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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Infection Control Policy

1. Purpose

The purpose of this policy is to set out the arrangements that {{org_field_name}} has in place to reduce the risk of infection and cross-infection in connection with its activities as a temporary staffing agency / employment business in England.

{{org_field_name}} supplies workers to third-party settings and does not itself provide regulated care services unless expressly stated elsewhere in writing. Accordingly, this policy is designed to ensure that {{org_field_name}} takes reasonably practicable steps, within its role as an employment business, to protect workers, clients, service users, visitors and others who may be affected by its activities.

This policy supports compliance with applicable health and safety law and current infection prevention practice, including the Health and Safety at Work etc. Act 1974, the Control of Substances Hazardous to Health Regulations 2002, the Personal Protective Equipment at Work Regulations 1992 as amended in 2022, and relevant UK Health Security Agency (UKHSA) and Health and Safety Executive (HSE) guidance.

Where workers are supplied into healthcare, care or other higher-risk environments, {{org_field_name}} will also seek to ensure, so far as reasonably practicable, that workers are informed of relevant infection prevention requirements for the placement and that appropriate cooperation takes place between {{org_field_name}} and the hirer.

2. Scope

This policy applies to all employees, agency workers, contractors and other staff engaged by or through {{org_field_name}}, as well as visitors attending any premises controlled by {{org_field_name}}.

It applies:

a. within {{org_field_name}}’s own office or administrative premises;
b. when workers are attending induction, training or interviews arranged by {{org_field_name}}; and
c. when workers are supplied to client, hirer, healthcare, care, education or other third-party settings.

This policy covers:

• standard infection prevention precautions;
• hand hygiene;
• personal protective equipment (PPE);
• respiratory hygiene and management of acute respiratory infection symptoms;
• cleaning and decontamination within areas controlled by {{org_field_name}};
• safe handling and disposal of waste and sharps where relevant to the placement;
• reporting of exposure incidents and work-related infections;
• fitness to work, vaccination considerations and work restrictions where appropriate; and
• cooperation with client infection prevention procedures and risk controls.

Where a worker is placed with a client, the worker must comply with the infection prevention and control procedures, PPE requirements, training instructions and reporting arrangements of the client site in addition to this policy.

3. Infection Control Responsibilities

3.1 Director / Senior Responsible Person

Has overall responsibility for ensuring that {{org_field_name}} maintains suitable infection prevention arrangements, reviews this policy, and allocates sufficient resources for implementation.

3.2 Infection Control Lead

Is responsible for coordinating infection prevention measures within {{org_field_name}}, keeping this policy under review, arranging training, monitoring compliance, and acting as an internal point of contact for infection control concerns.

3.3 Managers / Coordinators / Consultants

Managers, consultants and coordinators must ensure that workers are given relevant pre-placement information, including any infection-related control measures notified by the client, and that any reported illness, exposure, outbreak concern or work restriction is escalated appropriately.

3.4 Employees and Agency Workers

All employees and agency workers must:

• follow this policy and any infection prevention procedures that apply at the client site;
• attend required training;
• use PPE correctly where required;
• maintain good hand and respiratory hygiene;
• report symptoms of potentially infectious illness, exposure incidents, needlestick or sharps injuries, and any concerns about unsafe infection control practices without delay; and
• not attend work or placements where they have been advised not to do so due to infectious risk.

3.5 Client / Hirer Responsibilities

Where workers are supplied to a client, {{org_field_name}} expects the client / hirer to provide a safe working environment, site-specific infection prevention instructions, induction, local procedures, and any equipment or controls for which the client is responsible. {{org_field_name}} will cooperate with the client to clarify responsibilities before and during the placement so far as reasonably practicable.

4. Standard Infection Prevention Measures

{{org_field_name}} adopts standard infection prevention precautions and requires all staff and agency workers to apply them consistently in accordance with risk, role and setting.

