Deprivation of Liberty Safeguards: Guidance for Regulatory ...careinspectorate.wales/docs/cssiw/general/151208dolsguidanceen.pdf · Type Process Guidance ... helping to ensure that

Deprivation of Liberty Safeguards

Guidance for Regulatory Inspectorsand Support Staff:

Inspection and InformationRecording Process

Author Process Enabling TeamDate December 2015Review Date December 2016Type Process GuidanceVersion V4.0

V4.0 December 2015


Guidance for Inspectors and Support Staff

Contents Page No:

1. Introduction 1

2. Organisational context 2

3. Roles and responsibilities 4

The role of the Business Support Officer [BSO] 4The role of the area inspector 4

4. The process for recording DoLS notifications (see Flow chart 1) 5

5. Process for case-tracking DoLS authorisations during inspections(see Flow chart 2) 6

6. Frequently asked questions 8

Flow chart 1 - The role of the BSO (see note 4) 10Flow chart 2 - The role of the area inspector. (see note 5) 11

Annex 1 Notifying CSSIW of Deprivation of Liberty Authorisation requests12

Annex 2 Inspection Record Checklist and Aide Memoire 14

Summary of changes to previous guidance 21

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Guidance for Inspectors and Support Staff

1. Introduction

1.1 The Mental Capacity Act 2005 aims to protect people who lack capacity,whilst maximising whatever ability they do have to participate in makingdecisions, both large and small, that affect their lives. The Act incorporates fivekey principles;

• A person is assumed to have capacity - unless it is established that theylack capacity.

• A person must not be treated as being unable to make decisions unlessall practicable steps have been taken without success.

• A person is not to be treated as lacking the capacity to make a decisionsimply because they make – or are perceived to make – an unwisedecision.

• An action taken or decision made on behalf of a person assessed aslacking capacity must be taken/made in their best interests.

• Any action or decision must be carried out in such a way that is leastrestrictive of the person’s rights and freedom of action.

1.2 The Deprivation of Liberty Safeguards [DoLS] was incorporated into theMental Capacity Act in 2007 (coming into force in April 2009). The Safeguardswere intended to further protect some of the most vulnerable people wholacked capacity and in whose best interests it is necessary to restrict or curtailtheir freedom of movement and choice. The Safeguards are intended toensure that where it has been agreed as being necessary to deprive a personof their liberty that any such decision is made lawfully and properly. DoLS onlyapplies in registered care homes and hospitals.

1.3 In addition, a Supreme Court judgement in March 2014 reminds localauthorities that they must be pro-active in identifying and attempting to dealwith potential or actual deprivations of liberty in care homes includingSupported Living or other ‘own home’ settings. In addition the ruling introducedan ‘Acid Test’ which determines that where a person is under constantsupervision and control and are not free to leave their home without permissionor assistance from carers this may amount to a deprivation and should beaddressed. Where this is the case the safeguarding process will be via theCourt of Protection, rather than DoLS – it is for the local Supervisory Body tolook at any such issues that are raised or referred.

1.4 A decision which is made to legally restrict a person of their liberty is knownas an authorisation. A deprivation of liberty can be requested and issubsequently overseen by the Managing Authority (the hospital or care homewhere they receive their care). Any such request must be authorised by a

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Supervisory Body (usually a local authority or local health board) and be basedupon an assessment of the person concerned.

1.5 There are six separate elements (qualifying requirements) to theassessment process - all of which must be completed before a SupervisoryBody can give an authorisation. Assessments regarding age, no refusals,mental capacity, eligibility and best interest are usually undertaken by a BestInterest Assessor (BIA). The mental health assessment must always beundertaken by a doctor approved under section 12 of the Mental Health Act1983.

1.6 The Supervisory Body in agreement with the Managing Authority may thenmake requirements for the subsequent care of the person concerned. Allauthorisations must be subject to ongoing review to ensure that a deprivation isnot in place for any longer than is necessary and is least restrictive in nature.No individual authorisation should stand for longer than12 months at a time

1.7 There are two types of authorisation: ‘urgent’ and ‘standard’. Both requirequalifying requirements and a pre-determined process to be observed so thatany restrictions on a person’s liberty are lawfully made. A standardauthorisation is requested and then considered by the Supervisory Body.Where authorised, a timescale for reviews by a Best Interest Assessor [BIA]and/or Independent Mental Capacity Advocate [IMCA] are agreed.

