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{{org_field_name}}
Registration Number: {{org_field_registration_no}}
Challenging Behaviour Management Policy
1. Purpose
The purpose of this policy is to provide a consistent, safe, and person-centred framework for recognising, understanding, and supporting individuals whose behaviour may be perceived as challenging. At {{org_field_name}}, we are committed to promoting dignity, inclusion, and wellbeing for every person we support, and we recognise that behaviour is a form of communication that must be responded to with empathy, respect, and professionalism.
This policy is designed to guide staff in understanding triggers, reducing distress, and preventing escalation of behaviours that challenge, while ensuring safety and legal compliance. It is also intended to provide clarity and assurance to regulators, families, and partner agencies.
We uphold the principles of the Health and Social Care Standards, which state:
- “I am supported to understand and uphold my rights” (Standard 2.3)
- “I experience care and support where all people are respected and treated with dignity” (Standard 3.1)
- “If my independence, control and choice are restricted, this complies with relevant legislation and is justified, through risk assessment, and is kept to a minimum” (Standard 1.6)
2. Scope
This policy applies to all staff working for {{org_field_name}}, including:
- Care workers (permanent, temporary, and agency)
- Supervisory and management staff
- Volunteers
- Contractors engaged in care support activities
It applies to all situations in which people we support may display behaviour that challenges others, including verbal aggression, physical resistance, emotional outbursts, refusal of care, withdrawal, or behaviours that pose a risk to themselves or others.
3. Related Policies
This policy should be read in conjunction with:
- Risk Assessment and Management Policy
- Positive Behaviour Support Policy
- Safeguarding and Protection from Abuse Policy
- Incident Reporting and Notification Policy
- Personal Planning and Outcomes Policy
- Staff Training and Supervision Policy
- Mental Capacity and Consent Policy
3.1 Legal and regulatory framework
This policy must be read and applied in line with relevant legislation and regulatory requirements, including (but not limited to):
- Regulation of Care (Scotland) Act 2001 (regulation of care services and role of the Care Inspectorate).
- Public Services Reform (Scotland) Act 2010 (Care Inspectorate regulatory powers).
- Public Services Reform (Scotland) Act 2010 (Requirements for Care Services) Regulations 2011 (SSI 2011/210), including duties around personal plans, risk management and reviews.
- Adult Support and Protection (Scotland) Act 2007 (duty to act where an adult is at risk of harm).
- Adults with Incapacity (Scotland) Act 2000 (capacity, consent, welfare guardianship/power of attorney; decision-making principles).
- Mental Health (Care and Treatment) (Scotland) Act 2003 where relevant to the person’s legal status and safeguards.
- Health (Tobacco, Nicotine etc. and Care) (Scotland) Act 2016 and The Duty of Candour Procedure (Scotland) Regulations 2018 (organisational duty of candour).
- Equality Act 2010 (non-discrimination and reasonable adjustments).
- Human Rights Act 1998 (rights-based, least-restrictive practice).
- Data Protection Act 2018 / UK GDPR (lawful, secure recording and sharing of information).
- Health and Safety legislation relevant to safe systems of work and incident reporting.
4. Policy Statement
At {{org_field_name}}, we believe that all behaviour has meaning and is often an expression of unmet need, discomfort, distress, trauma, or lack of communication. We do not label people as “challenging”, but rather acknowledge that our role is to understand and respond appropriately to behaviours that may challenge the service, staff, or others.
We commit to:
- Supporting people with compassion, patience, and respect
- Using trauma-informed approaches that consider the person’s life history
- Promoting Positive Behaviour Support (PBS) as the preferred model
- Ensuring that restrictions or interventions are used only as a last resort, and are time-limited, proportionate, and legally justified
- Equipping staff with the skills and confidence to respond safely and supportively
5. Definitions
- Behaviour that challenges: Behaviour that presents risk or distress to the individual, staff, or others, and/or significantly impacts the quality of life or care delivery. This may include aggression, self-injury, property damage, or significant non-compliance.
- Positive Behaviour Support (PBS): A values-based, evidence-informed approach focused on understanding the reasons for behaviour and supporting people to achieve a better quality of life.
- Restrictive practice: Any planned or unplanned act (or omission) that restricts a person’s rights, freedom of movement, privacy, access to activities, or choice/control, including (but not limited to) physical restraint, seclusion, environmental restriction, constant/continuous supervision that is not proportionate, removal of mobility aids, restricted access to parts of the home, locked doors/keys held by staff, and chemical restraint (use of medication primarily to control behaviour rather than to treat an assessed health need). Restrictive practice must be lawful, necessary, proportionate, time-limited, recorded, reviewed, and the least restrictive option.
