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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Continence Promotion and Toileting Support Policy

1. Purpose

The purpose of this policy is to provide a clear, lawful and best-practice framework for temporary workers supplied by {{org_field_name}} when supporting service users with continence promotion and toileting needs during assignments with client organisations.

{{org_field_name}} operates as a temporary staffing agency/employment business. It supplies suitably checked and competent temporary workers to client organisations. {{org_field_name}} does not provide regulated care directly, does not assess service users’ care needs, does not create or authorise continence care plans, and does not take over the client organisation’s regulated provider responsibilities.

Temporary workers must follow the service user’s care plan, the client organisation’s policies, the instructions of authorised senior staff at the placement, and this policy. Continence and toileting support must always be delivered in a way that promotes dignity, privacy, independence, choice, safety, infection prevention and safeguarding.

This policy supports compliance with relevant legislation and guidance, including the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 where applicable to client organisations, the Care Act 2014, the Mental Capacity Act 2005, the Equality Act 2010, the Human Rights Act 1998, the Health and Safety at Work etc. Act 1974, UK GDPR and the Data Protection Act 2018, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, the Agency Workers Regulations 2010, and current NICE guidance on continence care.

2. Scope

This policy applies to:

• all temporary workers supplied by {{org_field_name}}, including registered nurses, healthcare assistants and support workers;
• all office staff involved in recruitment, placement co-ordination, compliance, worker support or client liaison;
• all assignments where temporary workers may be asked to support service users with toileting, continence care, personal care, hygiene, documentation or related observations;
• placements in nursing homes, residential care homes, supported living services, hospitals, hospices, community health settings or other health and social care environments.

This policy does not make {{org_field_name}} a regulated care provider. The client organisation remains responsible for assessing service users’ needs, preparing and reviewing care plans, providing suitable premises and equipment, managing clinical risk, supervising care delivery within the placement, and meeting any CQC registration requirements that apply to the regulated activity.

Temporary workers must follow this policy alongside the client organisation’s continence care, infection prevention and control, moving and handling, safeguarding, record-keeping, medication, catheter care and escalation procedures.

3. Related Policies

• Safeguarding Adults and Children Policy
• Infection Prevention and Control Policy
• Record Keeping and Confidentiality Policy
• Equality, Diversity, and Inclusion Policy
• Health and Safety Policy
• Code of Conduct for Temporary Workers
• Incident Reporting and Management Policy

• Recruitment and Selection Policy
• Right to Work Checks Policy
• DBS and Suitability Checks Policy
• Agency Worker Assignment and Conduct Regulations Policy
• Key Information Document and Terms of Engagement Procedure
• Data Protection and Confidentiality Policy
• Moving and Handling Policy
• Whistleblowing Policy
• Complaints Policy
• Mental Capacity and Consent Policy
• Lone Working Policy, where applicable
• Modern Slavery and Labour Exploitation Policy

4. Status of {{org_field_name}} as a Temporary Staffing Agency

{{org_field_name}} operates as a temporary staffing agency/employment business. The agency supplies temporary workers to client organisations but does not itself provide regulated care, assess service users, prepare care plans, prescribe continence interventions, provide premises or equipment, or manage the day-to-day regulated care service.

The client organisation is responsible for:

• assessing the service user’s continence and toileting needs;
• preparing, reviewing and communicating the care plan;
• providing safe systems of work, suitable equipment and appropriate supervision;
• ensuring that any regulated activity is carried on by a provider registered with CQC where registration is required;
• informing {{org_field_name}} of the skills, training, experience, checks and assignment requirements needed for the role;
• giving temporary workers an appropriate induction to the placement, including emergency procedures, infection prevention arrangements, moving and handling requirements, safeguarding reporting routes and documentation systems.