1.8 Where a standard authorisation is not possible in advance or where theneed has become acute, a Managing Authority can deprive a person of theirliberty for a maximum of seven days by means of an urgent authorisation. Arequest to the Supervisory Body for a standard authorisation must also bemade at the same time and steps taken to agree a way forward with theSupervisory Body as soon as possible.

1.9 For situations where the BIA does not support the application afterassessment, it is good practice for their report to be considered by thecommissioner and provider of the service with regards to the relevant person’scare.

1.10 The above is a brief overview for the purpose of this guidance document.Inspectors and others should refer to the ‘Mental Capacity Act [2005]’ and the‘Deprivation of Liberty Safeguards’ Code of Practice’ for additionalinformation

2. Organisational context

2.1 Welsh Government is required to monitor the operation of DoLS in Walesand to produce and publish an annual summary report on both the quantity andquality of requests [whether or not they are agreed] and authorisations withincare homes and hospitals.

2.2 The function for monitoring the operation of the Safeguards will beperformed on behalf of Welsh Ministers by Care and Social ServicesInspectorate Wales and Healthcare Inspectorate Wales. Both have the power

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to require Supervisory Bodies and Managing Authorities of care homes andhospitals to share information about requests for and authorisations made inthese services.

2.3 In May 2013 CSSIW produced a notification form (see Annex 1) thatrequired providers of care homes to inform of any requests for authorisationsmade in respect of people living in their service. This notification is the formalmechanism for capturing the quantity of DoLS applications for authorisations incare homes in Wales and the role of Business Support staff is vital in collectinginformation received.

2.4 Area inspectors within regional teams are essential in informing theorganisation about the quality of DoLS requests and authorisations andhelping to ensure that the process is lawfully applied and contributes to positiveoutcomes for those people affected. The routine case tracking duringscheduled inspections of people who are the subject of authorisations isrequired so that Welsh Ministers can be given an assurance about theoperation of DoLS in Wales.

2.5 It is also important for inspectors to consider requests which have not beenagreed as these may suggest wider issues relating to the care of the personconcerned and of other people living in the care home. There are certainservice areas (dementia care and learning disability services for example)where a higher number of applications might be expected – where this is notthe case an inspector might prompt discussion with the registered manager andstaff about how such issues are managed within the service.

2.6 Area inspectors should be aware of what potentially constitutes a restrictionor deprivation of liberty during inspections in all care homes and communitybased placements. As part of their regulatory role, they should be alert to whatmight constitute an unauthorised deprivation and discuss issues as they arisewith the registered manager/provider. Restrictions relating to the environmentor to the way people are supported (locked doors; limiting access to watersources; restrictions on movement within the home or in the community or theuse of audio monitors for example) should always be questioned and theirrationale determined.

2.7 Where such restrictions are used to manage difficult or challengingbehaviour, there is a need to ensure that where they amount to a deprivation ofa person’s liberty they are lawfully agreed and are in the best interests of theperson concerned. Where this is in doubt inspectors are required to provide a3rd party referral to the Supervisory Body who will then look at thecircumstances via the assessment process.

2.8 In light of the Supreme Court ruling, area inspectors need to bear in mindthe ‘acid test’ – ie is the person subject to continuous supervision and controland are they unable to leave if they choose to. This test has the potential toapply to a significant proportion of people who live in care homes. Again it isessential to ensure that any restrictions in place are agreed as being in theperson’s best interest and are the least restrictive approach to care provision.

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3. Roles and Responsibilities

The role of the Business Support Officer (BSO)

3.1 The role and responsibilities of the BSO are relatively brief, but essential inhelping Welsh Government quantify the number of authorisations in Wales.

3.2 The BSO is responsible for processing the electronic or paper receipt of theDoLS notification form, the scanning of the document and logging it onto theelectronic record.

3.3 The BSO is responsible for informing the relevant area inspector and theirarea manager that a notification has been received.

3.4 When requested by the inspector, the BSO will provide a copy of the DoLSInspection Record Checklist which the inspector will then use during theirinspection visit.

3.5 The BSO is responsible for logging onto the electronic record the completedInspection Record Checklist (see Annex 2).

The role of the area inspector

3.6 The role of the area inspector is essential in determining the quality ofauthorisations in care homes within their caseload. This is achieved throughcase tracking persons subject to a DoLS request or authorisation and helpsensure that processes relating to application, assessment and review are beingobserved. This work will help to provide an assurance about the operation ofDoLS in Wales.

