflect regulatory updates and best practices.

10. Policy Review and Updates

This policy is reviewed annually or in response to:

• Changes in legislation or regulatory requirements.
• CQC inspection feedback and audit findings.

Significant incidents involving staff fitness to practice.

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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}}
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