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Locking Service Users’ Doors Policy

1. Purpose

This policy sets out the care home’s arrangements for the use and management of locks on individuals’ bedroom doors and on external doors and exits. Its purpose is to protect individuals’ rights to privacy, dignity, autonomy, safety and freedom of movement while ensuring appropriate security of the premises.

The service will comply with the Regulation and Inspection of Social Care (Wales) Act 2016, the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended, the Mental Capacity Act 2005 and its Code of Practice, the Deprivation of Liberty Safeguards where applicable, applicable human rights requirements, fire-safety legislation and relevant Welsh Government and Care Inspectorate Wales guidance.

The service recognises that the use of a lock is not automatically a restrictive practice. An individual with the relevant capacity may choose to lock their own bedroom door to protect their privacy, dignity or possessions. However, where a locked door or other security measure is imposed or operated by the service in a way that restricts an individual’s liberty of movement, it may amount to control, restraint or restrictive practice and must be individually assessed, necessary, proportionate, lawful and the least restrictive means of managing the identified risk.

Where arrangements may amount to a deprivation of liberty, the service will assess the individual’s actual circumstances in accordance with current law and guidance and will ensure that lawful authority is obtained where required. The service will not deprive an individual of their liberty for the purpose of receiving care and support without lawful authority.

2. Scope

• Applicability: This policy applies to all staff and volunteers in the home. It covers both residential care and nursing care units, reflecting that the same principles apply in both settings.
• Coverage: It addresses locking of internal bedroom doors (individual rooms) and external doors (main entrance/exits) of the care home. The policy is relevant to all service users, including those who can consent to door locking arrangements and those who lack capacity to consent.
• Regulatory Basis: As a CIW-registered service in Wales, the home adheres to CIW guidelines and statutory requirements on premises security and resident rights. For example, regulations require that premises be secure from unauthorised access while not unnecessarily restricting individuals’ freedom of movement. This policy also operates within the framework of the Mental Capacity Act 2005 and DoLS for any practice that might limit a person’s liberty.

3. Policy Statement and Principles

We are committed to protecting and promoting every individual’s privacy, dignity, autonomy, safety, human rights and freedom of movement. The following principles apply to all decisions concerning bedroom locks, external-door security and other arrangements that may restrict movement.

• Privacy, dignity and personal space: Individuals will be supported to exercise privacy and control over their personal accommodation. Bedroom arrangements will enable freedom of movement and privacy and will be adapted where necessary to meet the individual’s assessed needs. Where an individual wishes and is able to use a bedroom lock safely, the service will support this choice. Staff must knock, identify themselves and obtain permission before entering an individual’s bedroom unless there is an emergency, an immediate safeguarding concern or another lawful and clearly recorded reason for entry.
• Emergency access: Bedroom locking arrangements must enable authorised staff to obtain access where this is necessary in an emergency. Master keys or another suitable emergency override arrangement will be securely controlled and available to authorised staff. Emergency access must only be used for a legitimate purpose and must not be used routinely to override an individual’s privacy or wishes.
• Security of the premises: The premises will be secure from unauthorised access. Security measures will protect individuals without unnecessarily compromising their rights, privacy, dignity or freedom of movement. The level of security will be appropriate to the individuals using the service and the risks identified.
• Individual choice and consent: An individual who has capacity to make the particular decision concerning their bedroom lock, access to the premises or leaving the service will be supported to make that decision. Capacity must not be assumed to be absent because of age, diagnosis, dementia, learning disability, mental illness or any other condition. Staff must not prevent an individual who has the relevant capacity from leaving merely because staff consider their decision unwise.
• Decision-specific capacity: Where there is reason to doubt an individual’s capacity to make a particular decision concerning locking arrangements, access or leaving the premises, an assessment will be undertaken 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 individual to make the decision themselves.
• Best interests: Where an individual lacks capacity to make the particular decision, any decision made on their behalf must be made in accordance with the Mental Capacity Act 2005 best-interests requirements. The individual must be involved as fully as possible and their wishes, feelings, values and beliefs must be considered. Relevant representatives, attorneys, deputies, advocates and others appropriately involved in the individual’s care must be consulted as required by law.
• Risk assessment and personal planning: Any service-imposed restriction concerning door locking, access or freedom of movement must arise from an individual assessment of risk and must be recorded in the individual’s personal plan. The record must identify the risk being addressed, the individual’s wishes and preferences, relevant capacity and best-interests considerations where applicable, alternatives considered, the agreed measure, its legal basis and arrangements for review.
• Least restrictive practice: Where the service is considering a measure that would restrict an individual’s movement, it must use the least restrictive effective option. Restrictions must never be imposed for staff convenience, because of staffing shortages, as punishment, to enforce compliance or merely because an individual has a particular diagnosis.
• Necessary and proportionate restriction: Where an arrangement amounts to control or restraint because it restricts an individual’s liberty of movement, it must only be used where necessary to prevent a risk of harm to the individual or another person and must be a proportionate response to the seriousness and likelihood of that harm.
• Deprivation of liberty: Not every locked-door arrangement or restriction amounts to a deprivation of liberty. Where this question arises, the service will consider the individual’s concrete circumstances and current legal requirements rather than relying solely upon a single test or the individual’s diagnosis or legal capacity. Where the arrangements amount to a deprivation of liberty, lawful authority must be obtained and maintained.