3.7 There is an expectation that a sample of persons subject to DoLSauthorisations in Wales will be case tracked through the annual round ofscheduled inspections. As the numbers of authorisations is small, in someservices this will mean case tracking all authorisations as they are rare events;in other services a sample will be case tracked. It is expected that the SupremeCourt judgement will lead to a significant increase in the number of referralsand subsequently the number of agreed authorisations. Where there aremultiple requests and/or authorisations in a single service, the inspector shouldsample a sufficient number to satisfy themselves that the provider/ManagingAuthority are competent in this area.

3.8 The area inspector is responsible for ensuring that case tracking takesplace as part of the scheduled inspection. They will need to case track asufficient number of authorisations to satisfy themselves that the service - asthe Managing Authority - understands their responsibilities, is adhering to theDoLS process and the requirements contained within a person's authorisation.

3.9 Where a scheduled inspection of a service has already taken place, it is notnormally necessary to carry out an additional inspection during the sameinspection year. It is normally appropriate to delay case tracking until the nextscheduled inspection – even if that is in the following inspection year. A brief file

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note should be made and retained in the ‘Events’ section of the electronicrecord both as a reminder and as a means of communicating this intention toany newly allocated inspector of the service.

3.10 There may be occasions however, when the inspector chooses toconsider the authorisation via case tracking as part of a follow up focusedinspection. This might occur where there are existing concerns regarding themanagement and understanding of DoLS or where there are issues regardingsupport for people whose behaviours are difficult to manage. In addition to theDoLS Inspection Record Checklist, a brief focused inspection report should becompleted and written in such a way that the identity of the person subject tothe authorisation is not readily apparent.

3.11 Where, during the course of case tracking, there are concerns relating to arequest and/or authorisation these should be brought to the attention of theArea Manager responsible for the local authority area within which theSupervisory Body operates.

3.12 The DoLS Inspection Record Checklist (see Annex 2) should be used tocapture the findings and will form part of the overall inspection record. Whencompleted the checklist needs to be forwarded to the BSO for logging onto theelectronic record. This information will then be used to help inform ourawareness of the operation of DoLS in Wales.

The role of the Area Manager

3.13 The role of the Area Manager is generally a strategic one and primarilyconcerned with monitoring the volume of authorisations in care homes withintheir local authority area(s). There may for example be instances where thereappears to be too many; too few or no authorisations at all and which mayprompt further enquiry through the local authority inspection process.

3.14 The Area Manager should ask regulatory inspectors to share any issuesregarding the quality and quantity of requests and authorisations – questionablerationale for depriving a person of their liberty or delays in the review processfor example. These may also prompt further enquiry during a subsequent localauthority inspection or require more immediate action. Over time the AreaManager will be able to form a judgement as to the management and operationof the DoLS within each local authority area.

4. The process for recording DoLS notifications(see Flow chart 1)

• The notification informing CSSIW that a request for a DoLS authorisationhas been made or agreed is received either electronically or in paperversion.

• The BSO attaches a copy of the notification onto the electronic record.

• The BSO informs the area inspector and their area manager by e-mail thata notification has been received.

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• When requested by the inspector, the BSO will provide a copy of the DoLSInspection Record Checklist which the inspector will then use during theirinspection visit.

• Once the DoLS Inspection Record Checklist has been completed by theinspector, the BSO will ensure the record is scanned and logged onto theelectronic record.

4.1 Statistics captured in this way will be collected centrally at the end of theinspection year and used to provide an annual summary report. There is noadditional role for the BSO in the process.

5. Process for case-tracking DoLS authorisations duringinspections (see Flow chart 2)

• Once informed that a notification has been received, the area inspectorneeds to consider the content and if necessary contact the ManagingAuthority/registered manager to clarify any issues and, where unclear,confirm whether the request for authorisation has been agreed or not.

• Where a request has been agreed, the inspector should decide when theperson subject to the DoLS authorisation is to be case tracked. This wouldnormally take place at the next scheduled inspection – either in the currentyear or the next – or the inspector may have sufficient concerns and decideto undertake a focused inspection of the service centred upon case trackingthe person concerned.

• Where a request has not been agreed, the inspector should considerwhether or not there is a need to follow up any issues that are related to theapplication. These might include, for example, the presentation andmanagement of individual behaviours or whether or not there is a clearunderstanding of the DoLS process within the care home. There is no needfor an inspection visit to take place, but there may be issues arising from afailed request which might warrant investigation at a future time.

