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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Handling of Service User Finances Policy

1. Purpose

The purpose of this policy is to ensure that {{org_field_name}} provides safe, lawful, transparent and person-led support where a person we support requires assistance with money, property, shopping, payments or other day-to-day financial matters. {{org_field_name}} will not take over a person’s financial affairs unless there is clear lawful authority to do so. Any support with finances must be the least restrictive option, must promote the person’s independence and choice, must be clearly recorded in the person’s personal plan, and must be carried out in line with the Health and Social Care Standards, the Care Inspectorate’s requirements, the SSSC Codes of Practice, Adult Support and Protection duties, the Adults with Incapacity (Scotland) Act 2000 and data protection law.

This policy ensures that:

• The financial interests of people we support are safeguarded against exploitation and mismanagement.
• Staff follow clear, legally compliant procedures when handling finances.
• Financial transactions are accurately recorded and regularly audited.
• Individuals receiving care maintain as much independence and control over their finances as possible.
• Best practices for preventing financial abuse are followed and monitored.

2. Scope

This policy applies to:

• All staff, including care workers, supervisors, and management, who may assist people we support with their financial transactions.
• Agency and temporary staff, ensuring they adhere to the same financial safeguarding procedures.
• People we support, their families, and representatives, ensuring they understand how finances are handled.
• External agencies, such as advocacy services and local authority financial guardians.
• Situations where staff are asked to assist with shopping, cash handling, payment cards, online payments, banking, benefits, bills, valuables, gifts, donations, financial correspondence, or any other matter involving a person’s money or property. Staff must not provide financial support unless it is authorised, risk assessed, recorded in the personal plan and within the limits of their role.

3. Legal and Regulatory Framework

This policy is underpinned by the following Scottish and UK legal and regulatory requirements and good practice expectations:

• Public Services Reform (Scotland) Act 2010 – establishes the current regulatory framework for care services in Scotland and the functions of Social Care and Social Work Improvement Scotland, known as the Care Inspectorate.
• Social Care and Social Work Improvement Scotland (Requirements for Care Services) Regulations 2011 (SSI 2011/210) – requires care services to be provided in a way that promotes the welfare, safety and needs of people using services, and requires a personal plan setting out how the person’s health, welfare and safety needs are to be met.
• Regulation of Care (Scotland) Act 2001 – establishes the SSSC and provides for Codes of Practice for social service workers and employers.
• Health and Social Care Standards: My support, my life – sets out what people should expect when using health, social care or social work services in Scotland, including dignity, respect, involvement, choice, safety, wellbeing and human rights.
• Care Inspectorate Quality Framework for Support Services (Care at Home, including supported living models of support) – expects assessment and personal planning to reflect people’s outcomes and wishes, and expects services to evidence quality assurance, safe practice and improvement.
• Care Inspectorate adult services records and notification guidance – requires services to keep clear records of financial support, authorisation, money spent on behalf of a person, receipt and return of money or valuables, and to notify protection concerns within required timescales.
• SSSC Codes of Practice for Social Service Workers and Employers 2024 – requires workers and employers to protect rights, maintain trust, follow policies about gifts and money, keep accurate records, maintain professional boundaries and report harm, exploitation or unsafe practice.
• Adult Support and Protection (Scotland) Act 2007 and Code of Practice – provides the framework for protecting adults at risk of harm, including financial harm, exploitation, theft, coercion and misuse of property or funds.
• Adults with Incapacity (Scotland) Act 2000 – applies where an adult lacks capacity to make some or all financial decisions. Any intervention must benefit the adult, be the least restrictive option, take account of the adult’s present and past wishes and involve relevant others where appropriate.
• Office of the Public Guardian Scotland requirements – relevant where there is a continuing Power of Attorney, financial guardianship, intervention order, Access to Funds authority, or other lawful authority relating to the adult’s property or finances.
• Human Rights Act 1998 – protects rights including respect for private and family life, property, dignity, autonomy and fair treatment.
• Equality Act 2010 – requires fair and non-discriminatory support, including reasonable adjustments where a person’s disability or communication needs affect how they manage money.
• UK GDPR and Data Protection Act 2018 – requires personal and financial information to be processed lawfully, fairly, securely and only where necessary.
• Common law duties of care, confidentiality and professional accountability – require staff to act honestly, safely, transparently and within the limits of their role.

