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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Managing Work-related Violence, Aggression and Abuse Policy

1. Purpose

This policy establishes the arrangements used by {{org_field_name}} to prevent and manage work-related violence, aggression, abuse, threats, harassment and related safety risks affecting temporary workers supplied to client organisations.

{{org_field_name}} operates as an employment business supplying temporary workers to clients. It does not itself provide or manage regulated care and is not registered with the Care Quality Commission solely by reason of supplying staff. Client organisations remain responsible for the management and delivery of their services, the safety of their premises, service-user risk assessments, care planning and the day-to-day direction and supervision of temporary workers. This does not remove or reduce the health and safety, employment, recruitment, safeguarding or other legal duties owed by {{org_field_name}}.

The purpose of this policy is to:

• prevent violence, aggression and abuse so far as is reasonably practicable;
• ensure that placement-specific risks are identified and communicated before a worker is supplied;
• establish clear responsibilities between {{org_field_name}}, the client organisation and the temporary worker;
• ensure that workers receive suitable information, instruction, training and support;
• promote early intervention, trauma-informed communication and safe de-escalation;
• ensure that any physical intervention is lawful, necessary, proportionate, least restrictive and undertaken only by appropriately trained and authorised workers;
• ensure that incidents, injuries, near misses and concerns are reported, investigated and used to improve risk controls; and
• protect the dignity, equality, human rights, safety and wellbeing of service users, workers and other people.

This policy supports compliance with the Health and Safety at Work etc. Act 1974, the Management of Health and Safety at Work Regulations 1999, the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013, the Employment Agencies Act 1973, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, the Equality Act 2010, the Worker Protection (Amendment of Equality Act 2010) Act 2023, the Mental Capacity Act 2005, the Care Act 2014, the Human Rights Act 1998 and applicable data-protection legislation.

2. Scope

This policy applies to:

• all employees, agency workers and other individuals supplied or assigned by {{org_field_name}}, regardless of the description of their contract or assignment;
• registered nurses, healthcare assistants, support workers, carers and any other temporary personnel supplied to client organisations;
• directors, managers, recruitment personnel, booking or allocation staff and compliance staff;
• incidents involving service users, patients, residents, relatives, visitors, members of the public, client employees, contractors or other agency workers;
• violence or aggression occurring at a client’s premises, during work-related travel, during community visits, while lone working, during telephone or video contact, through email or messaging systems, or through social media where there is a connection with work; and
• actual incidents, attempted incidents, threats, harassment, sexual harassment, hate-related abuse and near misses.

This policy applies throughout an assignment, including recruitment and placement preparation, arrival and induction, the performance of duties, breaks taken at the workplace, work-related travel, incident reporting and post-incident support.

3. Legal and regulatory framework

This policy must be read and applied in accordance with the following legislation and guidance, where relevant:

• the Health and Safety at Work etc. Act 1974;
• the Management of Health and Safety at Work Regulations 1999;
• the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013;
• the Safety Representatives and Safety Committees Regulations 1977 and the Health and Safety (Consultation with Employees) Regulations 1996;
• the Employment Agencies Act 1973;
• the Conduct of Employment Agencies and Employment Businesses Regulations 2003, as amended;
• the Agency Workers Regulations 2010;
• the Equality Act 2010;
• the Worker Protection (Amendment of Equality Act 2010) Act 2023;
• the Mental Capacity Act 2005 and its Code of Practice;
• the Human Rights Act 1998;
• the Care Act 2014;
• the Data Protection Act 2018 and UK GDPR;
• the Safeguarding Vulnerable Groups Act 2006;
• the Police Act 1997; and
• relevant Health and Safety Executive, government, professional and sector-specific guidance.

Where workers are supplied to a CQC-registered provider, the worker must follow the client’s lawful policies, care plans, risk assessments and instructions that are relevant to the assignment. Reference to a client’s CQC responsibilities does not mean that {{org_field_name}} is itself carrying on a regulated activity.