5.1 As part of case tracking, the inspector should focus upon the key elementsof the authorisation process and its management within the care home. Theinspector should be assured that the deprivation is an authorised one; has beenproperly attained and is subject to review. Discussion should take place withthe person concerned if that is possible, relatives, the staff supporting them andthe registered manager.

5.2 There may occasionally be a need to discuss the authorisation with theSupervisory Body, BIA (Best Interest Assessor) and/or an IMCA (IndependentMental Capacity Advocate) where issues arise and require clarification. Ingeneral terms, the inspector should consider the following;

• Has the correct request (urgent and/or standard) form been used; fullycompleted and retained as part of the individual file?

• Is the rationale for the request and any authorisation clear?

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• Is there evidence of capacity and best interest assessments beingundertaken?

• Is there evidence to show that the Managing Authority are complying withthe requirement[s] contained within the authorisation?

• Does the individual care plan include and reflect issues relating to andarising from the authorisation including any requirements made by theSupervisory Body?

• Is there documented evidence of ongoing reviews; a clear timescale forreview and involvement by a BIA and/or IMCA?

• Are there language or communication difficulties? If so, how are theseaddressed?

• Is there documentary evidence of staff training in DoLS taking place? Dodiscussions with staff support this and does their knowledge demonstratean understanding of the process?

• Are there positive outcomes in terms of the emotional, social and physicalwellbeing of the person subject to the authorisation?

• Consideration should be given to the general circumstances of theauthorisation and whether or not the liberty of other service users may besimilarly affected. For example, do locked doors; or restrictions on access tokitchens or sources of water, impact upon other people living in the home?

• Might there be other possible unauthorised restrictions in place that areunrelated to the authorisation that is being case tracked but are being usedto manage another persons behaviour?

• Do the care plans of other people reflect and contain Deprivation of LibertySafeguards considerations such as capacity or best interests?

5.3 The DoLS Inspection Record Checklist should be completed as fully aspossible during the inspection visit – there may be occasions when furtherclarification is required and this may delay the completion of the checklist. Oncecomplete the area inspector should forward the completed record to the BSOfor scanning and logging onto the electronic record. Any concerns should bebrought to the attention of the area manager.

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6. Frequently asked questions

Q.1. ‘Where a service user who is the subject of a DoLSauthorisation is transferred from hospital to a care home, isthere a need to carry out an inspection?’

A. Normally yes – it will be for the inspector to decide when will be the besttime to undertake the case tracking of the person concerned. However, anytransfer between a hospital and care home – or vice versa - will be overseen bythe Supervisory Body, but the Managing Authority will have now changed andan application for a new standard authorisation is required. Circumstances inrelation to the physical environment and staffing will differ and, in the case of atransfer to a care home, will need to be monitored by CSSIW as a result.Transfer arrangements – including the way in which the person concerned wasinvolved in the decision - may be an area for consideration. There might also bea need to consult with colleagues in Healthcare Inspectorate Wales about theirinvolvement if any. Where the person transferred becomes part of a group ofpeople subject to authorisations and living in the same service, the inspectorshould consider whether or not they need to case track this person as part of a‘sampled’ approach.

Q.2. ‘What are the qualifying requirements for anauthorisation?’

A. A person who is being considered for an authorisation under the Deprivationof Liberty Safeguards needs to meet certain ‘qualifying requirements’ for themto be deemed as eligible;

• They must be aged 18 years or over.

• They must lack capacity in regard to the proposed or actual care andtreatment plan.

• It is assessed as being in the best interests of the person concerned to bedeprived of their liberty in ways specified by the assessment.

• The person has a mental health disorder as defined by, and is not detainedor liable to be detained under a section of the Mental Health Act 1983. Thismeans any disorder or disability of the mind, apart from drug and alcoholdependence, and includes all forms of learning disability.

• An authorisation does not conflict with any previous advance decision.

Q.3. ‘What is an IMCA or BIA’?

A. An IMCA is an Independent Mental Capacity Advocate. Where a personwho is subject to an authorisation does not have anyone to represent theirinterests, the Supervisory Body may appoint an IMCA to represent the person.

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An IMCA will be appointed where there is a safeguarding issue irrespective ofwhether there is a family member.

