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{{org_field_name}}
Registration Number: {{org_field_registration_no}}
Restrictive Practices and Physical Interventions Policy
1. Purpose
{{org_field_name}} adopts a rights-based, least-restrictive approach in line with Welsh law and CIW expectations. Restrictive practices (any practice that limits a person’s rights or freedom of movement) are used only to prevent immediate risk of harm, for the shortest possible time, and only after less-restrictive options have been tried or are not possible. All decisions are person-centred, lawful, necessary and proportionate, and are recorded, reviewed and governed through our quality framework, supervision, and quarterly personal-plan reviews.
2. Scope
This policy applies to all workers engaged by {{org_field_trading_name}} (employees, bank, agency, students and volunteers) and to any person we support in the community. Where other providers are involved, the lead provider is identified and joint plans are agreed to avoid conflicting instructions.
3. Legal and Regulatory Basis
This policy must be read and implemented alongside the following legal and regulatory requirements and guidance:
- the Social Services and Well-being (Wales) Act 2014;
- the Regulation and Inspection of Social Care (Wales) Act 2016;
- the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended, including:
- Regulation 12 – requirement to have and keep up to date policies and procedures;
- Regulation 13 – duty of candour;
- Regulation 15 to 18 – personal plans, provider assessments and reviews;
- Regulation 21 – standards of care and support;
- Regulation 26 and 27 – safeguarding, abuse, neglect and improper treatment;
- Regulation 29 – appropriate use of control and restraint;
- Regulation 30 – prohibition on corporal punishment;
- Regulation 31 – deprivation of liberty;
- Regulation 34 and 36 – staffing, training, supervision and support;
- the Welsh Government statutory guidance for service providers and responsible individuals on meeting service standard regulations for domiciliary support services;
- Welsh Government guidance on reducing restrictive practices in childcare, education, health and social care settings, including the 2024 restrictive practice resources;
- the Mental Capacity Act 2005 and its Code of Practice;
- the Deprivation of Liberty Safeguards, where applicable, and Court of Protection authorisation where a deprivation of liberty arises outside a care home or hospital;
- the Human Rights Act 1998, including Articles 2, 3, 5, 8 and 14;
- the Equality Act 2010;
- Wales Safeguarding Procedures and current Welsh Government safeguarding guidance;
- Social Care Wales codes of professional practice and relevant workforce guidance;
- CIW notification requirements, inspection framework, inspection ratings approach and enforcement expectations.
Where legislation, statutory guidance, CIW requirements or Welsh Government guidance changes, this policy will be reviewed and updated without delay. Staff will be informed of changes and, where required, additional training or supervision will be provided.
4. Definitions
- Restrictive practice: any act or omission that restricts a person’s rights or freedom of movement.
- Physical intervention: direct physical contact to prevent imminent harm.
- Mechanical restraint: equipment used intentionally to restrict movement (e.g., lap belt).
- Environmental restriction: limits created by the environment (e.g., keypad locks, removal/positioning of items).
- Chemical restraint: medication used primarily to control behaviour rather than treat a diagnosed condition.
- Seclusion/long-term segregation: supervised confinement/isolation preventing the person from leaving — not used by {{org_field_name}} in domiciliary settings.
- Blanket rule: a general rule, routine or restriction applied to everyone, or to a group of people, without individual assessment, lawful justification or evidence that it is necessary and proportionate for that person.
- Communication restriction: any restriction created through the way information, choices, instructions or communication aids are used, withheld or presented, which limits the person’s ability to understand, express wishes, make choices or refuse support.
- Cultural restriction: any practice, custom, routine or staff expectation which limits a person’s rights, choices, identity, relationships, culture, religion, language, lifestyle or autonomy without individual lawful justification.
- Surveillance restriction: the use of monitoring, observation, cameras, sensors, tracking devices, door alerts, electronic monitoring or other surveillance in a way that limits privacy, liberty or autonomy. Surveillance must only be used where it is individually assessed, lawful, necessary, proportionate, recorded in the personal plan and regularly reviewed.
- Threatened restraint or control: threatening to use force, restriction, withdrawal of support or other consequences to secure compliance. This may amount to control or restraint and is not permitted unless it is lawful, necessary and proportionate to prevent harm.
- Improper treatment: includes discrimination, unlawful restraint or inappropriate deprivation of liberty. Any suspected improper treatment must be treated as a safeguarding concern.
