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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Client Property and Finance Handling Policy

1. Purpose

The purpose of this policy is to establish clear, safe, and lawful procedures for handling client property and finances by all temporary workers of {{org_field_name}}, including registered nurses and healthcare assistants working in care homes, nursing homes, and other health and social care settings. This policy ensures that temporary workers understand their responsibilities when entrusted with clients’ money, valuables, personal property, and possessions, especially in circumstances where clients may be vulnerable due to age, illness, disability, or capacity. This policy is designed to protect service users from financial abuse, loss, or misuse of property, to safeguard temporary workers from allegations of misconduct, and to assure client organisations and regulatory bodies of our commitment to good governance and accountability.

{{org_field_name}} is committed to supporting safe, lawful and transparent practice when its temporary workers are supplied to client organisations. This policy is informed by the Employment Agencies Act 1973, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, the Agency Workers Regulations 2010, the Mental Capacity Act 2005, the Care Act 2014, the Theft Act 1968, the Fraud Act 2006, the Safeguarding Vulnerable Groups Act 2006, the UK GDPR and the Data Protection Act 2018. Where the client organisation is a regulated care provider, temporary workers must also follow the client’s CQC-related policies, local safeguarding procedures and site-specific instructions.

{{org_field_name}} does not hold, manage, administer or control service-user funds, benefits, bank accounts, appointeeships, deputyships, lasting powers of attorney or personal property as part of its business. Temporary workers must not take on any financial management role for a client or service user. Any assistance with money, valuables or property must be incidental to the assignment, expressly authorised by the client organisation, documented in the client’s records, and carried out in accordance with this policy and the client organisation’s procedures.

2. Scope

This policy applies to:

• All temporary workers engaged by {{org_field_name}} under zero-hours or casual contracts, including registered nurses, healthcare assistants, and support staff
• All office and management staff responsible for placing workers or dealing with incidents involving client property or finances
• All situations where {{org_field_name}}’s workers handle, manage, or assist with client property, money, or valuables while on assignment
• All temporary assignments where workers are supplied to care homes, nursing homes, hospitals, supported living services, domiciliary care providers, local authority services or other health and social care settings, whether or not the client organisation is CQC-registered.
• Any incident, allegation, concern or complaint involving client money, valuables, possessions, financial documents, payment cards, passwords, PINs, benefits, online banking, personal devices, or suspected financial abuse.

Temporary workers must also follow any specific policies or procedures relating to property and finance management issued by the client organisation.

This policy does not authorise any temporary worker to provide regulated care on behalf of {{org_field_name}}, to manage a client’s finances, or to make independent decisions about a client’s property or money. Where the client organisation is the regulated provider, responsibility for the client’s care plan, financial procedures, mental capacity assessment process, safeguarding referrals and CQC-regulated governance remains with the client organisation.

3. Related Policies

• Safeguarding Adults and Children Policy
• Whistleblowing Policy
• Incident Reporting and Management Policy
• Code of Conduct for Temporary Workers
• Record Keeping and Confidentiality Policy
• Complaints Policy
• Disciplinary Policy
• Right to Work and Recruitment Compliance Policy
• Data Protection, Confidentiality and Records Management Policy
• Gifts, Hospitality and Professional Boundaries Policy
• Allegations Against Staff and External Referrals Policy
• Mental Capacity and Consent Policy
• Anti-Bribery, Fraud and Financial Crime Policy
• Agency Worker Handbook / Terms of Engagement
• Client Assignment and Handover Procedure

4. Principles of Client Property and Finance Handling

All temporary workers must:

