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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Best Practice in Intimate Personal Care Policy

1. Purpose

This policy sets out {{org_field_name}}’s arrangements for ensuring that intimate personal care is provided safely, lawfully and in a person-centred manner that protects each person’s dignity, privacy, autonomy, rights and well-being.

{{org_field_name}} will ensure that intimate personal care is provided in accordance with the Health and Social Care Act 2008, the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (as amended), including Regulation 9 – Person-centred care, Regulation 10 – Dignity and respect, Regulation 11 – Need for consent, Regulation 12 – Safe care and treatment, Regulation 13 – Safeguarding service users from abuse and improper treatment, Regulation 17 – Good governance and Regulation 18 – Staffing, together with the Mental Capacity Act 2005 and other applicable legislation.

Intimate personal care will be planned and delivered according to each person’s assessed needs, preferences, communication needs, wishes, beliefs and relevant protected characteristics. Staff will promote independence wherever possible, obtain and respect lawful consent, protect privacy, manage identified risks and provide care only within the limits of their training, competence and role.

2. Scope

This policy applies to all staff involved in the provision of intimate personal care at {{org_field_name}}, including nurses, care assistants, and support staff. It covers all aspects of personal care, including washing, dressing, toileting, continence care, and menstrual care, ensuring best practices are followed to uphold dignity and safety.

3. Principles of Best Practice in Intimate Personal Care

• Dignity and Respect: All personal care must be delivered with respect for the individual’s preferences, privacy, and cultural beliefs.
• Person-Centred Care: Care should be tailored to each individual’s needs, preferences, and comfort levels.
• Consent and Choice: Individuals must be involved in decisions about their care and given choices wherever possible.
• Privacy and Confidentiality: Care must be provided in a discreet manner, ensuring individuals feel safe and respected.
• Safeguarding and Safety: Staff must remain vigilant for any safeguarding concerns and follow proper protocols to protect individuals.
• Infection Prevention and Hygiene: Proper hygiene and infection control procedures must be maintained at all times.

4. Providing Intimate Personal Care Safely and Respectfully

Gaining and Maintaining Consent

• Staff must obtain lawful consent before providing intimate personal care, unless there is another lawful basis for providing the care.
• Before providing care, staff must explain what they propose to do, why the care is required and, where relevant, any significant risks, alternatives or choices, using communication that the person can understand.
• Staff must provide information in an accessible way and make reasonable adjustments where required. This may include using pictures, symbols, communication aids, interpreters, advocates or other appropriate communication support.
• Consent may be expressed verbally, in writing, through appropriate non-verbal communication or, where legally valid and sufficiently clear, by the person’s actions.
• Consent must be treated as an ongoing process and not as a one-off event. Staff must continue to observe the person’s verbal and non-verbal responses throughout intimate personal care.
• A person may refuse or withdraw consent at any time. Where a person with capacity refuses or withdraws consent, staff must stop the care, unless immediate action is otherwise lawfully justified, and must record and appropriately escalate any resulting risks or concerns.
• Staff must not use pressure, coercion, threats or inappropriate influence to obtain consent.
• Staff must never assume that a person lacks capacity because of their age, diagnosis, disability, appearance, behaviour or because they make a decision that others consider unwise.
• Where there is reason to doubt a person’s capacity to make a particular decision about intimate personal care, capacity must be assessed in accordance with the Mental Capacity Act 2005. Capacity is decision-specific and time-specific.
• All practicable steps must first be taken to support the person to make the decision themselves.
• Where the person is assessed as lacking capacity for the particular decision, any decision or action taken on their behalf must comply with the Mental Capacity Act 2005, including the statutory best-interests requirements and the requirement to choose the least restrictive available option.
• Staff must identify and take account of any relevant advance decision, Lasting Power of Attorney, deputy appointed by the Court of Protection or other person who has lawful authority to act in relation to the particular decision.
• Where appropriate, family members, carers, advocates and others interested in the person’s welfare must be consulted as required by the Mental Capacity Act 2005, but they must not be treated as having authority to consent unless they have the appropriate lawful authority.
• Capacity assessments, best-interests decisions, consent, refusals and withdrawal of consent relating to intimate personal care must be recorded appropriately.