5. Principles
We prioritise prevention, positive risk-taking, and the least-restrictive option. People’s will and preferences, language and communication needs (including the Active Offer of Welsh), culture, and relationships are central. Equality, diversity and human rights are actively upheld. Restrictions are temporary, individually justified, and removed at the earliest opportunity.
6. Prohibited Practices
{{org_field_name}} does not permit any restrictive practice that is unlawful, punitive, abusive, degrading, discriminatory, disproportionate, used for staff convenience or used as a substitute for adequate staffing, training, planning or skilled support.
The following practices are prohibited:
- seclusion or long-term segregation in domiciliary care or community settings;
- corporal punishment of any child or adult;
- pain-compliance techniques;
- prone restraint, floor holds, neck holds, basket holds, or any method that may impede breathing, circulation, communication, consciousness or swallowing;
- any physical intervention that is not part of an approved, trained and individually assessed approach;
- any blanket restriction that is not based on individual assessment, lawful authority and recorded rationale;
- using medication to sedate, control or make care easier for staff where this is not clinically prescribed and reviewed;
- withholding food, fluids, medication, continence support, mobility aids, communication aids, sensory aids, personal possessions, access to family, money or activities as a form of control;
- locking a person in, preventing a person from leaving, or using door controls in a way that may amount to deprivation of liberty without lawful authority;
- using surveillance, sensors, tracking devices or monitoring equipment without individual assessment, consent or best-interests decision-making, privacy assessment and review;
- using threats, intimidation, humiliation, coercion, raised voices or fear to make a person comply;
- any restrictive practice based on protected characteristics, diagnosis, staffing convenience, service routine or assumptions about risk.
Any worker who witnesses or suspects prohibited practice must stop the action immediately if safe to do so, protect the person from further harm, report to the Registered Manager without delay, record the concern, and follow safeguarding, whistleblowing, duty of candour and CIW notification procedures where required.
6.1 Identifying Subtle or Hidden Restrictive Practices
Restrictive practices are not limited to physical restraint. Staff must be alert to subtle or hidden restrictions that may become normalised in day-to-day care. A practice may be restrictive if it makes a person do something they do not want to do, or stops them doing something they want to do, unless the restriction is lawful, necessary, proportionate and individually justified.
Examples of subtle restrictive practices include:
- arranging furniture, equipment or household items so that the person cannot move freely;
- placing items out of reach to control choices or behaviour;
- using door sensors, alarms, cameras or trackers without clear lawful basis and review;
- giving choices in a way that steers the person towards the staff member’s preferred option;
- using language, tone or repeated instruction to pressure compliance;
- withholding communication aids, glasses, hearing aids, mobility aids or sensory items;
- applying house rules, routines or staff preferences without individual assessment;
- restricting access to visitors, telephone, internet, activities, money or possessions without lawful and proportionate reason;
- discouraging a person from making an unwise decision where they have capacity to make that decision;
- using risk assessments to remove ordinary choice rather than to support positive risk-taking.
Where staff identify a subtle or hidden restriction, they must report this to the manager so that the restriction can be reviewed, reduced or removed. Any restriction that remains in place must be recorded in the person’s personal plan with the reason, lawful basis, alternatives considered, impact on the person, review date and exit plan.
7. Prevention and Positive Behaviour Support (PBS)
Each person who may present behaviours of concern has a Positive Behaviour Support plan that: identifies functional causes/triggers, early signs and agreed de-escalation; details communication approaches, sensory/regulation needs and meaningful activity; and records the person’s preferences and reasonable adjustments (including Welsh-language needs). Plans are co-produced, shared with staff, practised in supervision, and reviewed at least every three months or sooner after any incident or change in need.
PBS plans must be used as a proactive well-being and prevention tool, not only as a response to behaviour. The plan must identify what improves the person’s quality of life, emotional well-being, communication, relationships, choice, meaningful activity, sensory regulation and sense of safety. The aim is to reduce the likelihood of distress and prevent situations where restrictive practice may be considered. Any restrictive strategy included within a PBS plan must have a clear rationale, lawful basis, time limit, review date, reduction plan and exit criteria.
8. Capacity, Consent and Best Interests
We presume capacity and support decision-making. For any planned restrictive practice, we complete a decision-specific capacity assessment where doubt exists. Where the person lacks capacity, a best-interests decision is recorded showing why the practice is necessary and proportionate, how less-restrictive alternatives were considered, and how the person’s wishes and feelings were taken into account. Representatives/advocates are involved where appropriate and agreed.
