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DCW41-Managing Service User Finances Policy

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Managing Service User Finances Policy

1. Purpose

The purpose of this policy is to ensure that {{org_field_name}} manages service users’ finances ethically, transparently, and in full compliance with all relevant regulations and best practice guidelines. This includes meeting the standards set by Care Inspectorate Wales (CIW) and adhering to applicable laws and guidance on financial safeguarding. Our organisation is committed to the following:

2. Scope

This policy applies to all levels of our domiciliary care service and outlines everyone’s roles in financial management and safeguarding:

3. Legal and Regulatory Framework

This policy is designed in accordance with the law and guidance in Wales governing financial safeguarding in social care. Key legislation and standards influencing this policy include:

4. Principles of Financial Management for Service Users

Our approach to managing service users’ finances is based on core principles that reflect our values and regulatory duties. All staff must understand and apply these principles in their work:

5. Assessing a Service User’s Financial Needs and Capacity

Before providing support with finances, {{org_field_name}} assesses each service user’s needs and ability to manage their money. This assessment ensures we understand the level of help required and any risks involved, so we can plan appropriate safeguards.

5.1 Financial Risk Assessment

At the start of care provision (and regularly thereafter), our staff conduct a financial needs and risk assessment for each service user. This assessment includes determining the service user’s ability to manage their own finances and identifying areas where they might need support. For example, we consider whether the individual can handle day-to-day transactions like shopping and paying bills, or if they find managing money confusing or difficult. We also look at the person’s vulnerability to financial abuse or errors – such as whether they have memory issues that cause them to misplace money, or if there are people around them who might take financial advantage. Importantly, as part of this assessment we document whether the service user has any legal representative for financial matters. This could be someone with a Lasting Power of Attorney (LPA) for property and affairs, a Court of Protection deputy, or an appointee for benefits. Knowing about these roles is crucial because it tells us who has legal authority or involvement in the person’s finances, so we can involve them in care planning and avoid any conflict or duplication in managing money.

The outcomes of the financial risk assessment are used to plan the person’s care. We incorporate the findings into the individual’s care plan – specifically noting what kind of help with finances is needed (if any), and who should provide that help. For instance, the care plan will state if the service user only needs help with grocery shopping once a week, or if they need full support to handle all cash due to severe dementia. It will also outline the safeguards in place, such as requiring two staff signatures for transactions above a certain amount, or that a particular trusted staff member or family member is the one to assist with money. Staff who are not assigned or required to support a particular individual with finances are precluded from involvement with that person’s financial affairs, in line with regulatory guidance. This means only those who need to assist will do so, and others will not insert themselves into the service user’s money matters, adding a layer of protection against misuse.

To manage financial assessments efficiently and consistently, we use a standardized financial risk assessment tool for all service users. This is usually a form or checklist that ensures we cover all relevant questions (like sources of income, typical expenses, capacity considerations, potential risks, and presence of legal reps). By standardizing, we make sure no important aspect is overlooked and that every service user is assessed fairly using the same criteria. The financial risk assessment is not a one-time event — it is a living process. We review it at least annually, or sooner if there is a significant change in the service user’s circumstances. Changes that could prompt an earlier review include a decline or improvement in the service user’s cognitive abilities, a change in financial status (such as receiving an inheritance or moving to a different benefits system), or any incident of suspected financial abuse. Regular reviews mean the support we provide can be adjusted to the person’s current needs and risks. Additionally, all staff receive training on how to identify financial abuse or risks as part of this assessment process. They learn what warning signs to look for when initially evaluating a person’s situation — for example, signs that a family member might be interfering with the person’s money or that the person is anxious about finances. Well-trained staff can catch potential issues early, at the assessment stage, and we can then put in place preventive measures as part of the care plan.

5.2 Mental Capacity and Decision-Making

Individual Financial Support Plan (IFSP). Where financial support is required, we create an IFSP (part of the personal plan) that sets: the specific tasks staff may complete; decision-making arrangements (capacity, consent, best-interests); spending methods authorised (e.g., cash, prepaid card); any transaction thresholds requiring two staff signatures or manager authorisation; where records/receipts are stored; and review frequency (at least 3-monthly, and sooner if needs change). The IFSP names any attorneys/deputies/appointees and clarifies that staff support is facilitative, not agency.

