{{org_field_logo}}

{{org_field_name}}

Registration Number: {{org_field_registration_no}}

---

Supporting Communication Needs Policy

1. Purpose

The purpose of this policy is to ensure that {{org_field_name}} provides effective, inclusive, and person-centred communication support for all people we support. Effective communication is fundamental to delivering high-quality care, promoting independence, and ensuring the rights and dignity of individuals. This policy is in line with the Health and Social Care Standards: My Support, My Life; the Scottish Social Services Council (SSSC) Codes of Practice for Social Service Workers and Employers 2024; the Public Services Reform (Scotland) Act 2010; the Social Care and Social Work Improvement Scotland (Requirements for Care Services) Regulations 2011, including Regulation 5 on personal plans; the Equality Act 2010; the Adults with Incapacity (Scotland) Act 2000; the Adult Support and Protection (Scotland) Act 2007; the Mental Health (Care and Treatment) (Scotland) Act 2003; the British Sign Language (Scotland) Act 2015 and the BSL National Plan 2023–2029; and relevant Care Inspectorate guidance and quality frameworks.

This policy aims to:

• Ensure all individuals have access to the communication methods and tools that best suit their needs.
• Promote inclusive communication and address any barriers to effective interactions.
• Train and support staff to communicate appropriately and sensitively with individuals who have additional communication needs.
• Maintain legal compliance and best practices in supporting individuals with speech, language, hearing, cognitive, or sensory impairments.
• Ensure that people we support can express their choices, preferences, and concerns freely and effectively.
• Ensure communication support is planned, recorded, reviewed and updated as part of each person’s personal plan, including any reasonable adjustments, communication aids, interpreters, advocacy support, accessible information, risks, preferences and agreed actions.

2. Scope

This policy applies to:

• All staff, including care workers, supervisors, and management, who interact with people receiving care.
• Agency and temporary staff, ensuring they understand and follow communication best practices.
• External professionals such as speech and language therapists and advocacy services involved in communication support.
• Families and carers, ensuring they are included in communication planning when appropriate.
• Legal representatives, welfare attorneys, welfare guardians, named persons, independent advocates and other representatives, where they have legal authority or the person has consented to their involvement.

3. Legal and Regulatory Framework

This policy supports compliance with the following legislation, standards and guidance relevant to Care at Home and Support Services in Scotland:

• Public Services Reform (Scotland) Act 2010 – Provides the statutory framework for the regulation and inspection of care services in Scotland by the Care Inspectorate. The Health and Social Care Standards and SSSC Codes of Practice are taken into account in the regulation and improvement of care services.
• Social Care and Social Work Improvement Scotland (Requirements for Care Services) Regulations 2011, SSI 2011/210 – Requires the provider to prepare a written personal plan for each person using the service within 28 days of the person first receiving the service. The personal plan must set out how the person’s health, welfare and safety needs are to be met, be developed following consultation with the person and, where appropriate, their representative, and be reviewed at least every six months or sooner where needs change.
• Health and Social Care Standards: My Support, My Life – The service will ensure that people are fully involved in decisions about their care and support, are supported to communicate in a way that is right for them and at their own pace, and have personal plans that set out how their needs, wishes and choices will be met.
• SSSC Codes of Practice for Social Service Workers and Employers 2024 – Workers must protect and promote the rights and interests of individuals and carers, communicate in a respectful, open, accurate and straightforward way, and work with individuals and carers to communicate using their preferred method and language. The organisation must support workers through induction, learning, development, supervision, policies and systems that enable them to meet the Codes.
• Equality Act 2010 – The service will not discriminate against people because of protected characteristics, including disability, race, religion or belief, age, sex, sexual orientation, gender reassignment, pregnancy or maternity, or marriage and civil partnership. The service will make reasonable adjustments, including auxiliary aids and accessible communication formats, where a person would otherwise be placed at a substantial disadvantage.
• Adults with Incapacity (Scotland) Act 2000 – Where a person has impaired capacity, staff will support the person to communicate their views as far as possible, take account of the person’s present and past wishes and feelings, and consult relevant representatives such as welfare attorneys, welfare guardians, nearest relatives, named persons or primary carers where appropriate and lawful. Any intervention must benefit the person and be the least restrictive option.
• Mental Health (Care and Treatment) (Scotland) Act 2003 – Where a person has a mental disorder, staff will respect the person’s rights, communication needs and participation in decision-making. People who have a mental disorder must be informed of and supported to access independent advocacy where this is relevant to their care, support, rights or welfare.
• Adult Support and Protection (Scotland) Act 2007 – Staff will recognise that communication barriers may increase a person’s risk of harm or reduce their ability to report harm, neglect, exploitation or abuse. Any concern that an adult may be at risk of harm must be reported in line with the organisation’s Adult Support and Protection and safeguarding procedures.
• British Sign Language (Scotland) Act 2015 and BSL National Plan 2023–2029 – The service will support BSL users to communicate in their preferred language and will make reasonable arrangements for BSL interpretation, communication support and accessible information where required.
• Data Protection Act 2018 and UK GDPR – Communication needs, communication support plans, advocacy involvement, interpreter arrangements and related records will be treated as personal information and, where relevant, special category health or social care information. Records must be accurate, relevant, up to date, securely stored, shared only where lawful and necessary, and handled in line with the organisation’s Data Protection and Confidentiality Policy.
• Care Inspectorate Quality Frameworks and Guidance – The service will use relevant Care Inspectorate quality frameworks, personal planning guidance, notification guidance and records guidance to self-evaluate and improve communication support.