Maintaining Privacy and Dignity

• Staff must treat every person with dignity and respect throughout intimate personal care.
• Staff must knock and obtain permission before entering a person’s private room or space, except where there is an immediate emergency or another lawful reason for entering.
• Doors, curtains and screens must be used appropriately to maintain privacy.
• Only those staff whose presence is necessary for safe care should normally be present during intimate personal care, taking account of the person’s wishes and assessed needs.
• Staff must minimise unnecessary exposure of the person’s body and use towels, clothing, blankets or other appropriate coverings where possible.
• Discussions about intimate care, continence, personal hygiene or health must take place discreetly and must not be unnecessarily overheard by other people.
• Privacy must be respected irrespective of whether the person is asleep, unconscious or lacks capacity.
• Staff must explain each stage of intimate personal care and must not expose, touch or proceed with intimate areas of care unnecessarily.

Supporting Independence

• Staff must encourage and support people to carry out as much of their own personal care as they are willing and able to undertake safely.
• The person’s care plan must identify the level of assistance required and the steps that staff should take to promote independence.
• Appropriate equipment, adaptations and reasonable adjustments must be provided where required following assessment.
• Identified risks must be managed in a way that supports the person’s autonomy and independence while taking reasonable steps to prevent avoidable harm.

Preferences About Staff Providing Intimate Care

• The person’s preferences about who provides their intimate personal care, including preferences concerning the sex or gender of the staff member, must be identified, recorded and respected as far as reasonably practicable.
• Staff must take account of the person’s cultural, religious and other relevant preferences and protected characteristics.
• Where a stated preference cannot reasonably be met, this must be discussed sensitively with the person and, where appropriate, the person lawfully acting on their behalf. Any agreed alternative arrangements must be documented.

Communication

• Staff must communicate respectfully before, during and after intimate personal care.
• Communication must be appropriate to the person’s individual needs and preferences.
• Staff must observe verbal and non-verbal indications of discomfort, distress, refusal, pain or withdrawal of consent and respond promptly.
• Any significant change in communication, behaviour, presentation, pain or distress identified during personal care must be recorded and escalated in accordance with the person’s care plan and the service’s procedures.

5. Specific Areas of Intimate Personal Care

Washing, Bathing and Personal Hygiene

• Intimate washing and bathing must be provided in accordance with the person’s assessed needs, preferences, care plan and consent.
• Staff must maintain privacy and minimise unnecessary exposure throughout the care.
• Water used for washing or bathing must be at a safe and comfortable temperature appropriate to the person and any identified risks.
• People must be supported to wash themselves as independently as possible and staff should assist only with areas for which assistance is required.
• Skin must be dried appropriately, particularly within skin folds and other areas vulnerable to moisture damage, where this forms part of the person’s assessed care needs.
• Any new or worsening redness, bruising, wound, rash, skin breakdown, pressure damage, swelling, pain or other concern identified during personal care must be recorded and escalated promptly in accordance with the person’s care plan and clinical needs.

Toileting and Continence Care

• Toileting and continence support must be provided promptly, discreetly and respectfully and in accordance with the person’s assessed needs and preferences.
• People must have reasonable access to toilet facilities and must not be left unnecessarily in wet or soiled clothing, bedding or continence products.
• Continence products must be used in accordance with assessed need and relevant professional advice.
• Staff must preserve the person’s privacy and dignity during changing, cleansing and disposal procedures.
• Skin condition must be monitored where required by the person’s care plan, and signs of moisture-associated skin damage, pressure damage, infection or other deterioration must be recorded and escalated promptly.