If a service user lacks the mental capacity to manage their finances or to make specific financial decisions, all actions must be taken in the person’s best interests, following the principles of the Mental Capacity Act 2005. In practice, this means that for any significant financial decision, staff will first assess whether the service user has the capacity to make that decision at that time. Capacity is decision-specific and time-specific; for example, an individual might be able to decide on buying groceries (a relatively simple decision) but not comprehend a complex issue like changing an insurance policy. We do not assume incapacity – we always start by helping the person to make the decision themselves if possible (perhaps by explaining information in a simpler way or choosing the best time of day when they are most alert). If after support the person still cannot understand, remember, or weigh the information well enough to make the decision, then we determine they likely lack capacity for that matter, and we proceed to make a best interest decision on their behalf.

When making a financial decision in a service user’s best interests, we involve the appropriate people to ensure the decision truly benefits the service user. If the service user has a legally appointed representative for finances (such as an LPA or deputy), that individual will be consulted and, in many cases, will be the primary decision-maker as empowered by law. Our staff will work with them, providing any relevant care-related input (for example, what the service user’s needs are, or any known preferences). If the service user has no such representative, we may involve an independent advocate or ask the local authority for guidance, particularly for major financial decisions. All decisions made on behalf of someone without capacity are carefully documented – we record what decision was made, why it was needed (i.e. evidence that the person lacked capacity), who was involved in deciding, and how it serves the person’s best interests. For instance, if it’s decided that a service user’s bills will be set up to auto-pay from their account because they cannot manage writing checks, we document the capacity assessment results, note that a best interest meeting was held (if applicable), and explain why this method is best for the person (perhaps it ensures their utilities don’t get cut off and they remain safe and comfortable). We also ensure compliance with all legal safeguards, such as the requirement to involve a deputy or attorney if one is in place, and the need to avoid any conflict of interest in the decision (staff should not be making isolated financial decisions without oversight).

To support proper implementation of the Mental Capacity Act in financial matters, our staff receive training on the Act’s principles and how to apply them. They learn, for example, the two-stage test of capacity and the concept of acting in best interests with the participation of relevant others. In situations where significant financial decisions need to be made (especially if they are complex or contentious), we will hold Best Interest meetings. These are meetings where various stakeholders (such as family members, a social worker, possibly a healthcare professional, and an advocate) come together to discuss what should be done with the person’s finances or property. By having a group discuss the issue, we promote transparency and collective judgment, which helps ensure the decision is well-rounded and in the person’s best interests. For example, a best interest meeting might be convened to decide whether to sell a service user’s house to pay for care – a big decision that should involve more than one person’s opinion. Finally, if a service user is found to lack capacity for managing their money and does not already have a legal representative, {{org_field_name}} will work with the relevant authorities to put proper arrangements in place. This could involve contacting the local authority or Court of Protection to appoint a deputy, or arranging an appointeeship for managing the person’s welfare benefits. We recognize that our staff and organisation should not take on full control of a person’s finances without formal authority; if professional management of funds is needed, it should be done through legal mechanisms to protect the service user.

6. Assisting Service Users with Financial Transactions

When staff assist service users with day-to-day financial activities, such as handling cash or shopping, it must be done carefully, following strict procedures that safeguard the service user’s money. This section describes how staff should conduct these tasks and provides practical examples to illustrate the correct approach.

6.1 Handling Cash and Payments

Staff may only assist with clearly authorised tasks set out in the personal plan/IFSP and with the person’s consent (or a recorded best-interests decision). A daily running balance is maintained in the financial log. For transactions at or above the locally set threshold (set by {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}), entries require two staff signatures or one staff plus a witness/representative signature, and a receipt must be attached. All cash movements are counted out loud with the person, change is returned immediately, and both parties sign the entry.

Consent is the first requirement: staff should obtain prior permission, ideally written consent, from the service user or their legal representative before engaging in financial transactions. For instance, at the start of service, we may have the service user (or their attorney/deputy) sign an agreement outlining what the staff can and cannot do regarding money. If a new situation arises (say the service user wants a staff member to start helping with rent payments), additional consent should be obtained for that specific task. Without such consent, a staff member should not proceed to manage or spend a service user’s money. This protects the service user’s right to control their own finances and also protects staff from misunderstandings. A practical example: if a service user hands a care worker some cash out of the blue and says “Here, take care of this for me,” the care worker should clarify why the service user wants them to have the money. If it’s meant for buying something or paying a bill, the staff should gently remind the service user that they will need to record this and get it authorised (perhaps the care plan should be updated to reflect this new assistance). If the service user is trying to give the cash as a personal gift or without a clear purpose, the staff member must politely decline and report it to their manager, as accepting money without documentation or as a gift is against policy.