• Protect the client’s rights, choices, dignity, and independence
• Respect the client’s property and finances as if they were their own
• Handle property and finances transparently and honestly, following written procedures at all times
• Record all transactions, property handling, or money movements accurately and contemporaneously
• Avoid any situation where they are left solely responsible for a client’s finances without appropriate authorisation and documentation
• Act only within the temporary worker’s assignment role, competence, training and the client organisation’s written instructions
• Never use their own personal bank account, payment card, phone, email address, online account or loyalty account for any client transaction
• Never ask for, record, photograph, store or use a client’s PIN, password, online banking details or security information
• Never borrow from, lend to, sell to, buy from, or enter into private financial arrangements with a client, service user, resident or their family
• Escalate immediately if a client asks the worker to do something outside the worker’s role or outside the client organisation’s procedure
• Never accept gifts, loans, or gratuities from clients or their families without prior consent and in line with the Gifts and Hospitality Policy (if applicable)
• Immediately report any suspicion, incident, or allegation of theft, fraud, financial abuse, or misuse of property following the Safeguarding and Whistleblowing Policies

5. Definitions

Client property includes, but is not limited to:

• Cash
• Debit or credit cards
• Chequebooks or bank documents
• Jewellery, watches, and other valuables
• Mobility aids
• Clothing and personal items
• Medication, medical devices, and health-related equipment
• Mobile phones, tablets, laptops and other personal electronic devices
• Keys, fobs, access cards and security codes
• Benefit letters, pension documents and financial correspondence
• Passwords, PINs, online banking credentials and digital wallet information
• Loyalty cards, vouchers, gift cards and prepaid cards
• Legal documents, including wills, powers of attorney, deputyship documents and appointeeship documents

Client finances refer to:

• Money belonging to the client for personal use
• Money entrusted to the worker for essential purchases
• Money collected on behalf of the client for agreed activities, such as shopping or outings
• Cash withdrawals or cash held for day-to-day personal spending
• Payments made in shops, online, by telephone or by card machine
• Benefit, pension or allowance money held by or for the client
• Any financial transaction requested by a client, family member, representative or client organisation

Financial abuse includes actual or attempted theft, fraud, scamming, coercion, misuse of benefits, misuse of property, misuse of bank cards, inappropriate pressure to give gifts or money, unauthorised borrowing, unexplained loss of money or possessions, and any situation where a person is prevented from controlling or accessing their own money or property.

6. Handling Client Property Safely

Temporary workers must:

• Keep all client property secure at all times
• Only handle client property with the client’s valid consent, or where the client lacks capacity for the specific decision, under a documented best-interests decision made in accordance with the Mental Capacity Act 2005 and the client organisation’s procedure. Temporary workers must not make independent mental capacity assessments or best-interests decisions about property or finances unless this is expressly within their professional role, competence and the client organisation’s written procedure.
• Respect the client’s right to access and use their own property without unnecessary restriction
• Record property handling in the client’s records, the property register, or any documentation required by the client organisation
• Immediately report any damage, loss, or discrepancy relating to client property
• Wherever possible, ensure that the handling, moving, checking or disposal of client property is witnessed by a member of the client organisation’s permanent staff
• Check and record the condition of property where relevant, especially where the item is valuable, fragile, damaged, missing, or disputed
• Never remove client property from the premises unless this is expressly authorised by the client organisation, documented in advance, and necessary for the client’s care or welfare
• Never dispose of, give away, donate, sell, transfer or destroy client property

Where a client may lack capacity in relation to property or financial matters, the temporary worker must immediately involve the senior person on duty at the client organisation. The worker must follow the client organisation’s Mental Capacity Act procedure and must not rely solely on verbal instructions from relatives, friends or visitors. Instructions from an attorney, deputy, appointee, advocate or other representative must be verified by the client organisation before the worker acts on them. Temporary workers must not store client property at their own homes, vehicles, lockers, bags, staff accommodation or any other unauthorised location.