Menstrual Care

• Menstrual care must be provided privately, sensitively and in accordance with the person’s needs, preferences and consent.
• Appropriate menstrual hygiene products must be made available according to individual need and preference.
• Staff must support the person to manage their own menstrual care as independently as possible.
• Unusual bleeding, pain or other significant concerns must be recorded and escalated for appropriate review.

Catheter and Stoma Care

• Catheter and stoma care must be provided only by staff who have received the training and competency assessment necessary for the task they are required to perform.
• Staff must work within the limits of their role, training and competence and must seek advice or assistance where a task falls outside their competence.
• Care must be provided in accordance with the person’s individual care plan, relevant professional instructions and infection prevention and control requirements.
• Appropriate hand hygiene and personal protective equipment must be used.
• Staff must monitor for signs of complications relevant to the person, including pain, leakage, blockage, bleeding, skin damage, infection or unexpected changes in output, and must record and escalate concerns promptly in accordance with the person’s care plan and clinical needs.

Dressing and Undressing

• People must be supported to choose their clothing wherever they are able to do so.
• Staff must take account of the person’s wishes, dignity, culture, religion, identity, comfort, weather conditions and assessed needs.
• Dressing and undressing must be carried out with the minimum necessary intrusion and exposure.
• People must be supported to undertake as much of the activity independently as they are able and willing to do safely.

6. Safeguarding and Recognising Abuse

Preventing Abuse and Improper Treatment

• Intimate personal care must never be provided in a manner that is abusive, degrading, discriminatory, neglectful, unnecessarily restrictive, rough, punitive or deliberately disrespectful.
• Staff must obtain and respect lawful consent in accordance with Section 4 of this policy and the Mental Capacity Act 2005 where applicable.
• No person may be subjected to unnecessary or disproportionate control or restraint during intimate personal care.
• Any restriction, restraint or intervention used to prevent harm must have a lawful basis and must be necessary and proportionate to the risk presented.
• A person must not be deprived of their liberty for the purpose of receiving care or treatment without lawful authority.
• Care must not significantly disregard the person’s assessed needs or leave them unnecessarily in an undignified condition.

Recognising Possible Abuse or Neglect

Staff must remain alert to signs that may indicate abuse, neglect or improper treatment, including:

• unexplained injuries, bruising, bleeding or marks;
• unexplained genital or intimate-area injuries;
• signs of sexual abuse or inappropriate sexual contact;
• distress, fear, withdrawal or significant behavioural change associated with personal care;
• fear of, or reluctance to receive care from, a particular staff member or other person;
• recurrent poor hygiene, untreated skin damage or avoidable soiling;
• repeated failure to provide required continence or personal care;
• inappropriate restraint, coercion, humiliation or degrading treatment;
• unexplained pain or distress during intimate personal care;
• any disclosure, allegation or indication that a person may have experienced abuse or neglect.

Staff must not investigate suspected abuse themselves beyond taking the immediate steps necessary to establish safety, obtain essential information and preserve evidence. Safeguarding concerns must be managed in accordance with CH13-Safeguarding Adults from Abuse and Improper Treatment Policy.

Immediate Action and Reporting

• Any member of staff who witnesses, suspects, receives an allegation of, or identifies evidence of abuse or neglect must take immediate action to safeguard the person from further harm.
• Where there is an immediate danger to life or a serious immediate risk of harm, staff must contact the emergency services by calling 999 and take reasonable action to protect the person.
• The concern must be reported immediately to the Registered Manager, Safeguarding Lead or the senior person responsible on duty in accordance with the service’s safeguarding procedure.
• The Registered Manager or Safeguarding Lead must ensure that appropriate safeguarding referrals are made to the relevant local authority adult safeguarding service where the statutory safeguarding criteria are met or where otherwise required.
• Where a crime is suspected, consideration must be given to referral to the police without delay in accordance with safeguarding procedures and the circumstances of the case.
• Where the concern involves the Registered Manager, Safeguarding Lead or another person to whom the concern would normally be reported, staff must use the service’s alternative senior-management, whistleblowing or external safeguarding reporting arrangements and must not report solely to the person implicated.
• Staff must preserve relevant evidence and must make an accurate, factual and contemporaneous record of what was observed, disclosed, reported and done.
• The provider must investigate, or cooperate with investigation of, allegations or evidence of abuse in accordance with Regulation 13 and applicable safeguarding procedures.
• The provider must notify the Care Quality Commission without delay where an incident is notifiable under the Care Quality Commission (Registration) Regulations 2009, including abuse or an allegation of abuse in relation to a person using the service.
• Other statutory notifications or referrals must be made where required.