A BIA is a Best Interest Assessor. They determine by way of an assessment,whether or not a deprivation is taking place and, if so, whether it is in the bestinterest of the person concerned. Their assessment includes recommendationswhich, if agreed by the Supervisory Body as requirements, help the ManagingAuthority care for the person concerned in ways which maximise their ability toparticipate in decisions and minimise any restrictions upon their liberty. BIAsare essential to establishing a timescale for reviewing authorisations so theyare not in place for any longer than is necessary.

Q.4. ‘What if someone has fluctuating capacity’?

A. A balance needs to be struck between the need to review and terminate anauthorisation if a person regains capacity and the repetitive cycle ofauthorisation-review-termination-authorisation brought about by fluctuatingcapacity.

Each case must be treated on its merits and kept under review. It must beassessed by a suitably qualified person whether or not the capacity that hasbeen regained is for the short or longer term. Where there is clinical evidence tosupport the view that capacity has been regained for only a limited period anauthorisation will be maintained subject to review. Where there is evidence toshow that capacity has been regained in the longer term the authorisationshould be terminated.

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Deprivation of Liberty Safeguards – Process steps

Flow chart 1 - The role of the BSO (see note 4)

DoLS notificationreceived via e-mail or

paper copy

E-mail version saved / paper versionscanned and saved into electronic

record

BSO informs by e-mail the area inspector andtheir area manager that a DoLS notification

has been received

When requested by theinspector, BSO provides via e-

mail a copy of the DoLSInspection Record Checklist

See Flow chart 2.

Once the InspectionRecord Checklist has

been completed by thearea inspector and

received by the BSO, theBSO scans the copy onto

the electronic record


Deprivation of Liberty Safeguards – Process steps

Flow chart 2 - The Role of the Area Inspector

[See note 5]

Area inspector receives e-mailconfirmation that a DoLS

notification has been received

Area inspectorconsiders information

If required,clarify issues

withSupervisoryBody and/orManagingAuthorityWhere request for

authorisation is agreed,arrange inspection

schedule to case trackperson concerned

Carry out inspectionvisit – case track

person(s) subject toauthorisation –

commence InspectionRecord Checklist(s) If required,

clarify issueswith

SupervisoryBody, BIA or

IMCA

Inspection RecordChecklist completed

Completed InspectionRecord Checklist sentto BSO for scanning

and logging


Annex 1 - Notifying CSSIW of Deprivation of Liberty SafeguardsRequests/Authorisation

Information requested under Section 31(1) Care Standards Act 2000

This form can be used to notify CSSIW of Deprivation of Liberty Safeguards(DoLS) Requests/Authorisation. Guidance on completing and submitting thisform is available on CSSIW website.

Please complete one form per request/authorisation

Part 1: The establishment

Name of service

Address of service

Name of person subject torequest/authorisationDate of birth

Part 2: Reason for notification

Officeuseonly

Event Brief statement as to nature of event Dateoccurreddd/mm/yy

- Deprivation of LibertySafeguards (DoLS)Authorisation request

NOT39 Urgent

NOT40 Standard

Outcome of requestfor Standardauthorisation

Part 3: Others contacted

Organisation Date contacted (dd/mm/yyy)

Supervisory BodyPlease specify the name of the supervisory authority for theDoLS authorisation request, the date the authorisationrequest was made and the contact telephone number for thesupervisory body.

Social Services Authority responsible forthe individualPlease specify the authority name

Local Health Board responsible for theindividualPlease specify the local health board name


Part 4: Form completed by:

Name

Job title

Date (dd/mm/yyyy)

Completed forms must not contain personal information which could identify theindividual.

Completed forms can be sent:

1. By e-mail to your local CSSIW regional office:

North Wales – CSSIW-Notifications-NorthSouth East Wales – CSSIW-Notifications-SoutheastSouth West Wales – CSSIW - Notification-South West

DoLS information sent to the regional e-mail addresses above will receive areceipt.