4. Bedroom Door Locking Guidelines

Bedroom-door arrangements must protect the individual’s privacy and dignity while ensuring that assessed care, support and safety needs can be met.

1. Locking arrangements

Bedroom doors will have locking arrangements appropriate to the design of the premises, the individual’s needs and the service’s fire and safety arrangements. Where a lock is provided for an individual’s use, its design must take account of the individual’s physical, cognitive, sensory and communication needs.

Where necessary, an appropriate emergency override arrangement will enable authorised staff to gain access in circumstances where immediate entry is necessary to protect life or prevent serious harm.

2. Individual access to keys or other locking devices

Individuals who wish to use their bedroom lock will be supported to do so where this can be done safely. Appropriate support or reasonable adjustments will be provided where required.

An individual’s diagnosis, disability or age must not, on its own, be used as a reason to withhold a key, fob, code or other means of operating their bedroom lock.

3. Where independent use of the lock presents an identified risk

Where there is evidence that an individual’s use of a bedroom lock may create a significant risk, the service must complete an individual risk assessment.

If the individual has capacity to make the relevant decision, staff will explain the identified risks and available options and will respect the individual’s decision unless another lawful basis for intervention applies.

If there is reason to doubt the individual’s capacity to make the relevant decision, capacity must be assessed in accordance with the Mental Capacity Act 2005. Where the individual lacks capacity, any decision concerning their use of the lock must be made in their best interests and must be the least restrictive effective option.

An MDT recommendation may inform the assessment but does not, by itself, provide legal authority to override an individual’s capacitous decision, impose restraint or deprive an individual of liberty.

Alternatives must be considered before imposing a restriction. Depending upon the individual circumstances, alternatives may include:

3. adapting the locking mechanism;
4. providing additional support or prompting;
5. providing secure storage for personal possessions;
6. increased observation where individually justified;
7. assistive technology or alert systems;
8. environmental modifications; or
9. changes to staffing support or routines.

Any restriction must be recorded in the individual’s personal plan and reviewed whenever circumstances change and at each relevant personal-plan review.

4. Staff access to bedrooms

Staff must knock, identify themselves and allow sufficient time for the individual to respond before entering.

Where the door is locked, staff must not use a master key or override mechanism merely for convenience or routine access.

Non-emergency entry should take place with the individual’s agreement unless another lawful basis for entry has been established and documented.

Staff may use emergency access without prior consent where there is a reasonable and immediate concern for the individual’s safety or the safety of another person, including a medical emergency, fire, suspected serious injury or another situation requiring immediate intervention.

The reason for emergency or non-consensual access must be documented. Where entry forms part of, or results in, control, restraint or restrictive practice, the additional recording requirements in this policy apply.

5. Privacy and planned checks

Individuals may choose to lock their bedroom door while they are inside their room.

Preferences concerning night-time checks, welfare observations and staff access must be discussed with the individual and recorded in the personal plan where relevant.

A clinical or safety risk, including falls risk, does not automatically authorise staff to override a capacitous individual’s wishes. Where additional access or observation is considered necessary, staff must consider consent, the individual’s capacity for the relevant decision, the identified risk, available alternatives and the least restrictive means of managing that risk.

Where the individual lacks capacity, any planned arrangement involving entry to the bedroom or restriction of their ability to lock the door must comply with the Mental Capacity Act 2005 and any other applicable legal authority.