- Physical restraint: The use of physical contact by one or more staff to restrict a person’s movement.
- Seclusion: Preventing a person from leaving a room/area (whether by locking, blocking exits, or intimidation), where the primary purpose is behavioural control.
- Chemical restraint: Medication used primarily to control behaviour or restrict movement (not prescribed/used primarily to treat an identified medical condition).
- Environmental restriction: Restricting access to items/areas/activities (including within a person’s own home) in a way that reduces rights, choice or liberty.
6. Preventing Challenging Behaviour
Prevention is at the heart of our approach. We take steps to understand, anticipate, and reduce the likelihood of behaviour that challenges through:
6.1. Holistic and Person-Centred Planning
We work collaboratively with the person, their family, and other professionals to develop personal plans that reflect:
- Preferences, triggers, and early signs of distress
- Communication methods and sensory needs
- Past trauma, phobias, or medical conditions
- Risk factors and protective factors
Each plan includes clear behavioural support strategies and is regularly reviewed.
Where any restriction may be used (including environmental restriction or physical intervention), the person’s plan must clearly evidence: the lawful basis (including capacity/consent considerations), the specific trigger/threshold for use, de-escalation attempts required first, the least restrictive option, maximum duration, who may authoriseter any significant incident and at least in line with personal planning review requirements.
6.2. Promoting Communication
Many challenging behaviours stem from unmet communication needs. We support people to express themselves through:
- Communication aids (e.g., Talking Mats, pictorial cards)
- British Sign Language or interpreters
- Keyworker relationships built on trust and understanding
6.3. Environment and Routine
We ensure environments are calm, consistent, and suited to the person’s sensory needs. Predictable routines, clear expectations, and familiar carers reduce anxiety and build trust.
7. Recognising and Responding to Challenging Behaviour
When behaviour that challenges occurs, staff must respond using the following graduated approach:
7.1. Early Intervention and De-escalation
Staff are trained to recognise early warning signs (e.g., pacing, restlessness, vocal changes) and take proactive steps to de-escalate, such as:
- Offering time and space
- Distraction or redirection
- Using a calm tone and non-threatening body language
- Removing triggers where safe to do so
7.2. Using Positive Behaviour Support (PBS)
Every person with recognised behaviour that challenges will have a PBS Plan as part of their personal plan. This will include:
- Functional behaviour assessment (what purpose the behaviour serves)
- Strategies for prevention, teaching alternative behaviours, and reinforcing positive choices
- Crisis management strategies if escalation occurs
7.3. Managing Immediate Risk
If behaviour escalates and poses a risk of harm:
- Staff must prioritise safety of all individuals, using protective strategies agreed in the person’s support plan.
- Capacity and consent: Capacity and consent must be considered at every stage. Where there is reason to believe the person may lack capacity in relation to a specific decision at that time, staff must act in line with the principles of the Adults with Incapacity (Scotland) Act 2000, including taking account of any relevant legal authority such as a Welfare Power of Attorney or Welfare Guardianship Order, and must seek advice from a manager as soon as practicable.
- Outside the agreed plan: If a restrictive practice is being considered outside what is agreed in the person’s support plan, staff must escalate to the Registered Manager (or on-call manager) before acting, unless there is an immediate risk of serious harm that requires urgent action to protect the person or others.
- Use of force: Any use of force must be necessary and proportionate, used for the shortest time possible, and must trigger post-incident review, including consideration of whether the incident constitutes a safeguarding/adult protection concern and whether Care Inspectorate notification thresholds may have been met.
- Physical interventions (only by staff who are trained and authorised) must be used only as a last resort, be lawful, necessary and proportionate, and reflect a human-rights, trauma-informed and least restrictive approach, consistent with Care Inspectorate guidance and expectations on restrictive practice.
- The use of any restrictive intervention must be proportionate, time-limited, and recorded.
7.4. Post-Incident Support and Review
After any significant behavioural incident:
- The person supported will be offered reassurance, debriefing, and the opportunity to recover in a safe space.
- Staff involved will receive support, including reflective supervision if needed.
- The Registered Manager will review the incident to ensure any learning is applied.
- Where required, incidents will be notified to the Care Inspectorate and other relevant bodies.