Where an individual lacks capacity to consent to care or support arrangements, staff must follow the Mental Capacity Act 2005. Any restrictive practice must be assessed as a decision-specific best-interests decision and must be necessary, proportionate, the least restrictive available option and clearly recorded.
Where arrangements in a domiciliary care or community setting may amount to a deprivation of liberty, this must be escalated immediately to the Registered Manager. The Registered Manager must review the person’s capacity, restrictions, supervision, freedom to leave, objections, risks, alternatives and the cumulative impact of the care arrangements. The Registered Manager must liaise with the placing authority, commissioner, legal representative or relevant responsible body and seek legal advice where required.
DoLS authorisations apply to care homes and hospitals. In a person’s own home, supported living or another community setting, a deprivation of liberty will usually require Court of Protection authorisation unless another lawful framework applies. No staff member may implement or continue arrangements that amount to a deprivation of liberty without lawful authority. Any urgent concern must be treated as a safeguarding and human rights matter.
Following the Supreme Court judgment of 2 June 2026 and CIW’s 15 June 2026 statement, {{org_field_name}} will keep deprivation of liberty arrangements under active review and will seek legal advice where changes to practice may be required.
9. Authorising Planned Restrictive Practices
Planned restrictive practices must be exceptional and:
- be grounded in an individual risk assessment with clear triggers, thresholds and exit criteria;
- be documented in the personal plan with rationale, technique, staff roles, time limits and review points;
- be approved by {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}} following multi-disciplinary input where relevant (e.g., OT/SLT/prescriber);
- be communicated to all relevant staff with practice guidance and competency checks; and
- be reviewed at least every three months and after any incident.
10. Emergency (Unplanned) Physical Intervention
Emergency physical intervention may only be used where there is an immediate risk of harm to the person or another person, and where de-escalation, distraction, withdrawal, environmental adjustment or other less restrictive approaches have been tried or are not possible in the circumstances.
Any emergency physical intervention must:
- be necessary to prevent harm;
- be proportionate to the seriousness and likelihood of harm;
- be the least restrictive option available;
- be used for the shortest possible time;
- stop as soon as the immediate risk reduces;
- avoid any technique that may restrict breathing, circulation, communication, swallowing or consciousness;
- be carried out only by staff trained and competent in the method used, except where immediate action is required to prevent serious harm and no trained person is available;
- be followed by reassurance, welfare checks, recording, management review and learning.
Staff must notify a manager as soon as possible and on the same day. A record must be completed within 24 hours. The manager must review whether the incident meets safeguarding, duty of candour, CIW notification, commissioner notification, prescriber notification, police or health professional referral thresholds.
Emergency interventions must not become routine. If an emergency intervention happens more than once, or if a pattern is identified, the person’s risk assessment, PBS plan, personal plan, staff training and commissioning arrangements must be reviewed without delay.
10.1 CIW Notifications, Safeguarding and Duty of Candour
The Registered Manager must consider whether any restrictive practice or physical intervention requires notification or referral. This decision and the rationale must be recorded.
CIW must be notified through CIW Online where the incident is notifiable, including where restrictive practice or physical intervention:
- results in death, serious injury or serious harm;
- involves abuse, neglect, improper treatment or suspected unlawful restraint;
- involves police attendance or potential criminal conduct;
- indicates a safeguarding concern;
- suggests a pattern, escalation or systemic failure in care planning, staffing, training or oversight;
- involves deprivation of liberty without clear lawful authority;
- causes significant distress, trauma or loss of dignity;
- materially affects the safety, well-being or rights of the person or others.
The local authority safeguarding team must be contacted without delay where there is any allegation, evidence or suspicion of abuse, neglect, improper treatment, unlawful restraint or inappropriate deprivation of liberty.
The duty of candour must be followed where something has gone wrong and has caused, or may cause, harm. The person and, where appropriate, their representative must receive a timely, open and honest explanation, an apology where appropriate, information about actions being taken and information about how to raise a concern or complaint.
The manager must ensure that notifications, safeguarding referrals, commissioner updates, family or representative communications and duty of candour actions are recorded clearly and reviewed for learning.
11. Chemical Restraint (Medication Used to Control Behaviour)
Medication must not be used to control behaviour unless prescribed for that purpose by a qualified prescriber following assessment, with a documented PRN/behavioural protocol that includes indications, maximum dose, contraindications and monitoring. Consent/best-interests is recorded and the primary purpose is explicit. The protocol is kept with the MAR and cross-referenced in the personal plan. Effects and side-effects are recorded at each administration, and the prescriber reviews necessity and effectiveness regularly; the manager seeks medicines optimisation/STOMP input where appropriate.
