1. What the regulation says
Care and treatment must be provided in a safe way for service users. (Reg 12(1) (the headline duty))
assessing the risks to the health and safety of service users of receiving the care or treatment, (Reg 12(2)(a) (risk assessment))
doing all that is reasonably practicable to mitigate any such risks, (Reg 12(2)(b) (risk mitigation))
Regulation 10 adds the dignity duty that this policy operationalises when a worker enters someone's home:
Service users must be treated with dignity and respect. (Reg 10(1): the headline duty)
The full text is at https://www.legislation.gov.uk/uksi/2014/2936/regulation/12 and https://www.legislation.gov.uk/uksi/2014/2936/regulation/10. Where this policy and the regulation diverge, the regulation wins.
2. Plain-English summary
Care and treatment must be provided in a safe way. The regulation lists the areas a provider must address, including risk assessment, risk mitigation, staff competence, safe premises, safe equipment, sufficient equipment and medicines, medicines safety, infection prevention and shared-care planning. Regulation 12 is central to CQC's safety expectations. Alongside this, service users must be treated with dignity and respect: in particular, you have to protect their privacy, support their autonomy, independence and involvement in the community, and have due regard to any relevant protected characteristics under the Equality Act 2010.
3. Purpose
A care worker enters someone's home, often when the person cannot get to the door. How the Service gets in, holds keys and protects access codes matters for the person's safety, their security and their dignity. This policy sets out how the Service agrees access, keeps keys and codes safe, and behaves as a guest in the person's home.
The Service must verify this policy against data protection law and its own insurance arrangements before adoption.
4. Scope
This policy applies to:
- how the Service enters every home it visits
- keys, key-safe codes, fobs and any other means of access the Service holds or uses
- everyone who enters a person's home on the Service's behalf
5. Roles and responsibilities
- Registered Manager: owns this policy, approves key-holding arrangements, reviews no-access and lost-key incidents, and ensures actions are completed.
- Care coordinator or office lead: records access arrangements, keeps the key register current, allocates access information only to workers who need it, and runs the no-access escalation process.
- Care workers: follow the recorded access arrangement, protect keys and codes, report no access, lost keys, failed access or security concerns immediately, and do not force entry.
- On-call lead: responds to no-access and urgent access concerns outside office hours and records the decision trail.
- Data protection lead or nominated manager: reviews any lost key, lost code or wrongly shared access information as a possible personal data breach.
6. Access and key-control procedure
The Service follows this procedure for every person:
- Agree access before care starts. Record how workers enter, who agreed it, any capacity or representative involvement, and the backup route if access fails.
- Check the arrangement is safe. Confirm whether the person answers the door, a keyholder attends, a key safe is used, or the Service holds a key.
- Record only what staff need. Store access details securely and share them only with workers attending that person.
- Issue and return keys safely. Sign held keys in and out, using a reference that does not reveal the person's address or name.
- Check access at each visit. Workers follow the care plan, enter only for agreed care, and leave the home secure.
- Escalate no access. Workers follow the no-access route, contact the office or on-call, and stay involved until the person's safety is confirmed.
- Respond to lost keys or exposed codes. Secure the person, consider lock or code change, assess data-breach risk, and open an incident or action where needed.
- Review after change. Review access details when a person moves, care ends, a worker leaves, a family arrangement changes, or a security concern is raised.
7. Consent to enter
The Service enters a home with the person's agreement. The access arrangement is agreed with the person, or their representative where the person cannot agree it themselves, and recorded in the care plan. A worker enters only to provide the agreed care, and only the parts of the home needed to provide it.
8. Agreed access arrangements
For each person, the Service records how workers get in. Common arrangements are:
- the person answers the door
- a family member or keyholder lets the worker in
- a key safe holds a key, opened with a code
- the Service holds a key to the property
The care plan names the arrangement, any backup, and who to contact if access fails.