7. Handling Client Finances

Temporary workers must avoid handling client money wherever possible. A temporary worker may only handle client money where all of the following apply:

• The handling of money is permitted by the client organisation’s written policy or care plan
• The task is necessary, proportionate and within the worker’s assignment role
• The client has capacity and gives valid consent, or the task is covered by a documented best-interests decision made through the client organisation’s procedure
• The worker has received appropriate induction or instruction from the client organisation before carrying out the task
• The transaction can be fully evidenced by receipts, records and, wherever possible, a second authorised person’s countersignature
• The worker is not placed in sole control of client funds, cards, passwords, PINs or accounts

All financial handling must be:

• Recorded immediately in the relevant finance records, such as petty cash records, financial transaction sheets, or receipts book
• Supported by evidence such as receipts, signatures, and bank statements where applicable
• Signed by the temporary worker and countersigned by a second authorised person whenever possible
• Made in cash or by authorised payment methods only; personal credit cards, accounts, or devices must never be used for client transactions

Unless the client organisation’s written procedure states otherwise, temporary workers must not handle cash or purchases above £20 in a single transaction or £50 in total during one shift. Any higher amount must be authorised in advance by the senior person on duty at the client organisation and reported to {{org_field_name}} as soon as practicable. Where the client organisation sets a lower limit, the lower limit must be followed.

Temporary workers must not:

• Withdraw cash from an ATM, bank, post office or cashback facility on behalf of a client
• Use, retain, photograph, copy, write down or ask for a client’s PIN, password, memorable information or online banking details
• Use contactless payment on behalf of a client unless the client organisation’s written policy expressly permits this and a receipt is obtained
• Conduct online shopping, online banking, telephone banking, money transfers, cryptocurrency transactions, betting, gaming or subscription purchases on behalf of a client
• Sign financial documents, contracts, receipts, benefit forms, banking documents or legal documents on behalf of a client
• Witness a will, power of attorney, deputyship document, financial agreement, gift transfer or any legal document for a client
• Accept appointment as an attorney, deputy, appointee, executor, beneficiary, trustee or nominee for a client
• Keep change, vouchers, loyalty points, cashback, refunds or reward points from a client transaction
• Mix client money with their own money or with another client’s money

8. Gifts, Loans, and Personal Benefit

Temporary workers must:

• Never accept gifts, loans, or money from clients or their families that may be seen as compromising professional boundaries
• Only accept a low-value token of appreciation, such as chocolates or biscuits, where refusal would cause unnecessary offence, where acceptance is permitted by the client organisation’s policy and {{org_field_name}}’s Gifts, Hospitality and Professional Boundaries Policy, and where the gift is reported and recorded. Cash, vouchers, gift cards, loans, personal discounts, tips, hospitality, personal services, favours and offers of inheritance must never be accepted.
• Never solicit gifts or personal favours from clients or their families

Any offer of a gift, loan, inheritance, personal benefit or private arrangement must be reported to {{org_field_name}} and the senior person on duty at the client organisation before acceptance. Where the offer may indicate undue influence, coercion, financial abuse, confusion, impaired capacity or boundary concerns, it must be treated as a safeguarding concern.

9. Safeguarding and Financial Abuse

Financial abuse includes:

• Theft
• Fraud
• Misuse or misappropriation of property, possessions, or benefits
• Undue pressure, duress, or threats related to finances
• Exploitation
• Scams, coercion or undue influence
• Misuse of bank cards, contactless payments, online banking, benefits or pensions
• Pressure to give gifts, loans, tips, inheritance or personal benefit
• Unexplained loss of cash, jewellery, devices, documents, clothing or possessions
• A person being prevented from accessing or controlling their own money or property
• Any concern that a worker, family member, visitor, attorney, deputy, appointee, professional or other person is exploiting the client financially

Temporary workers are required by this policy, their assignment terms, safeguarding expectations and any professional code that applies to them to:

• Report any suspicion, allegation, incident or disclosure of financial abuse, theft, fraud, coercion, neglect or unexplained loss immediately to the senior person on duty at the client organisation and to {{org_field_name}}
• Take urgent action to protect the client from immediate risk, including calling emergency services where there is immediate danger or a crime in progress
• Follow the client organisation’s safeguarding procedure, including escalation to the local authority safeguarding adults team where required
• Preserve evidence, including receipts, records, CCTV references, damaged property, transaction records and written notes
• Record concerns factually, without speculation, blame or personal opinion
• Cooperate fully with investigations by the client organisation, local authority safeguarding team, police, DBS, professional regulator or {{org_field_name}}

Where an allegation or finding indicates that a temporary worker may have harmed, exploited, abused, neglected or posed a risk of harm to a vulnerable person, {{org_field_name}} will consider whether a referral must or may be made to the Disclosure and Barring Service, the police, the relevant professional regulator, the client organisation and/or the local authority safeguarding team. This applies even where the worker resigns, is removed from assignment, or the client organisation is also making a referral.

