Financial Services A4 Template 1 col

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Managing Critical Client Incidents Policy
[Insert] Your organisation here
Table of Contents
1. Introduction ................................. 2
2. Directive Policy ........................... 2
3. Scope ........................................... 2
4. Definition and Terminology ........ 2
5. Procedure .................................... 4
5.1 Process Steps
5.2 Follow-up Action
5.3
5.4
4
7
5.2.1
Record details of Critical Client Incident ................................................................. 7
5.2.2
Counselling and Debrief Sessions ......................................................................... 7
5.2.3
Role of the Critical Client Incident Manager ........................................................... 8
Reporting
9
5.3.1
Weekly reports to the Chief Executive.................................................................... 9
5.3.2
Monthly Reporting [or as determined by your organisation] ................................... 9
5.3.3
Governance or Board Reports [as determined by your organisation]) ................... 9
Review
9
5.4.1 Analysis of the Critical Client Incident ........................................................................ 9
6. Related Documents .................... 9
7. Key Contacts ............................... 10
8. Policy Approval ........................... 10
Managing Critical Client Incidents ([insert] Your organisation here
1
1. Introduction
The purpose of this policy is to provide staff with instructions on how to manage a critical client
incident. It should be read in conjunction with [Insert] your Government funders Managing
Critical Client Incident Policy.
2. Directive Policy


[Insert] your Government funder’s Managing Critical Client Incidents Policy
[Insert] other relevant documents
3. Scope
[NOTE] Provide detail on what, when, where and to whom the policy applies. Also, document any
items, groups or circumstances the policy excludes or does not apply to.
Included:
This policy applies to: [As per note above]
Excluded: (delete if not necessary)
This policy does not apply to: [Insert]
4. Definition and Terminology
Client: is a person who receives, relies on or benefits from services delivered by [Insert] your
organisation. Interchangeable terms used are consumer and customer. Some organisations or
areas use specific descriptions for clients depending on the service setting, for example
person we support, resident or tenant.
Critical Client Incident: A critical client incident is an event (or alleged event) that occurs as
a result of, or during the delivery of services directly provided or funded by [Insert] your
organisation, and has caused or is likely to cause significant negative impact to the health,
safety or wellbeing of a client or service recipient. Critical client incidents will usually require a
crisis response, incident management, coordination and consideration of a range of risks and
sensitivities. Critical client incidents may include (but are not necessarily limited to):
Managing Critical Client Incidents ([insert] Your organisation here
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
The unexpected death, serious injury or alleged assault (including physical, sexual
abuse, sexual assault and indecent assault) of a client, that occurs as a result, or during
the delivery, of services

Allegations of serious unlawful or criminal activity or conduct involving an employee, a
subcontractor or volunteer that has caused, or has the potential to cause, serious harm
to clients

An incident where a client assaults or causes serious harm to others (including
employees, volunteers or contractors), as a result, or during the delivery, of services

A serious fire, natural disaster, accident or other incident which will, or is likely to
prevent, service provision, or which results in closure or significant damage to premises
or property, or which poses a significant threat to the health and safety of clients.
The assessment of whether an incident should be treated as a critical client incident should
take into account the following:

The standard of services provided may have been a contributing factor or may be
perceived as a factor

The extent of harm that resulted, or may result

The likelihood that others may be affected

The death, serious injury or harm has an obvious and direct correlation to the services
the person was receiving