4. Related Policies

• Health and Safety Policy
• Incident and Accident Reporting Policy
• Safeguarding Adults and Children Policy
• Whistleblowing Policy
• Supervision and Appraisal Policy
• Personal Care and Dignity Policy
• Code of Conduct

• Equality, Diversity and Inclusion Policy
• Anti-harassment and Sexual Harassment Policy
• Lone Working Policy
• Mental Capacity and Consent Policy or guidance
• Restrictive Practice and Physical Intervention Policy, where applicable
• Recruitment and Selection Policy
• Fitness to Work Policy
• Data Protection, Confidentiality and Records Management Policy
• Complaints Policy
• Duty of Candour and Client Notification Procedure, where contractually applicable
• RIDDOR and Statutory Reporting Procedure
• Emergency and Business Continuity Procedure
• Grievance Policy
• Disciplinary Policy
• Worker Welfare and Wellbeing Policy

5. Policy Statement

{{org_field_name}} recognises work-related violence, aggression, threats, abuse and harassment as foreseeable health and safety risks that must be prevented or reduced so far as is reasonably practicable.

{{org_field_name}} will work with client organisations to obtain and exchange sufficient information about the assignment, workplace, duties, service-user risks, control measures, required competence and emergency arrangements before supplying a worker. The client organisation remains responsible for risks arising from premises, systems and activities under its control and for the day-to-day direction and supervision of supplied workers. {{org_field_name}} remains responsible for the duties that apply to it as an employment business and, where applicable, as the worker’s employer.

{{org_field_name}} does not accept violence, abuse, harassment or victimisation as an unavoidable part of healthcare or support work. However, incidents will be assessed in context and managed in a proportionate, non-discriminatory and person-centred way, particularly where behaviour may be associated with dementia, delirium, mental illness, brain injury, learning disability, autism, communication needs, pain, fear, trauma or unmet clinical or personal needs.

No worker will be instructed or pressured to remain in a situation presenting a serious and imminent danger that cannot be adequately controlled. Workers may withdraw to a place of safety and obtain assistance in accordance with this policy.

The Director is accountable for implementing this policy. Day-to-day functions may be delegated to competent staff, but overall accountability remains with the Director.

6. Definitions

For the purposes of this policy:

• Work-related violence means any incident in which a person is abused, threatened or assaulted in circumstances relating to their work. It includes physical and psychological harm.
• Physical violence includes hitting, kicking, biting, scratching, spitting, pushing, grabbing, hair pulling, use of an object as a weapon, attempted assault and unwanted physical contact.
• Aggression includes threatening, intimidating, hostile or destructive conduct, whether verbal, non-verbal, written, electronic or physical.
• Abuse includes shouting, swearing, insults, humiliating comments, discriminatory language, sexual comments, stalking, threats, malicious allegations and online abuse.
• Harassment has the meaning given by the Equality Act 2010 and includes unwanted conduct related to a protected characteristic that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment.
• Sexual harassment means unwanted conduct of a sexual nature that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment.
• Third-party harassment means harassment carried out by someone who is not employed by {{org_field_name}}, including a service user, patient, resident, relative, visitor, client employee or contractor.
• Near miss means an event that did not result in injury or harm but had the potential to do so.
• Physical intervention means direct physical contact intended to prevent, restrict or manage a person’s movement.
• Restraint, for the purposes of the Mental Capacity Act 2005, includes the use or threat of force where a person resists, or any restriction of movement, whether or not the person resists.
• Restrictive practice means any act that restricts a person’s movement, liberty, choice or freedom to act independently.
• Serious and imminent danger means a situation presenting an immediate or developing risk of serious harm that cannot be adequately controlled by the worker using the information, equipment, staffing and training available.
• Client or hirer means the organisation to which a worker is supplied and under whose supervision and direction the worker performs the assignment.

