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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Staff Mental Health First Aid Policy

1. Purpose

The purpose of this policy is to provide a structured, compassionate and effective approach to promoting positive mental health and wellbeing within {{org_field_name}}, and to establish arrangements for the provision of Mental Health First Aid (MHFA) and other appropriate workplace support.

The policy applies to the mental health and wellbeing of staff and temporary workers engaged or supplied by {{org_field_name}} and is intended to support the identification and management of work-related risks to mental health, appropriate early support, lawful handling of mental health information and appropriate signposting to professional services.

{{org_field_name}} recognises that employers have duties to protect the health, safety and welfare of their employees and others who may be affected by their activities, including duties to assess and manage risks arising from work-related stress and other risks to mental health.

As an employment business supplying temporary workers to hirers, {{org_field_name}} will also comply with its obligations to obtain relevant information from hirers about known health and safety risks associated with an assignment, including relevant risks to mental health where known, the steps taken by the hirer to prevent or control those risks, and to provide the required information to the temporary worker before or when offering the assignment.

This policy will be implemented in accordance with applicable legislation, including:

• the Health and Safety at Work etc. Act 1974;
• the Management of Health and Safety at Work Regulations 1999;
• the Equality Act 2010;
• the Employment Rights Act 1996;
• the Employment Agencies Act 1973;
• the Conduct of Employment Agencies and Employment Businesses Regulations 2003, as amended;
• the Data Protection Act 2018; and
• the UK General Data Protection Regulation (UK GDPR).

Relevant guidance issued by the Health and Safety Executive (HSE), Acas and other competent authorities will also be taken into account.

2. Scope

This policy applies to: All directors, registered nurses, healthcare assistants, temporary workers, and office-based personnel engaged by {{org_field_name}}. All activities, environments, and settings where staff are employed, deployed, or supervised by {{org_field_name}} including client care settings, client placements, agency offices, and remote working environments. All arrangements for mental health first aid, staff wellbeing, support, and escalation of mental health concerns within the organisation.

3. Related Policies

• Staff Support and Wellbeing Policy
• Equality, Diversity, and Inclusion Policy
• Lone Working Policy
• Supervision, Appraisal, and Reflective Practice Policy
• Whistleblowing Policy
• Recruitment Policy
• Health and Safety Policy

4. Policy Statement

{{org_field_name}} is committed to promoting a mentally healthy workplace by: Raising awareness of mental health and reducing associated stigma. Providing access to Mental Health First Aiders (MHFAs) or equivalent support mechanisms. Supporting staff who experience mental health difficulties in or outside the workplace. Facilitating early intervention and signposting to appropriate professional services. Incorporating mental health into its broader health and safety, safeguarding, and wellbeing frameworks. Creating a culture where mental health is valued equally to physical health.

5. Responsibilities

Directors

The directors of {{org_field_name}} are responsible for:

• establishing, implementing and periodically reviewing this policy;
• maintaining appropriate arrangements for protecting the health, safety and welfare of employees and workers so far as the organisation’s legal responsibilities apply;
• ensuring that suitable and sufficient assessments are undertaken of risks arising from {{org_field_name}}’s own work activities, including reasonably foreseeable risks to mental health and risks associated with work-related stress;
• ensuring that significant findings of risk assessments are recorded where required by law;
• taking appropriate preventive and protective measures in response to identified risks;
• ensuring that, before supplying a temporary worker to an assignment, {{org_field_name}} obtains from the hirer the health and safety information required by the Conduct of Employment Agencies and Employment Businesses Regulations 2003, including information about any known health and safety risks and the steps the hirer has taken to prevent or control those risks;
• ensuring that relevant assignment health and safety information obtained from the hirer is provided to the temporary worker as required by law;
• ensuring that concerns about work-related stress or other risks to mental health reported by temporary workers are considered and, where the issue relates to the hirer’s workplace or working arrangements, raised promptly with the hirer as appropriate;
• considering and implementing reasonable adjustments where required by the Equality Act 2010;
• ensuring that information concerning a person’s mental or physical health is handled in accordance with the Data Protection Act 2018 and UK GDPR;
• ensuring that any designated Mental Health First Aiders or other appointed persons understand the limits of their role and do not undertake diagnosis, clinical assessment or treatment unless separately qualified and authorised to do so; and
• reviewing this policy annually or earlier where there is a relevant change in legislation, organisational arrangements or identified risk.

