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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Restraint, Restrictive Practice and Use of Force Policy

1. Purpose

The purpose of this Restraint, Restrictive Practice and Use of Force Policy is to provide clear guidance to all temporary workers, agency staff and directors of {{org_field_name}} on the safe, lawful, ethical and proportionate approach to restraint and restrictive practice when workers are supplied to care homes, hospitals, mental health units, supported living services or other health and social care settings.

{{org_field_name}} is a temporary staffing agency and does not provide regulated care directly. The client organisation remains responsible for the care plan, risk assessment, authorisation, supervision, recording and statutory notifications relating to restraint and restrictive practice within its service. However, {{org_field_name}} has a responsibility to supply suitable, trained and competent workers, to make workers aware of their duties, to respond to concerns, and to cooperate with clients, safeguarding authorities and regulators where concerns arise.

Restraint and restrictive interventions carry significant legal, physical, psychological and human rights risks. They must only be used as a last resort, for the shortest possible time, using the least restrictive option, and only where necessary and proportionate to prevent harm. Temporary workers must prioritise prevention, de-escalation, positive behaviour support, trauma-informed practice, dignity, respect and the rights of the person.

This policy supports compliance with the Human Rights Act 1998, the Mental Capacity Act 2005, the Deprivation of Liberty Safeguards, the Care Act 2014, the Equality Act 2010, the Health and Safety at Work etc. Act 1974, the Mental Health Units (Use of Force) Act 2018 where applicable, and relevant guidance from CQC, NICE, NHS England and the Department of Health and Social Care.

2. Scope

This policy applies to:

• All temporary workers of {{org_field_name}}, including registered nurses, healthcare assistants, and support staff working under zero-hours or casual contracts
• Directors and any other staff with responsibilities for monitoring the performance, training, and placement of temporary workers
• All client environments into which temporary workers may be supplied, including nursing homes, residential care homes, supported living services, hospitals, mental health units, community health settings and other health or social care settings. The client organisation remains responsible for the person’s care plan, risk assessment, restraint authorisation and statutory notifications.
• The support of adults who may lack capacity or require interventions due to challenging behaviours, cognitive impairment, learning disabilities, mental health needs, or complex care needs

Temporary workers are also required to comply with any additional restraint and restrictive practice policies provided by the client organisation during their placement.

This policy applies to adult placements. Where {{org_field_name}} supplies workers to services involving children or young people, workers must follow the client’s child-specific restraint, safeguarding and behaviour support policies, and {{org_field_name}} must ensure workers have role-specific training and competence before placement. If {{org_field_name}} does not supply workers to children’s services, this must be confirmed in the agency’s placement procedures.

3. Related Policies

• Safeguarding Adults and Children Policy
• Incident Reporting and Management Policy
• Supervision and Appraisal Policy
• Complaints Policy
• Whistleblowing Policy
• Code of Conduct for Temporary Workers
• Mental Capacity and Consent Policy (to be developed if not yet in place)

4. Definitions

Restraint is any act which intentionally restricts a person’s movement, liberty, or freedom, whether physical, mechanical, chemical, or through indirect means. This includes physical restraint, restricting access to parts of a building, removing mobility aids, or using medication to control behaviour where it is not medically necessary.

Restrictive Intervention is any intervention that restricts a person’s rights or freedom to choose, move freely, or live without unnecessary control, used with the intention of managing behaviour or reducing risk.

Types of restraint include:

• Physical restraint: using direct physical force to restrict movement
• Mechanical restraint: using equipment or devices to restrict movement (e.g., bedrails, lap belts)
• Chemical restraint: using medication to control behaviour not related to medical treatment
• Environmental restraint: locking doors, removing mobility aids, limiting access
• Psychological restraint: verbal threats, intimidation, or coercion to control behaviour

Restrictive Practice means any practice, action or arrangement that limits a person’s movement, liberty, autonomy, privacy, dignity, contact with others, access to possessions, access to parts of the environment, or ability to make choices. Restrictive practice may be obvious or subtle and may include blanket rules, environmental restrictions, surveillance, psychological pressure, mechanical restraint, physical restraint, chemical restraint, seclusion or segregation.