Every administration of PRN medication used in response to distress or behaviour of concern must trigger a review of the reason for use, whether non-medicinal strategies were attempted, the effect on the person, side effects, whether the person’s presentation changed, whether medical advice is required and whether the PBS plan or personal plan needs updating. Repeated use, increased frequency, sedation, falls, reduced engagement, change in presentation or concern that medication is being used to manage staffing or service pressures must be escalated to the prescriber, commissioner and Registered Manager without delay. Where chemical restraint may amount to abuse, neglect, improper treatment or unlawful restriction, safeguarding and CIW notification procedures must be followed.
12. Mechanical, Environmental, Surveillance and Technology-Based Restrictions
Mechanical, environmental, surveillance and technology-based restrictions must only be used where they are individually assessed, lawful, necessary, proportionate, least restrictive and clearly recorded in the person’s personal plan.
Mechanical restrictions, such as lap belts, specialist seating, bed rails, harnesses or positioning equipment, must only be used following appropriate professional assessment or clinical recommendation. The assessment must identify the purpose of the equipment, risks, benefits, alternatives considered, consent or best-interests decision, checks required at each use, review date and plan to reduce or remove the restriction where possible.
Environmental restrictions, such as locked doors, keypad locks, restricted access to rooms, removal of items, placement of furniture, door alarms or access controls, must not be used as blanket restrictions. They must be individually justified and must include arrangements that allow the person to access areas, possessions, visitors, activities and community life wherever safe and lawful.
Surveillance and technology-based restrictions, such as cameras, sensors, GPS trackers, monitoring devices, electronic medication dispensers, falls monitors or door alerts, must have a clear assessed purpose. The person’s consent must be obtained where they have capacity. Where the person lacks capacity, a best-interests decision must be recorded. The privacy, dignity and human rights impact must be considered. Surveillance must never be used for staff convenience or as a substitute for safe staffing, skilled care, observation or person-centred support.
All restrictions in this section must be reviewed at least every three months, sooner after any incident, and sooner if the person objects, their needs change, the restriction increases, or the restriction may amount to deprivation of liberty.
13. Recording and Post-Incident Review
For every restrictive episode, staff complete an incident record the same day covering:
- date/time/duration;
- location;
- precipitating events;
- less-restrictive strategies attempted;
- who used the intervention and their training/competency date;
- technique used;
- impact on the person;
- injuries/medical checks;
- debrief offered/completed;
- family/representative informed;
- manager’s review;
- actions to prevent recurrence.
The incident record must also include:
- whether the intervention was planned or emergency;
- the specific risk of harm being prevented;
- why the intervention was necessary and proportionate;
- why less restrictive options were not sufficient;
- whether the person consented, objected or lacked capacity at the time;
- any capacity assessment or best-interests decision relevant to the restriction;
- whether the intervention formed part of the personal plan or PBS plan;
- whether the intervention may amount to deprivation of liberty;
- whether the intervention was in line with staff training and approved methods;
- the person’s emotional presentation before, during and after the incident;
- whether advocacy, family, representative or commissioner involvement is required;
- whether safeguarding, CIW notification, police, health professional, prescriber or duty of candour action is required;
- the manager’s decision, rationale and follow-up actions;
- how learning will be used to reduce or remove future restrictive practice.
Managers analyse trends (e.g., ABC patterns, times/places, staff mix) and feed learning into supervision, refresher training and service improvement. Where there is injury, significant risk, pattern escalation or safeguarding concern, statutory notifications and commissioner/prescriber updates are considered and documented.
14. Welsh Language and Accessible Communication
We provide information, plans and debriefs in the person’s preferred language and format (Active Offer of Welsh; Easy Read; large print; interpreter). Staff follow the communication strategies set out in the personal plan.
15. Advocacy and Involvement
Where a person may be vulnerable or finds it difficult to be heard, we promote access to independent advocacy and involve chosen representatives. We document who supports the person and how they are involved in decisions and reviews.
16. Governance, Review and Oversight
Manager oversight: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}} reviews all incidents weekly, signs planned protocols, and ensures refresher training and competency checks are current.
Responsible Individual oversight: {{org_field_nominated_individual_first_name}} {{org_field_nominated_individual_last_name}} receives quarterly thematic analysis of all restrictive practices and physical interventions, including frequency, type, duration, location, person affected, staff involved, injuries, safeguarding referrals, CIW notifications, duty of candour actions, patterns, recurrence, training needs, quality-of-care learning and whether actions have been completed. The Responsible Individual must use this information to support effective oversight, service improvement and compliance with CIW inspection expectations.