7. Responsibilities

Director

The Director will ensure that:

• suitable and sufficient arrangements are maintained to identify, assess and control risks of work-related violence and aggression;
• competent persons are appointed to assist with health and safety compliance;
• the agency obtains relevant health and safety information from the client before introducing or supplying a worker;
• the suitability of the worker, including relevant experience, qualifications, training, health considerations and legal or professional requirements, is checked against the assignment;
• workers receive sufficient information about known risks, control measures, required competencies and emergency arrangements before accepting an assignment;
• workers are not knowingly placed in assignments for which they lack the required training, competence or support;
• incidents and near misses are recorded, investigated and reviewed;
• responsibility for any RIDDOR report is established promptly with the client and the appropriate report is made by the legally responsible person;
• workers receive appropriate medical, psychological and managerial support following an incident;
• serious concerns are escalated to the client’s senior management, commissioners, safeguarding bodies, police, HSE or another competent authority where legally required or justified;
• workers and, where applicable, their representatives are consulted about violence-related risks and control measures;
• personal information relating to incidents is handled lawfully and securely; and
• unsafe placements are suspended or terminated where adequate controls cannot be demonstrated.

Recruitment, compliance and booking staff

Recruitment, compliance and booking staff must:

• obtain sufficient details from the client about the proposed role, location, duties, working hours, supervision, required training and foreseeable health and safety risks;
• identify assignments involving lone working, community visits, known violence risks, restrictive interventions or specialist behavioural support;
• verify that the worker meets the client’s lawful and proportionate requirements;
• provide the worker with relevant information before the assignment begins;
• record material information received from the client and supplied to the worker;
• escalate incomplete, inconsistent or concerning information before confirming a placement; and
• avoid placing a worker where the client has not supplied sufficient information to assess suitability and safety.

Client or hirer

Before and during an assignment, {{org_field_name}} will require the client, so far as relevant to matters under its control, to:

• provide accurate information about the role, workplace, duties and foreseeable risks;
• provide relevant extracts from workplace and individual risk assessments, behaviour support plans and emergency procedures, subject to lawful confidentiality controls;
• disclose any known history of violence, aggression, harassment, weapons, absconding, self-harm or other significant risks where the information is necessary to protect the worker or others;
• identify required training, competencies, staffing levels and supervision arrangements;
• provide a safe workplace, suitable equipment, communication facilities and access to assistance;
• provide an effective local induction before the worker undertakes duties;
• ensure that the temporary worker is not asked to undertake tasks outside their competence or agreed assignment;
• review and communicate material changes in risk;
• respond promptly to incidents involving temporary workers;
• preserve relevant evidence, including CCTV where appropriate and lawful;
• notify {{org_field_name}} of incidents and investigation outcomes;
• establish who is responsible for any report to HSE, safeguarding bodies, police or other authorities; and
• take action where a service user, relative, visitor or member of staff subjects a temporary worker to violence, harassment or abuse.

Temporary workers

Temporary workers must:

• take reasonable care of their own health and safety and that of others who may be affected by their acts or omissions;
• co-operate with {{org_field_name}} and the client on health and safety matters;
• complete required training and act only within their competence;
• attend and participate in the client’s local induction;
• read and follow relevant risk assessments, care plans, behaviour support plans and emergency procedures;
• use de-escalation and other preventative measures where safe and appropriate;
• carry and use any required alarm, communication device or protective equipment correctly;
• report missing information, inadequate staffing, unsafe instructions or changes in risk immediately;
• summon assistance and withdraw to a place of safety where necessary;
• not use punitive, retaliatory, unauthorised or excessive force;
• preserve evidence following a serious incident where safe to do so;
• obtain medical attention where required;
• report incidents, threats and near misses to both the client and {{org_field_name}}; and
• co-operate with lawful investigations while maintaining confidentiality.

8. Risk assessment and placement suitability

Before supplying a worker, {{org_field_name}} will make reasonable enquiries of the client to identify foreseeable risks relevant to the assignment. The information sought must be proportionate to the role and may include:

• the nature and location of the work;
• the characteristics of the service or patient group;
• known patterns of violence, aggression, harassment or abuse;
• recent serious incidents or material changes in risk;
• lone-working or community-working arrangements;
• expected staffing levels and access to immediate assistance;
• environmental risks, including access and exit arrangements;
• alarm, communication and emergency systems;
• required clinical, behavioural-support or physical-intervention training;
• the availability of suitable equipment;
• supervision and escalation arrangements;
• relevant individual risk assessments and behaviour support plans; and
• any health surveillance or occupational-health requirements arising from the work.