Internal Contact Arrangements

• Safeguarding concerns must be reported to the Registered Manager or Safeguarding Lead at: {{org_field_registered_manager_email}}.
• The Registered Manager or Safeguarding Lead can be contacted by telephone on: {{org_field_phone_no}}.
• Outside normal office hours, staff must use the designated out-of-hours number: {{out_of_hours}}.
• Internal reporting must never delay contacting emergency services, the local authority safeguarding service, the police or another statutory body where immediate external referral is required.

7. Infection Prevention and Control in Personal Care

General Requirements

• Intimate personal care must be provided in a way that minimises the risk of infection to people receiving care, staff and others.
• Staff must follow CH17-Infection Prevention and Control Policy, current infection prevention and control procedures, the person’s individual care plan and any additional precautions identified through risk assessment.
• Infection risks associated with intimate personal care must be assessed and proportionate measures implemented to prevent, detect and control the spread of infection.
• Staff must follow relevant current statutory infection prevention and control requirements and applicable guidance.

Hand Hygiene

• Staff must perform hand hygiene at the appropriate points before, during and after personal care in accordance with infection prevention and control procedures.
• Gloves do not replace the need for hand hygiene.
• Any cuts or broken skin on staff members’ hands must be managed in accordance with infection prevention and control requirements.

Personal Protective Equipment

• Appropriate personal protective equipment, including gloves and aprons where indicated, must be selected and used according to the task and assessed risk of exposure to blood, body fluids, secretions, excretions or contaminated materials.
• Personal protective equipment must be changed between people and between tasks where required to prevent cross-contamination.
• Used personal protective equipment must be removed and disposed of safely.

Disposal of Waste

• Continence products, menstrual products, gloves, aprons and other personal-care waste must be disposed of in accordance with the service’s waste-management and infection prevention and control procedures.
• Waste contaminated with blood, body fluids or other potentially infectious material must be handled and disposed of using the appropriate waste stream.
• Staff must prevent contamination of hands, clothing, equipment and the environment while handling waste.

Cleaning, Decontamination and Laundry

• Bathrooms, toilets, commodes, reusable personal-care equipment and other contaminated surfaces or equipment must be cleaned and decontaminated in accordance with the service’s infection prevention and control procedures.
• Equipment intended for single-person use must not be shared unless it has been designed for reuse between people and can be appropriately decontaminated.
• Soiled or contaminated linen and clothing must be handled, transported and laundered in accordance with the service’s laundry and infection prevention and control arrangements.
• Clean and contaminated items must be managed in a way that prevents cross-contamination.

Escalating Infection Concerns

• Staff must report signs or symptoms of infection, suspected outbreaks, failures in infection prevention and control practice or contamination incidents promptly in accordance with the service’s escalation procedures.
• Appropriate professional or health protection advice must be sought where required.