Where an incident meets the Care Inspectorate notification criteria, the Registered Manager (or the on-call manager) must ensure the appropriate notification is submitted to the Care Inspectorate without delay and within the required timescales, in line with the current notification guidance for adult care services. Notifiable events may include (but are not limited to) the death of a person using the service, serious injury, serious accident or incident, allegations or concerns of abuse or harm, police involvement, significant service disruption, and allegations of staff misconduct. Where there is any uncertainty about whether an incident is notifiable, the Registered Manager must seek advice promptly and record the rationale for the decision made.
7.5 Duty of Candour
Where an unintended or unexpected incident occurs in the delivery of care and support that meets the criteria for the organisational Duty of Candour, {{org_field_name}} will follow the Duty of Candour procedure. This includes:
- providing the person (and/or their representative) with a meaningful apology,
- explaining what is known about what happened and what will be done to review/learn,
- offering support, and
- keeping a written record of all actions and correspondence relating to the procedure.
The Registered Manager is responsible for deciding when the Duty of Candour procedure applies and for ensuring it is completed in line with legal requirements.
8. Staff Training and Competency
We ensure all staff receive:
- Mandatory training in understanding behaviour that challenges
- Annual refresher courses in de-escalation and non-restrictive interventions
- Specific training in Positive Behaviour Support and trauma-informed care
- Supervision and mentoring by experienced senior staff
Staff are not permitted to use physical intervention unless trained and authorised to do so. Use of force outside training and policy parameters is a safeguarding concern and will be dealt with accordingly.
9. Partnership Working
{{org_field_name}} works in collaboration with:
- NHS community learning disability teams
- Social work and mental health teams
- Advocacy services
- Families, carers, and guardians
We take a multi-agency approach to planning and reviewing care for anyone with complex behavioural needs, ensuring support is comprehensive and coordinated.
10. Recording and Reporting
All incidents of behaviour that challenge must be recorded factually and respectfully.
Incident records must clearly state whether the event is notifiable to the Care Inspectorate and must document: (a) what notification was made (including the notification type/category), (b) who made it, (c) the date and time it was submitted, and (d) the Care Inspectorate reference/confirmation number (or other submission evidence). Where the incident is also a safeguarding/protection concern, staff must escalate it without delay in line with the Adult Support and Protection (Scotland) Act 2007 and local multi-agency adult protection procedures, and must record the actions taken (including referrals, advice received, and outcomes). Care Inspectorate notification requirements must be followed in parallel with adult protection procedures and must not replace them.
The report must include:
- What happened before, during, and after the behaviour
- What actions were taken, including de-escalation or restrictive interventions
- The impact on all involved
- What worked and what could be improved
The Registered Manager ({{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}) is responsible for:
- Reviewing all incidents
- Updating behaviour support plans
- Reporting to the Care Inspectorate when notifiable thresholds are met
11. Quality Assurance and Learning
We promote a culture of learning, not blame. All incidents involving behaviour that challenges are reviewed as part of:
- Team debriefs and reflective practice
- Monthly service audits
- Supervision and performance management
Lessons learned are used to update policies, training content, and risk assessments.
12. Safeguarding Considerations
Staff must be alert to the risk of:
- Behaviour being caused by abuse, neglect, pain, or illness
- Unwarranted use of restrictive practices
- Breach of human rights or dignity
If there is any concern that behaviour is a manifestation of abuse or distress caused by unmet needs, this must be escalated to the Safeguarding Lead ({{org_field_safeguarding_lead_name}}) immediately and the relevant safeguarding procedures followed.
13. Equality and Human Rights
{{org_field_name}} ensures that behaviour support strategies are not discriminatory and that all interventions:
- Uphold the person’s rights under the Human Rights Act 1998
- Are applied equitably regardless of gender, ethnicity, disability, or communication needs
- Are sensitive to cultural, spiritual, or neurodiverse differences
Any use of restrictive practices is only applied after risk assessment, is reviewed regularly, and is the least restrictive option possible.
14. Policy Review
This policy will be reviewed annually or sooner if there are:
- Changes in legislation or guidance
- Serious incidents requiring policy amendment
- Updates to the SSSC Codes of Practice or Care Inspectorate frameworks
The Registered Manager and Nominated Individual are responsible for coordinating reviews and ensuring changes are communicated and implemented.
Responsible Person: {{org_field_registered_manager_first_name}}{{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
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