4.1 Hand Hygiene

All staff and agency workers must clean their hands effectively with soap and water or an alcohol-based hand rub where appropriate. Hand hygiene must be carried out, as applicable:

• before starting work and on entering a client area;
• before and after direct contact with a person or with equipment used in their care or treatment;
• before any clean or aseptic task;
• after exposure to blood, body fluids, respiratory secretions, waste or contaminated surfaces;
• after removing gloves or other PPE;
• before preparing, handling or eating food; and
• after using the toilet, coughing, sneezing or blowing the nose.

4.2 Respiratory Hygiene

Staff and agency workers must follow good respiratory hygiene, including covering the nose and mouth when coughing or sneezing, disposing of tissues promptly, cleaning hands after contact with respiratory secretions, and following any placement-specific requirements where acute respiratory infection symptoms are present.

4.3 Personal Protective Equipment (PPE)

PPE must be selected on the basis of risk assessment and the requirements of the placement setting. Where PPE is required, it must be suitable, properly fitted where relevant, maintained or replaced as necessary, and used in accordance with instruction and training. PPE must be donned, removed and disposed of safely to reduce contamination risks.

{{org_field_name}} will ensure, so far as its legal responsibilities extend, that workers engaged by it are provided with required PPE or that clear arrangements are agreed with the client / hirer as to who will supply it for the placement.

4.4 Cleaning and Decontamination

Any premises, workstations, training spaces or equipment under the control of {{org_field_name}} must be kept in a clean condition and cleaned appropriately. Where workers attend client premises, client cleaning and decontamination procedures must be followed. Reusable equipment must be cleaned or decontaminated in accordance with manufacturer instructions and site procedures.

4.5 Waste and Laundry

Waste must be segregated, handled and disposed of according to the procedures applicable to the premises and the nature of the waste. Clinical or infectious waste must only be handled by workers who have received appropriate instruction and only in accordance with the client site’s procedures.

4.6 Sharps Safety

Needles and other sharps must be handled only where this is part of the worker’s authorised role and training. Sharps must never be re-sheathed unless a safer system of work specifically permits this. Approved sharps containers must be used correctly and disposed of in accordance with site procedures.

5. Risk Assessment, Placement Information and Cooperation with Clients

Before supplying workers into a role where infection risks may reasonably arise, {{org_field_name}} will seek to obtain sufficient information from the client / hirer about the nature of the placement, the environment, any known infection risks, required PPE, training expectations, immunisation expectations where relevant, and local reporting arrangements.

{{org_field_name}} will use that information, so far as reasonably practicable, to inform worker suitability, pre-placement briefing, and any control measures that fall within its responsibilities.

{{org_field_name}} will cooperate with clients / hirers in relation to infection prevention and health and safety, recognising that day-to-day control of the workplace and local systems of work will usually sit with the client / hirer.

6. Managing Infectious Diseases and Exposure Risks

{{org_field_name}} recognises that agency workers may work in environments where there is an increased risk of exposure to infectious diseases. The organisation will take reasonably practicable steps, within its role, to reduce that risk and to respond appropriately when concerns arise.

6.1 Fitness to Work and Symptoms Reporting

Any employee or agency worker who has symptoms of a potentially infectious illness, has been advised by a clinician not to attend work, or believes they may pose an infection risk in the workplace must inform {{org_field_name}} immediately and must also notify the client / hirer where required by site procedure. A risk-based decision will then be made regarding attendance, redeployment, postponement of assignment, or return to work.

6.2 Placement-Specific Restrictions

Where a client site has specific infection-related restrictions, screening requirements, vaccination requirements, or exclusion periods, workers must comply with those lawful and role-relevant requirements before and during the placement.

6.3 Outbreaks and Communicable Disease Concerns

If {{org_field_name}} becomes aware of an outbreak, suspected outbreak, or significant communicable disease concern affecting its workers or a placement setting, it will promptly liaise with the client / hirer and, where appropriate, seek or follow advice from the relevant UKHSA Health Protection Team or other competent public health authority.

