HCS122-Safe Key Holding and Access Management Policy

Registration Number: {{org_field_registration_no}}

Safe Key Holding and Access Management Policy

1. Purpose

The purpose of this policy is to ensure that the management of keys and access to the homes of the people we support is conducted in a secure, responsible, and legally compliant manner. The policy aims to safeguard the dignity, privacy, and security of individuals receiving care while maintaining operational efficiency and accountability. It also establishes clear procedures for obtaining consent, record-keeping, and handling emergency access situations, ensuring compliance with the Health and Social Care Standards (Scotland).

2. Scope

This policy applies to all staff members of {{org_field_name}}, including permanent employees, temporary staff, volunteers, and any third-party contractors who may require access to the homes of individuals we support. It is relevant to care coordinators, key workers, and management personnel responsible for the handling and safekeeping of keys. The policy also applies to individuals receiving care, their families, and any legal representatives involved in the decision-making process related to key access.

3. Related Policies

This policy should be read in conjunction with the following policies: Confidentiality and Data Protection Policy, which ensures that keyholder details and access permissions are securely maintained; Safeguarding Adults Policy, which ensures that key access is not misused and protects vulnerable individuals; Personal Plans and Risk Assessment Policy, which integrates key management as part of care planning; Incident Reporting and Management Policy, which outlines the process of reporting lost or stolen keys and access breaches; Health and Safety Policy, which ensures compliance with safety protocols when entering and leaving the premises of individuals receiving care.

4. Policy Statement

{{org_field_name}} is committed to maintaining the highest standards of security and accountability when handling keys or managing access to private residences. Key holding is a significant responsibility that must be handled with the utmost care to ensure the safety and well-being of individuals receiving care. This policy ensures that all key-holding activities are conducted transparently and ethically, minimising risks of unauthorised access, theft, or loss. It also ensures that all staff are trained on secure key management and that clear records are maintained at all times.

5. Responsibilities

5.1 Responsibilities of Staff

Staff members who hold keys must obtain explicit, written consent from individuals receiving care (or their legal representatives) before accepting responsibility for key holding. They must only use keys for authorised purposes and in line with an individual’s personal support plan. Keys should be stored securely when not in use and never shared with unauthorised personnel. Staff must follow key management procedures, including signing keys in and out where applicable, and immediately report lost, stolen, or misplaced keys to management. If a key is no longer required, it must be returned following proper deactivation procedures, ensuring that any necessary security updates (such as lock changes) are carried out.

5.2 Responsibilities of Management

Management is responsible for maintaining an accurate log of all keys held by {{org_field_name}}, including key issue dates, return records, and key holders. They must ensure that staff are properly trained on key security, access protocols, and the importance of obtaining consent before holding keys. Regular audits must be conducted to ensure compliance with key security standards, and any breaches of policy must be investigated promptly. Management must also ensure that individuals receiving care can review, update, or withdraw key-holding consent at any time without undue pressure. In cases where a key is lost or security is compromised, management must take immediate steps to mitigate risks, which may include changing locks or updating access codes.

6. Consent and Record Keeping

6.1 Obtaining Consent

Key holding must only be undertaken with the informed and documented consent of the individual receiving care or their legal representative. The decision to hold a key should be based on necessity and included in the individual’s care plan. The care plan must specify who holds the key, the purpose of key access, and any specific access restrictions (e.g., emergency-only use). Consent must be reviewed at least annually or sooner if circumstances change. If an individual revokes consent, alternative access arrangements must be agreed upon and documented.

6.2 Key Holding Log

A secure register of all keys held by {{org_field_name}} must be maintained to ensure transparency and security. The key-holding log must include the name and address of the individual receiving care, key identification details (e.g., key fob or code number), name of the staff member responsible for key use, date and time of key collection and return, and the reason for access. This log must be updated in real-time and be accessible only to authorised personnel.

6.3 Access by Third Parties

Keys will not be provided to third parties, such as family members, maintenance personnel, or other agencies, without written permission from the individual receiving care or their legal representative. If a third party requires access for essential maintenance, their details and reason for access must be documented. In emergencies where access by a third party is required, such as an urgent medical visit, authorisation must be obtained from management.

7. Key Security and Storage

7.1 Secure Storage of Keys

Keys should be kept in a secure, locked storage unit at {{org_field_name}}’s office when not in use. Staff must never leave keys unattended, store them in unprotected locations such as pockets or bags, or label them in a way that could identify the associated property. For electronic access, passcodes and key fobs must be securely managed, and their details must not be shared.

7.2 Handling Lost or Stolen Keys

If a key is lost or stolen, the staff member must immediately notify the registered manager. The individual receiving care (or their representative) must be informed without delay. A risk assessment should be conducted to determine security risks, and if necessary, locks must be changed. A full incident report must be filed, detailing the circumstances and actions taken. Staff members who lose keys repeatedly may be subject to additional training or disciplinary measures.

8. Emergency Access Protocols

Emergency access procedures should be clearly outlined in the individual’s care plan. If a staff member is unable to access a home due to a lock malfunction, lost key, or security concern, they must contact management immediately. If the person receiving care is in distress or at risk, emergency services must be contacted. If emergency access is needed outside of normal hours, staff must follow the {{out_of_hours}} contact procedures.

9. Compliance and Monitoring

This policy is aligned with the SSSC Codes of Practice for Social Service Workers and Employers (2024). Regular audits of key usage and storage must be conducted to ensure compliance, with records reviewed at least quarterly. Any breaches of this policy will result in disciplinary action, up to and including termination of employment, and may be reported to regulatory authorities if required. Staff must complete annual training on key security and access management.

10. Policy Review

This policy will be reviewed annually or earlier if there are changes in legislation, operational needs, or security concerns. Updates will be communicated to all staff members to ensure continued compliance and best practice in key security.

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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