6. Lockable storage

Appropriate arrangements will be available for the secure storage of an individual’s money, valuables and personal possessions where required. Where possessions or valuables are handed to the service for safekeeping, the required records will be maintained.

Medicines must be stored and managed in accordance with the service’s medicines policy, the individual’s assessed needs and the applicable medicines-management requirements. An individual who self-administers medicines will be supported to do so only in accordance with their medicines assessment and personal plan.

5. External Door Locking and Building Security

The service will maintain premises that are secure from unauthorised access while ensuring that security arrangements do not unnecessarily restrict an individual’s freedom of movement, privacy, dignity, independence or human rights.

• Controlled entry: External doors may use appropriate security measures, including controlled entry, keypads, fobs, intercoms or other security systems, where these are required to protect individuals and the premises from unauthorised access.
• Individual freedom of movement: Security arrangements must not be operated as a blanket restriction on individuals living at the service. Each individual’s ability to access outdoor areas and leave the premises must be considered according to their own circumstances, wishes, assessed needs and risks.
• Individuals with capacity: Where an individual has capacity to decide whether to leave the service, they must not be prevented from leaving merely because staff consider their decision risky or unwise. Staff may provide relevant information, advice and support and may agree appropriate arrangements with the individual, but must not impose an unlawful restriction.
• Where capacity is in question: Where there is reason to doubt the individual’s capacity to make the particular decision about leaving or relevant care arrangements, a decision-specific assessment must be undertaken in accordance with the Mental Capacity Act 2005. Staff must take all practicable steps to support the individual to make the decision themselves.
• Restrictions where capacity is lacking: Where an individual lacks capacity and a restriction on leaving is considered necessary, the arrangement must be in the individual’s best interests, necessary and proportionate, and the least restrictive effective option. The restriction must be clearly recorded in the individual’s personal plan and subject to regular review. Where the overall arrangements amount to a deprivation of liberty, lawful authority must be obtained.
• Assessment of deprivation of liberty: Staff must not determine that a deprivation of liberty exists solely because an individual is subject to continuous supervision or control, is not free to leave, lacks legal capacity or is living behind a locked external door. The individual’s actual and concrete circumstances must be considered in accordance with current law and guidance, including the type, duration, effect, purpose and manner of implementation of relevant restrictions, the individual’s experience of the arrangements and their wishes and feelings.
• Wishes and feelings: A person who lacks legal capacity under the Mental Capacity Act may nevertheless be capable, for Article 5 purposes, of expressing meaningful wishes and feelings about their living arrangements. Such expressions must be taken seriously. Where there is serious doubt about whether the person understands or accepts the arrangements, staff must not simply assume consent.
• Supporting access to the community: Where an individual requires assistance or supervision to leave the premises, the service will make reasonable arrangements to facilitate access to outdoor areas and the community in accordance with the individual’s personal plan and personal outcomes.
• Keypads, codes and electronic access: Access arrangements must be managed securely. Decisions about whether an individual is provided with a key, fob, code or other means of independently leaving must be made on an individual basis and must not be determined solely by diagnosis or membership of a particular unit or group.
• Fire safety and emergency egress: Security arrangements must comply with the premises fire-risk assessment, fire-safety strategy and emergency plan. Final exits and escape arrangements must enable rapid and safe escape in the event of fire. Final exit doors must not depend upon an individual locating or using a key or entering a security code during a fire where this would prevent prompt escape. Any specialist security arrangement required because of the needs of individuals must be addressed through the fire-risk assessment and must provide an effective means of emergency release.
• Night-time security: External doors may be secured at night for legitimate security reasons, but night-time arrangements must not impose an unjustified or unlawful restriction upon an individual’s freedom. Requests to leave must be responded to according to the individual’s circumstances, personal plan, capacity, assessed risks and any lawful restrictions in force.
• Door alarms, sensors and assistive technology: Door alarms, sensors or similar technology may be used where appropriate, but their use must be purposeful, lawful, proportionate and individually assessed where they are intended to monitor a particular individual. Where their use restricts an individual’s freedom, privacy or behaviour, this must be considered as part of the restrictive-practice assessment and recorded appropriately.

