Purpose
This policy sets out how Bubble Fresh (Bubblefresh Limited, company number 12691029) reports, records, and investigates all incidents, accidents, and near misses. We follow the Health and Safety at Work etc. Act 1974 and the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) 2013. Good incident reporting helps us keep people safe, spot risks early, and stop problems from happening again.
Scope
This policy applies to all Bubble Fresh employees, contractors, and anyone working on our behalf. It covers all incidents that happen during our work, whether on a client's property, in transit, at our office, or at any other location connected to our operations. It also covers incidents involving our clients, their visitors, council officers, or any other person present during our service delivery. Where our work is carried out under a council referral, the additional notification requirements in this policy also apply.
Roles and responsibilities
The Director, Lance James, has overall responsibility for incident reporting and investigation. The Director is the designated responsible person for RIDDOR 2013 reporting. This means the Director ensures this policy is followed, reviews all high-severity incident reports, and decides when to report to the Health and Safety Executive (HSE), insurers, and council partners. Team leaders support employees through the reporting process. They make sure the scene is safe, collect witness details, and complete initial notifications. All employees must report incidents immediately, preserve the scene where safe to do so, cooperate fully with any investigation, and complete written reports within the timescales in this policy. Where we work under council referrals, the Director is the single point of contact for incident notifications to council commissioning teams.
What to report
All employees must report any accident or injury (however minor), any near miss or dangerous occurrence, any damage to client property or belongings, any safeguarding concern, any situation where a client or employee was at risk, any equipment failure, any incident involving hazardous substances, and any road traffic accident that happens during work travel. Under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) 2013, certain incidents must also be reported to the Health and Safety Executive (HSE). These include deaths and specified injuries such as fractures (other than to fingers, thumbs, or toes), amputations, crush injuries leading to internal organ damage, loss of consciousness, serious burns, scalping needing hospital treatment, and permanent loss or reduction of sight. Over-7-day injuries (where someone cannot do their normal work for more than 7 consecutive days) must also be reported, along with dangerous occurrences, occupational diseases, and accidents to non-workers who are taken directly to hospital. If in doubt about whether something should be reported, report it.
How to report
Report incidents to a manager immediately by phone or in person. Complete a written incident report using a Bubble Fresh incident report form as soon as you can, ideally on the same working day. Blank forms are kept in all vehicles and in the office, and are available digitally. The form covers the date, time, and location, the people involved, a factual description of what happened, any injuries or damage, immediate action taken, witness names and contact details, and whether body-worn camera footage is available. Where there are witnesses to the incident, the team leader or manager should collect brief written statements as soon as possible while events are still fresh. If you are a client or member of the public and you witness an incident during our service, tell a team member or call us on 01933 213045 (Relay UK: 18001 then 01933 213045). You can also raise a concern through our Complaints Procedure.
Timescales
Report all incidents verbally straight away. Complete written reports within 24 hours. Under RIDDOR 2013, fatal and specified injuries must be reported to the HSE without delay by the quickest practicable means (usually by phone on 0345 300 9923), followed by a written report within 10 days using the online form at hse.gov.uk. Dangerous occurrences must be reported without delay, followed by a written report within 10 days. Over-7-day injuries must be notified within 15 days. Occupational diseases must be reported without delay once confirmed by a doctor. We escalate safeguarding concerns immediately in line with our Safeguarding Policy.
Severity classification
We classify all incidents into three severity levels to make sure we respond proportionately. High severity includes any death, any RIDDOR-reportable specified injury, any incident requiring hospitalisation, any safeguarding concern, any incident involving the police or emergency services, and any significant damage to a client's property. Medium severity includes injuries requiring medical treatment (but not hospitalisation), equipment failures that interrupted service delivery, minor damage to client property, and any incident that caused significant distress to a client or employee. Low severity includes minor injuries treated with first aid only, near misses with no injury or damage, and minor equipment problems that did not affect service delivery. The severity level determines our investigation timescales, notification requirements, and the level of management involvement. Where there is any doubt about the correct severity level, we treat the incident at the higher level.
Preserving the scene
After any serious incident, the priority is to make sure everyone is safe and to call the emergency services if needed. Once people are safe, employees should preserve the scene as far as reasonably practicable. Do not move or clean up items involved in the incident unless doing so is necessary to prevent further harm. Note the position of objects, equipment, and any substances involved. Take photographs if it is safe to do so. Keep the area secure until a manager arrives or gives permission to proceed. Collect the names and contact details of any witnesses. In RIDDOR-reportable incidents, the Health and Safety Executive (HSE) may need to inspect the scene. Do not disturb the scene until the Director confirms it is safe to do so. If body-worn camera footage was recording at the time of the incident, the footage must be preserved and flagged straight away in line with our Body-Worn Camera Policy.