10. Record Keeping and Documentation

Temporary workers must:

• Accurately record all interactions involving client property or money
• Retain receipts, invoices, and evidence of all financial transactions
• Use the client’s designated financial recording systems where applicable
• Document any handovers or transfers of property, including signatures from all parties involved
• Record incidents or concerns in the Incident Reporting system and notify the director immediately
• Record the date, time, location, amount, item description, purpose, authorisation, names of people present, receipts obtained, money received, money spent, change returned and the worker’s signature
• Ensure records are countersigned by the client, where appropriate, and by a second authorised person wherever possible
• Never amend, backdate, destroy or remove client financial records
• Report missing receipts, discrepancies or errors immediately to the senior person on duty and to {{org_field_name}}
• Keep records factual and avoid personal opinions, assumptions or accusations
• Ensure any copies, photographs or incident records containing personal or financial information are transferred securely to {{org_field_name}} or the client organisation and are not retained on personal devices

10.1 Data Protection and Confidentiality

Records relating to client property, money, valuables, financial arrangements, incidents, allegations, capacity, safeguarding concerns or health and care needs may contain personal data, special category data and/or criminal offence data. {{org_field_name}} and its temporary workers must handle such information in accordance with the UK GDPR, the Data Protection Act 2018, the client organisation’s confidentiality procedures and {{org_field_name}}’s Data Protection, Confidentiality and Records Management Policy.

Temporary workers must not photograph, copy, download, retain or share client financial documents, bank cards, receipts, care records, property records or safeguarding information unless this is expressly required for reporting purposes and authorised by the client organisation or {{org_field_name}}. Any such information must be sent using approved secure channels only and must be deleted from any personal device immediately after secure transfer, unless instructed otherwise by {{org_field_name}} for lawful investigation purposes.

Information must only be shared on a need-to-know basis with appropriate people or organisations, such as the client organisation, {{org_field_name}}, safeguarding authorities, the police, DBS, professional regulators or insurers, where there is a lawful basis to do so.

11. Training

{{org_field_name}} will:

• Provide all temporary workers with training on handling client property and finances as part of their induction
• Include financial safeguarding, property protection, and reporting requirements in safeguarding training
• Provide ongoing training and updates in response to changes in legislation, best practice, or after any incident or investigation
• Ensure workers understand that they must not manage client finances, hold client bank cards, use client PINs, conduct banking, or enter into private financial arrangements with clients
• Include practical scenarios on shopping, receipts, missing money, gifts, suspected theft, coercion, online banking requests and family requests
• Provide workers with clear escalation instructions for reporting concerns both to the client organisation and to {{org_field_name}}
• Record completion of relevant training and refresher updates

Temporary workers must not handle client property or money unless they have received appropriate training from {{org_field_name}} and any site-specific instruction required by the client organisation. Where no such instruction has been provided, the worker must decline the task and escalate to the senior person on duty.

12. The Director’s / Compliance Lead’s Responsibilities

As {{org_field_name}} does not provide regulated care and does not require CQC registration, responsibility for implementing this policy rests with the director or nominated compliance lead. The director or nominated compliance lead will:

• Maintain overall responsibility for the effective implementation of this policy
• Provide appropriate training and guidance to temporary workers and office staff
• Monitor incidents, complaints, and audits involving client property or finances
• Review all reports of financial abuse or suspected misconduct and take prompt action
• Liaise with client organisations, safeguarding teams, and regulatory bodies as necessary
• Remove workers from assignments where there is evidence of breach or serious concern
• Embed safeguarding of property and finances into the organisational culture through supervision and regular reviews
• Ensure this policy reflects {{org_field_name}}’s role as an employment business supplying temporary workers, not as the regulated care provider
• Ensure workers are issued appropriate terms, assignment information and instructions before assignments, in line with applicable agency rules
• Maintain records of incidents, allegations, complaints, investigations, worker removals and external referrals
• Consider whether any allegation requires notification to the police, DBS, professional regulator, local authority safeguarding team, client organisation or insurer
• Ensure workers are not re-supplied to assignments where there is unresolved risk relating to financial abuse, dishonesty, theft, fraud or unsafe practice
• Review patterns and trends in incidents involving particular workers, clients, locations or assignment types