{{org_field_name}} is responsible for:

• carrying out appropriate recruitment, identity, right-to-work, DBS, barred list, qualification, training and reference checks before supply, according to the role;
• confirming the temporary worker’s suitability for the assignment based on information provided by the client organisation;
• issuing required assignment information, terms of engagement and Key Information Documents where applicable;
• maintaining required agency records;
• responding promptly to concerns, complaints, safeguarding alerts or performance issues involving temporary workers;
• removing a temporary worker from an assignment where there is a reasonable concern about safety, competence, conduct or suitability.

5. Key Principles of Continence Promotion

Temporary workers must:

• Promote dignity, independence, and choice at all times when supporting clients with continence needs
• Recognise continence promotion as part of fundamental care, not simply task-based activity
• Provide person-centred care by understanding each client’s needs, preferences, and continence care plan
• Act sensitively and discreetly to minimise embarrassment, anxiety, and distress
• Encourage clients to maintain their continence abilities where appropriate
• Follow safe, hygienic practices in line with infection prevention and control guidance

6. Legal Framework

This policy is underpinned by the following legislation and guidance, as applicable:

• Employment Agencies Act 1973 and Conduct of Employment Agencies and Employment Businesses Regulations 2003 – requiring employment businesses to comply with rules on work-seeker information, hirer information, suitability, terms, fees, assignment details and records.
• Agency Workers Regulations 2010 – providing agency workers with day-one rights to access facilities and vacancy information, and equal treatment in basic working and employment conditions after the 12-week qualifying period in the same role with the same hirer.
• Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 – relevant to client organisations providing regulated care, including requirements on person-centred care, dignity and respect, consent, safe care and treatment, safeguarding, staffing, fit and proper persons, complaints and good governance.
• Care Act 2014 – supporting the wellbeing, dignity, safety and safeguarding of adults with care and support needs.
• Mental Capacity Act 2005 – requiring capacity to be presumed unless established otherwise, supporting people to make their own decisions, and ensuring any act or decision for a person lacking capacity is in their best interests and is the least restrictive option.
• Equality Act 2010 – prohibiting discrimination, harassment and victimisation and requiring reasonable adjustments where applicable.
• Human Rights Act 1998 – supporting rights to dignity, privacy, autonomy and freedom from degrading treatment.
• Health and Safety at Work etc. Act 1974 – requiring safe systems of work and co-operation between the agency, temporary workers and client organisations.
• UK GDPR and Data Protection Act 2018 – governing the lawful, fair, secure and confidential handling of service user, worker, health, safeguarding and DBS-related information.
• Immigration, Asylum and Nationality Act 2006 and current Home Office right-to-work guidance – requiring compliant right-to-work checks before employment or engagement to establish a statutory excuse where applicable.
• Safeguarding Vulnerable Groups Act 2006, Police Act 1997 and Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975 – supporting lawful DBS checks, barred list checks and suitability decisions for eligible health and social care roles.
• NICE guidance, including CG49, NG123 and CG148, where relevant to the service user’s needs and the temporary worker’s duties.

7. Temporary Workers’ Responsibilities

Temporary workers must:

• Familiarise themselves with each client’s care and continence plan as soon as possible after starting an assignment
• Assist clients with toileting and continence management in a way that maintains dignity, privacy, and comfort
• Encourage independence where possible (e.g., assisting to the toilet rather than automatically providing pads)
• Monitor and report any changes to continence patterns or concerns (e.g., increased frequency, incontinence, urinary tract infections, constipation)
• Ensure accurate documentation of toileting support, continence care interventions, and observations in line with the client’s record-keeping procedures
• Report concerns regarding potential safeguarding issues (e.g., signs of neglect relating to toileting or continence) following {{org_field_name}}’s Safeguarding Policy
• Comply with all infection prevention and control procedures, including the use of appropriate personal protective equipment (PPE)