Use of Force means the use of physical, mechanical or chemical force, or the threat of force, to make a person do something they are resisting or to prevent them from doing something. In mental health units, use of force must be managed in line with the Mental Health Units (Use of Force) Act 2018 and the client organisation’s statutory duties.

Blanket Restrictions are rules or restrictions applied to everyone, or to a group of people, without individual assessment of need, risk, capacity, consent or proportionality. Temporary workers must not introduce or apply blanket restrictions unless these are part of the client organisation’s lawful policy and individual care arrangements.

Seclusion means the supervised confinement and isolation of a person away from others in an area from which they are prevented from leaving. Temporary workers must not initiate seclusion unless they are specifically trained, authorised and acting strictly under the client organisation’s policy and legal framework.

Segregation means the planned separation of a person from others as part of their care or risk management arrangements. Temporary workers must only support segregation where it is part of an authorised care plan and client policy.

Prone restraint means holding a person chest-down or face-down. Planned or intentional prone restraint must not be used. If a person ends up in a prone position during an emergency intervention, workers must act immediately, where safe to do so, to move the person out of that position and protect their airway, breathing and circulation.

5. Principles of Restraint and Restrictive Intervention

Temporary workers must:

• Always act in the best interests of the client
• Use the least restrictive option necessary
• Presume the person has capacity unless it is established otherwise in relation to the specific decision at the specific time
• Support the person to make their own decision wherever possible
• Respect the person’s communication needs, disability, culture, religion, trauma history and known preferences
• Avoid blanket restrictions and ensure any restriction is individually assessed
• Use restraint only for the shortest possible time
• Monitor the person’s physical and emotional wellbeing throughout any intervention
• Stop the intervention as soon as the immediate risk has passed
• Never use planned or intentional prone restraint
• Never obstruct a person’s airway, breathing or circulation
• Never use restraint in a way that humiliates, degrades, punishes or frightens the person
• Apply restraint only when it is necessary, proportionate, and reasonable to prevent serious harm to the client or others
• Prioritise de-escalation, distraction, and other non-restrictive methods first
• Comply with the client organisation’s positive behaviour support plans (PBS)
• Avoid the use of restraint for discipline, punishment, or staff convenience
• Report every instance of restraint or restrictive intervention immediately

6. The Legal and Best Practice Framework

Temporary workers must act in accordance with the law, client policy, professional standards and this policy. The following legal and best practice framework applies where relevant:

• Human Rights Act 1998 — workers must respect the person’s right to life, dignity, liberty, private and family life, and freedom from inhuman or degrading treatment. Restraint must never be used in a degrading, humiliating, punitive or abusive way.
• Mental Capacity Act 2005 — workers must presume capacity unless the person lacks capacity for the specific decision at the specific time. Where a person lacks capacity, any act of restraint must be in the person’s best interests, necessary to prevent harm, proportionate to the likelihood and seriousness of harm, and the least restrictive option available.
• Deprivation of Liberty Safeguards — DoLS continue to apply in hospitals and care homes where a person aged 18 or over lacks capacity to consent to care or treatment arrangements and is under continuous supervision and control and not free to leave. Temporary workers must not decide whether DoLS applies but must report any concern that a person may be unlawfully deprived of liberty to the client’s nurse-in-charge, manager or safeguarding lead and to {{org_field_name}}.
• Care Act 2014 — restraint, restrictive practice, neglect, organisational abuse, discriminatory abuse or improper treatment may raise safeguarding concerns. Workers must report concerns immediately under the client’s safeguarding procedures and to {{org_field_name}}.
• Equality Act 2010 — workers must not discriminate against any person because of protected characteristics including disability, race, religion or belief, sex, age, sexual orientation, gender reassignment, pregnancy or maternity, or marriage and civil partnership. Workers must consider reasonable adjustments, communication needs and the risk of disproportionate restriction.
• Health and Safety at Work etc. Act 1974 — workers must take reasonable care of their own health and safety and the health and safety of others. {{org_field_name}} and the client organisation must cooperate to ensure workers are placed only where they have appropriate training, information and competence.
• Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 — these regulations apply directly to CQC-registered providers. {{org_field_name}} is not CQC-registered where it only supplies staff and does not provide regulated care. However, workers supplied into CQC-regulated services must follow the client’s policies and support the client to meet duties relating to person-centred care, dignity, consent, safe care, safeguarding, staffing and good governance.
• Mental Health Units (Use of Force) Act 2018 — where workers are supplied into mental health units, they must comply with the client organisation’s use of force policy, training requirements, recording requirements, post-incident review process and arrangements for reducing the use of force.
• NICE guidance NG10 and NG11 — workers should follow evidence-based approaches to preventing and managing violence, aggression and behaviour that challenges, including prevention, de-escalation, personalised support, positive behaviour support and restrictive interventions only as a last resort.
• NHS England and DHSC guidance on restrictive practice — workers must recognise that restrictive practice can include subtle restrictions, blanket rules, environmental limits, psychological pressure, surveillance and cultural practices, not only physical restraint.

