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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Technology-Enabled Care and Telecare Policy

1. Purpose

The purpose of this policy is to outline {{org_field_name}}’s approach to the safe and effective use of technology-enabled care and telecare within supported living services. This policy aligns with the latest Care Quality Commission (CQC) regulations and best practices to ensure that digital health solutions enhance the safety, independence, and quality of life of service users. It sets out the standards for implementation, monitoring, and governance of technology-enabled care (TEC) to ensure compliance, security, and ethical considerations.

2. Scope

This policy applies to all staff, service users, families, and external partners involved in the provision, management, and use of technology-enabled care and telecare services within {{org_field_name}}. It encompasses digital health tools, remote monitoring systems, assistive technologies, and telehealth consultations used to support service users in managing their health and well-being.

3. Definition of Technology-Enabled Care and Telecare

Technology-enabled care (TEC) and telecare refer to the use of digital and assistive technologies to enhance service users’ safety, autonomy, and healthcare management. This includes:

• Telecare systems: Remote monitoring devices such as fall detectors, motion sensors, and personal alarms.
• Telehealth services: Virtual consultations with healthcare professionals using video calls and online monitoring tools.
• Assistive technology: Devices such as voice-controlled assistants, smart medication dispensers, and environmental control systems.
• Digital health applications: Software and wearable technology to track vital signs, medication adherence, and lifestyle habits.

4. Implementation of Technology-Enabled Care

4.1 Assessment and Personalisation

• Before technology-enabled care (TEC), telecare, remote monitoring or assistive technology is introduced, {{org_field_name}} will complete and record an individual assessment of the service user’s needs, preferences, communication requirements, desired outcomes, risks, abilities and circumstances.
• The assessment will identify the specific purpose of the proposed technology, the expected benefit to the service user and whether the same outcome can reasonably be achieved by a less intrusive or less restrictive method.
• The assessment will consider the potential impact of the technology on the service user’s dignity, privacy, independence, autonomy, safety, freedom of movement and other legal and human rights.
• The service user will be given information about the proposed technology in a format and manner they can understand and will be supported to participate as fully as possible in decisions about its use.
• Consent to the care or treatment involving the technology will be obtained in accordance with Regulation 11 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 and applicable consent legislation.
• Where there is reason to doubt the service user’s capacity to make a particular decision about the proposed technology, their mental capacity will be assessed in relation to that specific decision and at the time the decision needs to be made, in accordance with the Mental Capacity Act 2005. All practicable steps will be taken to support the person to make the decision for themselves before they are treated as unable to do so.
• Where a service user lacks capacity to make the relevant decision, any decision made on their behalf will be made in accordance with the Mental Capacity Act 2005, including its best-interests requirements, and will use the least restrictive option reasonably available. Any person with lawful decision-making authority, including a relevant attorney or Court of Protection deputy, will be involved where their authority covers the particular decision.
• Family members, representatives, advocates, healthcare professionals and other relevant persons will be involved where appropriate and lawful. A family relationship alone does not give a person legal authority to consent on behalf of an adult who lacks capacity.
• The assessment, consent or capacity assessment, any best-interests decision, identified risks, agreed controls and the operation of the technology will be recorded within the service user’s care and support records.
• The continued use of TEC will be reviewed at planned intervals and sooner where there is a change in the service user’s needs, capacity, wishes, risks or circumstances; where the technology changes; following an incident or system failure; or where the service user withdraws consent or objects to its continued use.

4.2 Equipment Procurement and Installation

• TEC, telecare, monitoring equipment and associated systems used by {{org_field_name}} in providing care or support must be suitable for their intended purpose, safe, secure, properly installed, properly used and properly maintained.
• Before equipment is purchased, supplied or introduced, {{org_field_name}} will obtain appropriate assurance that it complies with applicable legal, regulatory, product safety and technical requirements relevant to its intended use.
• The suitability of equipment will be assessed against the individual service user’s assessed needs, abilities, environment and risks. Equipment must not be introduced solely because it is available or convenient.
• Installation and configuration must be undertaken by persons who are competent to perform the task. Settings, alert thresholds, escalation routes, authorised users and response arrangements must be checked before the equipment becomes operational.
• Where an external supplier, contractor, monitoring centre or technology provider is used, responsibilities for installation, maintenance, testing, fault reporting, information security, response to alerts and escalation must be clearly defined. {{org_field_name}} will retain responsibility for meeting its own regulatory obligations and will obtain assurance that contracted arrangements remain safe and effective.
• Staff who are required to operate, respond to, check or support the use of equipment must receive appropriate training and must be assessed as competent before undertaking those duties without supervision.
• Service users must receive appropriate information, instruction and support on the safe use of equipment in a form they can understand.
• Installation must take account of the service user’s privacy, dignity, autonomy and home environment and must use the least intrusive arrangement capable of meeting the assessed purpose.

