Our commitment
Bubble Fresh (Bubblefresh Limited, company number 12691029) recognises that some of our work involves employees working alone or in isolated situations. Many of our clients are vulnerable adults, and our staff regularly visit properties where conditions may be unpredictable. We are committed to keeping lone workers safe through thorough risk assessment, clear procedures, effective communication systems, and a culture where staff feel confident raising concerns about their safety. No employee will ever be required to work alone in a situation where risks cannot be properly controlled.
Legal framework
This policy is guided by the Health and Safety at Work etc. Act 1974, which places a general duty on employers to ensure, so far as is reasonably practicable, the health, safety, and welfare of their employees. It also reflects the Management of Health and Safety at Work Regulations 1999, which require employers to carry out suitable and sufficient risk assessments, including specific assessment of risks to lone workers. We also have regard to the Health and Safety Executive (HSE) guidance on working alone (INDG73) and the Corporate Manslaughter and Corporate Homicide Act 2007. Where our work is carried out under a council contract, we follow any additional lone working requirements set out by the council.
Scope
This policy applies to any Bubble Fresh employee who works alone at a client's property without direct supervision or the immediate presence of a colleague. This includes initial site assessments, smaller cleaning jobs, follow-up visits, and any situation where a team member may be alone on site. It also covers employees travelling alone between jobs, particularly in remote or rural areas. Our office hours are Monday to Friday, 8am to 6pm. Outside these hours, including weekends and bank holidays, the on-call manager is available for lone worker check-ins and escalation. The on-call manager cannot simultaneously be the lone worker being monitored; where this would arise, a second named contact is designated.
When lone working is not permitted
Lone working is not permitted in the following situations: biohazard cleaning jobs, properties with known aggressive or threatening occupants, any job where the risk assessment identifies a risk that cannot be adequately controlled by a lone worker, properties where there has been a previous violent or threatening incident involving our staff, first visits to properties where we have limited or no background information from the referring agency, and any job scheduled between 9pm and 6am (see the Night working section below). In all such cases, we deploy a minimum team of two.
Escalation from lone to paired working
Even where a job has been approved for lone working, certain situations require immediate escalation to paired working. These include any verbal threat, aggressive behaviour, or intimidation directed at the lone worker, any indication that other people at the property are under the influence of drugs or alcohol, the discovery of weapons, drug paraphernalia, or other items that pose a risk, a significant change in the condition of the property from what was expected (for example, structural damage or hazardous materials), the arrival of unexpected visitors who behave in a way that makes the lone worker uncomfortable, any situation where the lone worker feels unsafe for any reason, and repeated missed appointments or access difficulties that suggest the situation may have changed. In any of these situations, the lone worker must stop work, leave the property where safe to do so, and contact the office immediately. The job will be rescheduled with a team of two or more. We never require a lone worker to continue working in a situation where they feel at risk. Any employee who exercises their right to leave a property will be fully supported and will not face any negative consequences. Every escalation decision is documented and fed back into the risk assessment for that property, so future visits reflect the updated picture.
Risk assessment
Before we allow lone working, we carry out a risk assessment in line with the Management of Health and Safety at Work Regulations 1999. The assessment considers the nature of the task, the location and accessibility of the property (including whether it is in a remote or rural area), the condition of the property, any known risks associated with the client or environment (including information from the referring council or agency), the employee's experience, training, and physical fitness, the time of day the work will take place, mobile phone signal strength at the location, and whether the employee has any medical condition that could increase risk when working alone. Where the risk assessment identifies unacceptable risks, we do not allow lone working and send a team of two or more. Risk assessments are documented, reviewed before each job, and updated whenever circumstances change. We keep risk assessment records for a minimum of 3 years.
Dynamic risk assessment
A risk assessment carried out before a job cannot cover every situation a lone worker may face on arrival. We train all lone workers to carry out a dynamic risk assessment when they arrive at a property. This means pausing before entering the property to look for anything unexpected, such as signs of damage, unusual activity, unfamiliar people, aggressive animals, or anything that does not match the information provided in the referral. If anything causes concern, the lone worker must not enter the property. Instead, they should return to their vehicle, contact the office, and wait for further instructions. The office will decide whether the job can continue, whether a second team member should attend, or whether the job should be rescheduled. Dynamic risk assessment is a core part of our lone working training (see the Training section below).
Night working
We do not permit lone working between 9pm and 6am. All jobs scheduled during these hours require a minimum team of two. This restriction reflects the increased risks associated with working in the dark, reduced availability of support services, greater difficulty for emergency services in locating the property, and the increased vulnerability of a worker who is alone at night. Where an emergency or urgent council referral requires work outside these hours, the Director must approve the job and confirm that a team of two or more is available. The on-call manager must be briefed and monitoring check-ins throughout the job.