9. Key-safe codes and access details are personal information
A key-safe code or a held key is, in effect, the key to someone's home. The Service treats access details as personal information and protects them:
- codes are stored securely and shared only with the workers who need them to attend that person
- a code is never written on the key safe, left on display in the home, or written where it can be linked to the address
- access details are held in line with the Service's data protection arrangements
10. Holding and recording keys
Where the Service holds a key to a property, it keeps a key record:
- each key is given a reference that does not reveal the address, and is never labelled with the address or the person's name
- keys are signed in and out, so the Service knows who holds each key
- keys are stored securely at the office and not left in vehicles or carried longer than needed
- the Service holds keys only where its insurance allows
11. When a worker cannot get in
If a worker cannot get in or gets no reply, they follow the no-access procedure in the visit scheduling, missed and late visits policy: try to reach the person, use the agreed backup access, contact the office or on-call, and where there is reason to fear for the person's safety, call the emergency services and stay until help arrives. A worker does not force entry themselves.
12. Respecting the person's home
A worker is a guest in the person's home. The Service expects workers to:
- enter only the rooms needed for the agreed care
- treat the person's home, belongings and routines with respect
- leave the home secure on the way out, locking up and returning the key to the key safe or as agreed
13. Lost keys or a code that may be known to others
If a key is lost, or a worker believes a code may have become known to someone who should not have it, they report it to the office straight away. The Service acts to keep the person secure, which may include changing a lock or a code, and records what happened and what was done. Access codes are also reviewed when a worker who knew them leaves the Service.
14. Records and register links
The Service records, for each person, the agreed access arrangement and any backup, and keeps the key record up to date. The record should include:
- who agreed the access arrangement and when
- any representative or best-interests decision relied on
- key-safe code, held-key reference or keyholder arrangement
- workers authorised to receive access information
- key sign-out and return dates and times
- no-access event steps, contacts, decisions and outcome
- lost key, exposed code or security concern action taken
- whether the event opened an incident, safeguarding concern, data-breach record, risk entry or improvement action
No-access events and lost-key events are reviewed through the incident register where safety was affected. Repeated access failures are reviewed through the risk register or improvement-actions register.
15. Training and supervision
Staff who enter people's homes must be trained on access arrangements, confidentiality of key-safe codes, key handling, no-access escalation, personal safety and respectful conduct in the person's home. Supervisors check during spot checks and care reviews that workers follow the recorded access arrangement and leave the home secure.
16. Audit cadence
The Service checks, on a stated cadence, that:
- every active package records an agreed access arrangement
- access codes and held keys are stored securely and not labelled with addresses
- the key record matches the keys actually held
- access codes are reviewed when workers leave
- no-access and lost-key events are recorded and acted on
The Registered Manager reviews the results and records the improvement actions that follow.
17. Sources and further reading
This template is based on CQC's guidance for providers and managers, the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, and other topic-specific legislation and guidance listed below. It is a starting point for adaptation, not a substitute for legal, clinical, HR, safeguarding or specialist professional advice.
- CQC Regulation 12: Safe care and treatment
- CQC Regulation 10: Dignity and respect
- Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (https://www.legislation.gov.uk/uksi/2014/2936/regulation/12)
- UK GDPR and Data Protection Act 2018 (key-safe codes and keyholder details are personal data) (https://www.legislation.gov.uk/ukpga/2018/12/contents)
- Local authority safeguarding adults procedures
- Police and safe-access procedure where there is no access and a concern for the person's safety
- The Service's insurance terms covering the holding of clients' keys
18. Related reading
- Guide: Domiciliary care compliance guide
- Article: CQC compliance for domiciliary care: the evidence inspectors expect
- Related policy: Visit scheduling, missed and late visits
- Related policy: Lone working and personal safety policy
19. When to seek further advice
Seek specialist advice where the issue involves serious harm, safeguarding, deprivation of liberty, restraint, children, professional misconduct, controlled drugs, radiation, termination of pregnancy, infection outbreak, water safety, employment dismissal, DBS barring referral, or regulatory enforcement.
20. Document control
| Version | Date | Author | Changes |
|---|---|---|---|
| v1.1 | 2026-07-12 | Verivius (sample) | Added role ownership, access and key-control procedure, record fields, register links, training and supervision controls. |
| v1 | 2026-06-10 | Verivius (sample) | Initial sample template, conformed to the Verivius policy standard. |
This sample policy template was issued by Verivius. It is a template, not a substitute for legal advice or the tenant's own policy-development process. Where this template and live law or regulator guidance diverge, the live source wins.