6.1 Agency Status and Limits of Authority

{{org_field_name}} does not provide regulated care and does not authorise restraint, seclusion, segregation, DoLS arrangements or restrictive care plans. These decisions remain the responsibility of the client organisation and, where applicable, the relevant health or social care professionals, local authority, Court of Protection or statutory body.

Temporary workers supplied by {{org_field_name}} must not independently create, approve or amend restraint plans, behaviour support plans, DoLS arrangements or restrictive care arrangements. Workers may only follow the client’s authorised care plan, risk assessment and policy, and only where they have received appropriate training and instruction.

In an unforeseen emergency, a temporary worker may take immediate, reasonable, necessary and proportionate action to prevent serious harm, provided this is within their competence and is the least restrictive option available. The worker must stop as soon as the immediate risk has passed and must report and record the incident immediately.

7. Temporary Worker Responsibilities

Temporary workers must:

• Never use restraint unless trained, competent, and authorised by the client organization
• Confirm at the start of each assignment whether any person they support has a behaviour support plan, restraint plan, DoLS authorisation, risk assessment or specific restrictive practice protocol
• Ask the client’s nurse-in-charge, shift leader or manager for clarification before supporting any planned restrictive intervention
• Refuse to carry out any restraint or restrictive practice that appears unlawful, unsafe, abusive, discriminatory, punitive, degrading, outside their training, or not authorised by the client’s care plan
• Report immediately to the client and {{org_field_name}} if they are asked to use restraint without training, without a care plan, or in a way that causes concern
• Monitor the person’s breathing, airway, colour, level of distress, pain, consciousness and physical wellbeing during any intervention, where safe and appropriate
• Seek urgent medical assistance if the person shows signs of breathing difficulty, chest pain, loss of consciousness, injury, extreme distress or other medical concern
• Preserve dignity, privacy and communication throughout and after the intervention
• Only use restraint when necessary to prevent immediate harm and when other options have been exhausted
• Only apply restraint in line with the care plan and risk assessment of the client
• Consider the person’s capacity under the Mental Capacity Act 2005
• Use the minimum force for the minimum time
• Record and report every episode of restraint, even when it is brief or low-level
• Treat clients with dignity and respect during and after an incident
• Engage in reflection and debriefing with colleagues following an incident

Temporary workers must understand that “following orders” is not a defence to unsafe, abusive or unlawful restraint. If a worker believes an instruction from a client is unsafe, unlawful, discriminatory, degrading or outside their competence, they must not proceed and must escalate the concern immediately.

8. When Restraint May Be Considered

Restraint may be considered only when:

• There is a risk of immediate harm to the client or others
• The client is experiencing distress, confusion, or behaviours that challenge, where all de-escalation techniques have failed
• The person lacks capacity in relation to the specific decision at the specific time, and the restraint is necessary to prevent harm, proportionate to the likelihood and seriousness of that harm, in the person’s best interests, and the least restrictive option available.
• The client’s care plan and client organisation’s policy authorise the use of restraint

Restraint must never be:

• Used as a form of punishment
• Applied for staff convenience
• Used because of staffing shortages
• Used when less restrictive options have not been explored
• Used to enforce compliance where there is no immediate risk of harm
• Used because a person is noisy, distressed, non-compliant, wandering or refusing care, unless there is an immediate and serious risk of harm and less restrictive options have failed
• Used as a substitute for adequate staffing, supervision, care planning or therapeutic support
• Used in a planned or intentional prone position
• Used to restrict food, drink, toilet access, family contact, communication aids, mobility aids or personal possessions unless this is specifically authorised, risk assessed, lawful, proportionate and reviewed
• Used as a blanket restriction without individual assessment