Mental Health First Aiders / Appointed Staff

Where {{org_field_name}} appoints Mental Health First Aiders or other staff to provide mental health support, they will:

• undertake appropriate training relevant to the role assigned to them;
• provide an initial point of contact for workers who wish to discuss mental health concerns;
• listen in a supportive and non-judgemental manner;
• encourage the individual to seek appropriate professional assistance where necessary;
• understand that Mental Health First Aid does not constitute diagnosis, counselling, medical treatment or clinical care;
• maintain appropriate boundaries and act only within the scope of their role and competence;
• protect confidentiality and personal information in accordance with this policy and the organisation’s data protection arrangements;
• disclose information without the person’s agreement only where there is a lawful justification for doing so, including where disclosure is necessary to protect vital interests, comply with a legal obligation or address an immediate and serious risk of harm; and
• signpost individuals to appropriate internal, occupational health, NHS, emergency or other specialist support.

Mental Health First Aiders must not create informal or private records concerning an individual’s mental health. Any record that is required for legitimate organisational purposes must be created, stored, accessed, retained and deleted through {{org_field_name}}’s authorised record-keeping arrangements in accordance with Section 9 of this policy.

All Staff and Temporary Workers

All staff and temporary workers are expected to:

• behave in a respectful manner towards colleagues and others at work;
• comply with applicable health and safety arrangements;
• report work-related hazards or concerns that may present a risk to their own health or safety or that of others;
• seek appropriate assistance where they require support;
• respect the privacy and confidentiality of colleagues;
• not engage in bullying, harassment, victimisation or unlawful discrimination; and
• cooperate with reasonable measures introduced to protect health, safety and wellbeing.

Temporary workers must also comply with the reasonable health and safety policies, instructions and control measures applicable at the hirer’s workplace and should report concerns relating to an assignment to the hirer and/or {{org_field_name}}, as appropriate.

6. Definition of Mental Health First Aid

Mental Health First Aid (MHFA) is the help provided to a person who is experiencing a mental health issue, before professional help is obtained. It involves: Recognising early signs and symptoms of common mental health issues. Providing initial non-judgemental support and reassurance. Guiding the person to seek appropriate professional support. Ensuring safety and, if necessary, escalating to emergency services.

7. Status and Limits of Mental Health First Aid

Mental Health First Aid is a workplace support and signposting measure. It is not a substitute for professional medical assessment, psychiatric or psychological assessment, counselling, occupational health advice, safeguarding action or emergency intervention.

There is no general statutory requirement for {{org_field_name}} to appoint a Mental Health First Aider merely because it employs or supplies workers. The appointment of Mental Health First Aiders under this policy is an organisational support measure and does not replace {{org_field_name}}’s statutory duties relating to health and safety, risk assessment, workplace first aid, equality, data protection or the provision of assignment information to temporary workers.

A person acting as a Mental Health First Aider must not:

• diagnose a mental health condition;
• provide clinical treatment;
• undertake a professional suicide or psychiatric risk assessment unless separately qualified and authorised to do so;
• promise absolute confidentiality where disclosure may lawfully be necessary to protect life or safety or comply with a legal obligation; or
• act outside the scope of their training and competence.

Where professional, clinical or emergency assistance is required, the Mental Health First Aider must signpost or escalate the matter to an appropriate service in accordance with this policy.

8. Recognising Mental Health Concerns

Staff should be aware of common signs that a colleague may be experiencing mental health challenges, including: Changes in behaviour, mood, or appearance. Withdrawal from colleagues or social situations. Increased sickness absence or punctuality issues. Signs of stress, anxiety, or emotional distress. Reduced performance or concentration difficulties. Expressing feelings of hopelessness or worthlessness.