Every financial transaction that a staff member carries out for a service user must be meticulously recorded. We maintain a dedicated financial log for each service user to document all money movements. This can be a physical logbook kept in the service user’s home or an electronic system, depending on our organisation’s tools. Whenever money is handled, the staff member enters the date, description of the transaction (e.g., “Paid £30 to electricity bill” or “Bought groceries”), the amount of money spent or withdrawn, and the amount of any change returned. Both the staff member and the service user should sign the log entry. If the service user is unable to sign (due to a physical disability or cognitive impairment), then a witness (such as a second staff member or a family member present) should sign instead to verify the transaction. Receipts for any purchases or payments must be obtained and attached to the record. For example, if a care worker uses £20 of a service user’s money to buy groceries, when they return, they should have the store receipt. They would record in the log: “£20 given by [Service User] for grocery shopping; £18 spent as per receipt, £2 returned to [Service User].” The service user would sign (or a witness if needed) to confirm they received the correct change and the purchases. The receipt is then kept with the log (taped onto a page or stored in a designated envelope/folder). This practice ensures there is concrete proof of how the service user’s money was used.

Staff are only allowed to use a service user’s funds for the specific purpose intended by that service user. It is strictly forbidden to divert those funds for any other reason. For example, if a staff member is given £50 by the service user to pay their gas bill, that money must only go to pay that gas bill – not also pick up a coffee for the staff or pay another service user’s expense, and not even to pay a different bill unless the service user explicitly requests it. We emphasize that staff should treat the service user’s money with the same care as a trust fund that can only be used for that person’s benefit. Along these lines, under no circumstances should staff mix their own personal finances with the service user’s finances. Staff must never borrow money from a service user, nor lend money to a service user. This rule covers all scenarios big and small: a staff member shouldn’t ask a service user to loan them £5 for lunch, and similarly a staff member shouldn’t personally give £5 to a service user who has run out of cash. If a service user is short on money for something, the staff should report this to a manager so a proper solution can be found (like contacting family or making a note to bring the issue up with a social worker if needed) rather than the staff intervening with their own funds. Likewise, if a service user insists on giving a staff member a tip or gift in cash, the staff member must politely refuse and explain that it’s against our policy to accept money or significant gifts. Any such incident should also be reported to the manager to ensure transparency. These boundaries are set to maintain a professional relationship and prevent situations where either the service user or staff could be put in a vulnerable position financially.

To reinforce all of the above, our organisation conducts regular audits of financial records. Managers or designated auditors will randomly check the financial logbooks/electronic records and receipts to verify that procedures are being followed. For example, a manager might look at a month’s worth of entries for a particular service user and confirm that all entries have corresponding receipts and signatures, and that the sums add up correctly. We also check that consent forms are in place for the types of transactions being done. If any discrepancies or omissions are found (such as missing receipts or a signature that’s not there), we investigate and address them immediately, providing additional guidance or training to staff if needed. Audit results are documented, and any serious issues would be treated as potential misconduct. These audits not only help catch errors or irregularities but also act as a deterrent against intentional misuse of funds, since staff are aware that their handling of service user money is subject to oversight.

Gifts and hospitality. To protect everyone from undue influence, staff do not accept cash, tips or high-value gifts from people we support. Low-value, one-off tokens (e.g., a card or modest refreshment) may be accepted where refusal would cause distress, but must be declared to the Registered Manager the same day and recorded on the Gifts & Hospitality Register. Any request to add staff to wills or receive loans is declined and reported immediately.

6.2 Shopping and Personal Spending Assistance

When assisting service users with shopping or other personal spending, staff should follow person-centered practices that encourage independence while ensuring financial transparency and security.