6.4 Notifiable Diseases

{{org_field_name}} acknowledges that statutory notification of notifiable diseases in England is generally a duty of registered medical practitioners and certain laboratories, rather than a general duty imposed on staffing agencies. Where a worker reports a diagnosis or suspected diagnosis of a notifiable disease, {{org_field_name}} will cooperate with the relevant client site, public health authorities and any lawful instructions that apply.

6.5 Vaccination and Immunisation

Vaccination may form part of infection risk reduction for certain roles or settings. {{org_field_name}} will provide workers with information about relevant immunisation expectations notified by clients or arising from occupational risk assessment, for example in relation to influenza or hepatitis B in appropriate healthcare roles. Any handling of vaccination or health information will be undertaken in accordance with data protection law.

6.6 Exposure Incidents

Any sharps injury, blood or body fluid exposure, or other significant exposure incident must be reported immediately to the client site in accordance with local procedure and to {{org_field_name}} without delay so that appropriate support, recording, escalation and follow-up can take place.

7. Confidentiality and Data Protection
{{org_field_name}} will process personal data relating to infection status, health declarations, vaccination information, exposure incidents and occupational health matters only where lawful and necessary.

Health information will be handled as confidential special category personal data and will be accessed only by those with a legitimate need to know for employment, placement safety, legal compliance, or public health reasons.

Information will be shared with clients, occupational health providers, public authorities or regulators only where there is a lawful basis to do so and only to the extent necessary.

7.1 Needlestick and Sharps Injury Response
In the event of a needlestick or sharps injury, or contamination of broken skin, eyes, nose or mouth with blood or body fluids, the worker must immediately follow the client site’s emergency procedure, obtain urgent first aid, and seek prompt medical assessment in accordance with local protocol.

The worker must notify both the client / hirer and {{org_field_name}} without delay. {{org_field_name}} will record the incident, review whether further reporting is required, and support any necessary follow-up, including occupational health referral where appropriate.

8. Incident Reporting, Recording and Monitoring

All infection-related incidents, including suspected occupational exposure, sharps injuries, body fluid contamination, failures in PPE, significant communicable disease concerns, and unsafe infection control practices, must be reported to {{org_field_name}} as soon as possible and, where applicable, to the client / hirer in accordance with local procedure.

{{org_field_name}} will maintain appropriate records of reported incidents, concerns, actions taken and lessons learned. Records will be reviewed periodically in order to identify patterns, improve controls and support compliance.

Where an incident is potentially reportable under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR), {{org_field_name}} will assess the circumstances and make or support any required report to the appropriate enforcing authority.

Suitable audits, checks or reviews may be undertaken by {{org_field_name}} to monitor compliance with this policy and to improve infection prevention arrangements over time.

9. Training & Compliance

All employees and agency workers must receive infection prevention and control training appropriate to their role. This will normally include induction training and refresher training at suitable intervals, and may include additional training for workers placed in healthcare, care or other higher-risk settings.

Workers must also complete any client-mandated induction, infection prevention instruction, PPE training or competency checks that apply to the placement.

Failure to comply with this policy, with lawful management instructions, or with infection prevention procedures in the relevant work setting may result in disciplinary action, removal from an assignment, or other appropriate action.

10. Related Policies

This policy should be read alongside, where applicable:

• Health and Safety Policy
• Risk Assessment Policy
• COSHH Policy
• Accident and Incident Reporting Policy
• Safeguarding Policy
• Sickness Absence / Fitness to Work Policy
• Data Protection and Confidentiality Policy
• PPE Policy
• Whistleblowing Policy
• Equality, Diversity and Inclusion Policy

11. Policy Review

This policy will be reviewed at least annually, and earlier where necessary to reflect changes in legislation, HSE or UKHSA guidance, operational practice, client requirements, identified incidents, or lessons learned from audits or investigations.

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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.