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Registration Number: {{org_field_registration_no}}

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Technology-Enabled Care and Telecare Policy

1. Purpose

This policy outlines how {{org_field_name}} integrates technology-enabled care (TEC) and telecare solutions to improve care quality, promote independence, and ensure the safety of the people we support. It ensures that our digital and remote care interventions align with the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 and the principles set out in the Care Act 2014.

Technology is not used as a substitute for human care but as a complementary tool to enhance decision-making, streamline communication, reduce risks, and promote a better quality of life.

2. Scope

This policy applies to:

• All direct care staff and support workers using or supporting people with TEC or telecare
• Managers and team leaders overseeing the use of these systems
• External contractors or suppliers providing technical support
• People we support, families, and advocates engaged in technology-based interventions

It encompasses all technologies including fall sensors, GPS trackers, personal alarms, digital records, virtual consultations, and remote health monitoring tools.

3. Related Policies

To ensure seamless integration of TEC, this policy should be read alongside the following:

• CH04 – Good Governance
• CH07 – Person-Centred Care Policy
• CH09 – Consent to Care Policy
• CH11 – Safe Care and Treatment Policy
• CH13 – Safeguarding Adults from Abuse and Improper Treatment Policy
• CH18 – Risk Management and Assessment Policy
• CH34 – Confidentiality and Data Protection (GDPR)-Service User Policy

These related policies provide foundational principles such as safety, consent, data handling, and safeguarding which are essential for using TEC responsibly.

4. Policy Details

4.1 Assessment and Implementation

Before the deployment of any TEC solution:

• A thorough needs and risk assessment is completed involving the individual, their representative, and care staff.
• The decision to introduce technology is recorded in the care plan and revisited during reviews.
• We assess the appropriateness, user-friendliness, and accessibility of the device or system for each person.
• Where third-party technologies are used, we ensure they comply with industry safety standards and NHS Digital guidance if applicable.

4.2 Supporting Independence and Safety

TEC is used as a proactive intervention:

• Personal alarms and fall sensors help reduce emergency incidents and promote confidence.
• GPS trackers support those at risk of becoming disoriented outdoors, enabling safer community engagement.
• Medication reminders and dispensers support self-administration, promoting independence while maintaining oversight.
• Where possible, visual aids or voice interfaces are used to improve accessibility for individuals with sensory impairments or cognitive decline.

4.3 Staff Responsibilities and Training

• Staff are trained in ethical use, safe installation, daily operation, and emergency response procedures.
• Training includes privacy protocols, troubleshooting common faults, and ensuring devices are charged and functional.
• The Registered Manager ensures technical support is available and that manufacturers’ maintenance guidelines are followed.
• A TEC logbook is maintained for recording checks, updates, issues, and replacements.

4.4 Consent, Mental Capacity and Respect for Privacy

Technology-enabled care and telecare will only be used where there is a lawful basis for doing so and where its use complies with the person’s rights, wishes, preferences, privacy and dignity.

• Where technology forms part of a person’s care or treatment, consent will be obtained from the relevant person in accordance with Regulation 11 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014.
• A person will be presumed to have capacity to make the relevant decision unless it is established that they lack capacity. Staff will provide all practicable support to enable the person to understand, consider and communicate their decision about the proposed technology.
• Where there is reason to doubt whether a person has capacity to consent to the use of particular technology, a decision-specific assessment of mental capacity will be completed and recorded in accordance with the Mental Capacity Act 2005. Capacity will not be determined solely by reference to a person’s age, diagnosis, disability, appearance, behaviour or condition.
• Where a person lacks capacity to make the relevant decision, any decision to use technology as part of their care or treatment will be made lawfully under the Mental Capacity Act 2005. The decision will be made in the person’s best interests, will take account of the person’s past and present wishes and feelings, beliefs and values, and will involve consultation with those who are legally required or appropriate to be consulted. Any valid and applicable advance decision, Lasting Power of Attorney, deputyship or other lawful decision-making authority will be identified and respected.
• Any action or decision taken on behalf of a person who lacks capacity will be the least restrictive available option that can safely and effectively achieve the intended purpose.
• Consent to care or treatment and the lawful basis for processing personal information are separate legal considerations. The service will not assume that consent is always the appropriate lawful basis for processing personal data. The appropriate lawful basis and, where applicable, condition for processing special category data will be identified and documented in accordance with data protection law.
• Where surveillance, audio recording, video recording, vision-based monitoring or similar monitoring technology is proposed, its purpose, necessity, proportionality and impact on privacy, dignity and human rights will be assessed before use. People affected by overt surveillance will be appropriately informed, and any required consent or Mental Capacity Act decision-making process will be completed and documented.
• Covert surveillance by the service will only be considered in exceptional circumstances where there is a pressing and lawful justification, less intrusive measures would not adequately address the identified concern, and its use is lawful, necessary and proportionate. Appropriate senior management and legal advice will be obtained before covert surveillance is implemented.
• Decisions about TEC, consent, capacity and best interests will be recorded in the person’s care records and reviewed whenever their circumstances, capacity, wishes, needs or risks change.
• A person with capacity may withdraw consent to an aspect of care or treatment involving technology. Where this occurs, staff will respect the decision, explain any associated risks, consider alternative and less intrusive arrangements with the person, and record the discussion and resulting care arrangements.

4.5 Restrictive Technology and Deprivation of Liberty

Technology-enabled care will not be introduced or used merely for staff convenience or as an unjustified means of restricting a person’s freedom, movement, choices or access to their environment.