13. Working with Client Organisations

{{org_field_name}} will:

• Ensure temporary workers are informed of client-specific procedures for handling property and finances during assignment inductions
• Collaborate with clients to investigate any incidents relating to client property or finances
• Support client audits and safeguarding investigations as required
• Communicate this policy to all relevant clients and staff to maintain transparency and accountability
• Confirm, where reasonably practicable, whether the client organisation has site-specific procedures for handling service-user money, property, valuables, gifts and financial abuse concerns
• Make clear to clients that temporary workers must not be asked to manage client finances, hold bank cards/PINs, carry out banking, or act outside their assignment role
• Require clients to provide appropriate site induction where workers may come into contact with client property or money
• Require clients to notify {{org_field_name}} promptly of any allegation, complaint, discrepancy, safeguarding concern or police matter involving a temporary worker
• Support appropriate information sharing where necessary for safeguarding, investigation, regulatory reporting, legal claims or worker management

13.1 Employment Business Compliance

{{org_field_name}} will operate in accordance with the Employment Agencies Act 1973 and the Conduct of Employment Agencies and Employment Businesses Regulations 2003 when supplying temporary workers to hirers. Workers must be provided with appropriate terms and assignment information before work begins, and the agency must maintain suitable records of work-seekers, hirers, assignments and relevant checks.

{{org_field_name}} will not charge work-seekers fees for finding or seeking to find them work, except where a lawful statutory exception applies. For healthcare and care staffing assignments, no such fee must be charged to workers for work-finding services.

Where applicable, {{org_field_name}} will provide agency workers with a Key Information Document before agreeing terms, setting out key pay, deduction and engagement information. This is separate from this property and finance policy but forms part of the agency’s wider legal compliance framework.

14. Disciplinary Action

Any breach of this policy may result in:

• Immediate removal from assignment
• Suspension from further assignments while concerns are investigated
• Disciplinary or contractual investigation by {{org_field_name}}
• Notification to the client organisation
• Referral to external bodies where appropriate, including the police, local authority safeguarding team, Disclosure and Barring Service, professional regulators such as the NMC, and insurers
• Termination of employment, worker agreement or contractual relationship where warranted
• Recovery action where lawful and appropriate, for example where property is deliberately damaged, stolen or misappropriated

{{org_field_name}} will not ignore or close a safeguarding, financial abuse, theft, fraud or dishonesty concern solely because a worker resigns, stops accepting shifts, is removed by a client, or disputes the allegation.

15. Continuous Improvement and Monitoring

The director will:

• Review this policy annually or sooner if there are changes in legislation, statutory guidance, safeguarding frameworks, DBS guidance, agency worker rules, data protection requirements, client contractual requirements or relevant best practice.
• Regularly audit records relating to property and finance handling
• Respond to feedback from clients and workers to improve procedures
• Report significant learning points to clients and integrate them into training and supervision
• Audit a sample of incidents, complaints and finance/property records to identify recurring risks
• Review whether any clients are asking temporary workers to undertake inappropriate finance-related tasks
• Review whether workers are receiving adequate client-site induction before being asked to handle property or money
• Record learning from incidents and update training, client communications and worker guidance accordingly

16. Policy Review

This policy will be reviewed at least annually by the director or nominated compliance lead of {{org_field_name}}, or earlier where required due to legal, regulatory, safeguarding, data protection, DBS, client contractual or operational changes. Updates will be communicated to relevant office staff, temporary workers and, where appropriate, client organisations.

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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.