4.3 Data Protection, Privacy and Information Security

• Personal information processed through TEC, telecare, digital health applications, remote monitoring or surveillance must be processed in accordance with the UK General Data Protection Regulation, the Data Protection Act 2018 as amended, including amendments made by the Data (Use and Access) Act 2025, and other applicable information governance legislation.
• Before personal data is processed, {{org_field_name}} will identify and document an appropriate lawful basis under Article 6 of the UK GDPR. Where health information or other special category personal data is processed, an applicable condition under Article 9 of the UK GDPR must also be identified and documented.
• Consent to care or treatment and consent relied upon as a lawful basis for processing personal information are separate legal matters and must not be treated as interchangeable. Where {{org_field_name}} relies upon consent as the data protection lawful basis, the consent must meet the requirements of data protection legislation and must be capable of being evidenced.
• Service users will be provided with clear and accessible privacy information explaining, as applicable:
  • what information the technology collects;
  • the purpose for which it is collected;
  • the lawful basis for processing;
  • who can access it;
  • who it may be shared with;
  • whether an external technology provider processes the information;
  • how long it will be retained;
  • how it will be kept secure; and
  • the person’s applicable data protection rights.
• {{org_field_name}} will apply the principles of data minimisation, purpose limitation, accuracy, storage limitation, integrity, confidentiality and accountability when implementing and operating TEC.
• Access to information generated by TEC will be limited to authorised persons who require access for an identified and lawful purpose. Appropriate technical and organisational security measures will be used, including secure authentication, access controls, secure networks and encryption where appropriate to the risk.
• A Data Protection Impact Assessment will be completed before processing begins where the proposed use of technology is likely to result in a high risk to individuals’ rights and freedoms. This includes high-risk systematic monitoring or surveillance. The assessment will consider necessity, proportionality, risks to individuals and the measures required to reduce those risks.
• Where a Data Protection Impact Assessment identifies a high residual risk that cannot be adequately mitigated, the matter must be escalated to the organisation’s Data Protection Officer or other responsible information governance lead and, where legally required, prior consultation with the Information Commissioner must take place before processing begins.
• Personal information must not be retained for longer than is necessary for its lawful purpose and will be securely deleted or disposed of in accordance with {{org_field_name}}’s retention arrangements and applicable law.
• Suspected or actual personal data breaches involving TEC must be reported immediately through {{org_field_name}}’s data breach procedure. The breach must be assessed promptly to determine whether notification to the Information Commissioner and/or communication to affected individuals is legally required. Where notification to the Information Commissioner is required, it must be made without undue delay and, where feasible, within the statutory 72-hour period.

5. Monitoring and Support

5.1 Continuous Monitoring, Testing, Maintenance and Contingency Arrangements

• TEC and telecare equipment used as part of care or support will be subject to an appropriate programme of inspection, testing, servicing and maintenance based on the manufacturer’s requirements, identified risks, frequency of use and the importance of the equipment to the service user’s safety.
• {{org_field_name}} will keep records of relevant installation, testing, servicing, maintenance, repairs, identified faults and actions taken.
• Staff must report faults, damaged equipment, unexpected alerts, inaccurate readings, connectivity problems and other failures promptly in accordance with {{org_field_name}}’s incident and escalation procedures.
• Equipment that is known or suspected to be unsafe must not continue to be relied upon until it has been assessed and made safe, repaired or replaced.
• {{org_field_name}} will monitor and act upon relevant product safety alerts, manufacturer notices, recalls and other applicable safety information relating to equipment used in the service.
• Where a service user’s safety, care or support depends upon TEC, a proportionate contingency arrangement must be identified in advance. This must specify how the person will continue to receive safe support if equipment, electricity, telephone services, mobile networks, internet connectivity, software, monitoring centres or other essential systems fail.
• Contingency arrangements must be communicated to staff who may need to implement them and must be reviewed whenever the service user’s needs, risks or technology arrangements change.
• Where a fault or interruption creates an immediate risk, staff must implement the contingency plan without delay and escalate the matter in accordance with the level of risk.
• Technology failures and repeated false alerts must be reviewed to establish whether risk assessments, care plans, equipment, staffing arrangements or response procedures require amendment.