9. MHFA Procedures

Where a member of staff or temporary worker appears to require mental health support, the response should be proportionate to the circumstances and within the competence of the person providing assistance.

The following steps should normally be followed:

• Approach: Speak to the individual sensitively and, where practicable, in a private environment.
• Listen: Allow the individual to explain their concerns without judgement or unnecessary interruption.
• Consider immediate safety: Establish, without attempting to make a clinical diagnosis, whether there appears to be an immediate and serious risk to the individual’s safety or the safety of another person.
• Signpost: Where appropriate, provide information about relevant support, which may include the individual’s GP, NHS services, occupational health, NHS 111, NHS Talking Therapies, Samaritans or other appropriate specialist services.
• Workplace action: Where the concern may have arisen from, or been aggravated by, work, inform the appropriate responsible person so that relevant workplace risks can be assessed and appropriate action considered. Only information necessary for that purpose should be shared.
• Reasonable adjustments: Where a mental health condition may amount to a disability under the Equality Act 2010, consideration must be given to whether reasonable adjustments are required.
• Emergency action: Where there is a reasonable belief that there is an immediate and serious risk of harm, appropriate emergency assistance must be sought. This may include contacting 999 or other appropriate emergency services. Information may be disclosed without consent where there is a lawful and necessary basis for doing so, but only information reasonably necessary for managing the emergency should be disclosed.
• Recording: Any record created must comply with Section 9 of this policy.

Mental Health First Aiders and managers must not diagnose mental illness, assess clinical risk beyond the limits of their competence or attempt to provide professional treatment unless they are independently appropriately qualified and authorised to do so.

10. Confidentiality, Data Protection and Record Keeping

Information about an individual’s mental health is personal data and will normally constitute special category personal data concerning health for the purposes of the UK GDPR and Data Protection Act 2018.

{{org_field_name}} will process mental health information only where there is a lawful basis for processing under Article 6 of the UK GDPR and an applicable condition for processing special category data under Article 9 of the UK GDPR. Where the applicable Article 9 condition requires compliance with a condition in Schedule 1 to the Data Protection Act 2018, {{org_field_name}} will ensure that the relevant statutory requirements and safeguards are satisfied, including maintaining an appropriate policy document where required.

Mental health information will be:

• collected only where there is a legitimate and lawful reason for doing so;
• adequate, relevant and limited to what is necessary for the identified purpose;
• recorded accurately and, where necessary, kept up to date;
• used only for lawful and specified purposes;
• accessible only to persons who require access for an authorised purpose;
• protected by appropriate technical and organisational security measures;
• retained only for as long as necessary in accordance with {{org_field_name}}’s applicable retention arrangements; and
• securely deleted or destroyed when retention is no longer necessary.

Workers will be provided with the information required by applicable data protection legislation about how their personal information is processed, including through the organisation’s privacy notice or other appropriate privacy information.

Mental Health First Aiders must not maintain personal notebooks, informal files, private electronic notes or separate unofficial records identifying individuals who have approached them for mental health support.

Where a formal record is necessary, it must contain only information reasonably required for the relevant organisational purpose and must be stored within the organisation’s authorised record-keeping system.

Information about a person’s mental health will not be disclosed merely because the individual has sought support. Information may be shared where the individual has agreed to the sharing or where another lawful basis permits or requires disclosure. This may include circumstances involving:

• an immediate and serious risk to the life or safety of the individual or another person;
• compliance with a legal obligation;
• the establishment, exercise or defence of legal claims;
• the fulfilment of employment, social security or social protection obligations where the applicable statutory conditions are satisfied; or
• another lawful basis specifically permitted by data protection legislation.

Any disclosure must be necessary and proportionate, and only the minimum information reasonably required should be shared.

Where the mental health information is required in connection with workplace adjustments, sickness absence, health and safety management, occupational health or another employment-related function, it will be shared only with those who reasonably require the information for that function.

Nothing in this section prevents {{org_field_name}} from taking necessary action to protect a person in an emergency.

11. Staff Training and Awareness

{{org_field_name}} will: Ensure all staff receive mental health awareness training during induction. Provide additional MHFA training for designated staff where applicable. Offer refresher training as part of ongoing professional development. Promote mental health awareness through newsletters, meetings, and supervision.