4. Principles of Financial Management

{{org_field_name}} follows key principles to protect the finances of people we support:

4.1 Promoting Financial Independence

• Individuals must be encouraged to manage their own finances where possible.
• Staff will only assist when necessary and with clear consent.
• Training and support are provided to enhance financial skills and decision-making.

4.2 Transparency and Accountability

• All financial transactions must be accurately recorded, signed, and reviewed.
• Receipts must be obtained for all purchases made on behalf of people we support.
• Regular internal audits and checks are conducted to prevent errors or misuse.

4.3 Preventing Financial Abuse

• Zero tolerance for financial exploitation, theft, or coercion.
• Immediate reporting of any suspected financial abuse.
• Staff must not accept gifts, loans, or personal financial involvement with individuals they support.

4.4 Adhering to Legal Responsibilities

• Staff must understand the difference between supporting a person to make and carry out their own financial decisions and making decisions on the person’s behalf.
• Staff must not make financial decisions for a person unless this is specifically authorised by law and forms part of their agreed role.
• Where a continuing attorney, financial guardian, intervener, Access to Funds withdrawer, Department for Work and Pensions appointee, local authority, solicitor or other authorised person is involved, their identity, authority and scope of decision-making must be verified and recorded in the person’s personal plan.
• People we support must be involved in financial decisions to the maximum extent possible, including where they have reduced capacity. Staff must use communication support, advocacy or representative involvement where needed.
• Financial records and personal information must be handled confidentially and in line with UK GDPR, the Data Protection Act 2018 and {{org_field_name}}’s Data Protection and Confidentiality Policy.

4.5 Limits on Staff Involvement

Staff must not:

• borrow money from, lend money to, or exchange personal money with a person we support;
• accept loans, personal financial favours, personal gifts of money, tips or valuables from a person we support;
• use a person’s money, loyalty card, bank card or account for their own benefit or for the benefit of another person;
• keep a person’s bank card, PIN, cheque book, savings book, passport, benefit letters, legal documents or valuables unless this is specifically authorised, risk assessed and recorded;
• act as a witness to wills, legal documents, loans, contracts or financial agreements for a person we support;
• become involved in inheritance, wills, investments, property sales, tenancy decisions, benefit claims, pensions, tax matters or debt management unless this is part of an authorised organisational role and agreed with management;
• sign blank forms, blank cheques, withdrawal slips or receipts;
• make purchases that are not agreed by the person or their lawful representative;
• use their own personal bank account, online shopping account, mobile payment app or loyalty account to process a person’s money;
• dispose of, donate, sell or remove a person’s property without clear written authorisation.

5. Managing Financial Transactions Safely

5.1 Identifying Financial Assistance Needs

Before staff provide any support with finances, {{org_field_name}} will assess and record:

• what the person can do independently and what support, if any, they want or need;
• the person’s wishes, choices, routines, communication needs and preferred level of involvement;
• whether the person has capacity to make the relevant financial decision at the relevant time;
• whether there is any lawful representative or authority in place, such as a continuing Power of Attorney, financial guardian, intervention order, Access to Funds withdrawer or DWP appointee;
• the specific financial tasks staff may support with, such as shopping, small cash purchases, collecting receipts, paying bills or supporting access to statements;
• the risks of financial harm, coercion, exploitation, undue influence, theft, error or mismanagement;
• how the person’s independence, control and dignity will be promoted;
• what records must be completed after each transaction;
• what staff must not do.