Remote and rural locations
Some of our work takes place in rural or remote areas where mobile phone signal may be unreliable and emergency services response times may be longer. For lone working in these locations, we take the following additional steps: we check mobile phone signal strength at the property before the job begins (during the risk assessment or site visit), where signal is poor we provide the lone worker with a satellite-enabled personal safety device or arrange paired working instead, we allow additional travel time so that the lone worker is not rushed, we confirm the exact location (including what3words or grid reference where necessary) and share it with the office before the job starts, and we reduce the check-in interval to every 30 minutes. If we cannot confirm reliable communication from a remote location, lone working is not permitted.
Safety measures
We provide lone workers with a mobile phone with full charge. The office holds a record of the employee's location, expected duration of work, and contact details. Employees have access to a dedicated lone worker monitoring system with Global Positioning System (GPS) tracking and panic alert functionality. The system is monitored during all working hours, including weekends and bank holidays, by the office or on-call manager. Lone workers carry a personal safety alarm. All lone workers have access to a hands-free communication method so they can contact the office while keeping their hands free if needed. We make sure that lone workers' vehicles are properly maintained, fuelled, and carry a basic emergency kit including a first aid kit, torch, high-visibility vest, and phone charger.
GPS tracking and data protection
Our lone worker monitoring system collects employee location data through GPS tracking. We process this data on the basis of legitimate interests under Article 6(1)(f) of the UK General Data Protection Regulation (UK GDPR) (protecting the health and safety of lone workers) and our legal obligations under the Health and Safety at Work etc. Act 1974. We have conducted a Data Protection Impact Assessment for this processing. GPS tracking operates only during working hours and is deactivated outside of shifts. Location data is retained for 30 days and then deleted. Access to location data is restricted to the office or on-call manager responsible for lone worker monitoring. Employees are informed of the tracking through their employment terms and this policy. For full details of how we handle personal data, see our Privacy Policy.
Check-in procedures
Lone workers must check in with the office on arrival at the client's property and again on departure. For jobs exceeding two hours, additional check-ins are required at agreed intervals, normally every hour. For jobs in remote or rural locations, check-ins are required every 30 minutes. Each check-in must include a brief confirmation that the worker is safe and that conditions are as expected. If a check-in is missed, the office will attempt to contact the employee by phone within 10 minutes. If contact cannot be made within 20 minutes of the scheduled check-in, the office will activate the GPS tracking system to confirm the employee's location, attempt to contact the employee by all available means, contact the employee's emergency contact, and if necessary, contact the emergency services and dispatch a colleague to the location. We log all check-ins and any escalation actions taken.
Violence and aggression
Our staff may encounter verbal abuse, threats, intimidation, or physical aggression while working alone in clients' homes. We take all forms of violence and aggression seriously, whether directed at our staff by clients, their visitors, neighbours, or anyone else present at the property. Our approach to managing this risk includes gathering information from the referring council or agency about any known history of violence or aggression before the job begins, recording any incidents of violence or aggression on the client's file so that future risk assessments reflect the full picture, never requiring a lone worker to enter or remain in a property where they feel threatened, training all staff in conflict awareness and de-escalation techniques as part of their lone working training (see the Training section below), and supporting any employee who has experienced violence or aggression through our post-incident support procedures. If a lone worker experiences or witnesses violence or aggression, they must leave the property immediately where safe to do so, contact the office, and complete an incident report. Where a body-worn camera is in use in line with our Body-Worn Camera Policy, the footage may be used as evidence when reporting the incident. We report all violent incidents under our Incident Reporting Policy and to the relevant council partner where the work was carried out under a council referral. Where a criminal offence has been committed, we support the employee in reporting the matter to the police. If the violence or aggression is discriminatory in nature (for example, based on the employee's race, sex, religion, or any other protected characteristic), we also address this under our Equality and Diversity Policy.
Emergency procedures
If a lone worker encounters an emergency, including a medical emergency, aggressive behaviour, structural danger, or any situation where they feel unsafe, they should leave the property immediately where safe to do so and contact the office or emergency services. If the lone worker cannot make a phone call, they should activate the panic alert on their lone worker monitoring device. The office will coordinate the response, including contacting emergency services if the employee cannot do so, dispatching a colleague to the location, and notifying the employee's emergency contact. After any emergency, we carry out a full review of what happened, what worked well, and what we can improve. We record all emergencies in line with our Incident Reporting Policy.
Post-incident support
We recognise that lone working incidents, including violence, aggression, threats, accidents, or distressing situations in clients' homes, can have a lasting effect on an employee's mental health and wellbeing. After any incident, we provide the following support. The employee is stood down from lone working duties for at least the rest of the working day. A manager contacts the employee within 24 hours of the incident to check on their wellbeing. We offer access to professional counselling through our Employee Assistance Programme (EAP) at no cost to the employee. Where the incident involved violence or a traumatic event, we offer a structured debrief with a trained manager or external professional within 72 hours. We do not require the employee to return to the same property. If the employee needs time off to recover, we support this through our normal absence procedures. We follow up with the employee at 1 week, 1 month, and 3 months after a serious incident to check on their recovery and offer further support if needed. No employee will be penalised or treated unfairly for reporting an incident or for needing time to recover. If an employee has concerns about how an incident was handled, they can raise them through our Complaints Procedure or our Whistleblowing Policy.
