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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Internet Access for People Policy

1. Purpose

The purpose of this policy is to set out how {{org_field_name}} supports individuals to access and use the internet and digital communication technology safely, privately and in a manner which promotes their well-being, independence, choice, control, communication and personal outcomes.

This policy supports compliance with the Regulation and Inspection of Social Care (Wales) Act 2016 and the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended, including requirements relating to the provision of care and support, information, communication, respect and sensitivity, safeguarding and the appropriate use of restrictions.

In accordance with the statutory guidance for care home services, {{org_field_name}} will provide information about the availability of, and support to access, Wi-Fi, internet services, relevant digital communication devices and assistive technology.

Internet access and support will be provided in a way which respects each individual’s privacy, dignity, autonomy, independence, communication needs, wishes, preferences and personal outcomes. Any restriction, monitoring or intervention relating to an individual’s internet use must have a lawful basis and must be necessary, proportionate and consistent with applicable safeguarding, mental capacity, human rights and data protection requirements.

2. Scope

This policy applies to:

• All individuals receiving care at {{org_field_name}}, including those with additional support needs.
• Staff responsible for enabling and monitoring internet access.
• Visitors using the care home’s internet facilities.
• Third-party service providers involved in managing IT infrastructure and digital security.

3. Principles of Internet Access Management

3.1 Digital Inclusion and Human Rights

{{org_field_name}} recognises that access to digital communication and the internet can be important to an individual’s independence, autonomy, relationships, communication, access to information, participation in community life and achievement of personal outcomes.

Individuals will be supported, so far as reasonably practicable and in accordance with their wishes and assessed needs, to use the internet and digital technology for communication, learning, entertainment, accessing services, maintaining relationships and pursuing their personal interests.

Individuals’ use of the internet will be supported in a manner which respects their privacy, dignity, confidentiality, autonomy, independence and right to make choices about their day-to-day lives.

An individual will not have access restricted merely because staff disagree with, disapprove of or consider unwise a decision made by an individual who has capacity to make that particular decision. Where there is an identified risk, staff will support the individual to understand and manage that risk and will follow the principles of positive risk-taking, safeguarding and, where applicable, the Mental Capacity Act 2005.

3.2 Providing Secure and Reliable Internet

{{org_field_name}} will make internet access available in accordance with the facilities and arrangements described in the home’s statement of purpose and written guide to the service.

Where provided, internet and Wi-Fi systems will be managed with appropriate technical and organisational security measures designed to protect the home’s network, equipment and personal information from unauthorised access, malware and other cyber-security threats.

Arrangements may include:

• a separate guest network for visitors and personal devices;
• appropriate network security controls;
• reasonable technical support for individuals using the service; and
• security controls intended to prevent malicious activity or protect the integrity and security of the network.

Network security measures must not be used as a blanket means of restricting an individual’s lawful internet access solely because staff consider particular lawful content unsuitable.

Any individual restriction imposed for safeguarding reasons must be based on an identified risk, be necessary and proportionate, and be reviewed. Where the individual lacks capacity to make the relevant decision, any restriction must comply with the Mental Capacity Act 2005, be in the individual’s best interests and represent the least restrictive available option. Where restrictions may amount to a deprivation of liberty, lawful authority must be obtained in accordance with the applicable deprivation of liberty framework.

3.3 Personal Device Use

Residents may use their own smartphones, tablets, or laptops to access the internet. Where necessary, the home will provide access to communal devices, including:

• Desktop computers in shared spaces.
• Tablets available for personal or group use.
• Smart TVs for streaming services and communication.

For residents who do not have their own device, staff should support their use of care home-provided devices upon request.

3.4 Support for Residents with Additional Needs

Some residents may require assistance in using digital devices due to physical, sensory, or cognitive impairments. Staff will:

• Offer one-to-one guidance on using devices and online services.
• Assist with setting up email and video calls for staying in touch with family.
• Enable access to accessible features, such as screen readers, voice commands, or larger fonts.
• Monitor for signs of digital exclusion and provide personalised support.

3.5 Online Safety and Safeguarding

{{org_field_name}} will take reasonable steps to support individuals to use the internet safely while respecting their privacy, autonomy, independence and right to make choices.

Staff will support individuals, where appropriate to their needs and wishes, to understand online risks including:

• fraud and financial scams;
• phishing and malicious communications;
• identity theft;
• cyberbullying, harassment and abuse;
• grooming, coercion and exploitation;
• inappropriate requests for money or personal information;
• unsafe sharing of passwords or personal information; and
• other circumstances which may give rise to abuse, neglect, exploitation or improper treatment.

Where staff identify or receive information suggesting that an individual may be experiencing abuse, neglect, exploitation or improper treatment through online activity, they must act in accordance with the home’s safeguarding policy and the Wales Safeguarding Procedures. Immediate action must be taken where necessary to protect the individual or others from harm, and appropriate safeguarding referrals must be made where required.