Financial support must be clearly documented in the person’s personal plan. The plan must be reviewed when the person’s needs, capacity, risks, wishes, legal arrangements or financial support needs change.

5.2 Authorisation and Personal Plan Requirements

Staff may only support a person with finances where:

• the support is included in the person’s personal plan;
• the person has given informed consent, or where the person lacks capacity, the support is authorised by a lawful representative or other lawful process;
• the support is necessary, proportionate and the least restrictive option;
• the type and limit of support is clearly stated;
• the maximum amount of cash or value of transaction staff may handle is recorded;
• the recording process is clear;
• there is a named manager responsible for oversight;
• the person, and where appropriate their representative, understands how concerns or complaints can be raised.

The personal plan must not simply state “support with finances”. It must specify exactly what support is authorised, who has agreed it, any financial limits, how often the support is required, what records must be completed, and how the arrangement will be reviewed.

5.3 Supporting Day-to-Day Financial Transactions

Where financial support is authorised, staff may support the person with day-to-day transactions such as shopping, small purchases, paying agreed bills, checking change, collecting receipts, budgeting discussions or accessing information needed by the person. Staff must:

• involve the person as fully as possible in choosing what is bought or paid;
• explain the amount to be spent and confirm the person’s agreement before the transaction;
• keep the person’s money separate from staff money and from any other person’s money at all times;
• obtain an itemised receipt wherever possible;
• record the date, amount, purpose of expenditure, opening balance, closing balance, receipt number or explanation if no receipt is available;
• record the name and signature of the staff member completing the transaction;
• obtain the person’s signature where they are able and willing to sign;
• obtain a witness signature where required by the personal plan, local procedure or level of risk;
• report any discrepancy, missing receipt, missing money, unusual request or concern immediately to a line manager.

Staff must not make purchases based on their own preference, convenience or judgement unless this is necessary to prevent immediate harm and is reported and recorded.

5.4 Cash Handling and Secure Storage

Cash handling must be kept to the minimum necessary. Where staff handle cash on behalf of a person, they must:

• only handle cash that is authorised in the person’s personal plan;
• count cash in the presence of the person wherever possible;
• record the opening balance before spending and the closing balance after spending;
• keep receipts with the financial record;
• ensure money belonging to different people is never mixed;
• ensure the person’s money is never mixed with organisational money or staff money;
• return change and receipts to the person immediately unless the personal plan states otherwise;
• store money safely only where this has been agreed and recorded;
• never take money home, leave money unattended or store money in a staff vehicle;
• report discrepancies immediately.

Where a person keeps cash in their own home, staff may support them to check and record cash only where this is agreed in the personal plan. Staff are not responsible for cash or valuables held independently by the person unless {{org_field_name}} has formally agreed and recorded a specific responsibility.

5.5 Banking and Bill Payments

Staff must not carry out banking or bill payment activity unless it is specifically authorised in the personal plan and approved by a manager. Where support is authorised, staff must:

• support the person to remain in control of their own banking wherever possible;
• encourage safer payment arrangements such as direct debit or standing order where these are the person’s informed choice or are agreed by their lawful representative;
• never use online banking, telephone banking, mobile banking or banking apps on behalf of a person unless there is a specific organisational procedure, management authorisation and lawful authority;
• never ask for, record, store or use a person’s PIN, password, memorable information, security code or one-time passcode;
• ensure bank statements remain the person’s private information unless the person or lawful representative has agreed that staff may view specific information for a specific purpose;
• record any bank visit, bill payment or financial correspondence support in the person’s financial record and daily notes as appropriate;
• report any signs of unusual withdrawals, pressure from others, unpaid bills, unexplained debt, missing funds or suspected financial harm.

5.6 Use of Bank Cards, PINs and Digital Payments

Staff must not use, retain, photograph, copy, store or ask for a person’s bank card, PIN, password, security code or banking security information. Staff must not withdraw cash using a person’s bank card.

