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CQC guidance on surveillance technology in care services


CQC in December produced guidance on the use of surveillance technology. The commission suggests that it can help services:

  • protect people’s safety, for example from the risk of unsafe care or treatment
  • keep premises and property secure
  • help people stay safe without restricting their activities.

Open surveillance

Care services are more likely to use surveillance openly (overt surveillance). Which requires the provider to tell everyone that it affects. You can do this by talking to them before you start using surveillance or by putting up clear notices. In some circumstances, you may need their consent.

Covert surveillance

This is when you use hidden cameras or microphones people are not aware of. This is only likely to be appropriate in rare circumstances, if you have a pressing reason and only plan to use it for a short time. For example, you might decide to use it to identify a specific incident or allegation.

Regulations

If the provider uses surveillance to help keep people safe or monitor their wellbeing, CQC will treat it as part of their care. This means it must meet the regulations under the Health and Social Care Act.

But any recordings made of people also count as information about them. Collecting information about people is regulated by the Information Commissioner’s Office (ICO).

Things to be carried out before commencing surveillance

Before they start providers must be able to identify the purpose for using surveillance – the thing you want to achieve. The provider should:

  • Carry out an initial assessment
  • Check the right regulations
  • Fill in a data protection impact assessment
  • Carry out a needs assessment
  • What you should record

Records to be kept by the provider

The provider must keep a record of:

  • your purpose for using surveillance, including how it supports people’s needs
  • your initial assessment
  • your DPIA, if you’ve completed one
  • what alternatives to surveillance you’ve considered.

Consultation

The provider should tell people:

  • why they are considering surveillance (your purpose)
  • what type of surveillance they are thinking about using
  • where they are considering using it
  • what information they will collect
  • where and how they will store the information
  • who will have access to the information and how long will they keep it.

It’s best to keep a record of the process when people are consulted, along with their responses. Providers are reminded that initial consultation with people is not the same as getting consent.

People raising concerns

People who use your service or their families may raise concerns about privacy. If they do, the provider must take steps to address them. The aim is to make the impact on people’s privacy as small as possible.

Equipment and staff training

When choosing equipment, the provider must ensure it’s fit for purpose. For example, it may need to capture video at a high enough resolution that you can recognise people.

Staff training and record keeping

Staff must be properly trained in handling information gathered by surveillance.

To protect people’s information providers must make sure:

  • staff are properly trained in handling information gathered by surveillance
  • they have clear policies and procedures for when people ask for access to recordings, about sharing information and for complaints about surveillance
  • they keep a record of who has had access to the information, when and why
  • they have a clear policy about keeping information and recordings secure, how long you keep them for, and when and how you destroy them
  • if someone else (like a security company) is handling personal data on their behalf, their contract with them must set out clear rules on how they process it.

Use of hidden cameras

People sometimes worry about a loved one and their care. They might use hidden cameras or microphones to give themselves reassurance. If the provider finds that surveillance is being used in their service, it’s important to put the interests of the person first.

Summary

The appropriate use of surveillance technology will be a cause for concern for many providers.  The requirements of the GDPR have added another dimension to the importance of correctly handling people’s data. Before contemplation of its use providers would be well advised to refer to the CQC guidance on their website.

Albert Cook BA, MA & Fellow Charted Quality Institute
Managing Director
Bettal Quality Consultancy

CQC is driving social care services to make more use of technology


According to CQC technology is changing the way people provide care and treatment. It suggests that there are huge benefits to be gained for people who use services, families, carers and providers. But it’s important technology and innovation never come at the expense of high-quality, person-centred care.

Benefits of technology in care

Technology can:

  • give people more control over their health, safety and wellbeing
  • support them to be more independent or feel less isolated
  • link them to services which are important for them
  • enhance the care or treatment providers offer
  • help them communicate with families, professionals and staff
  • help staff to prioritise and focus their attention on people who need it most
  • capture and compare data and share good practice with peers.

If providers are to make the best use of technology then people’s safety, dignity and consent must be at the centre of decisions about their care. This applies to decisions about the use of new technology. Being clear about people’s rights, privacy and choice must always come first.

Questions to ask before using technology

CQC ask providers to consider the following question if they are thinking about using technology to deliver care.

  • How will you involve people who use your service in your plans and putting the new technology into use?
  • What do the people it will affect need to know to make an informed choice? Do they fully understand the implications of the new technology?
  • Who will the technology affect and how will it affect them?
  • What outcome do you want to achieve? How will you measure it?
  • Will the technology fully meet the needs of the people using your service? If not, what else do you need to provide?
  • Are there more appropriate ways to meet these needs?
  • What are the practical and legal issues you need to think about before you introduce new technology?
  • What are the risks and how will you manage them? Particularly during transition and early implementation of the technology or system. What is your contingency plan to keep people safe?
  • How have you involved your staff? What information and training do they need so they can be confident and competent? This includes understanding their responsibilities and         how to respond to associated risks.