{{org_field_name}} will assess whether the worker’s qualifications, experience, training, competence, health and any reasonable adjustments are compatible with the assignment.

A placement must not be confirmed where:

• material safety information is unavailable;
• the worker does not have required training or competence;
• foreseeable risks cannot be adequately controlled;
• staffing or supervision is materially inadequate;
• the client expects the worker to perform unauthorised restraint; or
• the placement would expose the worker or others to an unacceptable risk.

Risk assessment is a continuing process. The assessment must be reviewed following:

• a violent or aggressive incident;
• a near miss;
• a change in a service user’s needs or presentation;
• a change in duties, working hours, location, staffing or supervision;
• new information from a worker or client;
• a safeguarding concern; or
• evidence that existing controls are ineffective.

Significant findings and agreed control measures must be recorded. Workers must be consulted on the effectiveness of the controls that affect them.

9. Information sharing before placement

{{org_field_name}} will obtain from the client such information as is reasonably necessary to determine whether it is suitable to supply a particular worker and to protect the worker’s health and safety.

Relevant risk information must be communicated to the worker before the assignment begins, unless genuinely unforeseen circumstances make this impossible. In such circumstances, the information must be provided at the earliest opportunity and before the worker undertakes the affected activity.

Information about service users must be limited to what is necessary and proportionate for safety, suitability, care and safeguarding purposes. It must be shared securely and only with people who need it for their role.

Where the client refuses or fails to provide information that is material to worker safety or suitability, {{org_field_name}} may decline, delay, suspend or terminate the placement.

10. Preventing violence and aggression

Prevention must be based on the hierarchy of control and must not rely solely on the individual worker’s communication skills. Where risks cannot be eliminated, {{org_field_name}} and the client must consider suitable combinations of environmental, organisational, staffing, procedural, technological and training controls.

Control measures may include:

• appropriate staffing levels and skill mix;
• avoiding lone working where the assessment identifies an unacceptable risk;
• effective handovers;
• individual behaviour support plans;
• access to alarms, radios, telephones or other communication systems;
• safe room layouts and unobstructed exit routes;
• secure reception, access-control or visitor arrangements;
• safe systems for community visits;
• paired working or additional supervision;
• clinically appropriate responses to pain, infection, delirium, distress or unmet need;
• culturally appropriate and accessible communication;
• reasonable adjustments for disability;
• separation from known aggressors where necessary;
• controls relating to weapons or prohibited items;
• post-incident review and revised care planning; and
• suspension of an activity or placement until adequate controls are in place.

Workers should:

• introduce themselves and explain what they intend to do;
• communicate calmly, respectfully and without unnecessary confrontation;
• recognise early signs of fear, distress, agitation or escalation;
• identify known triggers and preferred calming strategies;
• respect personal space, privacy, dignity, communication needs and cultural differences;
• offer realistic choices where possible;
• avoid crowding, sudden movements, shouting, humiliating language or avoidable restrictions;
• seek assistance at an early stage; and
• discontinue or postpone a non-urgent intervention where continuing would create an unnecessary risk.

11. Lone working and community assignments

A worker must not be placed in a lone-working assignment involving a foreseeable risk of violence unless a suitable assessment has been completed and effective controls are in place.

Controls may include:

• pre-visit risk information;
• scheduled contact or check-in arrangements;
• a reliable means of communication;
• a clear escalation and missed-contact procedure;
• paired visits;
• safe arrival and departure arrangements;
• code words or duress arrangements;
• location information, where lawful and proportionate;
• authority to leave or cancel a visit where conditions are unsafe; and
• prompt access to police or emergency assistance.