Where the person uses a card independently, staff may provide general prompting or physical assistance only where this is agreed in the personal plan and does not involve staff knowing or entering the PIN.

Where shopping support is required, safer alternatives should be considered, such as prepaid shopping cards, store gift cards, managed shopping accounts, invoicing arrangements or direct payment to the supplier, provided these are agreed with the person or their lawful representative and recorded in the personal plan.

Contactless payments must only be supported where the person remains in control of the card and the arrangement has been risk assessed. Staff must not use Apple Pay, Google Pay, PayPal, Klarna, personal online shopping accounts, personal loyalty accounts or any personal digital payment method for a person we support.

5.7 Receipts, Records and Missing Receipts

Every transaction completed by staff on behalf of a person must be recorded. The record must include:

• date of transaction;
• amount received or spent;
• purpose of expenditure;
• source of money where relevant;
• opening and closing balance;
• receipt or invoice attached;
• name and signature of staff member;
• signature of the person where possible;
• witness signature where required;
• explanation and management countersignature where a receipt could not be obtained.

Missing receipts must be treated as an exception. Repeated missing receipts, unexplained discrepancies or poor recording must be escalated to management and investigated.

5.8 Discrepancies, Errors and Missing Money

Any discrepancy, missing money, missing property, unexplained transaction, incorrect balance, suspected theft, suspected fraud or concern about financial harm must be reported to the line manager immediately and recorded. The manager must review the records, speak to relevant staff, preserve any evidence and decide whether the matter requires:

• correction of an administrative error;
• internal investigation;
• notification to the person and/or lawful representative;
• Adult Support and Protection referral;
• Care Inspectorate notification;
• police referral;
• SSSC referral where a worker’s fitness to practise may be impaired;
• disciplinary action.

5.9 Gifts, Donations and Personal Benefit

Staff must not accept money, gifts, tips, vouchers, loans, personal items, hospitality or other benefits from a person we support, their family or representative, except where this is permitted under {{org_field_name}}’s Gifts and Hospitality Policy and approved by management.

Any offer of a gift, money, loan, tip, inheritance, personal favour or financial benefit must be reported to the line manager and recorded. Staff must politely explain that professional boundaries and safeguarding rules prevent them from accepting personal financial benefits.

5.10 Attorneys, Guardians, Appointees and Access to Funds

Where a person has a continuing attorney, financial guardian, intervener, Access to Funds withdrawer, DWP appointee, solicitor or other authorised person, staff must record:

• the person’s name and contact details;
• the type of authority held;
• the scope and limits of that authority;
• how the authority has been verified;
• what financial support staff may provide;
• when the authorised person must be contacted.

Staff must not assume that a family member has authority to make financial decisions. Evidence of legal authority must be requested where decisions are being made on behalf of the person. Where there is disagreement, suspected coercion, conflict of interest or concern that the authorised person is not acting in the person’s interests, staff must report this to management and follow Adult Support and Protection procedures.

5.11 Property, Money and Records When Support Ends or the Person Dies

When a person’s service ends, or where a person dies, any money, receipts, financial records, property or valuables held by {{org_field_name}} must be reconciled and returned only to the person or legally authorised representative. A clear record must be kept of what was returned, when, to whom, and by whom. Two staff members should verify the handover wherever possible. Staff must not release money or property to relatives, friends or others unless legal authority has been confirmed.

6. Safeguarding Against Financial Abuse

6.1 Identifying Financial Abuse

Staff must be alert to financial harm, exploitation or abuse. Indicators may include:

• missing money, bank cards, valuables, benefit letters or financial documents;
• unexplained withdrawals, spending, transfers or debts;
• unpaid bills, rent arrears or lack of food, heating or essentials despite adequate income;
• sudden changes in financial arrangements, wills, Power of Attorney, appointeeship or property ownership;
• the person appearing anxious, fearful or confused about money;
• another person pressuring, controlling or speaking for the person about money;
• relatives, friends, visitors or staff asking for loans, gifts, access to cards, passwords or cash;
• the person being prevented from accessing their own money or information;
• unusual purchases that do not appear to benefit the person;
• staff or others showing unusual interest in the person’s finances;
• repeated missing receipts, unexplained discrepancies or poor financial recording;
• online scams, doorstep crime, coercive control, romance fraud, telephone scams or financial exploitation by others.