8. Staff Training and Competency

Training and Development

• Staff must not undertake intimate personal care unless they have received the induction, information, instruction, training, supervision and competency assessment necessary for the duties they are required to perform.
• Training and development requirements must be appropriate to each member of staff’s role, responsibilities and the needs of the people they support.
• Training needs must be assessed at the start of employment and reviewed at appropriate intervals and whenever there are changes to the staff member’s role, relevant legislation or guidance, equipment, procedures or the needs and risks of people using the service.
• Staff must receive appropriate training relevant to their duties, including training necessary to maintain competence in dignity and respect, consent and the Mental Capacity Act 2005, safeguarding, infection prevention and control, moving and handling where applicable, and any specific personal-care or clinical procedures they are expected to undertake.
• The frequency of refresher or update training must be determined by applicable statutory requirements, recognised guidance, the provider’s assessment of risk, staff competency and the requirements of the role rather than by an automatic annual interval unless an annual interval is specifically required.

Statutory Learning Disability and Autism Training

• {{org_field_name}} must ensure that staff receive training on learning disability and autism, including how to interact appropriately with autistic people and people with a learning disability, at a level appropriate to their role.
• This requirement applies across the registered service and is not limited to staff working in a specialist learning disability or autism service.
• The service must be able to demonstrate that relevant staff have received the appropriate training and that their competence is supported and monitored.

Competency

• Staff must work only within the limits of their qualifications, training, skills, competence and experience.
• Staff learning a new personal-care or clinical task must receive appropriate supervision until they have demonstrated the required level of competence to undertake the task safely.
• Competency must be assessed by a person who is appropriately skilled and competent to make that assessment.
• Competency must be reviewed where required to ensure that it is maintained and must be reassessed where concerns, incidents, changes in practice or changes in the person’s needs indicate that this is necessary.
• Staff must seek assistance and must not undertake a procedure where they do not have the required knowledge, training or competence.

Supervision, Appraisal and Support

• Staff must receive appropriate ongoing supervision, support, professional development and appraisal necessary to enable them to carry out their duties safely and competently.
• Supervision must provide opportunities to identify concerns about dignity, consent, safeguarding, boundaries, infection prevention and control and the safe delivery of intimate personal care.
• Identified training or competency deficits must be acted upon promptly and staff must not undertake tasks unsupervised where they have not demonstrated the required competence.

Training and Competency Records

• The service must maintain appropriate records of induction, training, supervision, appraisal and competency assessments.
• Training compliance and identified learning needs must be monitored, and appropriate action must be taken where required training or competency requirements have not been met.

9. Documentation and Record-Keeping

Care Plans and Assessments

• Each person who requires intimate personal care must have an accurate and current care plan based on an assessment of their individual needs, preferences and relevant risks.
• The care plan must record, where relevant:
  • the personal care assistance required;
  • what the person can and wishes to do independently;
  • personal preferences concerning how care is provided;
  • privacy and dignity requirements;
  • communication needs and reasonable adjustments;
  • relevant cultural, religious and protected-characteristic considerations;
  • preferences about staff providing intimate personal care;
  • continence and skin-care requirements;
  • equipment or adaptations required;
  • identified risks and measures for managing those risks;
  • relevant professional instructions;
  • consent arrangements; and
  • any relevant capacity assessments, best-interests decisions, advance decisions or lawful representatives.
• Assessments and care plans must be reviewed when the person’s needs, risks, preferences or circumstances change and at other intervals determined by the service’s care-planning arrangements.

Records of Care Provided

• Records relating to intimate personal care must be accurate, complete, factual, contemporaneous and sufficiently detailed to demonstrate the care and support provided and any relevant decisions made.
• Staff must record personal care in accordance with the person’s care plan and the service’s record-keeping procedures.
• Records must include relevant refusals of care, withdrawal of consent, significant distress, changes in presentation and any departure from the planned care.
• Any new or worsening skin damage, unexplained bruising, bleeding, pain, infection, change in continence, deterioration in health or other significant concern identified during intimate personal care must be recorded and escalated appropriately.
• Actions taken in response to identified concerns must also be recorded.