5.2 Training and Staff Competency

• Staff must receive the training, support, supervision and competency assessment necessary for the TEC-related duties they are required to perform.
• Training must be appropriate to the staff member’s role and, where applicable, cover:
  • the purpose and limitations of the technology used;
  • safe operation and routine checks;
  • responding to alerts;
  • fault identification and escalation;
  • emergency and contingency arrangements;
  • consent and the Mental Capacity Act 2005;
  • privacy, dignity and human rights;
  • safeguarding risks associated with technology;
  • confidentiality, data protection and information security;
  • the appropriate use of surveillance or monitoring technology; and
  • incident and near-miss reporting.
• Staff must not undertake TEC-related tasks for which they have not received the necessary training or demonstrated the required competence.
• Competency will be reviewed where appropriate and following significant changes to equipment, software, the service user’s needs, identified risks or relevant legal or regulatory requirements.
• Refresher or additional training will be provided where monitoring, audits, incidents, supervision or competency checks identify a need.
• In accordance with the Health and Social Care Act 2008, {{org_field_name}} will ensure that each person working for the purposes of the regulated activities receives training on learning disability and autism that is appropriate to their role.

5.3 Service User Empowerment and Inclusion

• Service users are encouraged to participate in the selection and use of TEC solutions that best meet their needs.
• Regular feedback is collected from service users to evaluate the effectiveness and user-friendliness of implemented technologies.
• Training sessions and resources are available for service users and their families to build confidence in using TEC.

6. Ethical Considerations and Safeguarding

6.1 Consent, Mental Capacity and Best Interests

• Consent must be obtained before TEC is used as part of a person’s care or treatment where consent is legally required.
• Consent must be informed and voluntary. The service user must be provided with information they can understand about the nature and purpose of the technology, how it will operate, its material benefits and risks, what information it will collect, any significant impact on privacy or independence and any reasonable alternatives.
• The service user must be supported to communicate their decision using appropriate communication methods and reasonable adjustments.
• Consent is an ongoing process and must not be treated as permanent merely because consent was previously obtained. A person may change their mind or withdraw consent, and staff must respond appropriately when this occurs.
• Where a person refuses or withdraws consent, the reason and any discussion about alternative ways of safely meeting their assessed needs must be recorded. The person must not be disadvantaged merely because they have exercised a lawful right to refuse.
• Mental capacity must be presumed unless there is evidence giving rise to a reasonable doubt about the person’s capacity to make the particular decision. Capacity must be assessed in relation to the specific decision and at the time that decision needs to be made.
• Before concluding that a person lacks capacity, all practicable steps must be taken to support them to make the decision themselves.
• An unwise decision, disagreement with professional advice or refusal to use technology does not, by itself, establish that a person lacks capacity.
• Where the person lacks capacity to make the relevant decision, any decision made on their behalf must comply with the Mental Capacity Act 2005, including the statutory best-interests requirements, consideration of the person’s wishes, feelings, beliefs and values, consultation with relevant people where appropriate and selection of the least restrictive available option.
• Where an attorney acting under a registered Lasting Power of Attorney or a deputy appointed by the Court of Protection is involved, staff must confirm that their legal authority covers the particular decision before relying upon that decision.
• Capacity assessments, consent decisions, withdrawals of consent, best-interests decisions, relevant consultation and the reasons for decisions must be appropriately recorded.

