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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Maintaining Professional Boundaries Policy

1. Purpose

The purpose of this policy is to ensure that all employees of {{org_field_name}} maintain clear and appropriate professional boundaries with service users to safeguard their dignity, independence, and well-being, while also protecting staff from situations that may compromise their professional integrity.

Professional boundaries define acceptable behaviour between care workers and service users, ensuring a relationship that is based on trust, respect, and ethical standards. Breaching these boundaries can lead to exploitation, abuse, conflict of interest, or emotional dependency, which can compromise the quality of care provided.

This policy supports compliance with the Regulation and Inspection of Social Care (Wales) Act 2016, the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended, the Social Services and Well-being (Wales) Act 2014, Wales Safeguarding Procedures, CIW regulatory expectations and the Social Care Wales Codes of Professional Practice. It supports the provider’s duty to deliver care and support with sufficient care, competence and skill, to protect individuals from abuse, neglect and improper treatment, and to promote dignity, independence, well-being, choice, rights and personal outcomes.

2. Scope

This policy applies to all staff and workers engaged by {{org_field_name}}, including care workers, managers, office staff, agency workers, contractors, students and volunteers where applicable. For the purpose of this policy, “staff” includes persons employed by the service provider and persons engaged under a contract for services.

It applies to situations where employees:

• Provide direct care and support.
• Communicate with service users or their families.
• Manage financial or personal affairs on behalf of a service user.
• Are at risk of conflicts of interest or inappropriate relationships.

This policy also applies where staff:

• Work alone in an individual’s home.
• Have access to personal information, medicines, property, keys, money or valuables.
• Support individuals with shopping, appointments, correspondence or communication.
• Are contacted by individuals, relatives or representatives outside working hours.
• Become aware of a gift, loan, will, bequest, lasting power of attorney, financial arrangement or potential conflict of interest.

The policy ensures that professional relationships remain focused on delivering high-quality care and do not develop into friendships, financial transactions, or personal relationships that could be detrimental to the service user or staff member.

3. Defining Professional Boundaries

Maintaining professional boundaries means that:

• Staff should always act in a professional capacity. While care work is personal, interactions must be objective, respectful, and focused on the well-being of the service user.
• Staff must not form personal, romantic, sexual, exploitative, financial or inappropriate emotional relationships with individuals, their relatives or representatives. Staff must maintain a warm, kind and respectful professional relationship while ensuring that the relationship remains focused on the individual’s assessed care and support needs, personal plan and personal outcomes.
• Financial boundaries must be upheld. Employees must not borrow, lend, or accept money or gifts from service users.
• Physical boundaries should be appropriate. While some physical contact (e.g., assisting with mobility or personal care) is necessary, staff must always seek consent and ensure touch is appropriate and non-intrusive.
• Emotional boundaries should be clear. Staff must be supportive but should not become emotionally involved in a way that compromises their judgment or professionalism.
• Staff must not create or encourage dependency by giving special treatment, visiting outside agreed working duties, sharing personal problems, seeking emotional support from individuals or making the individual feel responsible for the worker’s feelings, employment or personal circumstances.
• Communication boundaries must be maintained. Care workers must not share personal details (e.g., phone numbers, home addresses, or social media connections) with service users.
• Staff must use the organisation’s agreed communication systems only. Staff must not contact individuals, relatives or representatives from personal phones, personal email addresses, private social media accounts or personal messaging accounts, unless this has been specifically authorised by the Registered Manager as part of the individual’s care arrangements and recorded appropriately.

3.1 Professional Boundaries and Personal Plans

Staff must provide care and support in accordance with the individual’s personal plan. Any boundary-related arrangement, such as support with shopping, money, correspondence, keys, medication, communication, appointments, family contact or access to the individual’s property, must be clearly recorded in the personal plan or associated risk assessment.

Staff must not agree to provide additional support outside the personal plan, even where the individual or family requests it, unless this has been authorised by the Registered Manager and the personal plan has been reviewed and updated where required.

Where a request from an individual, relative or representative places staff at risk of breaching professional boundaries, staff must politely decline, explain that they must follow the organisation’s policy, and report the request to the Registered Manager without delay.

4. Managing Professional Boundaries in Domiciliary Care

Domiciliary care presents unique challenges in maintaining professional boundaries as staff work in the private homes of service users. The following measures are in place to ensure professionalism is upheld:

• Relationships and conflicts of interest: Staff must not form personal, romantic, sexual, financial or inappropriate relationships with individuals, relatives or representatives. Any pre-existing personal, family, financial or social relationship must be declared to the Registered Manager before care is provided, or as soon as the staff member becomes aware of the conflict. The Registered Manager will complete a conflict-of-interest risk assessment and decide whether the staff member can continue to support the individual.
• Appropriate Use of Language and Communication: Staff must communicate respectfully and avoid over-familiar language, inappropriate jokes, or comments that could be misinterpreted.
• Avoiding Favouritism or Special Treatment: Care workers must ensure that all service users receive equal attention and support without developing preferential treatment for certain individuals.
• Ensuring Transparency in Care Delivery: Staff must document all care provided, ensuring that records are clear and accurate to protect against any claims of misconduct.
• Lone working in the person’s home: Staff must remember that working in an individual’s home can increase the risk of blurred boundaries. Staff must not use the individual’s home for personal convenience, including making personal calls, using the individual’s facilities without permission, bringing unauthorised persons into the home, accepting hospitality beyond a reasonable drink where appropriate, or staying beyond the agreed care visit unless this is necessary for the individual’s safety and is reported.
• Responding to Emotional Attachments: If a service user becomes overly attached to a care worker, this should be reported to the Registered Manager, who will assess the situation and may reassign staff if necessary.
• Unplanned contact or requests outside care visits: If an individual, relative or representative contacts a staff member outside agreed working arrangements, the staff member must not continue the contact through personal channels. The staff member must inform the Registered Manager and ensure any action is recorded in line with the organisation’s record keeping procedures.

5. Financial, Property and Gift Boundaries

Staff must protect individuals from financial abuse and must maintain strict financial boundaries at all times.

Staff must not:

• Borrow money, property or possessions from an individual, relative or representative.
• Lend money to an individual, relative or representative.
• Sell goods or services to an individual, relative or representative.
• Buy goods from an individual, relative or representative.
• Accept cash gifts, loans, vouchers or valuable items.
• Ask for or accept tips.
• Use an individual’s bank card, PIN, online banking, cheque book or account details unless this is expressly authorised in the personal plan and in line with the organisation’s financial procedures.
• Become involved in an individual’s will, bequest, inheritance, lasting power of attorney, appointeeship or financial decision-making, unless they have lawful authority outside their employment role and this has been declared and risk assessed.
• Act as an agent for an individual unless there is lawful authority and the arrangement has been approved by the Registered Manager.

Staff may only support an individual with money, shopping or financial transactions where this is included in the personal plan and risk assessment. All transactions must be recorded clearly, receipts must be obtained where possible, and records must be checked in line with the organisation’s financial procedures.

Token gifts of low value, such as chocolates or a thank-you card, may only be accepted where refusal would cause distress or offence. All gifts, offers of gifts or hospitality must be declared to the Registered Manager and recorded in the gifts and hospitality register. The Registered Manager will decide whether the gift may be retained, returned, shared with the team or otherwise managed.

Any concern about theft, pressure, misuse of money or property, fraud, unexplained financial loss, unusual gifts, changes to wills or pressure relating to money or property must be reported immediately as a safeguarding concern.

6. Social Media and Digital Communication Boundaries

In the digital age, it is essential to ensure that professional boundaries extend to online interactions:

• Staff must not add, follow, message, tag, post about, comment on, livestream, connect with or maintain contact with individuals, relatives or representatives through personal social media or messaging platforms, including Facebook, Instagram, TikTok, Snapchat, WhatsApp, Messenger, X or similar platforms.
• Personal phone numbers must not be shared. All communication with service users should take place through the organisation’s official channels.
• Photographs, videos or audio recordings of individuals, their homes, records, property or family members must not be taken on personal devices. Images or recordings may only be taken for an authorised care, safeguarding, medication, incident, wound care or record keeping purpose, using the organisation’s approved system, with appropriate consent or lawful basis, and in line with data protection, confidentiality and record keeping procedures.
• Staff must not discuss work, individuals, relatives, representatives, colleagues, complaints, incidents, safeguarding matters or the organisation’s confidential information on social media. This applies even where names are not used, as individuals may still be identifiable from context.

6.1 Confidentiality, Records and Information Sharing

Staff must respect the individual’s right to confidentiality and must only access, use or share information where this is necessary for their role, lawful, proportionate and in the individual’s best interests or required for safeguarding, regulatory or legal reasons.

Staff must keep accurate, timely and factual records of care and support provided, concerns, incidents, refused care, unusual requests, boundary concerns and any action taken. Records must not include personal opinions, judgemental language or unnecessary personal information.

Confidentiality must not be used as a reason to ignore or fail to report abuse, neglect, improper treatment, financial abuse, exploitation, unsafe practice or a serious boundary concern.

6.2 Duty of Candour

{{org_field_name}} promotes a culture of openness, honesty and candour. Staff must be open and honest with the organisation when things go wrong, including where a professional boundary may have been crossed, where an individual may have been placed at risk, or where a mistake, omission or incident has occurred.

Staff must report concerns promptly to the Registered Manager. The organisation will act in an open and transparent way with individuals and, where appropriate, their representatives, including providing information about incidents, explaining what action is being taken, and offering an apology where appropriate.

Staff must not obstruct, discourage, victimise or penalise any person for raising a concern, making a complaint, whistleblowing or acting in line with the duty of candour.

7. Responding to Boundary Concerns, Breaches and Allegations

Any concern, allegation, evidence or suspicion that professional boundaries have been breached must be taken seriously and reported without delay.

Staff must report immediately to the Registered Manager, or to the Responsible Individual where the concern relates to the Registered Manager. Where the concern involves immediate risk, abuse, neglect, improper treatment, exploitation or criminal behaviour, staff must also follow the Safeguarding Adults from Abuse and Improper Treatment Policy and emergency procedures.

