Cautionary contact register: Policy and process
Wycombe District Council (WDC) is committed to reducing incidents of violent, abusive and aggressive behaviour towards its employees. No WDC employee should ever have to experience such behaviour as part of their job.
Under the Health and Safety at Work Act (1974) WDC has a duty to ensure, so far as reasonably practical, that it reduces the risk of violence, aggressive or threatening behaviour towards its employees during the course of their work. This policy and process is therefore intended to help ensure that the council can meet its duties under the legislation, whilst complying with the requirements of the Data Protection Act.
One of the ways that WDC can minimise risk to its staff is to operate a Cautionary Contacts Register (CCR), which is a means of identifying individuals who could possibly pose a risk to the members of staff who come into contact with them, and/or premises where risks may be encountered.
The Health and Safety Executive defines work-related violence as
"Any incident in which a person is abused, threatened or assaulted in circumstances relating to their work".
This can include verbal and written abuse or threats, aggressive behaviour or harassment that causes distress (whether in person or over the phone), as well as physical attacks.
Examples of behaviour which may be considered unacceptable would include:
- Any physical assault
- Personal threats against employees/individuals
- Threats to personal and council property
- Violent behaviour resulting in damage of property (council or personal property)
- Verbal abuse and/or aggressive behaviour
- Religious, racial, homophobic or any other kind of hate abuse
- Attack or intimidation by aggressive animals (for example, dogs)
- Psychological manipulation: a type of social influence (external website) that aims to change the perception or behaviour of others through underhanded, deceptive, or even abusive (external website) tactics. By advancing the interests of the manipulator, often at the other's expense, such methods could be considered exploitative (external website), abusive (external website), devious, and deceptive (external website)
- Cyber bullying and abuse
3. Responsibilities of managers and employees
WDC takes the protection of our employees very seriously. Therefore all managers and staff must take responsibility for ensuring that they are safe - including the following:
- Carrying out risk assessments - managers should complete a risk assessment for their services and/or premises, and for their staff members (see risk assessment SWP01 - available on Wyspace). This assessment should include consideration of the risks of violence or abuse to employees, and ensure that any mitigation actions are acted upon
- Attending induction and other training as appropriate - managers should ensure that all new staff attend induction and health and safety training as soon as possible after they start. Where a risk assessment identifies that more specific training is needed this should be arranged as soon as possible
- Using personal protective equipment (PPE) where appropriate - if risks cannot be eliminated or controlled, then managers should ensure that should consider providing PPE, and ensuring that staff are fully trained in its usage. PPE might include:
- Recording equipment
- Panic alarms/buttons
- Mobile phones
- First aid kits
- Personal attack alarms
- Taking preventative action - if employees feel they might be at risk they should aim to remove themselves from the situation, and seek assistance. All attempts should be made to defuse or minimise violent or abusive situations
- Reporting any incidents quickly and clearly - employees must report any incidents (or near misses) to their manager as soon as possible, using the Violence at work incident report form (VAW1) [Word | 76KB] . Managers must ensure that any immediate mitigation actions are taken asap, and that the report is passed to the Corporate Health and safety team immediately
- Providing post-incident support - managers should ensure that appropriate post-incident support for employees takes place as necessary.
4. Reporting an incident
The council will maintain a Cautionary Contacts Register, which will record summary details of all individuals or premises which have been the subject of a report of violent, aggressive or abusive behaviour.
This register will be made accessible for all staff who have been designated (by their head of service) as being at risk of work-related violence. Heads of service will be asked regularly to review and designate which staff are entitled to access the CCR.
The process for reporting an incident is as follows:
- When an incident occurs in which a client's behaviour is unacceptable, after the incident has ended the officer affected shall complete Part 1 of the Violence at work incident report form (VAW1) [Word | 76KB] and submit it immediately to their manager for urgent review
- The manager will meet with the affected employee asap, and will agree any immediate actions required. The manager will then complete Part B of the VAW1 form, and send it to the Corporate Health and Safety team (firstname.lastname@example.org) marked private and confidential
- As soon as possible after receipt (ideally within 24 hours) the Corporate Health and Safety team will contact the manager to confirm the details, and to agree to add the offender's name and details (if known) to the CCR
- The Corporate Health and Safety team will then update the Cautionary Contacts Register (CCR) with information provided on the completed form VAW1. The system will then send an update to all designated CCR users, to advise them that a change has been made to the register
- The service manager will then write to the offender (if they are known) to advise them that their name has been placed on the CCR for a 12 month period (Cautionary contact register notification template [Word | 145KB]). Managers should also send a copy of the letter to the Corporate Health and safety team
- The CCR list will be managed by the Corporate Health and Safety team. Notifications will be sent to designated CCR users every time that a change is made to the list, and to remind users to check the list whenever they are planning to meet an external customer as part of their work.
- The CCR list will be reviewed regularly by the Corporate Health and Safety team, in conjunction with service managers.
5. Use of the Cautionary Contacts Register
The CCR will be administered by the Corporate Health and Safety team.
The CCR will only be accessible by employees who have been designated by their Head of Service as being at risk of work-related violence. The list of designated names will be reviewed every six months.
Cautionary contact register example [PDF | 118KB]
6. Reviewing the CCR
The Corporate Health and Safety team will review the CCR every six months and will consult with the relevant service manager about any entries which have reached 12 months age. Normally, if there have been no repeat incidents, entries would be removed after 12 months. However, for more serious incidents (eg physical assault), in consultation with relevant managers the Corporate Health and Safety team may keep the client details on the register for a period longer than the standard 12 months. In either case, the head of service should notify the person concerned (Cautionary contact register review templates [Word | 145KB]).
7. Data protection
Normally we will inform people when they have been entered on the CCR (see template letters). There may some exceptional circumstances where we feel that informing the individual may increase the risk to our employees, in which case we will not inform them.
The information held and processed on the CCR will be in accordance with the 'Eight principles of the Data Protection Act' and will be governed by security measures which prohibit unauthorised access, disclosure, alteration, loss and destruction of information.
An individual may request that their entry be removed from the CCR, and we will consider any such requests on its merits. The council may refuse the request on the basis that the data is held in order to comply with our legal obligations to our employees, under the Health and Safety Act 1974.
Cautionary contact register: Policy and process [PDF | 646KB] printable version