3.1 Rights-Based Communication Principles

{{org_field_name}} recognises communication as a rights, dignity, equality, safety and wellbeing issue. Staff must not treat communication support as optional or secondary to care tasks.

Staff will:

• presume that every person has the right to express views, make choices and be involved in decisions about their care and support;
• communicate with kindness, compassion, patience and respect;
• use the person’s preferred method and language wherever possible;
• allow the person enough time to understand information and respond;
• provide information in accessible formats where required;
• involve advocates, representatives, interpreters, family, carers and professionals where appropriate and lawful;
• avoid jargon, assumptions, discriminatory language or infantilising language;
• respect silence, refusal, distress, disagreement and non-verbal communication as meaningful communication;
• protect the person’s privacy and confidentiality when communication support is provided;
• record communication needs and agreed support clearly in the person’s personal plan.

Staff must never ignore, override or speak over a person because their communication is different, slower, non-verbal, assisted or difficult to understand.

4. Identifying Communication Needs

4.1 Initial Assessment

When a person starts to receive a service from {{org_field_name}}, their communication needs will be assessed as part of their initial assessment and personal planning process. A written personal plan will be prepared within 28 days of the person first receiving the service and will include the communication support required to meet the person’s needs, wishes, choices, rights, safety and wellbeing.

This includes:

• Preferred language or communication method (e.g., spoken, written, visual, assistive technology, British Sign Language (BSL)).
• The person’s preferred name, pronouns, cultural communication preferences and any words, signs, gestures, objects of reference or visual prompts that are meaningful to them.
• Whether the person needs information in an accessible format, such as Easy Read, large print, Braille, audio, pictorial format, translated information, BSL, video, digital format or another format chosen by the person.
• How the person communicates consent, refusal, pain, distress, anxiety, discomfort, choice, satisfaction and dissatisfaction, including non-verbal signs.
• Whether communication needs may affect the person’s ability to raise concerns, make complaints, report harm, understand risks or participate in reviews.
• Whether the person has a welfare attorney, welfare guardian, named person, independent advocate, appointee or other representative who should be consulted or involved.
• Any hearing or visual impairments requiring adjustments.
• Use of communication aids, such as hearing aids, speech devices, or pictorial symbols.
• The need for interpreters, advocacy, or family involvement.
• Any medical conditions, such as dementia, stroke, or autism, affecting communication.