Workers must not enter or remain at a location where they reasonably believe that there is a serious and imminent risk of violence that cannot be adequately controlled. They must move to safety, contact the client and {{org_field_name}}, and call the emergency services where necessary.

12. De-escalation and immediate safety response

De-escalation must be used only where it is safe, suitable and within the worker’s competence. A worker is not expected to continue attempting de-escalation where doing so would expose them or another person to an immediate risk of harm.

Where safe and appropriate, workers should:

• remain calm and use a non-threatening posture;
• listen without unnecessary interruption;
• acknowledge distress without agreeing to threats or abusive demands;
• use clear, simple and respectful language;
• allow additional processing time;
• reduce noise, crowding and unnecessary stimulation;
• offer realistic choices;
• avoid arguing, issuing unnecessary ultimatums or making provocative statements;
• maintain a safe distance and remain aware of exits;
• avoid standing between the person and their exit unless required by an immediate safety need;
• remove potential weapons where this can be done safely;
• request assistance early; and
• follow the person’s behaviour support plan and the client’s emergency procedures.

Workers must call 999 where there is an immediate threat to life, a weapon, a serious assault, a hostage situation, a fire, a medical emergency or another situation requiring an emergency response.

A worker must not put themselves at unnecessary risk to protect property or to prevent a person from leaving, unless there is a lawful and immediate reason to intervene and the worker is trained and authorised to do so.

13. Physical intervention, restraint and restrictive practice

Physical intervention must never be used as punishment, retaliation, for staff convenience, to secure compliance with an unreasonable instruction, or solely because a person is verbally abusive.

A client policy, care plan or instruction does not by itself provide legal authority to use restraint. Any physical intervention must have a lawful basis and must be:

• necessary to prevent an immediate or sufficiently serious risk of harm;
• proportionate to the likelihood and seriousness of that harm;
• the least restrictive effective response;
• used for the shortest possible period;
• consistent with the person’s rights, dignity and individual needs;
• within the worker’s current training and competence; and
• consistent with the client’s lawful policy and the agreed assignment.

Where the person lacks capacity in relation to the relevant matter, any restraint proposed under the Mental Capacity Act 2005 must satisfy the requirements of section 6 of that Act. The worker must reasonably believe that the person lacks the relevant capacity, that restraint is necessary to prevent harm to that person, and that the restraint is proportionate to the likelihood and seriousness of the harm.

The Mental Capacity Act must not be used to justify restraint solely to protect another person. Emergency action to protect another person must have a separate lawful basis and must still be necessary and proportionate.

Workers must not undertake planned restraint, seclusion, mechanical restraint or specialist restrictive intervention unless:

• the intervention is lawful and forms part of an authorised, current and individualised plan;
• the client has confirmed the intervention is required for the assignment;
• the worker has completed current, role-appropriate and recognised training;
• the worker has been assessed as competent;
• adequate staffing, supervision and emergency arrangements are available; and
• {{org_field_name}} has agreed that the activity falls within the assignment.

Following any physical intervention, the worker must:

• release or reduce the intervention as soon as the risk permits;
• monitor the person’s physical and emotional condition;
• obtain urgent medical assistance where there is injury, breathing difficulty, loss of consciousness, significant distress or any other clinical concern;
• inform the client’s responsible manager immediately;
• report the incident to {{org_field_name}} without delay;
• complete the client’s required contemporaneous records;
• record the reason, duration, type of intervention, persons involved, injuries, observations and outcome;
• preserve relevant evidence;
• raise a safeguarding concern where indicated; and
• participate in a post-incident review and debrief.

Any use of force outside the worker’s training, any unauthorised restraint, or any restraint causing injury must be treated as a serious incident and escalated immediately.

14. Safeguarding considerations

Violence, aggression or distress may indicate abuse, neglect, exploitation, coercion, discriminatory treatment, inappropriate restrictions, poor care, unmet needs or a deterioration in physical or mental health.