2. By Recorded Delivery to your local CSSIW regional office:

3. By Fax to your local CSSIW regional office:

CSSIW North WalesRegionGovernment Buildings,Sarn Mynach,Llandudno JunctionLL31 9RZFax: 0872 437 7301

CSSIW South EastWales RegionGovernment Buildings,Rhydycar BusinessParkMerthyr TydfilCF48 1UZFax: 0872 437 7302

CSSIW South WestWales RegionGovernment BuildingsPicton TerraceCarmarthenSA31 3BTFax: 0872 437 7303

For general enquiries please call

0300 7900 126

Completed forms should be sent directly to CSSIW and not individuallynamed staff


Annex 2

Care and Social Services Inspectorate Wales


Inspection Record Checklist and Aide Memoire

(Please use one form per request/authorisation)

Note: There is an expectation that persons subject to a Deprivation of Liberty Safeguards request/authorisation will be ‘casetracked’ during an inspection. In this way inspectors will monitor the quality of authorisations on behalf of Welsh Ministers and theirwork will contribute to an annual summary report on the operation of DoLS in Wales.

This Inspection Record Checklist/Aide Memoire is intended to assist inspectors with this task and should be completed as fully aspossible for each request/authorisation. Once completed, it is to be returned to the Business Support Officer for scanning andlogging onto the electronic record.

For additional guidance in completing this form please refer to the CSSIW document ‘Deprivation of Liberty Safeguards Guidancefor Inspectors and Support Staff’.

Name of person subject torequest/authorisation

Name of managing authority (Carehome/agency)

Address and contact details:

Date of inspection:


Information regarding the Authorisation

Type of authorisation(please tick)

Standard Urgent

Date authorisationconfirmed by inspectorDate authorisationcommencedDate authorisation expired(if known)Supervisory Body Telephone no:

BIA appointed?(Please tick)

Yes Not known Name (if known)

IMCA Appointed?(Please tick)

Yes Not known Name (if known)


Case Tracking

a. Process elementsPlease tick

Yes

No×

Notes

Has the correct request form(Standard or Urgent) beenused?Has the form been fullycompleted?

Has the form been retained onthe person’s file?

Is the rationale for therequest/authorisation clear?

Is there evidence of capacityand best interest assessmentstaking place?

Dates:

Is there evidence of reviewstaking place - or planned to takeplace?

Dates:


b. Managing Authority compliance

Please tick

Yes

No×

Notes

Is there evidence to showcompliance by the ManagingAuthority with requirementsmade in the authorisation?

Have the requirements beenincorporated into the person’scare plan?

Is there evidence to show thatthe person concerned is beingsupported to engage in theprocess?

Is there evidence to show thereare positive outcomes for theperson concerned?

Does discussion, if possible,with the person concerned ortheir family support this?

Does discussion with staffsupport this?


c. Staffing

Please tick

Yes

No×

Notes

Is the registered manager clearabout the process?

Is the registered manager clearabout the rationale for theauthorisation?

Is the registered manager clearabout the need to comply withthe authorisation requirements?

Have staff received training inthe Mental CapacityAct/Deprivation of LibertySafeguards?Do staff understand theprocess?

Do staff understand the need tocomply with the authorisationrequirements?


d. Other considerationsPlease tick

Yes

No×

Notes

Do the restrictions relating tothis authorisation impact uponother people living in the home?

If yes, might these constitute arestriction or an unauthoriseddeprivation[s] of liberty?

If yes, what steps arebeing/have been taken toresolve such issues?

Actions taken:

If yes, are they now resolved?

Are there any other possiblerestrictions or unauthoriseddeprivations of liberty unrelatedto this authorisation?If yes, what action is being/wastaken to address these?

Action taken:

Was it necessary to inform orconsult with the SupervisoryBody?


Other comments or observations:

Inspector completing form:

Name:

Date:

Date forwarded to BSO:


Summary of changes to previous guidance

Version Number Date ofPublication

Page Changes to previous version

V4.0 December2015

Annexes1&2

General review – no substantive changes. Previouschanges missed from Welsh V3.0 now included inannexes.

V3.0 October2014

Annexes1 & 2

Following legal advice, provider notification form andinspection checklist amended to allow capture ofpersons name and date of birth.

V 2.0 July 2014 3, 5 & 6 Incorporate into guidance reference to Supreme Courtjudgement of March 2014 and implications forprocess..

7 &10 Text inserted clarifying process issues for inspectorsand the need to take a ‘sampled’ approach wherethere are multiple authorisations in place.

Throughout All references to the QA+ system have been replacedby the neutral term ‘electronic record’.

Throughout Minor grammatical and formatting changes have beenmade to the text and layout.

Documents

Deprivation of Liberty Safeguards: Guidance for Regulatory ...careinspectorate.wales/docs/cssiw/general/151208dolsguidanceen.pdf · Type Process Guidance ... helping to ensure that