Quality-of-care review: Records and analysis of control, restraint and restrictive practice must be included in the service’s quality assurance and quality-of-care review processes. The review must identify whether restrictions are reducing, whether people’s rights and well-being are being promoted, whether personal plans remain accurate and whether staff have the competence and confidence to use least restrictive approaches.
Care-plan review: all restrictive measures are reconsidered at least every three months with the person and representatives and removed at the earliest opportunity.
Supervision and training: complex cases and incident learning are discussed in 1:1 supervision and appraisals; targeted coaching and refresher training are arranged where needed.
17. Roles and Responsibilities
All staff must:
- follow the person’s personal plan, PBS plan, risk assessment and communication plan;
- use prevention, reassurance, de-escalation and least restrictive options first;
- respect the person’s rights, dignity, privacy, culture, language, relationships and choices;
- support positive risk-taking and not remove choice solely because a decision involves risk;
- use restrictive practice only where it is lawful, necessary and proportionate to prevent harm;
- stop any restriction as soon as the risk reduces;
- never use prohibited practices;
- record all restrictive practice accurately and promptly;
- report concerns, poor practice, unlawful restraint or improper treatment immediately;
- take part in debriefs, supervision, training and reflective learning.
Coordinators and senior staff must:
- ensure staff have access to current personal plans, PBS plans and risk assessments;
- allocate staff with the skills and competence required to support the person safely;
- monitor patterns of distress, incidents, missed calls, late calls, staff changes and environmental triggers;
- escalate concerns where care arrangements appear to be restrictive, unsafe or no longer suitable.
The Registered Manager must:
- approve and review planned restrictive practices;
- ensure capacity, consent, best-interests and lawful authority are addressed;
- ensure staff are trained and competent;
- review all incidents and identify learning;
- make safeguarding referrals and CIW notifications where required;
- ensure duty of candour is followed;
- ensure restrictions are reviewed, reduced and removed wherever possible;
- ensure commissioners and relevant professionals are involved where risks change.
The Responsible Individual must:
- maintain oversight of restrictive practice across the service;
- review quarterly analysis and ensure actions are completed;
- challenge any increase, pattern or normalisation of restrictive practice;
- ensure the service has the resources, staffing, training and governance needed to meet legal and CIW requirements.
Agency workers, students and volunteers must follow this policy and must not use any restrictive intervention unless they have been authorised, trained, assessed as competent and briefed on the person’s plan, except in an immediate emergency to prevent serious harm.
18. Related Documents
- DCW07 Person-Centred Care
- DCW11 Safe Care and Treatment
- DCW13 Safeguarding Adults from Abuse and Improper Treatment
- DCW34 Confidentiality and Data Protection
- DCW39 Mental Capacity and DoLS
- DCW58 Medication Management
- DCW169 Staff Supervision
- Duty of Candour Policy
- CIW Notifications Policy
- Positive Behaviour Support Policy
- Mental Capacity Act Policy
- Deprivation of Liberty / Court of Protection Guidance
- Safeguarding Children Policy, where children receive services
- Whistleblowing Policy
- Complaints Policy
- Equality, Diversity and Human Rights Policy
- Welsh Language Policy
- Telecare and Technology-Enabled Care Policy
- Medication PRN Protocols
- Incident Reporting and Accident Policy
- Staff Training and Competency Policy
- Lone Working Policy
- Risk Assessment and Positive Risk-Taking Policy
19. Monitoring Against CIW Inspection Themes and Ratings
{{org_field_name}} will monitor restrictive practice and physical intervention as part of its quality assurance arrangements and CIW inspection readiness.
The service will review whether:
- people are supported to achieve well-being outcomes and are protected from harm;
- people’s rights, dignity, choice, communication needs and Welsh language needs are upheld;
- care and support is provided in line with personal plans, PBS plans and risk assessments;
- staff understand and follow least restrictive practice;
- staff are trained, supervised and competent;
- incidents are recorded, reviewed and used for learning;
- safeguarding, CIW notification and duty of candour requirements are met;
- restrictions are reducing over time;
- restrictive practice is not becoming normalised through routines, culture, staffing pressures or blanket rules;
- the Responsible Individual and Registered Manager have effective oversight.
Findings will be used to improve practice, update training, revise personal plans, inform the quality-of-care review and evidence compliance with CIW inspection expectations.
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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