Workers must:

• consider whether the incident gives rise to an adult or child safeguarding concern;
• take immediate action to protect a person from harm where safe and lawful;
• report the concern to the client’s safeguarding lead or responsible manager;
• report the concern to {{org_field_name}} without delay;
• call the police or emergency services where an immediate response is required;
• make an external referral where required by law or the applicable safeguarding procedure;
• preserve relevant evidence;
• record facts, observations and exact words where relevant; and
• avoid conducting their own investigation or confronting an alleged perpetrator where doing so may increase risk or compromise evidence.

Where a concern involves the client’s management, the worker must report it directly to {{org_field_name}} and use the Whistleblowing Policy or external safeguarding arrangements as appropriate.

No worker will be subjected to retaliation for raising a genuine safeguarding or safety concern in good faith.

15. Incident, injury and near-miss reporting

All incidents of work-related violence, aggression, abuse, harassment, threats, physical intervention and relevant near misses must be reported to:

• the client’s responsible manager in accordance with the client’s procedure; and
• {{org_field_name}} through its incident-reporting procedure.

Immediate verbal reporting must be followed by a written report as soon as reasonably practicable and, wherever possible, before the end of the shift.

The report must distinguish fact from opinion and include:

• the date, time and exact location;
• the names and roles of persons involved;
• what occurred before, during and after the incident;
• relevant known triggers or changes in presentation;
• the words used where threats, abuse or discriminatory comments were made;
• de-escalation and control measures attempted;
• any physical intervention used, including its type and duration;
• injuries, symptoms or psychological effects;
• first aid, medical assessment or treatment provided;
• damage to property;
• whether police, ambulance, safeguarding or another authority was contacted;
• the names of witnesses;
• relevant staffing levels and environmental conditions;
• whether CCTV or other evidence may exist;
• defects or failures in existing controls; and
• immediate action taken to prevent recurrence.

Reports must use objective, respectful and non-stigmatising language. They must not contain unnecessary clinical or personal information.

The absence of physical injury does not make an incident insignificant. Threats, stalking, harassment, sexual harassment, discriminatory abuse, attempted assaults and near misses must be recorded where they indicate a risk requiring control.

16. RIDDOR and external notification

Some injuries resulting from work-related violence may be reportable under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013.

Following a potentially reportable incident, {{org_field_name}} and the client must promptly establish:

• who was the injured person’s employer;
• who had control of the premises and work activity;
• whether the incident arose out of or in connection with work;
• the nature and severity of the injury;
• the worker’s period of incapacity; and
• which legal person is the “responsible person” required to submit the report.

The Director or nominated competent person must record the conclusion and must not assume that the client will submit a report without confirmation.

Where {{org_field_name}} is the responsible person, the report must be made within the applicable statutory time limit. Where the client is responsible, {{org_field_name}} must seek written confirmation that the matter has been considered and, where required, reported.

RIDDOR reporting does not replace internal incident reporting, safeguarding referrals, police reporting, professional-regulator notifications or contractual notifications.

17. Police involvement and preservation of evidence

Violence against a worker may constitute a criminal offence. The fact that an alleged perpetrator is a service user, patient or resident does not automatically prevent the matter from being reported to the police.

The police should be contacted immediately where there is:

• an immediate threat to life or serious injury;
• use or suspected possession of a weapon;
• a serious physical or sexual assault;
• stalking, credible threats or repeated targeted harassment;
• significant criminal damage;
• a hostage or barricade situation; or
• another emergency requiring police assistance.

Following a serious incident, workers and managers should preserve relevant evidence where safe and lawful. This may include contemporaneous notes, photographs of injuries, damaged clothing, names of witnesses, messages, emails and relevant CCTV. Workers must not access, copy or disclose records without proper authority.

18. Equality, harassment and sexual harassment

{{org_field_name}} prohibits discriminatory abuse, harassment, sexual harassment and victimisation by workers, client staff, service users, patients, residents, relatives, visitors and other third parties.