• Before introducing GPS tracking, door-monitoring technology, movement sensors, surveillance, remote monitoring or any other technology capable of restricting or materially influencing a person’s freedom, staff will assess whether its use amounts to restraint or forms part of arrangements that may amount to a deprivation of liberty.
• Where restraint is proposed in relation to a person who lacks capacity, it will only be used where the requirements of the Mental Capacity Act 2005 are met. The restraint must be necessary to prevent harm to the person and proportionate to the likelihood and seriousness of that harm.
• The service will use the least restrictive option that can safely and effectively meet the person’s assessed needs. Restrictions will be individually assessed and will not be imposed on a blanket basis because of a diagnosis, disability, age, perceived vulnerability or the convenience of the service.
• Where there is reason to believe that the overall arrangements for a person who lacks capacity to consent to those arrangements amount to a deprivation of liberty, the Registered Manager will ensure that the current legal framework for authorising the deprivation is followed.
• For a person accommodated in a care home, this includes making the appropriate request to the relevant supervisory body under the Deprivation of Liberty Safeguards where those safeguards apply, or obtaining other lawful authority where required.
• When considering whether arrangements amount to a deprivation of liberty, the service will apply the current legal definition and relevant case law rather than relying solely on historic tests or terminology.
• Any authorised deprivation of liberty and any conditions attached to the authorisation will be reflected in the person’s care plan and risk assessments. Staff involved in the person’s care will be made aware of the restrictions and conditions that apply.
• The necessity and proportionality of restrictive technology will be reviewed regularly and whenever the person’s circumstances, capacity, wishes, risks or care arrangements change. Technology or restrictions that are no longer necessary or proportionate will be removed or reduced without avoidable delay.
• Any concern that technology is being used unlawfully, disproportionately, abusively or as an unauthorised restriction will be treated as a safeguarding concern and escalated in accordance with the Safeguarding Adults from Abuse and Improper Treatment Policy.

4.6 Data Protection and Confidentiality

All personal information collected, generated, viewed, transmitted, stored or otherwise processed through technology-enabled care and telecare will be handled in accordance with the UK General Data Protection Regulation, the Data Protection Act 2018 as amended, including amendments made by the Data (Use and Access) Act 2025, and other applicable data protection legislation.

• Before personal information is processed through TEC, the service will identify and document an appropriate lawful basis for processing under Article 6 of the UK GDPR.
• Where TEC processes special category personal data, including information concerning a person’s physical or mental health, the service will additionally identify and document an appropriate condition for processing under Article 9 of the UK GDPR and any applicable requirements of the Data Protection Act 2018.
• Personal information collected through TEC will be adequate, relevant and limited to what is necessary for the specified purpose. Information will not be collected or retained merely because the technology is capable of collecting it.
• People will be given appropriate and accessible privacy information explaining, as applicable, what information is collected, the purpose for which it is used, the lawful basis for processing, who it may be shared with, how long it will be retained and the rights available to them under data protection law.
• A Data Protection Impact Assessment will be completed before commencing processing that is likely to result in a high risk to the rights and freedoms of individuals. This includes surveillance or monitoring where the nature, scope, context or purposes of the processing create such a high risk. The assessment will consider necessity, proportionality, privacy risks and appropriate measures to mitigate those risks.
• Where surveillance is used, access to images, recordings and monitoring information will be restricted to authorised persons with a legitimate need to access them. The purposes for which recordings may be viewed, disclosed, copied or shared will be defined and controlled.
• Audio recording will not be enabled routinely. Where audio recording is proposed, there must be a specific, evidenced and lawful need for it, and the additional impact on privacy must be considered and documented.
• Appropriate technical and organisational security measures will be applied to TEC systems and data. These will include, according to the assessed risk, secure authentication, appropriate access controls, secure transmission and storage, password management, system updates, protection against unauthorised access, and arrangements for responding to data-security incidents.
• Where an external supplier processes personal information on behalf of the service, appropriate due diligence will be undertaken and the required data-processing arrangements will be in place before processing begins. Access by suppliers will be limited to what is necessary for the agreed purpose.
• Personal information generated by TEC will be retained only for as long as necessary in accordance with the organisation’s retention arrangements and applicable legal requirements, after which it will be securely deleted or disposed of.
• Any personal data breach involving TEC will be reported internally without delay and managed in accordance with the organisation’s data-breach procedure, including assessment of whether notification to the Information Commissioner’s Office and/or affected individuals is legally required.
• Information gathered through TEC will be incorporated into, or linked appropriately with, the person’s care records where it is relevant to their care and treatment. Records will be accurate, complete, contemporaneous and stored securely.
• Compliance with data protection requirements relating to TEC will be monitored through appropriate governance arrangements, including access reviews, audits, incident reviews and review of Data Protection Impact Assessments where the processing, technology or associated risks materially change.

4.7 Emergency Procedures and Contingency Planning

• In the event of a technology failure (e.g., system crash, connectivity issue), manual logs and paper backups are immediately used.
• Emergency contact procedures are in place and known to staff.
• Our CH19 Emergency and Business Continuity Plan contains detailed contingency strategies for the loss of critical TEC infrastructure.

5. Quality Assurance and Governance

• TEC use is regularly evaluated via internal audits, feedback surveys, and incident reviews.
• Governance meetings review data for trends and issues to inform continuous improvement.
• Findings are shared with staff, and action plans are generated for improvement.

The Nominated Individual and Registered Manager are responsible for overseeing the safe integration of all TEC services and ensuring staff follow protocols and undergo refresher training where required.

6. Policy Review

This policy will be reviewed on an annual basis, or earlier if:

• There are changes in CQC guidance or legislation
• New technologies are introduced into service
• Significant incidents occur relating to TEC use
• Feedback or audit findings recommend changes

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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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