Consent and Mental Capacity Records

• Where relevant, records must demonstrate how consent was obtained and any significant refusal or withdrawal of consent.
• Where a person’s capacity to make a particular decision is in doubt, the assessment and outcome must be recorded in accordance with the Mental Capacity Act 2005 and the service’s procedures.
• Where a decision is made for a person who lacks capacity, the record must demonstrate the basis for the decision, the applicable best-interests process and relevant consultation.
• Any lawful authority relied upon, including a relevant Lasting Power of Attorney, Court-appointed deputy or applicable advance decision, must be appropriately identified and recorded.

Safeguarding and Incident Records

• Safeguarding concerns, allegations, disclosures and incidents relating to intimate personal care must be documented promptly and factually and managed in accordance with CH13-Safeguarding Adults from Abuse and Improper Treatment Policy.
• Required internal incident reports, safeguarding referrals and statutory notifications must be completed without delay in accordance with applicable requirements.
• CQC notifications must be made where required by the Care Quality Commission (Registration) Regulations 2009 and in accordance with CH25-Notification of Other Incidents Policy.

Security and Confidentiality of Records

• Records relating to intimate personal care must be stored and maintained securely.
• Access must be limited to people with a legitimate reason to access the information.
• Confidential information must be shared only where there is a lawful basis for doing so and in accordance with the service’s confidentiality and data-protection arrangements.
• Records must not contain disrespectful, judgemental, discriminatory or inappropriate language.

10. Involvement of People, Families and Lawful Representatives

Involvement of the Person

• The person receiving care must be placed at the centre of the assessment, planning, delivery and review of their intimate personal care.
• People must be supported to express their wishes, preferences and choices and to participate in decisions about their care to the maximum extent possible.
• Information must be provided in a format and manner that the person can understand, with reasonable adjustments or communication support where required.
• A person’s decision to involve, or not involve, family members or other people in their care must be respected where the person has capacity to make that decision.

Families, Representatives and Advocates

• Family members, friends and representatives must not automatically be treated as having authority to make decisions about an adult’s intimate personal care merely because of their relationship with the person.
• Where the person has capacity, information about their intimate personal care must only be shared with relatives or representatives with the person’s consent or where there is another lawful basis for sharing it.
• Where a person lacks capacity in relation to a particular decision, staff must act in accordance with the Mental Capacity Act 2005.
• Where appropriate, people interested in the person’s welfare, including family members or carers, must be consulted as part of the best-interests process, but consultation does not itself give that person authority to consent on the individual’s behalf.
• Where a person holds a valid and applicable Lasting Power of Attorney, is a deputy appointed by the Court of Protection or otherwise holds lawful decision-making authority, their authority must be verified and respected within its legal scope.
• Where the person has substantial difficulty participating in relevant decisions and the statutory criteria for advocacy are met, appropriate arrangements must be made for advocacy in accordance with applicable legislation.

Feedback and Concerns

• People receiving intimate personal care must be able to raise concerns, make choices and provide feedback about how their care is provided without fear of disadvantage.
• Communication methods must be adapted where necessary to enable the person to express concerns or preferences.
• Feedback or concerns about dignity, privacy, consent or the delivery of intimate personal care must be considered and acted upon appropriately.
• Any indication that the person may be frightened of a particular member of staff, reluctant to receive care from them or distressed by the manner in which personal care is provided must be taken seriously, documented and escalated appropriately.

11. Related Policies

• CH08-Dignity and Respect Policy
• CH07-Person-Centred Care Policy
• CH13-Safeguarding Adults from Abuse and Improper Treatment Policy
• CH17-Infection Prevention and Control Policy
• CH18-Risk Management and Assessment Policy
• CH27-Staff Supervision, Training, and Development Policy

12. Policy Review

• This policy will be reviewed annually or sooner if new CQC regulations or best practice guidelines emerge.
• Amendments will be made to ensure continued compliance with regulatory and clinical best practices.
• Feedback from staff and the people we support will be incorporated into the review process.

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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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