8.1 Prohibited and High-Risk Practices

Temporary workers must not use or participate in any intervention that is abusive, degrading, punitive, discriminatory, unsafe or outside their training. The following are prohibited unless there is an immediate emergency and no safer alternative is available:

• Planned or intentional prone restraint
• Any restraint that restricts breathing, the airway, circulation or the person’s ability to communicate distress
• Pain-inducing techniques
• Restraint used as punishment, discipline, coercion or convenience
• Unauthorised seclusion or segregation
• Unauthorised removal of mobility aids, communication aids, call bells or personal possessions
• Unauthorised locking of doors or blocking exits
• Use of medication to sedate or control behaviour for convenience rather than clinical need
• Any intervention that humiliates, frightens, threatens or degrades the person

Where a worker witnesses prohibited or unsafe practice by any person, they must report it immediately to the client’s senior person on duty and to {{org_field_name}}. Where there is immediate danger, emergency services must be contacted.

9. Assessment, Planning, and Prevention

{{org_field_name}} does not complete the person’s clinical or care-provider restraint assessment unless specifically commissioned and legally able to do so. The client organisation is responsible for individual care planning, risk assessment, mental capacity assessment, best interests decision-making, DoLS authorisation requests and positive behaviour support planning. Temporary workers are responsible for reading, understanding and following these plans before providing support.

Temporary workers must:

• Familiarise themselves with each client’s care plan and behaviour support plan
• Identify triggers and early warning signs of escalating behaviour
• Use de-escalation strategies, redirection, and calming techniques wherever possible
• Respect the client’s known communication needs and preferences
• Work closely with the client’s permanent staff to follow approved intervention strategies
• Check whether there are communication passports, hospital passports, behaviour support plans, trauma-informed care plans or reasonable adjustment plans
• Avoid escalating language, unnecessary touch, crowding, confrontation, threats or rushed care
• Consider pain, infection, hunger, thirst, toileting needs, medication effects, sensory needs, fear, confusion, delirium, dementia, mental distress or environmental triggers
• Use respectful communication and give the person time and space wherever safe
• Seek support early from permanent staff where behaviour begins to escalate

9.1 Medication and Chemical Restraint

Medication must never be used for punishment, convenience, coercion, intimidation or routine behaviour control. Medication may only be administered by workers who are legally authorised, competent, trained and working within their role, professional registration and the client’s medication policy.

Registered nurses or other authorised workers supplied by {{org_field_name}} may administer prescribed medication only in accordance with the prescription, MAR chart, PRN protocol, care plan, relevant consent or best interests decision, and the client organisation’s policy.

Temporary workers must not request or pressure clinical staff to sedate a person for convenience or to compensate for staffing, environmental or communication difficulties. Any concern about inappropriate sedation, over-medication or medication being used as restraint must be reported immediately to the client’s senior person on duty and to {{org_field_name}}.

10. Post-Incident Procedures

Following any use of restraint:

• The worker must immediately report the incident to the client and to {{org_field_name}}
• An incident form must be completed accurately and in full
• The person must be checked for injury, pain, distress, breathing difficulty or other adverse effects
• Medical attention must be requested immediately where there is any concern about injury or physical or psychological harm
• The worker must record whether de-escalation was attempted and why restraint became necessary
• The worker must record the start time, end time, position of the person, staff involved, observations during the intervention, injuries, witnesses and action taken afterwards
• The client organisation should review whether the care plan, risk assessment or behaviour support plan requires updating
• The worker must cooperate with any safeguarding enquiry, complaint, investigation, police enquiry, professional regulator enquiry or client review
• A factual record must be documented, including the reason for the intervention, type of restraint used, duration, and outcome
• The client organisation must consider whether the person, their representative, family member, advocate, attorney or deputy should be informed, in line with confidentiality, consent, best interests, safeguarding and the client’s duty of candour procedures. Temporary workers must not independently disclose confidential information unless authorised or required for safeguarding or emergency reasons.
• Temporary workers must participate in a debriefing session with the client’s team and reflect on the incident during supervision
• The director will review all restraint incidents as part of quality assurance and safeguarding duties