12. Integration with Staff Wellbeing

This policy complements the broader Staff Support and Wellbeing Policy by: Addressing mental health as part of holistic staff wellbeing. Ensuring access to advice and support beyond formal supervision or HR processes. Encouraging reflection on personal wellbeing during supervision and appraisal.

13. Access to Support

Staff may access mental health support through: Internal MHFAs. Supervision with directors. Referral to Occupational Health (where applicable). External services such as GP services, NHS Talking Therapies, Mind, Samaritans, or other specialist mental health organisations. The agency will provide staff with up-to-date information on support services and encourage their use.

14. Supporting Return to Work

Where a member of staff has been absent from work because of a mental health condition or mental health-related concern, {{org_field_name}} will manage their return to work sensitively and on an individual basis.

An appropriate manager or director will discuss the return to work with the individual and consider any relevant information that the individual wishes to provide.

Where appropriate, {{org_field_name}} may seek occupational health or other relevant professional advice, subject to applicable data protection requirements and any consent required for the particular referral or disclosure.

Where the individual’s mental health condition amounts to a disability for the purposes of the Equality Act 2010 and the duty to make reasonable adjustments applies, {{org_field_name}} will consider and implement reasonable adjustments that are required by law.

Depending on the circumstances, reasonable adjustments may include changes such as:

• a phased return to work;
• temporary or permanent adjustments to working hours or shift patterns;
• additional or modified breaks;
• adjustments to duties or workload;
• changes to communication or supervision arrangements; or
• other reasonable measures appropriate to removing or reducing the disadvantage experienced by the individual.

Adjustments will be considered on an individual basis and will be reviewed where appropriate. The fact that a particular adjustment has been made for one individual does not mean that the same adjustment will necessarily be appropriate or reasonable in another case.

Where the individual is a temporary worker undertaking an assignment for a hirer, {{org_field_name}} will liaise with the hirer as necessary regarding relevant workplace arrangements and reasonable adjustments, while ensuring that health information is disclosed only where there is a lawful basis and only to the extent necessary.

15. Risk Assessment and Temporary Assignments

{{org_field_name}} will identify and assess reasonably foreseeable risks to health and safety arising from its work activities, including risks of work-related stress and other work-related risks capable of adversely affecting mental health.

Risk assessments undertaken by {{org_field_name}} will be suitable and sufficient and will identify appropriate preventive and protective measures.

Where {{org_field_name}} employs five or more employees, the significant findings of risk assessments and any groups of employees identified as being especially at risk will be recorded as required by the Management of Health and Safety at Work Regulations 1999.

Risk assessments will be reviewed where there is reason to believe that an assessment is no longer valid or where there has been a significant change in the matters to which it relates.

Where a work-related mental health or stress risk is identified, {{org_field_name}} will take reasonably practicable measures within its control to eliminate the risk or, where elimination is not reasonably practicable, to reduce and control the risk appropriately.

Measures may include, where appropriate:

• addressing excessive or unsafe workload or working patterns;
• reviewing working hours and shift arrangements;
• improving management support or communication;
• addressing bullying, harassment, conflict or inappropriate behaviour;
• clarifying job roles and responsibilities;
• managing organisational change appropriately; and
• implementing other appropriate control measures identified through the risk assessment.

Temporary worker assignments

Before introducing or supplying a work-seeker or temporary worker to a hirer, {{org_field_name}} will obtain sufficient information from the hirer as required by the Conduct of Employment Agencies and Employment Businesses Regulations 2003.

This will include obtaining information regarding:

• any known health and safety risks associated with the position or assignment; and
• the steps that the hirer has taken to prevent or control those risks.

Known risks may include relevant risks to mental health or risks associated with work-related stress where those risks are known to the hirer.

When offering an assignment to a temporary worker, {{org_field_name}} will provide the worker with the required health and safety information obtained from the hirer. Where the hirer has stated that there are no known health and safety risks, this will also be communicated to the worker as required.