6.2 Safeguarding, Restrictions and Deprivation of Liberty

• TEC must be used in a way that safeguards service users from abuse, neglect, improper treatment and avoidable harm.
• Technology must not be used for punishment, staff convenience, coercion or as an unnecessary or disproportionate restriction on a service user’s freedom, privacy, movement or autonomy.
• Where technology is intended to reduce or manage a risk, the level of restriction created by the technology must be proportionate to the identified risk and must be the least restrictive approach reasonably available.
• Any use of TEC that may amount to restraint must comply with the Mental Capacity Act 2005 where applicable and must be necessary and proportionate to the risk of harm it is intended to prevent.
• Staff must remain alert to the possibility that an arrangement involving monitoring, alarms, tracking, locked systems, remote observation or other technology may contribute to restrictions that amount to a deprivation of liberty.
• Assessment of whether arrangements constitute a deprivation of liberty must reflect the current legal framework, including the UK Supreme Court judgment of 2 June 2026. Staff must not rely solely on the former Cheshire West “acid test”. The circumstances must be considered as a whole, including the type, duration, effect and manner of implementation of restrictions, the person’s wishes and feelings, any objection and other legally relevant factors.
• Compliance or an absence of obvious physical resistance must not automatically be treated as agreement. Staff must consider the person’s verbal and non-verbal communication, behaviour, wishes and feelings and must provide appropriate support to enable them to express their views.
• Where there is doubt as to whether arrangements in supported living amount to a deprivation of liberty, or whether the person can validly consent to the arrangements, the matter must be escalated promptly to the Registered Manager and the relevant commissioning or local authority professionals so that appropriate legal advice or authorisation can be considered.
• Supported living is a community setting. Where a deprivation of liberty in such a setting requires legal authorisation under the current framework, the appropriate court process must be followed. Staff must not assume that the care-home Deprivation of Liberty Safeguards process can be used for a supported living placement.
• Safeguarding concerns involving TEC, including unauthorised monitoring, deliberate misuse of devices, neglect of alerts, inappropriate access to recordings or data, technology-facilitated abuse or disproportionate restrictions, must be reported immediately in accordance with {{org_field_name}}’s safeguarding procedures.
• Any immediate risk to the service user must be addressed without delay.
• Where an incident meets the criteria for a statutory notification to the Care Quality Commission or another statutory body, the Registered Manager or other authorised person must ensure that the required notification is made within the applicable statutory timescale.

6.3 Surveillance and Monitoring Technologies

• Where TEC is capable of observing, tracking, listening to, recording or systematically monitoring a person, {{org_field_name}} will determine whether its use constitutes surveillance or otherwise creates a significant intrusion into privacy.
• Surveillance or monitoring technology must have a clearly identified and legitimate purpose. {{org_field_name}} must be able to demonstrate why the proposed monitoring is necessary and proportionate and why a less intrusive means would not reasonably achieve the same purpose.
• The use of surveillance must comply with applicable health and social care regulation, data protection legislation and human rights requirements.
• Before surveillance or intrusive monitoring is introduced, {{org_field_name}} will consider and document:
  • the specific purpose;
  • the people whose privacy may be affected;
  • where and when monitoring will occur;
  • what information will be collected or recorded;
  • whether recording is necessary;
  • who will be permitted to access the information;
  • how information will be secured;
  • how long information will be retained;
  • whether less intrusive options are available;
  • consent and mental capacity requirements;
  • the impact on dignity, privacy and autonomy; and
  • any safeguarding implications.
• A Data Protection Impact Assessment must be completed where the surveillance or monitoring is likely to result in a high risk to individuals’ rights and freedoms.
• Service users must be involved in decisions about surveillance affecting them and must receive accessible information explaining its purpose and operation.
• Where consent to care or treatment is required, this must be obtained in accordance with Section 6.1. Where the person lacks capacity to make the relevant decision, the Mental Capacity Act 2005 must be followed and any best-interests decision must be fully recorded.
• Where consent is relied upon as the lawful basis for processing personal information, data protection requirements for valid consent must additionally be satisfied.
• Surveillance must be configured and positioned to minimise unnecessary intrusion into private life. Monitoring in areas where a person has a particularly high expectation of privacy requires especially careful justification and safeguards.
• Access to live feeds, recordings, images, audio, location information and other monitoring data must be restricted to specifically authorised persons with a legitimate need to access it.
• Staff authorised to operate or access surveillance systems must receive appropriate training in the equipment, confidentiality, data protection, safeguarding, privacy and escalation procedures.
• The continued necessity and proportionality of surveillance must be reviewed regularly and whenever the person’s circumstances, wishes, capacity, risks or care arrangements change.
• Covert surveillance by {{org_field_name}} must not be used as routine care practice. Any exceptional proposal for covert surveillance must be escalated to senior management and must not proceed without appropriate legal, safeguarding, data protection and human rights consideration.
• Where a service user or family member installs or proposes to install their own recording or monitoring equipment, {{org_field_name}} will consider the service user’s wishes and rights and the privacy and legal rights of other people who may be affected. The person must not receive a poorer standard of care because they or their representative have raised concerns or used monitoring equipment.