Internet use, private communications, messages, calls, browsing activity or social-media activity must not be routinely observed, accessed or monitored by staff.

Any monitoring or restriction considered necessary because of an identified safeguarding risk must:

• have a clear and recorded purpose;
• have an appropriate lawful basis;
• be necessary and proportionate to the identified risk;
• interfere with the individual’s privacy and autonomy no more than is necessary;
• take account of the individual’s wishes, feelings and capacity to make the relevant decision;
• comply with the Mental Capacity Act 2005 where the individual lacks capacity;
• comply with data protection requirements where personal information is processed;
• be recorded in the individual’s relevant assessment and personal plan where it forms part of their care and support arrangements; and
• be reviewed regularly and removed when it is no longer necessary.

Where an individual has capacity to make the relevant decision, staff must recognise that the individual may make decisions involving risk. Safeguarding concerns do not, by themselves, remove an individual’s right to make a capacitous decision.

Any concern about online financial abuse, exploitation, grooming, harassment or other abuse must be reported and managed under the home’s safeguarding procedures.

3.6 Data Protection, Confidentiality and Privacy

{{org_field_name}} will respect individuals’ privacy and confidentiality when they use the internet, digital communication devices and online services.

Personal information obtained in connection with an individual’s internet use will be processed in accordance with the UK General Data Protection Regulation, the Data Protection Act 2018, as amended, and the home’s data protection, confidentiality, information security and records-management policies.

The home will not routinely collect, access or retain information about an individual’s browsing activity, messages, emails, video calls, social-media communications, passwords or other private online activity.

Where it is necessary to process personal information relating to an individual’s internet use, {{org_field_name}} will:

• identify and document an appropriate lawful basis for the processing;
• process only information which is adequate, relevant and necessary for the identified purpose;
• ensure that processing is fair and transparent;
• protect the information using appropriate technical and organisational security measures;
• restrict access to staff who have a legitimate need to know;
• retain information only for as long as required under the home’s retention arrangements; and
• provide the individual with relevant privacy information as required by data protection law.

Consent will not be treated as the only lawful basis for sharing information. Information may be shared without consent where there is another lawful basis to do so, including where sharing is necessary to meet a legal obligation, protect vital interests, undertake lawful safeguarding activity or otherwise comply with applicable data protection legislation.

Where information obtained through internet activity reveals or concerns special-category personal information, {{org_field_name}} must ensure that both an appropriate lawful basis and an applicable condition for processing special-category information are identified before processing takes place.

Where proposed monitoring or other processing is likely to result in a high risk to individuals’ rights and freedoms, the home will complete a Data Protection Impact Assessment before the processing begins, where required by data protection legislation.

Staff must not request, record or use an individual’s password, PIN or other authentication information unless there is a lawful and clearly documented reason for doing so and appropriate safeguards have been put in place.

Where an individual may lack capacity to make a particular decision concerning internet access, online activity or the sharing of information, capacity must be considered in relation to that specific decision in accordance with the Mental Capacity Act 2005. A person must not be treated as lacking capacity merely because they make an unwise decision.

Where the individual lacks capacity, any decision made on their behalf must be made in their best interests, take account of their wishes, feelings, beliefs and values, and use the least restrictive option that is reasonably available. Any restriction amounting to a deprivation of liberty must have lawful authority.

3.7 Managing Internet Usage in Shared Spaces

Individuals may use personal digital devices and access the internet in communal areas, subject to reasonable arrangements necessary to protect the privacy, dignity, safety and rights of other people using the service.

Staff will support individuals to use devices considerately in shared areas. This may include encouraging the use of headphones for audio, video calls or other content where sound may unreasonably disturb other people.

Individuals will not be required to stop using the internet or a personal device solely because a meal, activity or other organised event is taking place. Individuals will be supported to make choices about how they spend their time, subject to any individually assessed care, support or safety needs and reasonable consideration for the rights of other people.

Where an individual’s use of a device in a communal area infringes another person’s privacy, dignity or safety, staff should first use the least restrictive practical intervention and support the individuals involved to reach an appropriate solution.

Any individual restriction which goes beyond ordinary arrangements for considerate communal living must be based on an assessed need or identified risk, be necessary and proportionate, and be recorded and reviewed in accordance with the individual’s personal plan and applicable mental capacity and safeguarding requirements.

3.8 Visitors’ Internet Use

Visitors may access the guest Wi-Fi under the following conditions:

• They must comply with the home’s acceptable use policy.
• Any content accessed must be appropriate for a care home setting.
• Visitors must not use the internet for any activities that could compromise security or safeguarding.