6. Safeguarding Considerations, Mental Capacity and Deprivation of Liberty

Door-locking and security arrangements can engage an individual’s fundamental rights and may constitute restrictive practice, control or restraint or, depending upon the individual’s circumstances, a deprivation of liberty. The following requirements therefore apply.

• Protection from other people: Where an individual is at risk from another resident, visitor or other person, staff will take appropriate safeguarding and risk-management action. An individual who wishes to lock their bedroom door for their own protection will be supported to do so where appropriate. Staff must also address the source of the risk so that the individual is not unnecessarily required to restrict their own life because of another person’s behaviour.
• Restricting an individual because of risk: Locking an individual in their bedroom must not be used as routine behaviour management, punishment, staff convenience, compensation for inadequate staffing or a substitute for appropriate care and support. Restrictive measures may only be used where lawful, necessary to prevent harm, proportionate to the identified risk and the least restrictive effective response.
• Immediate emergencies: Nothing in this policy prevents staff taking necessary and proportionate action in a genuine emergency to prevent immediate harm. Once the immediate emergency has passed, any continuing restriction must have a lawful basis. The incident must be recorded and reviewed and any safeguarding, regulatory or other notification requirements must be considered.
• Mental Capacity Act 2005: Where an individual’s capacity to make a particular decision is in question, staff must follow the Mental Capacity Act 2005. Capacity must be assessed in relation to the specific decision at the relevant time. The person must be presumed to have capacity unless it is established otherwise, and all practicable steps must be taken to support the person to make the decision.
• Best-interests decisions: Where the individual lacks capacity to make the particular decision, any decision made on their behalf must comply with the Mental Capacity Act 2005. The decision-maker must consider the person’s past and present wishes and feelings, beliefs and values, consult appropriate people as required, consider all relevant circumstances and select the least restrictive effective option.
• Current deprivation-of-liberty assessment: Following the Supreme Court judgment of 2 June 2026, staff must not rely solely on the former Cheshire West “acid test” of continuous supervision and control and not being free to leave. Assessment of whether arrangements constitute a deprivation of liberty requires consideration of the individual’s concrete circumstances and the overall degree and intensity of the restriction.

Relevant considerations may include:

• the type of restriction;
• its duration;
• its practical effect upon the individual;
• the way the restriction is implemented;
• the setting and the relative normality of the arrangements;
• the purpose of the measure, while recognising that a beneficial purpose does not by itself make a deprivation lawful;
• externally imposed restrictions as distinct from limitations arising from the individual’s own physical or medical condition;
• the individual’s wishes, feelings, compliance or objection; and
• whether the individual has sufficient awareness of their circumstances to communicate meaningful acceptance or rejection of them.

No single factor is determinative. Where there is serious doubt about whether an individual is genuinely accepting of the arrangements, staff must not infer valid consent merely from an absence of active resistance.

• DoLS and lawful authority: Deprivation of Liberty Safeguards remain part of the legal framework in Wales for eligible adults aged 18 or over in care homes and hospitals. Where the service concludes that an individual’s arrangements amount, or are likely to amount, to a deprivation of liberty and DoLS is the applicable legal mechanism, the managing authority must make the appropriate request to the supervisory body.
• Urgent authorisation: Where the statutory criteria are met and the deprivation must begin before a standard authorisation can be obtained, the managing authority may grant an urgent authorisation in accordance with the Mental Capacity Act 2005 for the permitted period. An urgent authorisation must not be treated as an indefinite or automatically renewable authority. Any extension beyond the initial urgent-authorisation period requires the involvement and approval of the supervisory body in accordance with the statutory DoLS provisions and is subject to the statutory maximum period.
• Other legal routes: Where DoLS is not the appropriate legal mechanism, the service must seek appropriate professional or legal advice and ensure that any deprivation of liberty is authorised through the correct legal route, which may include the Court of Protection, Mental Health Act 1983 or another applicable legal jurisdiction.
• CIW notification: The service provider must notify Care Inspectorate Wales of any request made to a supervisory body concerning the application of the Deprivation of Liberty Safeguards, using CIW Online and in accordance with the notification requirements applying at the time. Any additional DoLS-related notification required by CIW must also be completed.
• Review of restrictions: Restrictions must be reviewed whenever circumstances change and as part of the individual’s personal-plan review. Reviews must consider whether the restriction remains necessary, proportionate and lawful and whether it can be reduced or removed.
• Authorisation conditions: Any conditions attached to a DoLS authorisation, court order or other legal authority must be incorporated into the individual’s personal plan and followed.
• Change in circumstances: The service must not continue to rely upon an authorisation where relevant circumstances have materially changed without considering whether a review, reassessment or new application is required.
• Involvement and advocacy: Individuals must be involved as fully as possible in decisions concerning restrictions. Information must be provided in a manner appropriate to the individual’s communication needs. Representatives, attorneys, deputies, Relevant Person’s Representatives and advocates must be involved where required or appropriate. Independent advocacy must be facilitated where the individual is entitled to it.