The death, serious injury or harm is due to unusual circumstances

The duty of care that may be expected of the department and/or the funded service
provider in relation to the incident.
The Chief Executive Officer or Critical Client Incident Manager is responsible for
determining if a specific incident is to be classified as a critical client incident.
Critical Client Incident Manager: an officer, generally at manager or senior level, appointed
by the Chief Executive, and responsible for managing incidents until conclusion. The Critical
Client Incident Manager (or their delegate) is the lead contact in relation to the incident.
Disclosure: providing information about a critical client incident to others not directly involved
in the incident, but who may be affected, either directly or indirectly (for example, family
members of the affected client, other clients who may have been harmed and/or their families).
Please note that meeting reporting requirements (for example, mandatory notification,
reporting to SAPOL) does not constitute disclosure. Disclosure decisions must take into
account the potential for others to have been affected or harmed, the potential for others still to
Managing Critical Client Incidents ([insert] Your organisation here
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be at risk of harm or require assistance to alleviate the effects of harm; and risks in disclosing
or not disclosing information. They must also take into account what information will be
provided, to whom, for what purpose and with what justification, in what format and
appropriate approval mechanisms, and will be made in accordance with the Information
Sharing Guidelines (ISG) and [Insert] your Government funder’s and or your organisation’s
Disclosure Policy.
Funded organisation: organisations funded by a Government department that provide direct
client services on the Department’s behalf.
Worker: as per the Work Health and Safety Act 2012, a worker includes anyone who works
for [Insert] your organisation as an employee, employee of a labour hire company placed with
[Insert] your organisation, contractor, sub-contractor, trainee, work experience student or
volunteer. A worker includes anyone employed or those engaged in a voluntary capacity by
the [Insert] your organisation.
[NOTE] Provide explanation of other key definitions and terms specific to your area’s policies
and explanations of any abbreviations or acronyms used.
5. Procedure
The text below provides a guide for your organisation when developing procedures.
Instructions should be tailored to suit your organisation and its relationship to the client and
service but must reflect the broad framework below and align with your organisation’s policy.
5.1 Process Steps
The following outlines the process that must be followed in relation to all critical client
incidents. See Flow Chart
1. Immediate response - safety: The safety of clients, workers and others is of the
highest priority. Following any incident, workers must respond immediately and
appropriately to ensure the safety and wellbeing of client(s) and/or others. This may
involve calling for an ambulance or police or administering first aid.
2. Report - SAPOL: If the incident may constitute a criminal offence or if police
attendance is necessary to ensure safety or restore order, the incident must
immediately be reported to the South Australia Police (SAPOL). In the event of
such reporting, workers must seek to preserve physical evidence (e.g., medical or
scene examination, seizure of clothing).
3. Notifying: Employees must immediately advise their line manager and/or Chief
Executive of an apparent critical client incident either in person or by phone.
Important
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If the line manager is not available, it is the responsibility of the staff member aware
of, or involved in, the critical client incident to ensure that the next most appropriate
senior staff member is notified.
[NOTE] Provide detail of any other instructions that staff may require in the
immediate response, for example instructions on obtaining consent from the client or
guardian to take action
4. Assessment: The Critical Client Incident Manager will assess and determine if
the incident is to be classified as a critical client incident.
5. Incident Manager: If it is deemed that an incident is a critical client incident, the
department will appoint a Critical Client Incident Manager. The role of the Critical
Client Incident Manager is outlined in section 5.2.3.
6. Initial reporting: If an incident is deemed a critical client incident, the Incident
Manager must initially report the incident to the following:

Chief Executive of [Insert] your organisation

Relevant authorities and organisations

Client’s family, advocates and significant others

Client’s other service providers

[Insert] your organisation’s Government funder
The initial notification may be via email and must include the words Critical Client
Incident in the header, and provide the following information:

Date and time of the critical incident

Location of the critical incident

Details of the funded organisation involved (if applicable)

A succinct summary of what happened including, the relationship of any
alleged perpetrator(s) to the alleged victim(s)

The immediate steps that were taken to address the situation

Current safety issues (i.e. is the client safe?)

Coordination requirements (e.g. with other agencies, other areas of the
department)

Name of the appointed Critical Client Incident Manager.
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Critical Client Incident Managers may be required to advise other key stakeholders,
on an as needs basis, after further assessment of the incident.
7. Reporting: Those involved in or aware of the incident must adhere to any
mandatory or legislative reporting requirements within the appropriate timeframes,
and any other statutory guidelines and procedures for incident management.
In the case of a death, the Critical Client Incident Manager must refer to the [Insert]
your Government funder Coronial Policy and Guidelines.
[INSERT] Refer staff to the appropriate policies/procedures relevant to your
organisation or program, for example: Responding to Child Protection Concerns
Procedures
8. Disclosure: A disclosure assessment must be undertaken for all Critical Client
Incidents. This assessment takes into account the potential for, and likelihood that,
others (for example, other current or former clients) have been affected and/or
experienced harm, or the potential for others to be still at risk of harm or require
assistance to alleviate the effects of harm. Disclosure decisions must also take into
account the risks in disclosing, or not disclosing, information; and the potential
impacts of disclosure. If the assessment indicates disclosure may be warranted,
consideration must also be given to any constraints or limitations on disclosure (for
example, the timing of an investigation by SAPOL or another body); appropriate
parties to receive a disclosure; and managing the disclosure process. The State’s
Information Sharing Guidelines are a useful guide in the assessment process.
9. Critical Client Incident management: Critical client incidents will receive
high level and high quality incident management, including regular update reports
provided to the Chief Executive, [Insert] your Government funder/s and other relevant
organisations or authorities.
10. Incident closure/downgrading: At the discretion of [Insert] your organisation’s
Chief Executive and the Incident Manager, an incident may be downgraded or
closed as a critical client incident (for example, when the initial crisis is passed and
the situation has stabilised sufficiently to be managed with existing processes and
procedures).


The Critical Client Incident Manager will provide information to [Insert] your
organisation Chief Executive and recommend that a matter be downgraded or
closed
The Critical Client Incident Manager, in consultation with [Insert] your organisation
Chief Executive will make a decision and advise [Insert] your Government funder/s
and relevant authorities where appropriate.
11. Review: [Insert] your organisation will review the information gathered as a result of
the critical client incident with the aim of improving service quality and minimising
risks. This should be documented and reviewed along with other .
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5.2 Follow-up Action
5.2.1 Record details of Critical Client Incident
1. The Critical Client Incident Manager and staff members involved in the incident
must record all details related to the incident as it occurred, as soon as practical.
The following information should be included in any notes made by staff (as
relevant) [advise staff where and how to keep these notes). The information is
the same as initial reporting. See S5.1.6. See reporting template provided.