Body-worn camera footage as evidence
Where a body-worn camera was active during an incident, the footage is an important source of evidence. The employee involved must note on their incident report form that footage is available and the approximate time of the incident. The Director or team leader will secure the footage promptly and flag it for extended retention beyond the standard 2-month period set out in our Body-Worn Camera Policy. Footage relevant to an incident must not be viewed, copied, shared, or deleted by anyone other than the Director or an authorised manager. Where footage may be needed for a legal matter, insurance claim, HSE investigation, council review, or disciplinary process, we maintain a chain of custody record showing who accessed the footage, when, and why. We share footage with external parties only in the circumstances set out in our Body-Worn Camera Policy, including with law enforcement, insurers, or council partners where there is a lawful basis to do so.
Council notification
Where an incident occurs during work carried out under a council referral, we notify the referring council's commissioning team promptly, in addition to our own internal reporting. For high-severity incidents (including RIDDOR-reportable incidents, safeguarding concerns, or any incident resulting in significant injury, hospitalisation, or damage), we notify the council by phone within 4 hours and follow up with a written summary within 24 hours. For medium-severity incidents, we notify the council in writing within 48 hours. For low-severity incidents and near misses, we include a summary in our quarterly contract reporting to the council. Where a council contract sets its own incident notification timescales or procedures, we follow those requirements. We work cooperatively with council partners during any joint investigation and share relevant information within the limits of data protection law. We keep a record of all council notifications, including the date, time, method, and the name of the person notified.
Client notification
Where an incident occurs at a client's property or directly affects the client, we inform the client (or their representative, social worker, or advocate) as soon as reasonably practicable. We explain clearly what happened, what immediate steps we have taken, and what will happen next. Where the client has been referred by a council partner, we coordinate our client communication with the referring council to make sure the client receives consistent and accurate information. We handle all client communications with care and sensitivity, keeping in mind that our clients are often in vulnerable situations. We record what we told the client and when.
Insurance notification
We notify our insurance provider of any incident that may give rise to a claim. This includes any injury to an employee, client, or third party, any damage to client property or belongings, any damage to a third party's property, and any incident that could lead to a legal claim or complaint. We notify our insurer as soon as practicable, and always within the timescales required by our policy terms. We do not admit liability or make any commitment to pay compensation without first consulting our insurer. We keep our insurer informed of any developments, including the outcome of investigations and any correspondence from the injured party, their solicitor, or a regulatory body. We retain copies of all correspondence with our insurer as part of the incident file.
Investigation
We investigate all reported incidents in proportion to their severity. High-severity incidents are investigated with initial findings reported within 5 working days. Medium-severity incidents are investigated within 10 working days. Low-severity incidents and near misses are investigated within 20 working days. Where practicable, investigations are led by a person who was not directly involved in the incident, to maintain objectivity. We put interim safety measures in place while the investigation is ongoing where needed. Investigations aim to establish the facts, identify the root cause, and work out what action is needed to prevent the same thing from happening again. We review body-worn camera footage, witness statements, incident report forms, risk assessments, and any other relevant evidence as part of the investigation. We document all findings and corrective actions in a written investigation report. Where an investigation shows that a risk assessment needs updating, we update the relevant assessment and brief affected staff before work resumes. We share investigation findings with relevant council partners where the incident occurred on a council-referred job.
Corrective and preventive actions
Every incident investigation results in a clear set of corrective actions (steps to fix the immediate problem) and preventive actions (steps to stop similar incidents from happening in the future). Each action is assigned to a named person with a target completion date. The Director tracks all open actions using an action log and reviews progress at least monthly. Actions are not closed until the person responsible has confirmed completion and the Director has verified that the action has been effective. Examples of corrective and preventive actions include updating risk assessments, changing working procedures, providing additional training, replacing or repairing equipment, issuing safety alerts to the team, and revising Personal Protective Equipment (PPE) requirements. Where an action relates to a council-referred job, we inform the council of the steps we are taking. We report on the status of corrective actions as part of our regular contract reporting to council partners.