7. Staff Responsibilities

All staff must understand and implement this policy consistently.

• Service provider and Responsible Individual: The service provider and Responsible Individual must ensure that appropriate governance arrangements are in place so that door security, restrictive practice and deprivation-of-liberty requirements are implemented lawfully and effectively. They must maintain oversight of compliance, quality assurance, relevant CIW notifications and any recurring or systemic restrictions on individuals.
• Registered Manager: The Registered Manager is responsible for the day-to-day implementation of this policy. The manager must ensure that:
  • relevant assessments and personal plans accurately describe any door-locking or freedom-of-movement arrangements;
  • decision-specific capacity assessments and best-interests decisions are completed where required;
  • restrictions have an identified legal basis;
  • DoLS or other legal authorisation is sought where required;
  • CIW notifications are completed as required;
  • restrictive practices are monitored and reviewed;
  • staff receive appropriate training and supervision; and
  • action is taken promptly where practice is unlawful, disproportionate or unnecessarily restrictive.
• Care and nursing staff: Staff must:
  • respect individuals’ privacy and choices concerning their bedroom doors;
  • knock and seek permission before entering unless lawful emergency or other justified access is required;
  • understand each individual’s personal plan and any relevant restriction or authorisation;
  • use the least restrictive approach;
  • not impose blanket restrictions;
  • keep master keys, fobs and access codes secure;
  • promptly report concerns about an individual’s access, safety, capacity, wishes or restrictions; and
  • escalate any situation in which they believe an individual may be unlawfully restricted or deprived of liberty.
• Recording control, restraint and restrictive practice: Where staff use an intervention that constitutes control or restraint, including restricting an individual’s liberty of movement, a record of the incident must be made within 24 hours. The record must include sufficient information to establish:
  • what occurred;
  • the circumstances and identified risk;
  • why the intervention was considered necessary;
  • what alternatives were considered or attempted;
  • the form and duration of the restriction;
  • the individual’s response and any expressed wishes or objections;
  • any injury, distress or other impact;
  • action taken afterwards; and
  • whether the personal plan, risk assessment, safeguarding arrangements or legal authority require review.
• Master-key or override use: Non-routine use of a master key or emergency override must be recorded with the reason for entry. Where use of the master key forms part of a restriction, restraint or safeguarding incident, the appropriate additional recording and escalation requirements must also be followed.
• Maintenance and premises staff: Staff responsible for premises and maintenance must ensure that locking mechanisms, emergency-release arrangements, alarms and security systems are properly maintained. Defects affecting safety, security or emergency evacuation must be reported and addressed promptly.
• Training: Staff whose work may involve decisions concerning door locking, freedom of movement, capacity or restrictive practice must receive training appropriate to their role covering:
  • privacy, dignity and human rights;
  • the Mental Capacity Act 2005;
  • best-interests decision-making;
  • deprivation of liberty and DoLS;
  • the current legal approach to assessing deprivation of liberty;
  • Regulation 29 and restrictive practice;
  • the Welsh Government Reducing Restrictive Practices Framework;
  • safeguarding;
  • positive and preventative approaches to behaviour;
  • recording and reporting requirements; and
  • relevant fire-safety and emergency-access procedures.

Training must be refreshed at appropriate intervals and following material changes to legislation, national guidance or CIW requirements.

8. Compliance and Quality Assurance

Compliance with this policy will form part of the service’s governance, monitoring and quality-assurance arrangements.