11. Training and Competence

{{org_field_name}} will ensure that temporary workers receive appropriate induction and training relevant to their role and placements. This will include, as applicable:

• safeguarding adults and, where relevant, safeguarding children
• Mental Capacity Act 2005 and DoLS awareness
• equality, diversity, human rights and dignity
• positive behaviour support and least restrictive practice
• de-escalation and communication skills
• health and safety, incident reporting and lone working where relevant
• client-specific induction before or at the start of placement

{{org_field_name}} will only supply workers to placements where restraint, physical intervention, seclusion, segregation, rapid tranquillisation or other restrictive interventions may be required if the worker has appropriate evidence of current training, competence and suitability for that placement.

Workers must not participate in planned physical restraint, seclusion, segregation or specialist restrictive interventions unless they have been trained and assessed as competent in the relevant approved techniques and have been authorised by the client organisation.

Training must be proportionate to the worker’s role, the client setting and the risks of the assignment. {{org_field_name}} will maintain records of training, refresher dates, competency evidence and any placement restrictions.

12. Reporting, Record Keeping, and Notifications

Temporary workers must report every restraint, restrictive intervention or use of force incident immediately to the client’s nurse-in-charge, shift leader, manager or safeguarding lead, and to {{org_field_name}}.

The worker must complete the client organisation’s incident record and any {{org_field_name}} incident record required. Records must be factual, accurate, timely and include:

• the date, time and location of the incident
• what happened before the incident, including known triggers
• de-escalation and less restrictive options attempted
• why restraint or restriction was considered necessary
• the type of intervention used
• who was involved
• the duration of the intervention
• the person’s position during the intervention
• observations of breathing, distress, pain, injury or other welfare concerns
• whether medical assistance was required
• the outcome and post-incident support provided
• who was informed

The client organisation is responsible for statutory notifications to CQC, DoLS supervisory bodies, commissioners, safeguarding authorities, police or other regulators where required. {{org_field_name}} will cooperate with the client and relevant authorities and will make its own safeguarding referral where it believes this is necessary to protect a person from abuse, neglect or unlawful restraint.

{{org_field_name}} will retain agency incident records securely in line with data protection requirements and will use incident information to identify concerns about worker competence, client safety, training needs, repeat incidents or unsafe placements.

13. Support for Temporary Workers

{{org_field_name}} recognises that dealing with restraint situations may cause stress or distress to workers. The director will:

• Offer debriefing and emotional support following incidents
• Provide reflective supervision to help workers process difficult experiences
• Encourage workers to raise concerns about any assignment where they feel unsafe or unsupported

Where a restraint-related incident raises concerns about a worker’s conduct, competence, fitness to practise, health, safety or suitability, {{org_field_name}} may remove the worker from the assignment while the matter is reviewed. Where appropriate, {{org_field_name}} may notify the client, safeguarding authority, Disclosure and Barring Service, professional regulator, police or other relevant body.

14. Director’s Responsibilities

As {{org_field_name}} is a temporary staffing agency and does not provide regulated care directly, the director is responsible for:

• Ensuring this policy is implemented, reviewed, and monitored
• Confirming that all temporary workers receive appropriate training
• Ensuring that all restraint incidents are investigated fully
• Liaising with client organisations, safeguarding teams, commissioners, professional regulators, the Disclosure and Barring Service, police or CQC where appropriate and lawful.
• Removing workers from placements if concerns about their ability to manage restraint appropriately arise
• Promoting a culture of positive behaviour support and least restrictive practice across all placements
• Ensuring workers are not supplied to assignments requiring restraint competence unless suitable evidence of training and competence has been obtained
• Ensuring client requirements for training, induction, restraint competence and placement risks are checked before supply wherever reasonably practicable
• Reviewing incidents to identify whether a worker should be retrained, supervised, restricted from certain assignments, suspended or referred to an external body
• Ensuring the agency does not authorise care plans, DoLS arrangements, seclusion, segregation or restrictive interventions unless legally entitled and specifically commissioned to do so
• Ensuring records are kept securely and confidentially

15. Working with Client Organisations

Client organisations are responsible for ensuring that any restraint, restrictive practice, use of force, DoLS arrangement, seclusion, segregation or behaviour support plan within their service is lawful, authorised, risk assessed, care planned, recorded, reviewed and notified to relevant bodies where required.