Post-incident support for staff
We recognise that being involved in or witnessing an incident can be distressing, particularly given the sensitive environments in which we work. We offer support to any employee affected by an incident. This includes an immediate check-in with their manager or team leader on the day of the incident, a follow-up welfare conversation within 48 hours, access to our Employee Assistance Programme (EAP) for free and confidential counselling and mental health support, adjusted duties or time off where the employee needs it to recover, and ongoing check-ins for as long as the employee needs support. No employee will be penalised for taking time to recover from a traumatic incident. If an employee does not feel comfortable speaking to their direct manager, they can speak to the Director or any other member of the management team. We also encourage employees to support each other and to let a manager know if they notice a colleague who seems to be struggling after an incident. Where an employee has been absent following an incident, we carry out a supportive return-to-work conversation to make sure they feel ready and to agree any adjustments needed. Our approach to staff wellbeing is set out in more detail in our Health & Safety Policy and our Social Value Statement.
Near-miss reporting
A near miss is any event that could have caused injury, damage, or harm but did not. Near misses are just as important to report as actual incidents because they help us identify and fix risks before someone gets hurt. We actively encourage near-miss reporting and treat it as a positive contribution to safety, never as a cause for blame or disciplinary action. We make near-miss reporting easy by accepting verbal, written, or digital reports, and by allowing anonymous reporting where an employee prefers. Management reviews all near-miss reports promptly and takes action where a risk is identified. We track near-miss reporting rates as a positive safety performance indicator, reviewed quarterly. We share examples of near misses (with personal details removed) during team briefings so that everyone can learn from them. A healthy near-miss reporting rate is a sign that our team is engaged with safety and looking out for each other.
Learning from incidents
Management reviews incident and near-miss data quarterly to identify patterns and trends. We share lessons learned with the team through briefings, updated procedures, or additional training as appropriate. We carry out a formal lessons-learned review after every high-severity incident, and we include the findings in our team briefings and, where relevant, in our reporting to council partners. Where an incident reveals a gap in our training or procedures, we update our training programme and risk assessments accordingly. We keep a record of all lessons learned and the actions taken as a result.
Training
All employees receive training on incident reporting during induction. This covers how to recognise and report incidents and near misses, how to complete the incident report form, how to preserve the scene and collect witness details, RIDDOR-reportable categories and timescales, body-worn camera evidence procedures, and the importance of honest, blame-free reporting. We provide refresher training annually and after any significant change to this policy or our procedures. Incident reporting training forms part of each employee's minimum 20 hours of annual training, as set out in our Training & Development Policy.
Record-keeping and confidentiality
We keep accurate, complete records of all incidents, investigations, corrective actions, and notifications. Incident records may contain personal data, including special category health data under Article 9 of the UK General Data Protection Regulation (UK GDPR). We process this data on the basis of legal obligation under Article 6(1)(c) of UK GDPR (to comply with the Health and Safety at Work etc. Act 1974 and RIDDOR 2013) and under Article 9(2)(b) for health data. Only people who need incident records for investigation, prevention, or reporting purposes can access them. We keep incident records for 6 years (Limitation Act 1980). RIDDOR records are kept for at least 3 years (RIDDOR 2013 Regulation 12). Body-worn camera footage linked to an incident is kept for the duration of the investigation and any subsequent legal or insurance matter, as set out in our Body-Worn Camera Policy. We handle all incident information with care and do not share it more widely than necessary. Where we share incident information with council partners, insurers, or regulatory bodies, we share only what is needed for the specific purpose and in line with data protection law.
Related policies
This policy should be read alongside our Health & Safety Policy, Safeguarding Policy, Risk Assessment Policy, Body-Worn Camera Policy, Lone Working Policy, COSHH Policy, Infection Control Policy, Environmental Policy, Complaints Procedure, and Whistleblowing Policy. Together, these policies set out how we manage safety, risk, and accountability across our operations.
Contact us
If you have any questions about this policy or need to report an incident, contact us on 01933 213045 (Relay UK: 18001 then 01933 213045) or by post at Bubblefresh Limited, 6 Carnegie Street, Rushden, Northamptonshire, NN10 9SN. In an emergency, always call 999 first.
Changes to this policy
We may update this policy from time to time to reflect changes in legislation, guidance, or our working practices. Where we make material changes, we will notify our council partners, affected clients, and any other affected parties, and ensure all employees are briefed on the changes before they take effect.
Review
The Director, Lance James, reviews this policy annually and following any significant incident. Last reviewed: February 2026. Next review due: February 2027.
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