The Registered Manager and Responsible Individual will ensure that audits include, where relevant:

• individuals’ ability to enter and leave the premises;
• access to bedroom locks, keys, fobs and codes;
• use of master keys and emergency override arrangements;
• whether bedroom and external-door restrictions are reflected accurately in personal plans and risk assessments;
• evidence of consent or decision-specific Mental Capacity Act assessments where required;
• best-interests decisions;
• whether restrictions remain necessary and proportionate;
• whether less restrictive alternatives have been considered;
• current DoLS authorisations or other lawful authority;
• compliance with conditions attached to authorisations;
• CIW notifications;
• restrictive-practice records;
• safeguarding incidents associated with door locking or restrictions;
• fire-safety compatibility of locking systems; and
• themes, patterns and opportunities to reduce restrictions.

Any use of control or restraint must be recorded within 24 hours in accordance with Regulation 29. Records must contain sufficient information to support individual review and wider governance analysis.

The service will maintain the records required by the Regulations, including the date and circumstances of measures of control or restraint used in relation to an individual.

Records relating to control, restraint and restrictive practice will be reviewed as part of the service’s governance and quality-of-care arrangements. Trends will be considered to establish whether:

• particular individuals are subject to repeated restrictions;
• restrictions are being used because of environmental or staffing issues;
• additional assessment or specialist advice is required;
• staff require further training or supervision;
• personal plans require amendment; or
• restrictions can be reduced or eliminated.

The service provider must notify Care Inspectorate Wales of any request to a supervisory body concerning the application of DoLS and must comply with any other applicable statutory notification requirements.

Any apparent unlawful restriction or deprivation of liberty will be escalated immediately to the Registered Manager. Immediate steps will be taken to safeguard the individual’s rights and welfare, review the arrangements and obtain appropriate professional or legal advice and lawful authority where required.

Where inappropriate restriction, abuse, neglect or improper treatment is alleged or suspected, the service’s safeguarding procedures and the Wales Safeguarding Procedures will be followed and appropriate referrals and notifications made.

Any breach of this policy will be investigated. Remedial measures may include immediate changes to an individual’s arrangements, safeguarding action, additional training or supervision, disciplinary action, revision of personal plans or risk assessments, regulatory notification and wider service improvement.

9. Policy Review

This policy will be reviewed at least annually and sooner where:

• legislation or case law changes;
• Welsh Government statutory guidance changes;
• Care Inspectorate Wales publishes relevant new or revised requirements or guidance;
• national guidance concerning restrictive practice changes;
• fire-safety requirements affecting locking arrangements change;
• audit or quality-assurance activity identifies deficiencies;
• an incident, safeguarding concern or complaint identifies a need for review; or
• learning from a DoLS assessment, court decision or other legal process identifies required changes.

The service provider and Responsible Individual will ensure that the policy remains consistent with the service’s statement of purpose and with other relevant policies, including safeguarding, control and restraint/restrictive practice, Mental Capacity Act and DoLS, medicines management, fire safety, risk management and complaints policies.

Where policy changes affect individuals or their representatives, information will be communicated in an appropriate and accessible manner. Staff will be informed of revisions and provided with additional training where required.

References and legal framework

This policy must be read alongside the current versions of:

• Regulation and Inspection of Social Care (Wales) Act 2016;
• Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended;
• Welsh Government statutory guidance for service providers and Responsible Individuals on meeting the service standard regulations for care home services;
• Mental Capacity Act 2005;
• Mental Capacity Act 2005 Code of Practice;
• Deprivation of Liberty Safeguards and the applicable supplementary Code of Practice;
• Regulation 29 of the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017 concerning appropriate use of control and restraint;
• Regulation 31 of the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017 concerning deprivation of liberty;
• Welsh Government Reducing Restrictive Practices Framework;
• Human Rights Act 1998 and Article 5 of the European Convention on Human Rights;
• Supreme Court judgment of 2 June 2026, A Reference by the Attorney General for Northern Ireland of a devolution issue under paragraph 34 of Schedule 10 to the Northern Ireland Act 1998 [2026] UKSC 16;
• applicable CIW guidance concerning Deprivation of Liberty Safeguards and notifications;
• Social Services and Well-being (Wales) Act 2014 and applicable safeguarding requirements;
• Regulatory Reform (Fire Safety) Order 2005 and applicable residential care premises fire-safety guidance; and
• Wales Safeguarding Procedures.

Regulation 31 of the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017 requires that an individual must not be deprived of their liberty for the purpose of receiving care and support without lawful authority. The service will therefore ensure that door-locking and security arrangements are individually assessed, rights-based, lawful and regularly reviewed.

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