The communication assessment and communication support plan will be reviewed whenever the person’s needs, wishes, circumstances, health, capacity, sensory needs or communication methods change, and at least every six months as part of the personal plan review. A review will also take place where staff have increased difficulty understanding what the person wants, where there are communication-related incidents, complaints or safeguarding concerns, or where the person, their representative, family, advocate or staff request a review.

4.2 Communication Support Plan

Where a person has communication needs, these will be recorded in a communication support plan within their personal plan. The plan will be developed with the person and, where appropriate, their representative, family, carer, advocate and relevant professionals.

The communication support plan will include:

• the person’s preferred language, communication method and accessible information format;
• how the person communicates choices, consent, refusal, pain, distress, anxiety, enjoyment, concerns and complaints;
• any communication aids, equipment, visual prompts, hearing aids, glasses, dentures, technology, BSL support, interpretation, translation or advocacy required;
• how staff must support communication during personal care, medication support, meals, moving and assisting, outings, reviews, complaints and emergencies;
• how staff should check understanding without placing pressure on the person or using leading questions;
• what may make communication harder, such as noise, poor lighting, anxiety, pain, fatigue, infection, unfamiliar staff, time pressure or changes in routine;
• what staff should do if communication breaks down or the person appears distressed;
• who should be contacted for specialist advice, such as Speech and Language Therapy, sensory impairment services, advocacy, GP, district nursing, learning disability services, dementia services or mental health services;
• the date the plan was agreed, the people involved, and the review date.

The plan must be written in respectful, person-centred language and be available to staff who need it to provide safe, consistent and rights-based care.

5. Supporting Different Communication Needs

5.1 Verbal Communication Support

For individuals who have difficulty with verbal communication, staff will:

• Use clear, simple language and avoid jargon.
• Speak slowly and at an appropriate volume.
• Allow extra time for individuals to process and respond.
• Check understanding in a respectful and non-judgemental way, for example by asking the person how they would like information explained, using visual or written prompts where helpful, and asking open questions. Staff must not test, pressure, patronise or embarrass the person.
• Adapt tone and body language to be reassuring and supportive.

Staff must not assume that a person has understood information because they nod, smile, remain silent or do not ask questions. Staff must consider whether pain, fatigue, distress, sensory impairment, mental health, medication, infection, cognitive impairment, trauma or environmental factors may be affecting communication.

5.2 Non-Verbal and Alternative Communication Methods

For individuals who rely on non-verbal communication, {{org_field_name}} ensures access to:

• Sign language interpreters (including BSL for Deaf individuals).
• Picture Exchange Communication Systems (PECS) for individuals with learning disabilities or autism.
• Makaton for those who use simplified signs and symbols.
• Communication boards, flashcards, and written instructions.
• Speech-to-text devices and text-based communication tools.
• Augmentative and Alternative Communication (AAC) devices, including text-to-speech software.

Staff will follow the person’s agreed communication support plan and will not remove, disable, ignore or fail to make available communication aids that the person relies on, unless there is a clear, recorded and lawful reason relating to immediate safety. Any concern about safe use of equipment must be discussed with the person, their representative where appropriate, and relevant professionals.

Where a person uses AAC, objects of reference, communication passports, Talking Mats, pictures, photographs, symbols, gestures, facial expressions or other personalised approaches, staff must use these consistently and record what works well for the person.

5.3 Supporting Individuals with Sensory Impairments

For individuals with hearing impairments, staff will:

• Ensure hearing aids are working properly and are worn when needed.
• Use visual aids such as written notes or digital text displays.
• Face the individual when speaking and ensure good lighting for lip-reading.
• Reduce background noise and distractions to improve comprehension.

Ask the person how they prefer staff to communicate with them and record this in the communication support plan. Staff must not assume that lip-reading, written notes or increased volume will meet the person’s needs. Where required, staff will arrange appropriate communication support, including BSL/English interpreters, Deafblind communication support, captioning, relay services or other specialist support.

For individuals with visual impairments, staff will:

• Provide large print or Braille materials where required.
• Use audio descriptions and spoken instructions.
• Ensure safe, accessible environments with clear signage and pathways.
• Support individuals to navigate their surroundings safely.