Where {{org_field_name}} becomes aware during an assignment of a material concern relating to a temporary worker’s health or safety, including a work-related mental health risk, it will take appropriate action within the scope of its responsibilities and will raise matters requiring action at the workplace with the hirer.

Nothing in this policy transfers to {{org_field_name}} health and safety responsibilities which legally rest with the hirer. Equally, the fact that a worker is under the day-to-day direction or control of a hirer does not remove the statutory duties which apply to {{org_field_name}} as an employment business.

16. Equality, Disability and Reasonable Adjustments

{{org_field_name}} will comply with the Equality Act 2010 in relation to mental health, disability and the treatment of staff, workers and other persons to whom the Act applies.

{{org_field_name}} will not unlawfully discriminate against, harass or victimise a person because of disability or another protected characteristic.

A mental health condition may amount to a disability under the Equality Act 2010 where the applicable statutory definition of disability is satisfied. A formal medical diagnosis is not necessarily determinative of whether a person is disabled for the purposes of the Act.

Where the duty to make reasonable adjustments under the Equality Act 2010 applies, {{org_field_name}} will take reasonable steps to avoid or remove the substantial disadvantage experienced by the disabled person.

Reasonable adjustments will be considered according to the individual’s circumstances and may include, where reasonable:

• adjustments to working hours, shifts or breaks;
• adjustments to duties, workload or working arrangements;
• changes to communication, supervision or management arrangements;
• time or arrangements to attend relevant appointments;
• appropriate equipment, services or other support; or
• other adjustments capable of removing or reducing the relevant disadvantage.

{{org_field_name}} will discuss potential adjustments with the individual and will not make assumptions about what a person’s mental health condition prevents them from doing.

Where a reasonable adjustment concerns a temporary worker’s placement at a hirer’s premises, {{org_field_name}} will work with the worker and, where necessary, the hirer to identify and implement appropriate arrangements, having regard to the respective legal responsibilities of the parties.

Information concerning disability, mental health or reasonable adjustments will be processed and disclosed in accordance with Section 9 of this policy.

No person will be subjected to unlawful detrimental treatment because they have raised a genuine concern about discrimination, requested a reasonable adjustment, supported another person’s complaint or exercised another right protected by equality legislation.

17. Monitoring and Continuous Improvement

The directors will monitor the implementation and effectiveness of this policy and will review whether the arrangements in place are adequate to manage relevant workplace mental health and wellbeing risks.

Monitoring may include consideration of:

• anonymised or appropriately aggregated staff feedback;
• identified health and safety risks;
• relevant incidents;
• sickness absence trends where there is a lawful basis for processing the information;
• themes arising from supervision or management processes, where it is lawful and appropriate to use the information for that purpose; and
• the effectiveness of control measures introduced following risk assessments.

Any monitoring involving identifiable information concerning an individual’s physical or mental health will be undertaken in accordance with the UK GDPR, Data Protection Act 2018 and Section 9 of this policy.

Personal health information will not be collected or analysed merely because it might be useful. {{org_field_name}} will ensure that any such processing is necessary, proportionate and supported by an appropriate lawful basis and special category processing condition.

Information used for organisational trend analysis should be anonymised or appropriately aggregated wherever the purpose can reasonably be achieved without identifying individual workers.

The directors will use relevant findings to:

• review whether additional or different control measures are necessary;
• address identified workplace risks;
• review the effectiveness of support arrangements;
• update relevant procedures where required by changes in legislation; and
• ensure that legally required arrangements remain effective.

18. Policy Review

This policy will be reviewed periodically and whenever necessary to ensure that it remains accurate and effective.

An earlier review will be undertaken where appropriate, including where:

• there is a relevant change in legislation;
• applicable statutory guidance materially changes;
• organisational arrangements or the nature of the agency’s activities change materially;
• an incident, complaint or identified risk indicates that the policy may no longer be adequate; or
• a relevant risk assessment indicates that existing arrangements require revision.

The annual internal review date shown below is an organisational review cycle and does not replace any requirement to review a risk assessment or control measure sooner where circumstances require it.

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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}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.