Sample policy · Domiciliary care

Entry to the home, keys and access policy (domiciliary care)

Statutory anchor: Regulation 12 (safe care and treatment), Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (SI 2014/2936). This policy also engages Regulation 10 (dignity and respect). · primary source

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:

5. Roles and responsibilities

6. Access and key-control procedure

The Service follows this procedure for every person:

  1. Agree access before care starts. Record how workers enter, who agreed it, any capacity or representative involvement, and the backup route if access fails.
  2. 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.
  3. Record only what staff need. Store access details securely and share them only with workers attending that person.
  4. Issue and return keys safely. Sign held keys in and out, using a reference that does not reveal the person's address or name.
  5. Check access at each visit. Workers follow the care plan, enter only for agreed care, and leave the home secure.
  6. 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.
  7. 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.
  8. 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 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:

10. Holding and recording keys

Where the Service holds a key to a property, it keeps a key record:

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:

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:

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:

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.

18. Related reading

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.

What good looks like here

Written from an ex-CQC inspector's chair, but the point is safe, well-led care your team can stand behind. Each row shows what strong evidence looks like, what thin evidence looks like, and where the expectation comes from.

A domiciliary service holds something few other regulated services hold: the means to open a person's front door at a time when that person often cannot come to it. A key-safe code that spreads beyond the workers attending that person, or a held key that the register says is in the office when it is not, does not present as a care failure on the day it happens. It surfaces weeks later as an entry nobody can account for, money or belongings the person cannot explain, or someone who has quietly stopped feeling safe in their own home and starts declining calls. That is why the key record is checked against the keys physically in the cabinet rather than trusted, why a code is reviewed when the worker who knew it moves on, and why a lost key is handled as both a security event for that person and a possible personal data breach. Done well the arrangement is close to invisible: the person's home still feels like theirs, the people coming through the door are the people they expect, and the property is left secure every time.

  1. The key record matches the keys the Service physically holds, reconciled by sign-out and return, so the Service knows who holds the means of entry to each person's home, not a register that has drifted from reality.

    Strong evidence: Keys given a reference that does not reveal the address or name, signed in and out so the Service knows who holds each key, stored securely at the office and not left in vehicles, and the audit confirming the key record matches the keys actually held (sections 6, 10 and 16).

    Weak evidence: A key register printed, filed and never checked against the cabinet, so three of the references have no key behind them and nobody can say when they left. A sign-out column blank for weeks because the same coordinator hands keys over informally each morning. Keys tagged with a flat number, a street name or the person's initials are the other tell: the reference is meant to mean nothing to whoever finds it on a pavement. The reconciliation interval is a Verivius default; the underlying duty to account for the means of entry to someone's home sits in Regulation 12.

    Our recommended baseline. Not a legal or regulatory requirement, but a sensible standard we suggest where the rules leave the detail to you. Adapt it to your service.

  2. Key-safe codes are handled as personal information: stored securely, given only to the workers attending that person, and never written on the safe or anywhere that links them to the address.

    Strong evidence: Codes stored securely and shared only with the workers who need them, never written on the key safe, left on display in the home or written where they can be linked to the address, and the audit confirming codes and held keys are stored securely and not labelled with addresses (sections 9 and 16).

    Weak evidence: Key-safe codes typed into a free-text notes field on the scheduling system that the whole rota can open, or passed round a staff messaging group where any new starter can scroll back and read them. Inside the home, the giveaway is a code written on the inside cover of the care folder, on a sticky note by the door, or on the key safe itself, sitting next to the address on every page. A code that can be linked to an address is personal data about that person, so the people who can see it have to be narrowed to the workers attending them.

    A legal duty. This comes from legislation that applies to your service, so meeting it is not optional. The exact provision is cited beneath the badge.

    UK GDPR Article 5(1)(f) and Article 32(1)(b) and (4); Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, reg 17(2)(c)

  3. Access codes and keys are reviewed and, where needed, changed when a worker who knew them leaves the Service, not left live so that a former worker can still open the person's door.

    Strong evidence: Access codes reviewed when a worker who knew them leaves the Service, and the audit confirming access codes are reviewed when workers leave (sections 13 and 16).

    Weak evidence: A leavers checklist that covers the rota login and the uniform but never asks which people the worker attended or which codes they knew, so the codes stay live indefinitely. Or an audit line reading "codes reviewed on leaving" with no list of which codes were looked at, no decision on whether any needed changing, and no evidence that a change was made where it was. Reviewing on a leaver is our recommended trigger rather than a statutory one, but leaving a former worker able to open a current client's door is hard to defend either way.

    Our recommended baseline. Not a legal or regulatory requirement, but a sensible standard we suggest where the rules leave the detail to you. Adapt it to your service.

  4. A lost key, or a code that may have become known to others, leads to the person being made secure, a decision either way on changing a lock or code, and a review as a possible personal data breach, not an informal note in the daybook. The test that matters is whether one real lost-key event can be followed through to what actually changed for that person.

    Strong evidence: Lost keys or exposed codes reported straight away, action to keep the person secure including changing a lock or code, review by the data protection lead as a possible personal data breach, and the record field for whether the event opened an incident, safeguarding concern, data-breach record, risk entry or improvement action (sections 5, 13 and 14).

    Weak evidence: A lost key recorded as one line in the office daybook, "key mislaid, turned up next day", with no consideration of who could have used it in between, no lock or code change decision either way, and no referral to the data protection lead or nominated manager to assess it as a possible personal data breach. The weakest version is a service that can describe the process in interview but cannot pull up a single real lost-key or exposed-code event and follow it through to what changed for that person.

    Our recommended baseline. Not a legal or regulatory requirement, but a sensible standard we suggest where the rules leave the detail to you. Adapt it to your service.

  5. The agreed access arrangement and its backup are recorded with the person's consent, including the representative or best-interests basis where the person could not agree it themselves.

    Strong evidence: The access arrangement agreed with the person, or their representative where the person cannot agree it, and recorded in the care plan, and the record fields for who agreed the access arrangement and when and any representative or best-interests decision relied on (sections 7, 8 and 14).

    Weak evidence: A care plan front sheet with "key safe" ticked and the code beside it, but no name of who agreed the arrangement and no date it was agreed. Where the person could not agree it themselves, the thin version records that a relative gave the code over the phone. A relative cannot consent on an adult's behalf unless they hold a registered lasting power of attorney for health and welfare or a deputyship, so what belongs on file is the person's capacity for this specific decision at the time it was taken, who was consulted, and why a key safe was in their best interests rather than a keyholder attending.

    A legal duty. This comes from legislation that applies to your service, so meeting it is not optional. The exact provision is cited beneath the badge.

    Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, reg 11(1) and reg 11(3); Mental Capacity Act 2005 ss.2-4 (and ss.9-11, s.16 on attorneys and deputies)

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Last verified 20 July 2026

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Last reviewed 10 June 2026