Staff will explain who they are when entering the person’s home, describe what they are doing before providing care or support, and ensure that any written information, rota changes, complaints information, medication information or review documents are provided in a format the person can access.

5.4 Supporting Individuals with Cognitive or Speech Impairments

For individuals with dementia, stroke, or other neurological conditions, staff will:

• Use repetitive and familiar phrases to reinforce understanding.
• Encourage use of gestures, facial expressions, and touch cues.
• Allow additional time for processing and responding.
• Break down complex information into short, clear steps.
• Use reminders and memory aids (e.g., written schedules, clocks, and calendars).

Staff must presume that the person is able to participate in decisions unless there is evidence that they are unable to do so for the specific decision at the specific time. Staff will provide all practicable support to help the person understand, retain, use or weigh relevant information and communicate their decision. Where the person has impaired capacity, staff will still involve the person as far as possible and will consult relevant legal representatives or others who know the person’s wishes, in line with the Adults with Incapacity (Scotland) Act 2000 and the personal plan.

5.5 Access to Advocacy and External Support

{{org_field_name}} will ensure that people are informed about, and supported to access, independent advocacy where this would help them understand information, express their views, make choices, participate in reviews, raise concerns, make complaints, understand risks, or protect their rights.

Advocacy will be offered in particular where the person:

• has difficulty understanding, retaining or communicating information;
• has no family, carer or representative to support them;
• has a mental disorder, learning disability, dementia, acquired brain injury or other condition affecting communication or decision-making;
• is subject to safeguarding, Adult Support and Protection, mental health or Adults with Incapacity processes;
• appears distressed, unheard, overruled or unable to express disagreement;
• wishes to make a complaint or challenge a decision about their care or support.

Where required and with the person’s agreement, {{org_field_name}} will seek support from Speech and Language Therapy, sensory impairment services, community learning disability teams, dementia services, mental health services, occupational therapy, GP, district nursing, social work, BSL/English interpreters, translation services, Deaf organisations, Deafblind services and other relevant professionals or community supports.

Referrals, advice received and agreed actions must be recorded in the person’s personal plan and communication support plan.

5.6 Accessible Information

{{org_field_name}} will provide information in a format and language that the person can understand. This includes, where required, information about the service, care visits, changes to visits, personal plans, reviews, medication support, complaints, safeguarding, privacy notices, consent, charges and how to contact the service.

Accessible formats may include Easy Read, large print, Braille, audio, pictures, photographs, symbols, translated information, BSL, video, digital text, email, communication apps or another format agreed with the person.

Staff must check that the person has had enough time and support to understand important information before asking them to make a decision. Where information is urgent, staff will still make reasonable efforts to communicate in the person’s preferred way and will record the steps taken.

5.7 Communication, Risk and Safeguarding

Communication needs can increase the risk that a person may not be able to report harm, abuse, neglect, exploitation, poor care, pain, distress or unmet needs. Staff must be alert to changes in communication, behaviour, mood, presentation, physical condition or engagement that may indicate distress or harm.

Staff must report any safeguarding or Adult Support and Protection concern immediately in line with {{org_field_name}}’s safeguarding procedures. This includes concerns that a person is being prevented from communicating, is being spoken for inappropriately, is being denied access to communication aids, is being intimidated, or is unable to raise concerns because of communication barriers.

Where communication needs create or increase risks, the personal plan must include clear guidance on how staff will reduce those risks while respecting the person’s rights, choices, privacy, dignity and independence.

6. Staff Training and Competency

To ensure high-quality communication support, all staff must complete training in:

• Effective communication strategies tailored to different needs.
• Awareness of non-verbal communication methods.
• Safeguarding individuals who are non-verbal or have limited communication.
• Use of assistive communication technology and aids.
• Recognising signs of distress or frustration due to communication barriers.
• Confidentiality and GDPR compliance when handling communication records.
• The Health and Social Care Standards, with particular focus on involvement, personal planning, communication, dignity, rights and choice.
• The SSSC Codes of Practice 2024, including workers’ responsibilities to communicate using the person’s preferred method and language.
• Equality Act 2010 duties, including reasonable adjustments and accessible information.
• Adults with Incapacity principles, supported decision-making and how to involve people who have impaired capacity.
• Adult Support and Protection awareness, including how communication barriers may affect a person’s ability to disclose harm or raise concerns.
• Awareness of BSL, Deaf culture, sensory impairment, dementia, stroke, aphasia, autism, learning disability, mental health, trauma-informed practice and distress communication.
• How to use and maintain communication aids, visual prompts, communication passports and assistive technology where these are part of a person’s support plan.