If a care plan includes helping a service user with shopping (for groceries, clothing, toiletries, etc.) or managing personal spending, staff must only use the money that the service user has provided for that purpose, or a predefined method like a prepaid store card entrusted to the service user. Staff should not use their own money to buy items for the service user, except perhaps in an emergency situation which must later be reported and reimbursed properly – the general rule is to avoid that because it complicates accountability. More importantly, staff should never ask for or use the service user’s bank debit/credit card directly (since, as noted, staff are not allowed to know the PIN or keep the card). Instead, typical practice is that the service user will hand the staff a certain amount of cash to do the shopping, or the service user’s family might provide a set amount of money or a voucher/card for the task. For example, a service user might give a support worker £40 in cash and a shopping list for the week’s groceries. The support worker uses only that £40 for the shopping trip. If the staff somehow spends more due to prices or buying an unlisted item needed, they should ideally call the service user (or their representative) for approval or use their judgment if previously agreed (like spending up to a small buffer amount). However, they should not just add their own money to cover it or use the service user’s card – any deviation from the cash given should be communicated and logged.

Keeping receipts for all purchases is mandatory. Every time something is bought with the service user’s money, the staff must obtain a receipt from the vendor and bring it back. Those receipts are then attached to the financial records or kept in a dedicated place for that service user. We require this for a couple of reasons: it serves as proof of what was purchased (so we can show that the money was indeed spent on the service user’s needs), and it allows the service user or others to see the exact cost of items. For instance, if a service user wonders “why did the shopping cost £38 this week?”, staff can go through the receipt with them to explain the purchases. In practice, staff should make sure to collect even small receipts (even if buying a single item like a prescription or a pint of milk) because it’s part of the audit trail. All receipts are then logged or filed according to our procedure – often, the date on the receipt will be cross-referenced with the entry in the financial log for that date. If a receipt is accidentally missing, the staff must write a note to explain (e.g., “taxi driver did not give a receipt” or “parking meter – no receipt available”) and have it signed by the service user or a witness to ensure transparency.

We strongly encourage service users to make their own purchases whenever possible, with staff acting only as support. This is in line with promoting independence and dignity. Depending on the individual’s abilities and preferences, this might mean the staff accompanies the service user to the shop and the service user physically pays at the till, while the staff is just there to assist with carrying items or handling the cashier if the person requests. Or it might mean the service user can choose items and the staff handles the payment under the person’s direction, if handling cash is difficult for them. Even in cases where the service user cannot go out, staff can involve them in the process by, for example, going through a shopping catalogue or website together and letting the service user decide what to buy. The idea is not to remove the person from their financial decisions. For example, rather than the staff unilaterally deciding what groceries to buy, the service user should be consulted about their preferences (brand of cereal, type of soap, etc.) and budget. If a service user has capacity and is interested, they could also be supported to check their change and receipts after a purchase as a life skill exercise, thereby staying engaged with managing their money. By doing as much as they can by themselves, service users maintain a sense of control and competence with regards to their personal finances.

To ensure accountability and good practice in shopping support, {{org_field_name}} utilizes a receipt tracking system as part of our financial records. This might be a simple envelope or folder labelled with the service user’s name where all their receipts are collected and numbered corresponding to entries in the log, or a spreadsheet where each expense is logged along with a scanned copy of the receipt. Periodically, a supervisor might review this to ensure no receipts are missing and that expenditures match the service user’s needs and plans. Additionally, for each service user who requires regular help with shopping or spending, we develop a Shopping Support Plan (or personal spending plan). This support plan is part of their overall care plan and details how the person likes to handle shopping and money. It can include information such as: preferred shopping days and stores, usual weekly budget, any special instructions (e.g., “Service user prefers to pay with exact change if possible” or “Service user gets anxious with large notes, so break down the money into smaller denominations for them”), and any risks or precautions (like “Needs prompting to remember PIN if at ATM, but staff must not handle card directly”). It might also list who is authorized to help them with shopping – for example, maybe a particular staff member or a family member typically assists, to ensure consistency. Having this plan means that any staff member stepping in to help will know the person’s preferences and the agreed method of support, leading to a person-centered approach every time.

Online purchasing controls. Where online orders are necessary, accounts are created in the service user’s name (or attorney/deputy/appointee) with unique credentials stored securely for the person/representative—not staff. Saved payment methods are restricted to prepaid/limited-balance cards where possible. Each order is pre-agreed with the person, itemised on the financial log with order number, delivery note and e-receipt attached, and reconciled within 24 hours of delivery. Staff must not route any purchase through personal accounts.