7. Regulatory Compliance and Quality Assurance

7.1 Adherence to CQC Regulations and Statutory Requirements

{{org_field_name}} will ensure that the use of TEC is consistent with all applicable requirements of the Health and Social Care Act 2008 and the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, including, where relevant:

• Regulation 9 – Person-centred care: TEC must be appropriate, meet the service user’s assessed needs and reflect their preferences. Service users must be involved in decisions about technology used as part of their care or support.
• Regulation 10 – Dignity and respect: TEC must be used in a manner that protects privacy, dignity, autonomy and personal relationships and avoids unnecessary intrusion.
• Regulation 11 – Need for consent: Care and treatment involving TEC must only be provided with appropriate consent or other lawful authority, and the Mental Capacity Act 2005 must be followed where the person lacks capacity to make the relevant decision.
• Regulation 12 – Safe care and treatment: Risks associated with the selection, operation and failure of TEC must be assessed and reasonably practicable steps taken to mitigate those risks. Equipment used in providing care or treatment must be safe and used safely.
• Regulation 13 – Safeguarding service users from abuse and improper treatment: TEC must not expose a service user to abuse, neglect, improper treatment or unnecessary or disproportionate restraint or restriction.
• Regulation 15 – Premises and equipment: Equipment used by {{org_field_name}} must be suitable for its purpose, secure, properly used and properly maintained.
• Regulation 17 – Good governance: {{org_field_name}} must maintain effective governance arrangements for TEC, including risk management, secure and accurate records, audits, monitoring, feedback and improvement.
• Regulation 18 – Staffing: Staff involved in selecting, operating, monitoring or responding to TEC must receive appropriate training, support, supervision and competency assessment.

Nothing in this policy removes the requirement to comply with any other applicable regulation or statutory duty.

7.2 Records, Audit, Incident Reporting and Continuous Improvement

• {{org_field_name}} will operate effective governance systems to assess, monitor and improve the quality and safety of TEC used in the delivery of regulated activities.
• Records concerning TEC must be accurate, complete, secure and contemporaneous and, where applicable, include:
  • the assessment of need and intended outcome;
  • risk assessments;
  • the service user’s wishes and preferences;
  • information provided to the service user;
  • consent and any withdrawal of consent;
  • mental capacity assessments;
  • best-interests decisions;
  • relevant consultation and legal authority;
  • equipment and configuration details where necessary for safe care;
  • alerts and significant responses;
  • identified faults and actions taken;
  • maintenance and testing;
  • incidents and near misses;
  • safeguarding concerns;
  • reviews and changes to care arrangements; and
  • significant decisions concerning continued, changed or discontinued use of the technology.
• Audits will examine, as appropriate:
  • whether technology remains necessary and proportionate;
  • whether it continues to meet the service user’s needs and preferences;
  • equipment reliability and maintenance;
  • response times and management of alerts;
  • staff competence;
  • consent and Mental Capacity Act compliance;
  • privacy and data protection compliance;
  • safeguarding concerns;
  • incidents and recurring faults; and
  • evidence that identified improvements have been implemented.
• Feedback from service users and, where appropriate, people lawfully acting on their behalf will be sought and acted upon as part of the evaluation and improvement of TEC.
• TEC-related incidents and near misses must be reported through {{org_field_name}}’s incident reporting arrangements and reviewed in proportion to their seriousness. Where an incident identifies a risk or deficiency, action must be taken without delay to reduce or remove the risk.
• Where a TEC-related incident amounts to or involves a statutory notifiable event, including a qualifying serious injury, abuse or allegation of abuse, specified police involvement, or an event that threatens the provider’s ability to carry on the regulated activity safely, the Registered Manager or other authorised person must ensure that the Care Quality Commission is notified without delay or within any other applicable statutory timescale.
• Where an incident meets the statutory criteria for the duty of candour, {{org_field_name}} will follow its Duty of Candour Policy and the requirements of Regulation 20.
• Where an incident involves a personal data breach, the requirements of Section 4.3 and {{org_field_name}}’s data breach procedures must be followed.
• Audit findings, incidents, complaints, feedback and lessons learned will be used to improve TEC arrangements, care planning, training, risk management and this policy.

8. Related Policies

This policy should be read in conjunction with:

• SL02 – Safe Care and Treatment Policy
• SL07 – Confidentiality and Data Protection Policy
• SL13 – Risk Management and Incident Reporting Policy
• SL19 – Equality and Inclusion Policy
• SL21 – Health and Safety Policy
• SL25 – Safeguarding and Protection of Vulnerable Adults Policy

9. Policy Review

This policy will be reviewed annually or sooner if CQC regulations, business needs, or technological advancements require updates.

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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.