Supervisors will assess staff competence through induction, observation of practice, supervision, spot checks, feedback from people receiving support, feedback from families or representatives where appropriate, care record audits and incident or complaint analysis. Refresher training and additional coaching will be provided where communication practice falls below expected standards or where a person’s needs change.

7. Monitoring and Evaluating Communication Support

To ensure continuous improvement, {{org_field_name}} will:

• review each person’s communication support plan at least every six months as part of the personal plan review, and sooner where needs, wishes, risks or circumstances change;
• check that communication needs and reasonable adjustments are clearly recorded in personal plans and daily records;
• seek feedback from people receiving support about whether staff communicate in a way that is right for them and at their own pace;
• seek feedback from representatives, families, carers, advocates and professionals where appropriate and lawful;
• audit whether accessible information, interpreters, communication aids, advocacy and specialist referrals are provided when needed;
• monitor complaints, concerns, incidents, safeguarding referrals and missed outcomes where communication may have been a factor;
• use findings from audits, complaints, incidents, supervision and feedback to improve staff training, personal plans and practice;
• include communication support in service self-evaluation and quality assurance processes.

7.1 Recording Requirements

Staff must record communication support accurately, respectfully and promptly. Records must include:

• identified communication needs and preferred communication methods;
• agreed reasonable adjustments and accessible information formats;
• communication aids, equipment or technology used;
• interpreter, translation, advocacy or specialist support required or provided;
• how the person expressed choices, consent, refusal, distress, pain, satisfaction or dissatisfaction;
• any communication barriers experienced during care or support;
• action taken to overcome communication barriers;
• referrals made and advice received from professionals;
• review dates and changes to the communication support plan.

Records must be factual, person-centred, free from discriminatory language and written in a way that the person would recognise as respectful. Communication records must be managed in line with Data Protection Act 2018, UK GDPR, confidentiality requirements and the organisation’s records management procedures.

7.2 Complaints and Raising Concerns

{{org_field_name}} will ensure that people with communication needs are able to raise concerns, make complaints and give feedback in a way that is accessible to them. Staff will provide support to use the complaints procedure, including accessible formats, interpreters, advocacy or representative support where required.

Staff must take seriously any verbal, non-verbal, written, behavioural or other indication that a person is unhappy, distressed, worried or objecting to care or support. Such concerns must be recorded and escalated in line with the Complaints Policy, Safeguarding Policy or Adult Support and Protection procedures as appropriate.

People will be informed that they may complain directly to the Care Inspectorate at any time, and staff will support them to do so where required.

8. Related Policies

This policy should be read alongside:

• Person-Centred Care Planning Policy
• Equality, Diversity, and Inclusion Policy
• Safeguarding and Protection Policy
• Training and Continuing Professional Development Policy
• Data Protection and Confidentiality Policy
• Complaints Policy
• Adult Support and Protection Policy
• Advocacy Policy
• Mental Capacity / Adults with Incapacity Policy
• Accessible Information Policy
• Interpreting and Translation Policy
• Personal Planning Policy
• Record Keeping Policy
• Consent Policy
• Incident Reporting and Notification Policy

9. Policy Review

This policy will be reviewed at least annually, or sooner where there are changes to legislation, Health and Social Care Standards, SSSC Codes of Practice, Care Inspectorate guidance, BSL policy, safeguarding requirements, data protection requirements, organisational learning, complaints, incidents, inspection findings or identified good practice. Any amendments will be communicated to staff and relevant stakeholders, and staff will receive additional guidance or training where changes affect their role.

---

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}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.