The Registered Manager will:

• Take immediate action to protect the individual and any other person who may be at risk.
• Consider whether the concern is a safeguarding concern.
• Make referrals to the local authority safeguarding team, police, CIW, Social Care Wales, the Disclosure and Barring Service or other relevant bodies where required.
• Record the evidence or substance of the concern, actions taken, referrals made, outcomes and learning.
• Consider whether the staff member should be removed from visits, suspended, redeployed, supervised more closely or subject to disciplinary action.
• Consider whether the individual’s personal plan, risk assessment, staff allocation or communication arrangements need to be reviewed.

Boundary breaches may constitute misconduct or gross misconduct. Examples include, but are not limited to, financial abuse, theft, accepting inappropriate gifts, forming a personal or sexual relationship with an individual, unauthorised contact, misuse of social media, breach of confidentiality, falsification of records, failure to report abuse or placing an individual at risk.

Where a member of staff fails to report abuse, suspected abuse, neglect, improper treatment or a serious boundary concern, this may result in disciplinary action.

Staff may use the Whistleblowing Policy where they feel unable to raise a concern through normal management routes, or where they believe a concern has not been acted upon properly.

7.1 CIW Notifications

The Registered Manager and Responsible Individual must consider whether a boundary concern, allegation or incident is notifiable to CIW. Notifications must be submitted through CIW Online in line with CIW requirements.

CIW must be notified where required, including where there is:

• Any abuse or allegation of abuse involving the service provider, staff member or volunteer.
• Any allegation of misconduct by a member of staff.
• Any serious accident, injury or incident affecting the safety or well-being of an individual.
• Any incident reported to the police.
• Any event that prevents, or could prevent, the provider from continuing to provide the service safely.

A record must be kept of the decision to notify, the notification made, the date submitted, the person submitting it, and any action or response from CIW.

7.2 Mental Capacity, Consent and Undue Influence

Staff must not assume that an individual has or lacks capacity. Where a boundary concern involves consent, gifts, money, relationships, communication, photographs, sharing information or decisions about care and support, staff must consider whether the individual has the mental capacity to make the specific decision at the relevant time.

Where there are concerns that an individual is being pressured, coerced, groomed, exploited or unduly influenced by staff, relatives, representatives or others, this must be reported as a safeguarding concern.

Where an individual lacks capacity for a relevant decision, any action must be taken in accordance with the Mental Capacity Act 2005, best interests principles and the organisation’s safeguarding procedures.

8. Staff Training and Support

{{org_field_name}} will ensure that staff receive induction, training, supervision and support appropriate to their role. This will include:

• Professional boundaries and expected standards of conduct.
• Social Care Wales Codes of Professional Practice.
• Safeguarding adults and, where applicable, safeguarding children.
• Wales Safeguarding Procedures.
• Financial abuse, gifts, money handling and conflicts of interest.
• Confidentiality, data protection, record keeping and social media.
• Duty of candour, complaints and whistleblowing.
• Mental capacity, consent, undue influence and positive risk-taking.
• Lone working and safe practice in domiciliary care.

Professional boundaries will be discussed during induction, supervision, appraisal, team meetings, spot checks, competency checks and where concerns, complaints, incidents or safeguarding matters arise.

Staff must seek advice from the Registered Manager if they are unsure whether a request, relationship, gift, communication or action could breach professional boundaries.

8.1 Monitoring and Quality Assurance

The Registered Manager and Responsible Individual will monitor compliance with this policy through supervision, spot checks, audits of care records, financial transaction checks, complaints, safeguarding records, incident reviews, staff feedback and feedback from individuals and representatives.

Any trends, repeated concerns, boundary incidents, safeguarding issues or training needs will be reviewed as part of the organisation’s governance and quality assurance arrangements. Learning will be used to improve practice, update policies and reduce the risk of recurrence.

9. Related Policies

This policy should be read in conjunction with:

• Staff Conduct and Code of Ethics Policy (DCW28)
• Safeguarding Adults from Abuse and Improper Treatment Policy (DCW13)
• Confidentiality and Data Protection Policy (DCW34)
• Disciplinary and Grievance Policy (DCW31)

• Whistleblowing Policy
• Complaints Policy
• Duty of Candour Policy
• Supporting Individuals to Manage Their Money Policy
• Gifts and Hospitality Policy or Register
• Social Media Policy
• Lone Working Policy
• Mental Capacity and Consent Policy
• Record Keeping Policy
• Medication Policy, where boundary concerns involve medicines
• Staff Supervision and Appraisal Policy
• Equality, Diversity and Human Rights Policy

10. Policy Review

This policy will be reviewed at least annually or sooner where there are changes in legislation, Welsh Government statutory guidance, CIW requirements, Social Care Wales Codes of Professional Practice, Wales Safeguarding Procedures, organisational practice, safeguarding learning, complaints, incidents or audit findings.

The Registered Manager and Responsible Individual will ensure that staff are informed of any changes and that relevant training, supervision or competency checks are completed.

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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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