• confirm at the start of the assignment where continence records, care plans, risk assessments, PPE, clinical waste facilities, moving and handling equipment and escalation contacts are located;
• only provide continence and toileting support that is within their role, competence, training and the client organisation’s instructions;
• not undertake catheterisation, catheter removal, bladder scanning, digital rectal examination, manual evacuation, bowel interventions, medication administration or other clinical procedures unless they are appropriately qualified, competent, authorised by the client organisation and acting within their professional scope of practice;
• escalate immediately to the nurse in charge, senior care lead, manager on duty or other authorised person if the care plan is missing, unclear, unsafe, out of date or inconsistent with the service user’s presentation;
• report serious or urgent concerns to both the client organisation and {{org_field_name}}, including suspected neglect, unexplained injury, repeated missed toileting support, unsafe moving and handling, lack of PPE, signs of infection, pressure damage, dehydration, constipation, urinary retention, blood in urine or faeces, or acute deterioration.

8. Continence Promotion Strategies

Temporary workers may support the following strategies only where they are included in the service user’s care plan, authorised by the client organisation and within the worker’s competence:

• Encouragement and reminders: Prompting clients regularly to use the toilet
• Bladder training: Supporting agreed care plans aimed at increasing bladder capacity and promoting continence
• Fluid intake management: Encouraging adequate hydration to prevent dehydration and reduce the risk of urinary tract infections
• Dietary considerations: Being mindful of diet-related bowel health and reporting concerns if clients experience constipation or diarrhoea
• Positioning and mobility support: Ensuring clients can access toilets safely or are positioned correctly when using commodes or bedpans
• Environmental adjustments: Ensuring clients have access to toilets that are safe, clean, and accessible

• Temporary workers must not introduce a new bladder training, bowel management, fluid restriction, toileting schedule or continence product regime without authorisation from the client organisation’s authorised senior staff.
• Temporary workers must not restrict fluids unless this is clearly documented in the care plan and authorised by an appropriate clinician or senior member of the client organisation’s care team.
• Continence products must not be used as a substitute for timely toileting support, dignity, mobility assistance or person-centred care.

Temporary workers must always check with the client’s permanent care team before implementing new continence-promoting techniques, ensuring consistency and safety.

9. Assisting with Toileting

When providing direct toileting support, temporary workers must:

• Respect clients’ preferences and privacy at all times
• Use screens, curtains, or closed doors to maintain dignity
• Ensure the client is comfortable and safe when using toilet facilities, commodes, bedpans, or urinals
• Apply safe moving and handling techniques when assisting with transfers
• Observe for and report signs of skin damage, pressure sores, or discomfort
• Clean and disinfect equipment after use to minimise infection risk
• Dispose of continence products safely and hygienically in line with client procedures and local regulations

• obtain the service user’s consent before providing support, unless a lawful best-interests decision applies;
• explain what they are doing in a clear, respectful and age-appropriate way;
• respect known preferences relating to gender, culture, religion, privacy, communication and personal routines wherever reasonably practicable;
• use the moving and handling plan and equipment specified by the client organisation;
• not use unsafe manual lifting or unsupported transfers;
• ensure call bells, mobility aids, toilet paper, wipes, continence products, handwashing facilities and clothing are accessible before leaving the service user;
• report immediately if toilets, commodes, bedpans, urinals, hoists, slings or other equipment are unsafe, unavailable, dirty or unsuitable.

10. Continence Products

Temporary workers must:

• Only use or support the use of continence products or equipment specified in the service user’s care plan, such as pads, pull-ups, washable products, commodes, urinals, bedpans or toileting aids. Catheters, sheaths, drainage bags, bowel management systems or other clinical devices must only be handled in accordance with the worker’s role, competence, training, professional registration where applicable, and the client organisation’s procedures.
• Ensure that products are applied, fitted, and changed safely, with due consideration to client dignity
• Document product usage accurately where required by the client organisation
• Never improvise or make changes to a continence management plan without authorisation from a senior nurse or client manager

Temporary workers must not change the type, size, frequency or method of use of continence products unless instructed by authorised staff at the client organisation. Concerns about leakage, discomfort, skin damage, odour, distress, inappropriate product use or insufficient supplies must be reported promptly to the client organisation and, where relevant, to {{org_field_name}}.