Innovative use of technology can help answer our five key questions

When CQC inspect and monitor health and social care services, there are five key questions they ask. The following examples illustrate how technology can support good and outstanding person-centred care.

Safe

Helping ensure key information is accurate and easy to share with caring professionals in real time

Effective

Supporting effective communication and more efficient use of resources, including finances

Caring

Supporting person-centred care and helping staff to spend more time on the things that really matter

Responsive to people’s needs

Supporting providers to be more proactive and responsive to changing needs by helping to identify developing risks or needs more quickly

Well-led

Supporting more effective quality assurance through more effective communication, information sharing and improved data analysis.

Bettal Quality Consultancy

Here at Bettal we have recognised the contribution that technology can make to high quality social care services. We have developed a digital audit tool to measure a services performance against the key Lines of Enquiry. Next year we will be launching our new digital person centred plan and digital risk assessment tool.

For further information on Bettal products please visit our Care Service Products section.

Summary

CQC have recognised that technology has an important part to play in social care services. We are only at the beginning of a journey that will see far greater use of technology in the future. The benefits to service users and staff are there for all to see, and I have no doubt that in time you will see less time spent with onsite inspection. The creation of digital routs which will allow inspectors to measure social care services performance off site. This will lead to a further reduction in the number of inspectors.

However, it still needs to be repeated that technology should not be viewed as a substitute for staff time spent with service users, but rather a supportive mechanism that allows more time to be spent with them.

Albert Cook BA, MA & Fellow Charted Quality Institute
Managing Director
Bettal Quality Consultancy

Supporting service users who suffer hearing loss


Action on Hearing Loss’ have published guidance for staff in residential care homes designed to support service users who have hearing loss.

The central thrust of the guidance is a recognition that deafness and hearing loss shouldn’t stop older people living well in residential care homes.  The guide provides practical tips and advice for care staff on improving the quality of care for older people who are deaf or have hearing loss.

More than two-thirds of older people have hearing loss. Around 71% of people aged over 70 have some kind of hearing loss. It’s estimated that 75% of people in a care home have hearing loss – and that this will increase to 80% by 2032.  Unaddressed, this can lead to social isolation and an increased risk of other health problems, such as depression and dementia. There is solid that hearing aids can reduce these risks, but the problem is that too many older people are waiting far too long to get their hearing tested or face barriers seeking help because of other conditions.

People who are deaf who use British Sign Language (BSL) may be at risk of loneliness and loss of cultural identity if they are unable to communicate in a meaningful way in BSL with care staff or other people in their care home.

How care staff can help?

1.0    Care staff should be alert to the early signs of hearing loss

The assessment of service users should offer service users the opportunity to have a hearing test. When new residents arrive at the home, staff should be aware of the signs of hearing loss, such as asking others to repeat things, failing to follow conversation in noisy places and behavioural changes, such as withdrawal from social activities.

A ‘Hearing check‘ can help identify people who may need a hearing test.

2.0    Provision of support to ensure older people get the most out of their hearing aids

Where a person has a hearing aid, staff should record this in the service users  care plan and make a note of other accessories that may be needed, such as replacement batteries or tubing. When someone is fitted with hearing aids by their audiologist, they should be provided with written instructions on how to operate and maintain their hearing aids.

Staff should carry out regular checks to make sure their hearing aids are functioning and fitted correctly. If hearing aids are worn continuously, hearing aid batteries typically last no more than a week and hearing aid earmoulds and tubing require regular cleaning.

3.0    Ask older people if they need help to communicate or understand information

If older people who are deaf or have hearing loss need staff to follow simple communication tips or if they need more communication time when receiving care, make sure this is recorded in their care plan.

In England, ensuring communication and information needs are recorded and met is a legal requirement under NHS England’s Accessible Information Standard.

4.0    Make sure the care home environment is welcoming for older people with hearing loss

A high level of background noise can make it difficult for older people with hearing loss to understand what is being said and participate fully in conversations and social activities. Carpeted floors, padded tablecloths and soft furnishings should be used wherever possible to help absorb background noise.

Older people with hearing loss may also benefit from assistive technology, such as hearing loops, personal listeners and flashing smoke alarms

5.0    Take account of the cultural and communication needs of older people who are deaf

Older people who are deaf are less likely to benefit from hearing aids and they may need specialist care and support that recognises the unique language and culture of the deaf community.

They may also need support from a qualified BSL interpreter, as well as help to contact family and friends and local Deaf clubs or other community groups.

Summary

Given that there is evidence that it is estimated that 75% of people in a care home have hearing loss, it is essential that care homes adopt a strategy to support service users who suffer with this problem. The guidance provided for staff by ‘Action on Hearing Loss’ should be followed. Hearing loss should form part of the assessment process, and actions to support service users contained in the care plan. This will ensure that service users can still retain quality of life.