6.3 Managing Service Users’ Bank Cards and PINs

Our policy has strict rules regarding bank cards, credit cards, and personal identification numbers (PINs) belonging to service users: staff should not hold or directly handle a service user’s cards, nor should they ever know or use a service user’s PIN. This is a non-negotiable safeguard to prevent fraud and protect both parties. For example, even if a service user trusts a particular support worker and offers them their debit card and writes down the PIN to withdraw cash, the support worker must kindly refuse. The correct approach in that scenario would be to explain, “I’m sorry, I can’t take your bank card or know your PIN – it’s against our policy and it’s for your protection. But I can help you in another way, perhaps by going to the bank with you so you can withdraw the money, or by contacting your family member (or manager) to find a safe solution.” Staff can assist a service user to use their own bank card – for instance, accompanying them to an ATM, standing with them for support while they enter their PIN, and carrying the cash or shopping bags if needed – but the staff should not be the one inserting the card and entering the PIN out of the service user’s sight. Under no circumstance should a staff member write down or memorize a service user’s PIN code. If a service user cannot manage their PIN or card due to memory issues or dexterity problems, the situation should be addressed through formal arrangements (like having an appointee or deputy handle finances, or using alternative methods of payment such as direct debits or prepaid cards) rather than violating this rule.

Staff are also prohibited from withdrawing money on behalf of a service user unless they have a specific legal authority to do so. Typically, our staff do not have that legal authority as individuals. A legal authorisation for finances might be held by a family member or professional (through LPA or deputyship). In some cases, the organisation or manager might have an appointeeship for a service user’s benefits, but even then, strict procedures would govern how money is accessed and used. If a service user asks a staff member, “Can you go to the bank and take £100 out of my account for me?”, the staff should refuse because they are not allowed to do that on their personal behalf. Instead, the staff can offer assistance by accompanying the person to the bank, or if the person is housebound, discuss with a manager whether there is any safe procedure (such as arranging a bank home visit or involving an attorney). The reason for this rule is to eliminate opportunities for theft and to ensure that any large financial transactions are carried out with proper oversight. It also protects staff from allegations – if we don’t allow them to withdraw cash on their own, then there is less chance someone can accuse them of taking money.

Another crucial point is that staff must never mix a service user’s finances with their own. Mixing finances could take many forms, all of which are unacceptable. For instance, a staff member should not put a service user’s money into their personal bank account even temporarily, not even with the intention to keep it “safe”. They should not cash a service user’s check in their personal account, nor use a personal credit card to buy something for a service user and then keep the service user’s cash as “reimbursement” – all transactions should be directly using the service user’s funds or accounts in a transparent way. If a staff member finds themselves holding a service user’s cash (perhaps the service user insisted they keep the change and it’s not safe to leave it), the staff must report and hand it over to a manager or follow a procedure to secure it, rather than taking it home or mixing it with their own money. Essentially, there should be a clear line between personal finances and the service user’s finances, so it’s always evident whose money is whose.

We implement these rules through strict internal policies and by exploring alternative solutions so that staff rarely, if ever, need to handle bank cards or large sums of cash directly. For example, one alternative we encourage is the use of prepaid cards or limited balance accounts for service users. A prepaid card can be loaded with a certain amount of money by the service user or their family, which the staff can then use for shopping without needing the main bank card or PIN. These cards often can be set with spending limits and do not provide access beyond the loaded amount, adding security. Another alternative is involving family members: if a trustworthy family member is available, the service might arrange for the family member to manage bank withdrawals and then provide the cash to the service user for daily needs, so staff aren’t put in the position of doing it. In cases where no informal support is available, sometimes the organisation works with social services to appoint an agent or appointee for managing finances formally. Throughout all of this, our policy ensures that staff do not become the service user’s agent financially – meaning they should not be the ones making banking decisions or being given general control of money. Staff roles are limited to supportive tasks under clear direction and monitoring. We train our staff on these rules so they understand that even if a service user pleads or finds it convenient to hand over a card, the answer must be no for the protection of all involved. By adhering to these safeguards, we greatly reduce the risk of financial loss or allegations of misconduct related to bank cards and accounts.

Accessible, bilingual financial information. We provide financial explanations, statements, and consent forms in the person’s preferred language and format (Active Offer of Welsh, Easy Read, large print). Key terms (e.g., spending limits, card rules) are explained and confirmed back to ensure understanding, and this is recorded in the IFSP.

7. Preventing and Reporting Financial Abuse

Financial abuse can have devastating effects on individuals, and preventing it is a central goal of this policy. We take a proactive approach: training staff to spot warning signs of financial abuse and establishing clear steps for reporting and responding to any concerns. In this section, we describe how to recognize potential financial abuse and what to do if abuse or suspicion of abuse arises.