11. Capacity, Consent, and Choice

Temporary workers must:

• Support clients to make their own choices regarding continence care whenever possible
• Presume that the service user has capacity to make decisions about continence and toileting support unless there is reason to believe otherwise, and escalate any concerns about capacity to authorised staff at the client organisation.
• Follow best interest decision-making processes in accordance with the Mental Capacity Act 2005 when clients lack capacity
• Work closely with client organisations and families, where appropriate, to ensure care plans are person-centred and lawful
• Avoid coercing or forcing clients into continence management routines against their will

• support the service user to make decisions by giving information in a way they can understand;
• respect an unwise decision where the person has capacity;
• ensure any support provided to a person who lacks capacity is in accordance with the Mental Capacity Act 2005, the care plan and any best-interests decision recorded by the client organisation;
• use the least restrictive approach and avoid any unnecessary restriction, restraint, coercion or deprivation of liberty;
• report immediately if they believe a person is being unlawfully restricted, ignored, coerced or deprived of dignity in relation to toileting or continence care.

12. Infection Prevention and Control

All toileting and continence care must be provided in line with infection prevention and control requirements. Temporary workers must:

• Use appropriate PPE, including gloves and aprons
• Practice good hand hygiene before and after providing personal care
• Dispose of waste products (e.g., used pads, gloves) safely in line with client and local waste management policies
• Ensure that continence care equipment is cleaned and maintained safely
• Report infection risks, including urinary tract infections or gastrointestinal symptoms, to the client organisation promptly

• follow standard infection prevention and control precautions, including hand hygiene, appropriate PPE, safe disposal of waste and cleaning of shared equipment;
• follow the client organisation’s procedures for clinical waste, offensive hygiene waste and linen;
• avoid placing used continence products, gloves, aprons or wipes in domestic waste unless the client organisation’s waste procedure permits this;
• report immediately if PPE, handwashing facilities, clinical waste facilities, cleaning products or safe disposal arrangements are unavailable;
• follow client organisation procedures for diarrhoea, vomiting, suspected urinary tract infection, suspected infectious outbreak or other infection risks.

13. Record Keeping

Temporary workers must:

• Maintain clear, accurate, and timely records of toileting support and continence care in line with client organisation policies
• Record observations regarding changes in continence patterns, fluid intake, bowel movements, and client discomfort
• Report concerns regarding skin integrity, signs of neglect, or safeguarding risks immediately to the client and {{org_field_name}}
• Treat all records as confidential, in accordance with the UK GDPR and the Data Protection Act 2018

Temporary workers must record continence and toileting support in the client organisation’s records only, unless instructed otherwise by {{org_field_name}} for incident, safeguarding, complaint, supervision or compliance purposes. Temporary workers must not remove, photograph, copy or share service user records, care plans, body maps, photographs, continence charts or clinical information unless there is a lawful basis, authorisation and secure method approved by the client organisation and/or {{org_field_name}}.

14. Training and Competence

{{org_field_name}} will:

• Provide induction and refresher training for all temporary workers regarding continence care and toileting support
• Ensure workers understand person-centred care, dignity in care, infection control, and safeguarding in relation to continence promotion
• Require registered nurses to comply with the Nursing and Midwifery Council (NMC) Code in all aspects of continence care
• Provide additional support or supervision to workers where concerns or learning needs are identified

Before supplying a temporary worker to a role involving personal care, continence support or regulated activity with adults, {{org_field_name}} will take reasonable steps to confirm that the worker has the appropriate identity checks, right-to-work status, references, qualifications, training, DBS check level and barred list check where eligible and required for the role.

Where a role involves regulated activity with adults, the agency will consider eligibility for an Enhanced DBS check with an Adults’ Barred List check. DBS guidance confirms that a person carrying out regulated activity with adults can be asked to apply for an Enhanced DBS check with an Adults’ Barred List check.