{{org_field_name}} will take reasonable and proactive steps to prevent sexual harassment in the course of employment. These steps will include:

• assessing the risk of sexual harassment, including risks presented by third parties;
• communicating expected standards to workers and clients;
• providing suitable training;
• maintaining accessible reporting routes;
• acting promptly on complaints and warning signs;
• requiring clients to take appropriate protective action;
• preventing retaliation or victimisation;
• reviewing placements and controls following an incident; and
• refusing, suspending or ending placements where a client fails to address a material risk.

A worker will not be expected to tolerate harassment or sexual harassment because it is committed by a person receiving care or because the person may have a disability or health condition. Any relevant impairment, capacity issue or clinical context will be considered when deciding the most appropriate response, but reasonable measures must still be taken to protect the worker.

Reports must be handled sensitively, confidentially and without assumptions about the affected person’s sex, gender, sexuality, age, disability, race, religion or other characteristic.

19. Post-incident response and worker support

Following an incident, {{org_field_name}} will make timely contact with the worker and assess their immediate and continuing support needs.

Depending on the circumstances, support may include:

• first aid or emergency medical treatment;
• advice to seek assessment from a GP, urgent treatment centre or accident and emergency department;
• occupational-health referral;
• confidential counselling or an employee-assistance service;
• a supportive debrief separate from any formal investigation;
• reasonable paid or unpaid time away from assignments, according to contractual and statutory entitlements;
• assistance in reporting the incident to the police;
• support during safeguarding, police, client or professional-regulator processes;
• temporary or permanent removal from the placement;
• adjustments to duties, hours or location;
• additional training or supervision; and
• regular welfare follow-up.

Debriefing must not compel a worker to relive the incident immediately after it occurs and must not be used to allocate blame.

The worker must be informed of the progress and outcome of the agency’s review, subject to confidentiality and data-protection restrictions.

No worker will be penalised, subjected to detrimental treatment or refused future work merely because they reported a genuine incident, sought assistance, contacted the police, raised a safeguarding concern or withdrew from serious and imminent danger.

20. Serious and imminent danger and stopping work

A worker who reasonably believes that a situation presents serious and imminent danger must:

• move themselves and, where safe and appropriate, others to a place of safety;
• summon assistance;
• contact the emergency services where necessary;
• inform the client’s responsible manager;
• inform {{org_field_name}} as soon as practicable; and
• record the circumstances.

The worker must not be required to return to the affected activity until the risk has been reassessed and suitable controls have been implemented.

{{org_field_name}} may suspend or terminate an assignment where:

• required risk information has been withheld;
• the client does not respond appropriately to incidents;
• agreed controls are absent or ineffective;
• staffing or supervision is unsafe;
• the worker is repeatedly exposed to preventable violence, harassment or abuse;
• the client expects unauthorised restrictive practice; or
• continuing the placement would create an unacceptable risk.

21. Information, instruction, training and competence

Before being supplied to an assignment, workers must receive information and training appropriate to the foreseeable risks of the role.

Core training will include, as applicable:

• recognition of work-related violence, aggression, abuse and harassment;
• dynamic risk assessment;
• prevention and early intervention;
• communication and de-escalation;
• personal safety and escape;
• emergency and alarm procedures;
• lone-working safety;
• safeguarding;
• equality, discriminatory abuse and sexual harassment;
• mental capacity, consent and the least restrictive principle;
• the legal and ethical limits of physical intervention;
• incident and near-miss reporting;
• preservation of evidence;
• accessing medical and psychological support; and
• responsibilities under client and agency procedures.

Workers must not perform planned physical intervention or restraint unless they have completed suitable role-specific practical training and have been assessed as competent.

Training must be refreshed:

• at intervals identified by the training provider, risk assessment, professional requirements or client contract;
• when legislation, guidance or procedures materially change;
• where an incident identifies a competence gap;
• where the worker has not used a skill for a prolonged period;
• following concerns about practice; or
• before undertaking a materially different assignment.

Training records must state the subject, provider, date, assessment method, expiry or review date and any restrictions on the worker’s competence.

Online awareness training alone is not sufficient where a worker may be expected to use practical personal-safety or physical-intervention skills.

