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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Safe Key Holding and Access Management Policy

1. Purpose

This policy outlines the procedures for safe key holding and access management at {{org_field_name}}, ensuring that all keys, fobs, and access codes used within our supported living services are securely managed, controlled, and monitored. The aim is to protect the safety, privacy, and security of people we support, staff, and property while maintaining efficient access to premises.

This policy ensures compliance with Care Quality Commission (CQC) regulations, data protection laws, and health and safety legislation, ensuring that key access is strictly controlled to prevent unauthorised entry, loss, or misuse.

2. Scope

This policy applies to:

• All staff handling or managing keys and access controls.
• People we support, ensuring their privacy and rights are upheld.
• Contractors, visitors, and external agencies accessing properties.
• All premises, office spaces, storage rooms, and confidential areas managed by {{org_field_name}}.

3. Legal and Regulatory Compliance

This policy aligns with:

• Health and Social Care Act 2008 (Regulated Activities) Regulations 2014:
  • Regulation 12 – Safe Care and Treatment (Ensuring safe access to buildings and protection of vulnerable individuals)​
  • Regulation 10 – Dignity and Respect (Respecting individuals’ privacy in key access procedures)​
  • Regulation 13 – Safeguarding from Abuse (Preventing unauthorised access that could lead to harm)​
  • Regulation 17 – Good Governance (Ensuring policies on key management are well-documented and followed)​
• General Data Protection Regulation (GDPR) 2018 – Ensuring confidentiality of door entry codes, access logs, and keyholder information.
• Health and Safety at Work Act 1974 – Ensuring safe premises access and emergency evacuation procedures.
• Fire Safety Order 2005 – Ensuring keys and access systems do not obstruct emergency exits or evacuation procedures.

4. Principles of Safe Key Holding and Access Management

• Security and Safety – Key management must prioritise the security of people we support, staff, and premises.
• Access Control – Only authorised individuals should hold or access keys, fobs, and entry codes.
• Dignity and Privacy – Staff must respect the personal space and autonomy of people we support when entering their rooms or homes.
• Accountability – All key holders must be trained, authorised, and monitored to prevent unauthorised or inappropriate use.
• Emergency Preparedness – Key access must allow for emergency entry while maintaining security protocols.

5. Safe Key Holding Procedures

5.1 Key Classification

All keys within {{org_field_name}} are categorised as follows:

• Master Keys – Provide access to all areas and must be strictly controlled.
• Individual Room or Home Keys – Assigned to specific people we support for personal use.
• Staff Keys – Assigned for specific shifts and returned after use.
• Office and Storage Keys – Restricted to authorised personnel only.
• Emergency Keys – Secured in a locked, designated area with access strictly monitored and recorded.

5.2 Authorised Key Holders

• Only designated staff members will be assigned keys based on their role and responsibilities.
• A key register must be maintained to log:
  • Who holds which keys.
  • The time and date keys were issued and returned.
  • The reason for key access.
• Managers must approve any temporary or permanent allocation of keys.

5.3 Secure Storage and Logging of Keys

• All keys must be stored in a secure, locked cabinet when not in use.
• Access logs must be kept for key retrieval and return.
• Key safes may be installed at specific locations for controlled access.
• Staff must never leave keys unattended in open areas or shared spaces.

6. Managing Access for People We Support

6.1 Personal Key Ownership

• People we support should be given full control of their own keys unless there is a risk to their safety or well-being.
• If an individual cannot safely manage their key, a risk assessment must be conducted, and alternative arrangements made.
• Any changes in who holds an individual’s key must be documented in their care plan.

6.2 Entry to Private Spaces

• Staff must always knock and wait for permission before entering a person’s living space.
• In emergency situations (fire, medical emergency, safeguarding concern), staff may use keys to gain access without prior consent, but this must be fully documented and justified.

7. Visitor and Contractor Access Management

7.1 Access Control for External Visitors

• Visitors must sign in and out when entering and leaving any premises.
• Visitors should be escorted where necessary to ensure security.
• External contractors must be issued temporary keys only with manager approval and must return them immediately after use.

7.2 Confidentiality of Access Information

• Door entry codes and access logs must be stored securely and only shared with authorised personnel.
• Staff must never disclose access codes or key locations to unauthorised individuals.

8. Emergency Key Access Procedures

8.1 Emergency Situations

• Emergency keys must be accessible in the event of a fire, medical emergency, or security breach.
• Staff must follow fire safety and evacuation protocols, ensuring people we support are not locked in or restricted.
• If a key is lost or stolen, staff must report it immediately to management, and locks must be changed if required.

9. Lost, Stolen, or Misused Keys

• If a key is lost or stolen, the incident must be reported immediately to the Registered Manager.
• A risk assessment must be conducted to determine whether locks need to be changed.
• Any misuse or unauthorised duplication of keys will be treated as a serious security breach and may result in disciplinary action.

10. Staff Training and Accountability

• All new staff must receive key holding and access management training as part of their induction.
• Staff must complete annual refresher training on:
  • Safe key handling.
  • Emergency access procedures.
  • GDPR compliance regarding access codes.
• Staff who misuse key access privileges may be subject to disciplinary action.

11. Compliance Monitoring and Quality Assurance

• The Registered Manager will conduct regular audits of key registers and access logs.
• Compliance with key management procedures will be reviewed during CQC inspections and internal quality checks.
• If any security incidents occur, policies and procedures will be reviewed and updated accordingly.

12. Related Policies

• SL13 – Safeguarding Adults from Abuse Policy​
• SL16 – Health and Safety at Work Policy​
• SL18 – Risk Management and Assessment Policy​
• SL20 – Fire Safety and Evacuation Procedures​
• SL42 – Confidentiality and Data Protection Policy​

13. Policy Review

This policy will be reviewed annually, or earlier if:

• Legislation or CQC guidance changes.
• A security incident occurs, requiring updates.
• Feedback from staff or people we support suggests improvements.

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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.