Client organisations are responsible for providing site-specific induction, including local continence procedures, care documentation systems, moving and handling arrangements, infection prevention and control procedures, safeguarding contacts, emergency procedures, equipment use and escalation routes.

Temporary workers must:

• Complete required training before being assigned to care roles involving personal care
• Request additional guidance or support if unsure about any aspect of continence care
• Participate in reflective practice and supervision as part of continuous professional development

• not accept or continue an assignment where they are asked to perform duties outside their competence, training, professional scope of practice or the client organisation’s authorisation;
• inform {{org_field_name}} immediately if they are asked to undertake catheter care, bowel interventions, medication-related continence care or other clinical tasks for which they are not competent or authorised;
• maintain evidence of relevant training and professional registration where applicable.

15. Safeguarding and Continence

Poor continence care, neglect, or inappropriate toileting support can constitute abuse. Temporary workers must:

• Be vigilant for signs of neglect, including prolonged periods without toileting assistance, inappropriate use of continence products, or disregard for dignity
• Report safeguarding concerns immediately following {{org_field_name}}’s Safeguarding Policy
• Cooperate fully with safeguarding investigations and contribute to learning from incidents to improve practice

Temporary workers must report concerns including, but not limited to:

• service users being left wet, soiled or without toileting assistance for unreasonable periods;
• continence products being used for staff convenience rather than service user need;
• deliberate fluid restriction without clinical authorisation;
• lack of privacy, exposure, humiliation or disrespect during toileting;
• unsafe or excessive restraint connected with toileting routines;
• unexplained bruising, genital injury, skin damage, pressure damage or pain;
• repeated failure to follow continence care plans;
• lack of access to toilets, call bells, mobility aids, commodes or continence products;
• discriminatory treatment linked to disability, age, sex, race, religion, gender reassignment, pregnancy, sexual orientation or any other protected characteristic.

16. Director’s and Agency Management Responsibilities

The director or nominated senior manager of {{org_field_name}} will:

• Take full responsibility for implementing, reviewing, and monitoring this policy
• Ensure that all temporary workers receive appropriate training and supervision in continence promotion and toileting
• Review incident reports, complaints, and safeguarding referrals related to continence care
• Liaise with client organisations to address concerns and promote best practices
• Identify areas for continuous improvement and incorporate learning into training and supervision

• ensure the agency does not hold itself out as providing regulated care unless it is lawfully registered to do so;
• ensure workers are supplied only to assignments for which they appear suitable based on the information available to {{org_field_name}};
• ensure client organisations provide sufficient information about the role, setting, risks, required skills, training and checks before a worker is supplied;
• ensure concerns about unsafe requests, unclear care plans, safeguarding issues or worker competence are escalated promptly to the client organisation;
• maintain appropriate agency records in line with the Conduct Regulations and related guidance.

17. Working with Client Organisations

Before supplying a temporary worker, {{org_field_name}} will seek sufficient information from the client organisation to determine the nature of the role, required experience, required qualifications, training, DBS level, barred list eligibility, health and safety risks, working hours, supervision arrangements and any specific continence or personal care duties.

The client organisation must provide accurate and timely information about the assignment so that {{org_field_name}} can assess worker suitability and comply with agency-sector obligations. Current GOV.UK guidance confirms that employment businesses must understand and comply with the Conduct Regulations, including requirements relating to information, terms, suitability and records.

{{org_field_name}} will:

• Ensure temporary workers are informed of client-specific continence management protocols and expectations upon assignment
• Encourage temporary workers to collaborate with the client’s permanent staff to maintain continuity of care
• Respond promptly to concerns raised by clients regarding continence care provided by temporary workers
• Support client audits, inspections, and safeguarding processes relating to continence management and dignity in care

• request clarification from the client organisation where continence duties are unclear or appear to involve clinical tasks;
• confirm whether the assignment involves regulated activity with adults and whether an Enhanced DBS check with barred list information is required;
• remind client organisations that they remain responsible for care planning, clinical governance, supervision, equipment, premises, risk assessments and regulated provider duties;
• document concerns raised by temporary workers about unsafe continence care, lack of equipment, poor hygiene, missed care, safeguarding risks or unclear instructions.