Mental health and wellbeing
Working alone, particularly in challenging environments such as the homes of vulnerable adults, can affect an employee's mental health over time, even without a specific incident. We are committed to supporting the wellbeing of all lone workers. We do this by making sure that lone workers are not isolated from the rest of the team (we include them in team briefings, training days, and social activities), encouraging open conversations about mental health and providing a supportive environment where staff feel comfortable raising concerns, rotating lone working duties so that the same employee is not always working alone, monitoring workload and scheduling to prevent excessive lone working, training managers to recognise signs of stress, anxiety, or low mood in lone workers, providing access to the Employee Assistance Programme (EAP) for confidential support at any time, and carrying out regular one-to-one check-ins between managers and lone workers to discuss how they are coping. If a lone worker tells us they are struggling, we will work with them to adjust their duties, reduce lone working, or provide additional support as needed.
Insurance
Our employers' liability insurance and public liability insurance cover lone working activities carried out in accordance with this policy. Employees must follow the procedures set out in this policy, including risk assessments, check-in procedures, and safety measures, to make sure that insurance cover remains valid. Following these procedures is important for everyone's protection; however, if an employee is injured while lone working, we will always support them regardless of the circumstances. We review our insurance cover annually to make sure it remains appropriate for the types of lone working we carry out. Details of our current insurance cover are available from the office on request.
Council notification
Where a lone working incident occurs during work carried out under a council referral or contract, we notify the relevant council partner promptly. This includes any violent or aggressive incident involving a client or anyone at the property, any emergency requiring attendance by the police, ambulance, or fire service, any safeguarding concern identified during the visit, and any escalation from lone to paired working that suggests the referral information was incomplete or inaccurate. We share relevant details with the council in line with our data-sharing agreements and Privacy Policy. Where a council partner has its own lone working or incident reporting protocol, we follow it alongside our own procedures. We cooperate fully with any council investigation into a lone working incident.
Training
All employees who may work alone receive specific lone working training before they carry out any lone working duties. Training covers personal safety awareness, conflict awareness and de-escalation techniques, recognising and responding to signs of violence and aggression, the check-in procedure and what to do if something goes wrong, emergency procedures including use of the panic alert, how to carry out a dynamic risk assessment on arrival at a property, mental health awareness and knowing when to ask for help, and use of the lone worker monitoring system and GPS device. We refresh this training annually. We also provide additional training after any serious incident or where we identify gaps through incident reviews. We consider individual medical fitness for lone working as part of our risk assessment and will adjust duties where necessary. Training records are maintained in line with our Training and Development Policy.
System testing
The Director is responsible for making sure our lone worker monitoring system is tested and working properly. We test the system, GPS tracking, panic alerts, and check-in escalation procedures at least every three months. Testing includes a simulated missed check-in to confirm the escalation procedure works from start to finish, a test of the panic alert function on each device, confirmation that GPS tracking is accurate and responsive, and a check that all emergency contact details are up to date. We record the results of each test and address any faults within 24 hours. If a fault cannot be fixed within 24 hours, lone working is suspended until the system is fully operational.
Record keeping
We keep records of all lone working risk assessments, check-in logs, incident reports, escalation actions, post-incident support provided, training completed, and system test results. These records are stored securely and access is restricted to management. The legal basis for processing personal data in lone working records is legal obligation under Article 6(1)(c) of the UK General Data Protection Regulation (UK GDPR), and where health data is involved, the condition at Article 9(2)(b) (employment obligations) and Schedule 1 Part 1 of the Data Protection Act 2018. We retain lone working records for a minimum of 3 years. Where a record relates to an incident reportable under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR), we retain it for a minimum of 6 years. Records are available for audit or inspection by council partners and regulatory bodies on request.
Related policies
This policy should be read alongside our Health and Safety Policy, which sets out our overall approach to workplace safety; our Risk Assessment Policy, which covers how we identify and control workplace risks; our Incident Reporting Policy, which covers how we report and investigate incidents; our Safeguarding Policy, which covers our duty to protect vulnerable adults; our Privacy Policy, which explains how we handle personal data including GPS tracking data; our Training and Development Policy, which covers our training programme; our Body-Worn Camera Policy, which covers the use of cameras during service delivery; our Equality and Diversity Policy, which covers fair treatment and our response to discriminatory behaviour; our Whistleblowing Policy, which provides a safe route for raising concerns about how incidents are handled; and our Complaints Procedure, which covers how we handle complaints.
Changes to this policy
We may update this policy from time to time. Any changes will be posted on this page with an updated date. Where we make material changes that affect lone working procedures, safety measures, check-in requirements, or escalation processes, we will notify all employees directly and provide updated training where needed.
Review
The Director, Lance James, reviews this policy annually or following any lone working incident or near miss. We also review the policy if there are changes to our services, our council contracts, or relevant legislation. Last reviewed: February 2026. Next review due: February 2027.
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