7.1 Identifying Signs of Financial Abuse

Care staff are in a unique position to notice when something might be wrong with a service user’s finances. Financial abuse can include a wide range of acts, from outright theft to more subtle coercion. Some common signs that could indicate financial abuse or mismanagement include:

Our staff are trained to recognise these signs and remain vigilant. In practice, this means paying attention during everyday interactions. For example, when helping with shopping, does the service user suddenly not want to buy much when previously they were comfortable spending within their budget? When assisting with paying for something, does the person express confusion like “I thought I had more money, I don’t know where it’s gone”? Such comments shouldn’t be ignored. Staff are encouraged to gently ask open-ended questions if they suspect something (without being accusatory), like “Do you feel okay about how your money is going lately?” while also ensuring not to alarm the service user or make promises they can’t keep. Additionally, we have systems in place to monitor financial patterns. By regularly reviewing the financial logs and receipts, managers might notice irregularities – for example, if one week a large sum was withdrawn from the service user’s account with no clear use, or if receipts show purchases that seem out of the ordinary for the person (like expensive electronics the person never received). These monitoring activities act as a secondary net to catch issues that the frontline staff might miss or be unaware of. Ultimately, identifying financial abuse early is crucial so that we can intervene and prevent further harm.

7.2 Reporting Financial Concerns

If any staff member suspects financial abuse or even just an unusual financial situation that doesn’t seem right, they must report their concerns immediately according to our procedures.

How to report:

Send an email detailing the concern to the Registered Manager at: {{org_field_registered_manager_email}}.

Call the office to inform the Registered Manager at {{org_field_phone_no}}.

If the concern arises out of office hours, call the out-of-hours phone number: {{out_of_hours}}.

Time is of the essence in safeguarding – the sooner we report, the sooner we can investigate and stop any potential abuse. The first point of contact for reporting is typically the staff member’s line manager or the organisation’s Safeguarding Lead (as identified in our Safeguarding Adults Policy). This should be done as soon as the concern arises – ideally on the same working day. For example, if during a morning visit a care worker discovers that a service user’s £100 emergency cash is missing from its usual place and the service user is very confused and upset about it, the care worker should finish ensuring the person is safe, then call their manager straight away to report the details of what they observed. They should not wait until the next day or the next team meeting; immediate reporting is vital.

Once a concern is reported internally, {{org_field_name}} will initiate an internal investigation in line with our safeguarding policies. A senior staff member or manager will gather initial information – this might involve talking privately with the staff who reported it, checking financial records, and speaking with the service user (if appropriate and they are not distressed by discussing it) to get more context. We handle such investigations sensitively and confidentially, to protect the rights of everyone involved. At the same time, we recognize that some situations require outside authority involvement. We are committed to informing the appropriate external authorities as needed without delay. In Wales, this typically means contacting the Local Authority’s Adult Safeguarding team, since they have the statutory duty to look into allegations of abuse of adults at risk. We would provide them with all relevant information and follow their guidance on next steps. If we suspect that a crime has been committed – for example, if money has been stolen or someone is committing fraud – we will also report the matter to the Police. Additionally, we will notify Care Inspectorate Wales (CIW) as required, especially if the incident meets the threshold of a reportable incident (CIW as the regulator should be informed of serious incidents, including financial abuse allegations, as part of our regulatory compliance). By involving these authorities, we ensure that an impartial investigation can occur and that the service user gets the protection and justice they deserve.

During and after an investigation, our priority is to safeguard the service user from further harm. Depending on the nature of the concern, immediate protective measures might include restricting a suspect individual’s access to the service user’s finances. For example, if a particular staff member is accused or strongly suspected, we would remove them from duties involving that service user (often suspension from all duties during investigation is appropriate). If a family member or outside person is the suspected abuser, we might advise the service user (and their attorney, if applicable) to secure bank accounts (perhaps changing locks, PINs, or moving funds to a safe account) and avoid unsupervised visits until things are resolved. We might also increase our own oversight: perhaps the manager will personally oversee the service user’s financial log for a time or conduct daily checks. Corrective or supportive actions will be tailored to the situation, but could involve anything from helping to set up direct debits so the service user has less cash in the house (if cash theft was the issue) to engaging advocacy or counseling for the service user if they are upset by what happened. The goal is to immediately plug any identified gaps and ensure the service user feels safe and supported regarding their finances going forward.