18. Suitability, Right-to-Work, DBS and Agency Compliance

{{org_field_name}} will complete recruitment and compliance checks appropriate to the role before supplying temporary workers to assignments involving continence or toileting support.

These checks may include:

• identity verification;
• right-to-work checks in line with current Home Office guidance;
• references and employment history checks;
• qualification and professional registration checks, including NMC registration where applicable;
• training and competence checks relevant to the assignment;
• DBS checks at the appropriate level where the role is eligible;
• Adults’ Barred List checks where the role is regulated activity with adults and the check is legally permitted;
• assessment of any disclosed criminal record or safeguarding concern in line with safer recruitment, rehabilitation of offenders and data protection requirements.

{{org_field_name}} will not knowingly supply a worker to carry out regulated activity with adults if the worker is barred from doing so.

Right-to-work checks must be completed before work starts and must follow the current prescribed process. Where checks are conducted correctly, the employer may establish a statutory excuse against a civil penalty.

19. Agency Worker Rights, Assignment Information and Key Information Documents

{{org_field_name}} will comply with applicable agency worker and employment business requirements, including providing required terms and assignment information and, where applicable, a Key Information Document before agreeing terms with an agency worker.

Agency workers must be given clear information about the nature of the work, expected duties, pay, deductions, holiday entitlement, working time arrangements, location, start date, reporting arrangements, required checks, known risks and any special requirements of the assignment.

Agency workers have day-one rights in relation to access to collective facilities and information about relevant vacancies at the hirer’s workplace. After the 12-week qualifying period in the same role with the same hirer, agency workers are entitled to equal treatment in basic working and employment conditions, including relevant pay and working time rights.

Where an umbrella company or third-party payroll arrangement is used, {{org_field_name}} will ensure that the worker receives clear information about pay, deductions and who is responsible for payment, in line with current government guidance on Key Information Documents and umbrella company arrangements.

20. Health and Safety, Equipment and Moving and Handling

The client organisation is responsible for providing a safe working environment, suitable equipment, local risk assessments, moving and handling plans, PPE, waste disposal arrangements and supervision at the placement.

Temporary workers must:

• follow the client organisation’s moving and handling plans and risk assessments;
• use only equipment they have been trained and authorised to use;
• check that equipment appears clean, safe and suitable before use;
• report defective, missing or unsuitable equipment immediately;
• refuse to undertake unsafe moving and handling or toileting assistance and escalate concerns to the client organisation and {{org_field_name}};
• report accidents, incidents, near misses and unsafe conditions in line with both client organisation and agency procedures.

21. Continuous Quality Improvement

The director will:

• Review this policy annually or sooner if legislative, regulatory, or best practice changes occur
• Audit incident reports, feedback, and complaints to identify patterns or areas for improvement
• Implement changes to training, supervision, and placement procedures based on learning and feedback
• Promote a culture of respect, dignity, and person-centred care across all aspects of toileting and continence support

The director or nominated senior manager will also review:

• feedback from client organisations about continence and toileting support;
• feedback from temporary workers about unsafe practices, unclear care plans or inadequate equipment;
• safeguarding alerts, complaints, incidents and near misses involving continence care;
• training gaps and repeated competency concerns;
• whether assignment information provided by client organisations is sufficient;
• whether agency records meet employment business requirements.

22. Policy Review

This policy will be reviewed at least annually by the director or nominated senior manager of {{org_field_name}}, or sooner where required due to changes in legislation, statutory guidance, CQC requirements relevant to client placements, NICE guidance, employment business requirements, safeguarding practice, incidents, complaints, audit findings or operational needs.

Updates will be communicated to relevant office staff, temporary workers and, where appropriate, client organisations. {{org_field_name}} will retain records of policy review, approval and communication.

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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.