Date and time of the critical incident

Location of the critical incident

Details of the your organisation involved (if applicable)

A succinct summary of what happened including, the relationship of any
alleged perpetrator(s) to the alleged victim(s)

The immediate steps that were taken to address the situation

Current safety issues (i.e. is the client safe?)

Coordination requirements (e.g. with other agencies, other areas of the
department)

Name of the appointed Critical Client Incident Manager.
2. Staff must ensure that they comply with any other external mandatory reporting
requirements and record when this occurs.
[INSERT] All external mandatory reporting requirements relevant to your
organisation and to the nature of the incident
3. In the case of a reportable death or death in custody that is deemed a critical
client incident staff must also refer to [Insert] your Government funder/s Coronial
Policy.
The death of a client does not in itself constitute a critical client incident.
However, if the death involves circumstances that are out of the ordinary then it
may constitute a critical client incident.
5.2.2 Counselling and Debrief Sessions
1. Staff and clients involved in the incident should be encouraged to seek
counselling and support as appropriate. Confirm this suggestion in writing.
Where appropriate a staff de-briefing should take place.
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5.2.3 Role of the Critical Client Incident Manager
1. A Critical Client Incident Manager must be appointed by [Insert] your
organisation’s Chief Executive, to supervise and manage the incident to its
conclusion and to provide a single point of contact and coordination, including for
[Insert] your Government funder/s.
2. The Critical Client Incident Manager is responsible for:
a) Overseeing the management of the incident, including cross-departmental
and cross-agency coordination, and monitoring SAPOL investigations and
court proceedings where required.
b) Ensuring a report outlining the details of the incident and relevant background
is provided to [Insert] your Government funder/s within five business days or
as negotiated, of [Insert] your organisation becoming aware of the critical client
incident.
c) Ensuring that clients and staff involved in the incident have been encouraged
to seek counselling and support.
d) Ensuring compliance with [Insert] your organisation Disclosure Policy.
e) Providing regular updates to Chief Executive and [Insert] your Government
funder/s.
f) Recommending to the Chief Executive when the matter can be downgraded
or closed.
[INSERT] Provide other relevant instructions to assist the incident manager in
the critical client incident, including explaining their role and responsibility and
what resolution means in your work area
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5.3 Reporting
5.3.1 Weekly reports to the Chief Executive
1. The Critical Client Incident Manager will provide the Chief Executive with status
updates on new and existing critical incidents by close of business each [Insert
day or frequency]
2. The Critical Client Incident Manager will maintain and regularly update the
[Insert] your organisation Critical Client Incident Register based on these status
updates and prepare a summary report as required by the Chief Executive and
other relevant stakeholders.
5.3.2 Monthly Reporting [or as determined by your organisation]
1. The Critical Client Incident Manager is responsible for the coordination and
preparation of the monthly Executive Summary Reports [as determined by your
organisation]
2. The monthly Executive Summary Report will include information relating to new
critical incidents; ongoing critical incidents; downgraded and closed incidents; the
timeliness of briefings; and detail of risks identified and quality improvement
strategies introduced as a result of a critical client incident.
5.3.3 Governance or Board Reports [as determined by your organisation])
1. The Incident Manager is responsible for the coordination and preparation of the
Governance and Board Reports [as determined by your organisation]
2. [INSERT] Provide other relevant instruction here on how this will be achieved.
5.4 Review
5.4.1 Analysis of the Critical Client Incident
1. [NOTE] Provide instruction here on how your organisation will have
systems/processes in place for reviewing critical client incidents and making
necessary improvements to service delivery. Provide instruction here on how this
will be achieved.
List the ways in which your organisation will prevent similar incidents
6. Related Documents
[INSERT]
List any existing documents associated with the Managing Critical Client Incidents Policy.
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7. Key Contacts
Area
Contact Details
Contact Person
[Insert] your Government
funder/s.
[Insert] your organisation insurer
Coroner’s Office
SAPOL
[Insert] other organisations
8. Policy Approval
Content Author:
This person is
responsible for getting
the content written and
reviewed, consultation,
checking with subject
experts and obtaining
authorisation and
maintaining adequate
records.
[Insert name and
position]
No signature
required from the
content author
XX / XX
/ 20XX
Policy Custodian:
(Director or authorised
delegate)
This person is responsible for the
integrity of the policy document and
for checking to ensure that the content
is up-to-date.
............................................
[Insert name and position]
This person is responsible for providing final
approval of the policy. A delegated authority
needs to understand the business context for
the policy, content, standards, sensitivity,
confidentiality issues, access and use criteria
and the risks associated with the policy not
being accurate or up to date.
...........................................
[Insert name and position]
Signature required
Signature required
XX / XX
Delegated Authority: (Chief
Executive, Chairperson)
/ 20XX
Managing Critical Client Incidents ([insert] Your organisation here
XX / XX
/ 20 XX
10
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