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Registration Number: {{org_field_registration_no}}

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Safe Key Holding and Access Management Policy

1. Purpose

The purpose of this policy is to ensure that {{org_field_name}} manages key holding and access to service users’ homes safely and securely in compliance with Care Inspectorate Wales (CIW) regulations, data protection laws, and best practices in domiciliary care. Our primary aim is to protect service users, their property, and their right to privacy, while ensuring that care workers can access homes safely and efficiently when required.

Our objectives are to:

• Ensure that all key holding practices are secure, transparent, and accountable.
• Prevent unauthorised access to service users’ homes.
• Provide staff with clear guidance on key handling, storage, and access procedures.
• Comply with CIW regulations and safeguarding policies to protect vulnerable individuals.
• Maintain accurate records of key usage and access permissions.
• Handle lost, stolen, or misplaced keys efficiently and securely.

2. Scope

This policy applies to:

• All employees, including care workers, managers, and administrative staff.
• The Registered Manager and Responsible Individual, responsible for compliance.
• Service users receiving domiciliary care and reablement support.
• Families and authorised representatives, where key access permissions apply.
• External professionals or contractors, who may require temporary access.

3. Legal and Regulatory Framework

This policy aligns with:

• The Regulation and Inspection of Social Care (Wales) Act 2016, ensuring safety in home care access.
• The Social Services and Well-being (Wales) Act 2014, protecting service users’ dignity and autonomy.
• The Data Protection Act 2018 (UK GDPR), governing the handling of service user key information.
• The Health and Safety at Work Act 1974, ensuring safe working conditions for domiciliary care staff.
• The Safeguarding Vulnerable Groups Act 2006, preventing abuse through secure access controls.
• Care Inspectorate Wales (CIW) Best Practice Guidance on Safe Access to Service Users’ Homes.

4. Service User Consent and Key Holding Agreements

4.1 Obtaining Consent

• Keys must only be held with the full written consent of the service user or their legal representative.
• Service users have the right to refuse key holding services; alternative access arrangements will be explored.
• Consent must be documented in the service user’s care plan and reviewed annually.

4.2 Key Holding Agreement

Before accepting responsibility for a service user’s key, {{org_field_name}} will ensure:

• A formal key holding agreement is signed by the service user and care provider.
• The agreement specifies access times, key storage, and authorised personnel.
• Service users are informed of their right to withdraw consent at any time.

How we manage this efficiently:

• A structured consent form ensures compliance with CIW regulations.
• Key holding records are updated regularly to reflect changes in service user needs.

5. Secure Storage and Handling of Keys

5.1 Key Storage in the Office

• Keys must be stored in a locked, secure cabinet with restricted access.
• Only authorised staff members have access to the key cabinet.
• Keys must be clearly labelled with an anonymous code (not service user names or addresses).

5.2 Key Storage in the Community

• Care workers must not carry unnecessary keys unless required for scheduled visits.
• Keys must be kept in a secure pouch or lockable key case while in transit.
• Keys must never be left unattended in a vehicle or public place.

How we manage this efficiently:

• An electronic key management system logs key issuance and returns.
• Staff receive training on key security and proper storage procedures.

6. Accessing Service Users’ Homes Safely

6.1 Procedure for Key Access

• Care workers must knock and announce themselves before entering, even if they have a key.
• If a service user does not respond, staff must follow the no-response protocol.
• Staff must ensure that the key is returned to the designated storage location after use.

6.2 Alternative Access Methods

If a service user refuses key holding, {{org_field_name}} may:

• Use a secure key safe, with access codes shared only with authorised personnel.
• Arrange for a family member or designated individual to provide access.
• Assess alternative care delivery options if access is restricted.

How we manage this efficiently:

• Service user preferences are documented in the care plan.
• Emergency key access procedures are clearly outlined for staff.

7. Recording and Monitoring Key Usage

7.1 Key Log System

• Every key issue and return must be recorded in the key log system.
• The log must include date, time, staff member name, and purpose of use.
• Regular audits will be conducted to ensure accuracy and accountability.

7.2 Reporting Misuse or Unauthorised Access

• Any unauthorised key use must be reported immediately to the Registered Manager.
• Staff found misusing keys may face disciplinary action.

How we manage this efficiently:

• Automated key tracking software ensures real-time monitoring.
• Managers conduct spot checks to verify compliance with key handling procedures.

8. Lost, Stolen, or Misplaced Keys

8.1 Immediate Actions for Lost Keys

If a key is lost or stolen:

1. Report the incident immediately to the Registered Manager.
2. Inform the service user and assess the risk level.
3. Arrange for a locksmith to change the lock if necessary.
4. Conduct an internal review and update procedures to prevent recurrence.

8.2 Preventative Measures

• Staff must use key fobs or identifiable tags that do not reveal service user details.
• Backup access methods (such as key safes) should be considered for high-risk cases.

How we manage this efficiently:

• A lost key protocol ensures swift and secure resolution.
• Risk assessments are conducted following incidents to improve security measures.

9. Emergency Access and Safeguarding Procedures

9.1 Emergency Access to a Service User’s Home

In an emergency (e.g., service user is unresponsive or in distress):

• Care staff should attempt contact via phone before entering.
• If entry is required, follow the agreed emergency access plan.
• If access is denied or there are safeguarding concerns, emergency services should be contacted.

9.2 Safeguarding Considerations

• All key handling staff must undergo a DBS check.
• Any concerns regarding home access must be reported to safeguarding teams.

How we manage this efficiently:

• Emergency entry procedures are outlined in the service user’s care plan.
• Safeguarding officers oversee all key-related security concerns.

10. Staff Training and Compliance

10.1 Key Holding Training

• All staff must complete training on key handling, access management, and security.
• Refresher training is conducted annually to reinforce best practices.

10.2 Compliance Audits

• Quarterly audits review key logs and storage protocols.
• Any discrepancies are addressed through internal investigations and corrective actions.

How we manage this efficiently:

• Training records track staff competency in key holding.
• A compliance officer ensures adherence to best practices.

11. Related Policies

This policy aligns with:

• Safeguarding Adults Policy (DCW13).
• Confidentiality and Data Protection Policy (DCW34).
• Risk Management and Assessment Policy (DCW18).
• Emergency and Crisis Management Policy (DCW27).

12. Policy Review

This policy will be reviewed annually or sooner if required due to legislative changes, business needs, or CIW updates. The Registered Manager and Responsible Individual are responsible for ensuring compliance.

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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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