22. Co-operation and co-ordination with clients

{{org_field_name}} and the client must co-operate and co-ordinate so far as necessary to protect temporary workers and other people affected by the assignment.

Before placement, the parties should agree:

• the assignment duties and limits;
• known risks and control measures;
• required qualifications, training and competence;
• local induction requirements;
• supervision and staffing arrangements;
• lone-working controls;
• access to alarms, equipment and assistance;
• emergency and evacuation arrangements;
• incident-reporting routes;
• safeguarding escalation;
• arrangements for post-incident support;
• responsibility for RIDDOR assessment and reporting;
• arrangements for investigating incidents; and
• how material changes will be communicated.

{{org_field_name}} will not rely solely on a general contractual statement that the client is responsible for health and safety. Material placement-specific information must be obtained and communicated in practice.

Client-specific instructions must not require a worker to act outside their competence, professional code, assignment terms or the law.

23. Data protection, confidentiality and incident records

Personal data contained in risk assessments, care plans and incident reports must be processed in accordance with UK GDPR, the Data Protection Act 2018 and the organisation’s data-protection policies.

{{org_field_name}} will:

• identify an appropriate lawful basis for processing incident information;
• apply the additional conditions required when processing health data, criminal-offence data or other special-category data;
• collect only information that is adequate, relevant and necessary;
• restrict access to authorised persons;
• use secure transfer and storage methods;
• maintain appropriate retention periods;
• preserve records for longer where required for safeguarding, litigation, insurance, regulatory or statutory purposes;
• document lawful disclosures to clients, safeguarding bodies, police, HSE, insurers or professional regulators; and
• avoid placing unnecessary service-user details in general staffing or booking systems.

Confidentiality does not prevent the lawful sharing of necessary information to protect a person from harm, comply with a legal duty, investigate an incident or support legal proceedings.

24. Governance, monitoring and quality assurance

The Director or nominated competent person will monitor:

• the number and type of incidents and near misses;
• the location and client involved;
• the type of assignment and shift;
• injuries and absence;
• discriminatory and sexual harassment;
• lone-working incidents;
• incidents involving restraint;
• repeat perpetrators or locations;
• failures in staffing, induction, equipment or communication;
• delays in reporting;
• police, safeguarding and RIDDOR referrals;
• action taken by clients; and
• the effectiveness of corrective measures.

Data will be reviewed at planned intervals and after any serious incident. Appropriate information will be shared with workers and clients while protecting confidentiality.

Corrective action may include:

• revising a risk assessment;
• obtaining additional client assurances;
• changing staffing or supervision arrangements;
• providing further training;
• reviewing worker suitability;
• changing or ending a placement;
• revising contractual requirements;
• escalating a concern to a commissioner, safeguarding authority, HSE, police or professional regulator; and
• updating this policy or associated procedures.

Closure of an incident investigation must not occur until actions have been allocated, target dates set and completion checked.

25. Record keeping and retention

{{org_field_name}} will maintain appropriate records of:

• information obtained from the client before placement;
• information provided to the worker;
• worker training and competence;
• incidents and near misses;
• injuries and post-incident support;
• investigations and corrective actions;
• safeguarding, police and regulatory referrals;
• RIDDOR decisions and reports;
• client correspondence; and
• decisions to suspend, continue or terminate placements.

Records must be accurate, secure, accessible to authorised persons and retained in accordance with applicable statutory, contractual, insurance, safeguarding and limitation-period requirements and the organisation’s retention schedule.

26. Policy review

This policy will be formally reviewed at least annually and sooner where:

• relevant legislation, statutory guidance or regulatory expectations change;
• a serious incident or significant near miss occurs;
• incident trends indicate that controls may be ineffective;
• a safeguarding review, police investigation, HSE enquiry or legal claim identifies a concern;
• the nature of the assignments supplied by {{org_field_name}} changes;
• workers or clients identify a material deficiency; or
• audit shows that the policy is not being implemented effectively.

Workers and, where applicable, their representatives will be consulted on relevant changes.

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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.