{{org_field_name}} will:

• Collaborate with client organisations to ensure client-specific restraint procedures and plans are communicated to temporary workers
• Verify that workers assigned to placements where restraint may be necessary have the required skills and training
• Support clients in safeguarding investigations and quality assurance processes related to restraint and restrictive practices
• Ensure that temporary workers understand and comply with each client’s policies regarding restraint
• Request relevant information from clients about assignment risks, required competencies and client-specific restraint or behaviour support procedures
• Decline or withdraw a worker from a placement where the worker does not have the training, competence or support required for the assignment
• Ask clients to provide induction and handover information about care plans, behaviour support plans, communication needs, known risks and emergency procedures
• Cooperate with safeguarding enquiries, complaints, investigations and learning reviews
• Raise concerns with the client where workers report unsafe, excessive, discriminatory or unauthorised restraint or restrictive practice

15.1 Mental Health Units and Use of Force

Where {{org_field_name}} supplies workers to a mental health unit, workers must comply with the client organisation’s policy under the Mental Health Units (Use of Force) Act 2018 and associated statutory guidance.

Workers must follow the client’s requirements on reducing the use of force, approved techniques, training, recording, post-incident review, involvement of patients, family or advocates where appropriate, and monitoring of disproportionate use of force.

Workers must not use force unless it is necessary, proportionate, the least restrictive option, within their training and competence, and required to prevent harm. Any use of force must be reported and recorded immediately in accordance with the client’s policy and this policy.

15.2 Equality, Human Rights and Disproportionate Restraint

{{org_field_name}} recognises that restraint and restrictive practice can disproportionately affect people with protected characteristics, including disabled people, autistic people, people with learning disabilities, people from racialised communities, older people, people with dementia and people with mental health needs.

Temporary workers must consider communication needs, cultural needs, religious needs, trauma history, sensory needs, disability-related needs and reasonable adjustments before and during any intervention.

Workers must challenge and report any restraint or restrictive practice that appears discriminatory, excessive, humiliating, degrading or based on assumptions about a person’s diagnosis, disability, race, age, sex, behaviour, communication style or mental health.

16. Continuous Quality Improvement

The director will review restraint and restrictive practice incidents involving agency workers to identify learning, training needs, suitability concerns, unsafe placements and trends.

{{org_field_name}} will use the following sources to improve practice:

• incident reports
• worker feedback
• client feedback
• safeguarding outcomes
• complaints
• supervision records
• training and competency records
• concerns about repeated restraint or unsafe client environments

Where concerns are identified, {{org_field_name}} may take action including retraining, supervision, restricting assignments, removing a worker from placement, reviewing client suitability, making safeguarding referrals or notifying relevant external bodies where appropriate.

This policy will be reviewed annually or sooner if there are changes in legislation, statutory guidance, CQC expectations, NICE guidance, NHS England guidance, safeguarding requirements or agency operations.

17. Concerns, Whistleblowing and Refusal to Participate in Unsafe Practice

Temporary workers have a duty to raise concerns where they believe restraint, restrictive practice or use of force is unsafe, unlawful, abusive, discriminatory, excessive, degrading, unauthorised or outside their competence.

Workers must report concerns immediately to the client’s senior person on duty and to {{org_field_name}}. If the concern is not addressed, or if the person remains at risk, workers must escalate the concern under safeguarding and whistleblowing procedures.

{{org_field_name}} will support workers who refuse to participate in unsafe, unlawful or abusive restraint or restrictive practice. Workers will not be penalised for raising genuine concerns in good faith.

18. Policy Review

This policy will be reviewed annually by the director of {{org_field_name}} or earlier if required by changes in legislation, statutory guidance, CQC guidance, NICE guidance, NHS England guidance, safeguarding requirements, client requirements or operational needs. All updates will be communicated to temporary workers and client organisations to ensure full compliance.

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