We encourage an open culture where staff feel comfortable reporting any concerns. To support this, we have a Whistleblowing (Speaking Up) Policy (DCW29) that allows staff to report issues anonymously if they prefer. If a staff member for some reason fears reprisal or is uncomfortable raising a concern through the normal line, they can use the whistleblowing channel to report financial wrongdoing. All staff are regularly informed that the organisation will protect them from negative consequences when they report honestly and in good faith. Every report of financial concerns, no matter how minor it may seem, is logged and reviewed. We maintain a record of such incidents (even small ones like “service user thought £10 was missing but later found it”) because patterns might emerge over time. Management periodically reviews these logs to ensure appropriate actions were taken and to identify any trends – for example, if multiple staff have concerns about the same individual or location, that flags a higher risk that needs closer attention. This continuous monitoring and the existence of clear reporting protocols help us respond to issues promptly and learn from each case to improve our financial safeguarding practices.

External reporting and notifications. Financial concerns that indicate abuse, significant loss, pattern escalation, or crime are referred without delay to:
• Local Authority Safeguarding — {{org_field_local_authority_authority_name}} ({{org_field_local_authority_phone_number}} / OOH {{org_field_local_authority_out_of_hours_phone_number}} / {{org_field_local_authority_authority_email}}) — following regional pathways.
• Police — where theft or fraud is suspected (Fraud Act 2006).
• CIW — where the incident meets the notifiable-incident threshold.
We inform commissioners where applicable and document actions, outcomes and protective measures.

8. Staff Training and Responsibilities

All staff at {{org_field_name}} have a responsibility to uphold this policy and protect service users’ finances. To do so effectively, our organisation provides training and clear guidelines, and we expect every staff member to be diligent and proactive regarding financial safeguards.

Firstly, all staff must complete financial safeguarding training on an annual basis. This training covers how to properly assist service users with money, how to maintain records, how to prevent and detect financial abuse, and familiarizes staff with the contents of this policy. New employees receive this training as part of their induction, and then all staff attend refresher courses or e-learning updates at least once every year. By training annually, we ensure that everyone’s knowledge is up-to-date and that we reinforce the importance of these procedures regularly. The training will often include real-life scenarios and examples (such as how to fill out a financial log, or how to handle a situation if a service user offers you a gift) to make it practical and relatable for care staff.

All staff are expected to follow this policy to the letter when assisting service users with money management. This means adhering to every procedure described – from obtaining consent, to logging transactions, to not sharing PINs, etc. We understand that in day-to-day work, time pressures or unique situations can tempt shortcuts, but this policy’s rules must always be observed for the protection of all. Supervisors and the Registered Manager will monitor compliance through spot checks and supervision meetings, addressing any deviations immediately. Staff who fail to follow the policy (for example, forgetting to log a transaction or not keeping a receipt) will be re-trained or disciplined as appropriate, depending on the severity of the lapse, because non-compliance can put service users at risk. Conversely, we recognize and praise good practice when staff consistently demonstrate excellent financial care and record-keeping.

An equally important responsibility for every staff member is to report any concerns about financial mismanagement or abuse immediately (as detailed in section 7.2). This is part of the duty of care we owe to our service users. Even if a staff member only has a slight suspicion, it is better to report it and have it checked than to stay silent and potentially allow abuse to continue. We make it clear that reporting is not only encouraged but required – failing to report something one knew about could result in disciplinary action, because it violates our safeguarding obligations. We support staff in this by making sure they know the procedure and contacts (like who the Safeguarding Lead is, how to use the whistleblowing hotline, etc.), and by fostering a culture where raising concerns is viewed positively as doing the right thing.

To ensure staff truly understand their responsibilities and are competent in these areas, our organisation has a financial management competency framework in place. This means we have identified key competencies (skills and knowledge) that staff should have regarding financial stewardship. For example, a competency might be “Can accurately document financial transactions and maintain records” or “Understands how to apply the Mental Capacity Act in financial decisions.” Staff are assessed against these competencies through observations, periodic knowledge tests, or supervision discussions. If a staff member is found to be lacking in a certain area – say, they’re unsure how to recognize a financial scam that might target a service user – we will provide coaching, mentoring, or additional training to build that competency. The framework helps managers and staff have a clear understanding of expectations and allows us to tailor professional development to ensure everyone is capable and confident in managing service users’ finances safely.