4. Responsibilities

4.1 Management Responsibilities

Management must:

• ensure that the arrangements for internet access and digital communication are consistent with the service’s statement of purpose and written guide;
• ensure appropriate arrangements are in place for the security and maintenance of internet and Wi-Fi systems provided by the service;
• ensure individuals receive appropriate support to access digital communication devices, assistive technology, Wi-Fi and internet services in accordance with their assessed needs and personal outcomes;
• ensure staff understand the distinction between supporting safe internet use and unlawfully monitoring or restricting an individual’s private activity;
• ensure that any individual restriction relating to internet or digital-device use is appropriately assessed, necessary, proportionate, recorded, regularly reviewed and supported by lawful authority where required;
• ensure that capacity assessments and best-interests decisions are undertaken and recorded where required by the Mental Capacity Act 2005;
• ensure safeguarding concerns arising from online activity are managed in accordance with the home’s safeguarding policy and the Wales Safeguarding Procedures;
• ensure that any processing of personal information associated with monitoring or safeguarding complies with applicable data protection legislation and the home’s data protection arrangements;
• ensure staff receive information, instruction and training appropriate to their role in relation to digital safety, safeguarding, privacy, mental capacity and data protection;
• monitor the implementation of this policy and take action where practice is inconsistent with it; and
• review this policy when there is a relevant change in legislation, statutory guidance, regulatory requirements or service arrangements.

4.2 Staff Responsibilities

Staff must:

• support individuals to use digital devices and access the internet in accordance with their wishes, assessed needs, communication requirements and personal plans;
• promote digital inclusion while respecting individuals’ independence, choice, privacy, dignity and autonomy;
• provide information and support about online safety in a manner appropriate to the individual’s needs and level of understanding;
• remain alert to indications of online abuse, exploitation, coercion, fraud, grooming, harassment or other safeguarding concerns and report concerns immediately in accordance with safeguarding procedures;
• not routinely observe, access, search or monitor an individual’s browsing activity, messages, emails, social-media accounts, calls or other private online communications;
• not request or use an individual’s password, PIN or other authentication information unless there is a lawful, necessary and appropriately recorded reason for doing so;
• follow the Mental Capacity Act 2005 where there is reason to doubt an individual’s capacity to make a specific decision concerning internet or digital-device use;
• recognise that an individual with capacity is entitled to make decisions which others may consider unwise;
• follow any properly authorised and recorded restriction contained within the individual’s personal plan;
• use the least restrictive response when supporting an individual to manage an identified online risk;
• maintain confidentiality and process personal information in accordance with the home’s data protection and confidentiality arrangements; and
• report any technical, cyber-security, data-protection or safeguarding incident through the appropriate organisational procedure.

4.3 Resident Responsibilities

Residents are encouraged to:

• Use the internet in a safe and respectful manner.
• Be mindful of others’ comfort in shared spaces.
• Report any technical issues or security concerns to staff.

5. Related Policies

This policy must be read and applied alongside the home’s relevant policies and procedures, including:

• Safeguarding Adults from Abuse, Neglect and Improper Treatment Policy;
• Confidentiality and Data Protection Policy;
• Computer Systems and Security Policy;
• People’s Decision-Making and Autonomy Policy;
• Control, Restraint and Restrictive Practice Policy;
• Deprivation of Liberty Safeguards Policy, where applicable;
• People Taking Positive Risks Policy;
• Supporting People to Manage Their Money/Financial Safeguarding Policy;
• Dignity and Respect Policy;
• Communication and Engagement with People and Families Policy;
• Complaints Policy; and
• Whistleblowing Policy.

Where there is a safeguarding concern arising from internet or digital-device use, the safeguarding policy and Wales Safeguarding Procedures must be followed.

Where a proposed intervention may restrict an individual’s choice, movement, communication or access to information, the Mental Capacity Act 2005, relevant restrictive-practice procedures and, where applicable, the Deprivation of Liberty Safeguards must be considered before the restriction is implemented.

6. Policy Review

This policy will be reviewed at least annually and will be reviewed and updated sooner where necessary to ensure that it remains consistent with current legislation, statutory guidance, CIW regulatory requirements, safeguarding arrangements, data protection requirements and the service’s statement of purpose.

An earlier review will be undertaken where:

• relevant legislation, statutory guidance or regulatory requirements change;
• CIW or another relevant authority issues guidance affecting the operation of this policy;
• safeguarding or data-protection incidents identify a weakness in the policy;
• monitoring or audit identifies that practice is inconsistent with legal or regulatory requirements;
• there is a significant change to the home’s internet, Wi-Fi, digital communication or monitoring arrangements; or
• changes to the service’s statement of purpose affect the arrangements covered by this policy.

Any changes which affect individuals will be communicated in an appropriate and accessible manner, and staff will be informed of and supported to understand changes relevant to their role.

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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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