Financial abuse may be a form of adult harm and must be taken seriously even where the amount of money appears small.

6.2 Reporting Financial Concerns

If financial abuse, exploitation, theft, fraud, coercion, neglect or mismanagement is suspected, staff must:

• take immediate steps to protect the person from further harm, without placing themselves or the person at unnecessary risk;
• report the concern immediately to their line manager or safeguarding lead;
• record the concern factually, including dates, times, people involved, amounts, evidence and action taken;
• preserve receipts, records, notes, messages, statements or other relevant evidence;
• follow {{org_field_name}}’s Adult Support and Protection Policy and local adult protection procedures;
• ensure a referral is made to the relevant local authority Adult Support and Protection team where an adult may be at risk of harm;
• notify Police Scotland where theft, fraud or immediate risk is suspected;
• notify the Care Inspectorate of a protection concern within 24 hours where required;
• consider whether a referral to the SSSC is required where a worker’s conduct or fitness to practise may be impaired.

Staff must not investigate suspected financial abuse themselves beyond making the person safe, reporting, recording and preserving evidence.

7. Staff Training and Compliance

To ensure safe practice, {{org_field_name}} will ensure that all staff who may support people with financial matters receive induction, training, supervision and competency checks appropriate to their role. Training will include:

• this policy and associated financial recording procedures;
• professional boundaries, gifts, money and conflicts of interest;
• identifying and reporting financial harm and adult protection concerns;
• consent, capacity and the principles of the Adults with Incapacity (Scotland) Act 2000;
• the role of attorneys, guardians, interveners, Access to Funds withdrawers and DWP appointees;
• accurate financial recording, receipts, balances and audit requirements;
• data protection and confidentiality when handling financial information;
• whistleblowing and reporting poor practice;
• the SSSC Codes of Practice for Social Service Workers and Employers.

Staff must not support a person with financial transactions until they have been trained and assessed as competent. Managers must address any recording errors, poor practice or breaches through supervision, retraining, investigation or disciplinary action as appropriate.

8. Monitoring and Auditing Financial Compliance

{{org_field_name}} will monitor financial support arrangements to ensure people are protected and staff practice is safe, transparent and accountable. The service will:

• audit financial records at least monthly, or more frequently where risk is identified;
• check receipts, balances, signatures, authorisations and personal plan instructions;
• confirm that funds belonging to different people are separate and identifiable;
• confirm that service funds and personal funds are never mixed;
• review missing receipts, discrepancies, late entries or unclear records;
• sample daily notes and personal plans to ensure financial support matches authorised support;
• seek feedback from people and, where appropriate, their representatives about how financial support is provided;
• record audit findings and actions taken;
• escalate concerns to senior management, Adult Support and Protection, the Care Inspectorate, Police Scotland or the SSSC where required;
• use audit findings to improve training, supervision, personal planning and procedures.

Managers must ensure that financial audits are not treated as a paper exercise. Audit findings must be used to improve safety, independence, dignity, accountability and outcomes for people.

9. Related Policies

This policy should be read alongside:

• Safeguarding and Protection Policy
• Person-Centred Care Planning Policy
• Data Protection and Confidentiality Policy
• Whistleblowing Policy
• Incident Reporting Policy

10. Policy Review

This policy will be reviewed annually or sooner if there are changes in legislation, Care Inspectorate guidance, SSSC Codes of Practice, Adult Support and Protection procedures, best practice, organisational learning, audit findings, complaints, incidents or safeguarding concerns. Any amendments will be communicated to all staff and relevant stakeholders, and staff training will be updated where required.

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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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