In addition to annual mandatory training, we provide regular refresher sessions and updates to keep staff informed of best practices. These might be quarterly briefings, memos, or parts of team meetings where we discuss any changes in regulations (for example, if CIW issues new guidance or if a new type of financial scam is making rounds in the community). We may also review case studies – possibly from our own organisation or from news in the care sector – to learn lessons and improve our practice. For example, if another care provider had an incident of financial abuse that became public, we might discuss what happened and how to avoid something similar. By continuously educating our staff, we maintain a high level of awareness and vigilance. Our goal is that every staff member, at all times, is well-equipped to manage service user finances correctly and to respond tMonthly reconciliation & RI oversight.

{{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}} (or delegate) completes monthly reconciliations of logs, balances, receipts and online orders; exceptions are investigated and closed with written actions. The Responsible Individual receives a quarterly thematic analysis (patterns, exceptions, learning) and confirms actions are complete. Findings feed supervision, spot-checks and refresher training.o any concerns in line with this policy.

Scam prevention. Staff stay alert to common scams (doorstep, phone, online). Unexpected requests for transfers, vouchers or card details are refused and reported to the manager the same day. Where a person is targeted, we help them contact their bank, place warning markers (with consent), and update the IFSP with protective actions.

9. Related Policies

This Managing Service User Finances Policy should be read in conjunction with several other organisational policies. Together, these policies form a comprehensive framework to ensure service users are protected and that staff have clear guidance on all aspects of care related to finances and safeguarding:

Each of these related policies interlinks with the Managing Service User Finances Policy. Staff are expected to be familiar with them and understand how they influence actions related to service users’ finances. During training and induction, we highlight these connections so that employees have a holistic view of our responsibilities and standards. Keeping these policies aligned and updated together also helps us remain compliant with CIW regulations and provides a strong, consistent message about our commitment to ethical care and safeguarding.

Record keeping and retention. Financial logs, receipts, delivery notes, e-receipts, reconciliations, audits and IFSPs are treated as confidential records under DCW34. We retain financial records for a minimum of 6 years after service ends (or longer where required by funders/investigators) and then dispose of them securely. Data breaches are reported to {{org_field_data_protection_officer_first_name}} {{org_field_data_protection_officer_last_name}} ({{org_field_data_protection_officer_email}} / {{org_field_data_protection_officer_phone}}).

Closure, bereavement and return of property/funds. On service end or death, we produce a final reconciliation within 5 working days, return balances and property to the person’s representative/executor against a signed receipt, and file the close-down pack (final balance, copy receipts, sign-off by {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}). Any unclaimed funds/property are safeguarded and escalated to the local authority for direction.

10. Policy Review

This policy will be reviewed on a regular basis to ensure it remains current, effective, and in line with any changes in legislation or best practice. At a minimum, the Managing Service User Finances Policy is reviewed annually. The annual review will consider any feedback from the past year, results of audits, incidents or near-misses, and changes in external requirements. If updates are needed (for example, to add a new procedure or clarify a point), those changes will be made and communicated to all staff.

In addition to the scheduled yearly review, an earlier review will be conducted if required due to certain circumstances. These circumstances include: significant legislative or regulatory changes (for instance, if the Welsh Government introduces new rules about handling client money, or if CIW updates its guidance), major organisational or business changes (such as if we start providing a new type of service that involves different financial arrangements), or any important lessons learned from a safeguarding incident. Essentially, if something happens that affects how we should manage service user finances, we will not wait for the annual cycle – we will revise the policy as soon as practicable to address the new situation.

The responsibility for ensuring that this policy is kept up to date and that it is followed in practice lies with the Registered Manager and the Responsible Individual. These leaders must ensure that the policy review takes place as scheduled and that any necessary revisions are implemented. They are also responsible for making sure that once a policy is updated, all staff are made aware of the changes (for example, through training sessions or official memos). Furthermore, the Registered Manager and Responsible Individual must oversee compliance with the policy on an ongoing basis. This might involve periodic spot checks, discussing the policy in staff meetings, and checking that procedures like audits and training (as described in this document) are actually happening. During inspections or audits by CIW and other bodies, they will likely examine whether the provider has an up-to-date finances policy and whether staff are adhering to it – it is the role of our management to make sure the answer to both is yes. By actively managing the review and enforcement of this policy, the Registered Manager and Responsible Individual help maintain high standards of financial safeguarding and ensure that {{org_field_name}} remains compliant with all its obligations.

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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