Albert Cook BA, MA & Fellow Charted Quality Institute
Managing Director
Bettal Quality Consultancy

New Skills for Care advice on safe staffing


Skills for Care as part of their ‘Good and Outstanding Range’ have produced guidance for managers on safe staffing. The guide explains what the CQC looks for in terms of safe staffing and how a service can meet the regulation requirement. It includes guidance around deciding and maintaining safe staffing levels, safe recruitment practices and how to ensure staff are safe and competent.

It draws on evidence from over 60 CQC inspection reports and case studies from residential and community-based services who are rated ‘good’ and ‘outstanding,’ to help providers to understand what ‘good’ looks like and learn from best practice.

What is safe staffing

According to the guide safe staffing is about having enough staff, who have the right values and skills, to deliver high quality care and support. It involves:

  • having safe staffing levels, including putting contingency plans in place;
  • recruiting the right people, with the right values, skills and experience to deliver safe care and support;
  • doing the right recruitment checks;
  • ensuring staff are competent and safe to do their role.

Safe staffing is not just about numbers it about having experienced and competent staff who have a clear understanding of the requirements of service users care plans, who stay with the service long enough to establish meaningful relationships with those who they care for.

Identifying characteristics of services who have inadequate staffing

There are some common characteristics of services who have inadequate staffing. If some, or all, of these apply to your service this could indicate that a service is not meeting the requirements for safe staffing.

  • High turnover of staff;
  • Struggle to recruit enough staff;
  • New staff leave within a short time of joining;
  • High sickness rates that are particularly stress related;
  • Unorganised rota system and processes that are difficult to use and review;
  • Rota’s are constantly changing;
  • Staff only have time to perform duties and tasks with no time to ‘care’;
  • Staff don’t have time to communicate with
    people they support, families and professionals;
  • Little consistency in staff;
  • Over-reliance on temporary workers;
  • Staff inductions are limited and/or rushed;
  • Staff learning, and development is restricted to mandatory training;
  • Limited support for staff such as supervisions.

Impact on service users

  • staff have no time to respond to calls for help;
  • there is not enough time to do an effective handover;
  • staff support people to get ready and have meals at a time that best suits them rather than the individual;
  • not enough staff to support people at meal times;
  • medication documentation is rushed.

CQC checks on safe staffing

CQC will require managers to demonstrate how they arrived at the numbers of staff to ensure service users are safe. Dependency tools can help the manager to decide how many staff will be needed. They can be used to collate information about the needs (or dependency) of people who need care and support, how many hours/staff support will be needed, and enable the manager to log other requirements such as time for administration, record keeping and communicating. This can help to make informed decisions about how many staff will be needed in your service to meet safe staffing levels. In addition, it provides evidence of how you arrived at your decision about the numbers of staff.

When using a dependency tool, the manager must ensure staff are competent to use it and use it consistently. If they don’t, this can have a negative impact on the outcome of a services inspection.

One residential home graded inadequate by CQC, found that having checked the records following the use of the dependency tool, that records of the assessment hadn’t been completed for some weeks. The provider was unable to demonstrate on what basis they’d decided the current staffing numbers per shift against the needs of people.

Summary

This latest guide by Skills for Care on safe staffing gives providers useful advice on how to ensure CQC requirements can be met. It helps providers to recognise the characteristics of services who have safe staffing issues. Dependency tools can be useful in providing evidence of how managers decided on staffing levels, but they should only be used by competent and experienced staff capable of keeping records up to date. Managers are strongly advised to obtain the guide on safe staffing by visiting the Skills for Care Website.

Albert Cook BA, MA & Fellow Charted Quality Institute
Managing Director
Bettal Quality Consultancy

Do we care enough for our older people in society?


As much as we welcome, Philip Hammond, the UK’s Conservative chancellor of the exchequer, £650million additional grant funding for local authorities in England to spend on services for older people and adults with long-term disabilities in his 2019/20 Budget. It is hard not to draw the conclusion that this is a pittance of the amount required to provide quality care services and respect the dignity of our older people.

Mr. Hammond claims this will help ease the ‘immediate pressures’ faced by social care services. But only £240million of this money is earmarked for propping up the social-care system. While the Association of Directors of Adult Social Services has been lobbying for £2.35 billion after enduring year-on-year funding shortfalls.

According to Labour MP Frank Field, co-author of‘A New Deal to Reward Kindness in a Forgotten Profession’, cuts to local-authority budgets have resulted in a ‘race to the bottom’ in the commissioning of paid-for homecare provision. The inevitable result is poor-quality, rushed personal care.

Emily Holzhausen of Carers UK says unpaid carers, some of them pensioners themselves, who are typically looking after other elderly family members, are ‘exhausted, demoralised and have lost vital community connections because there is not enough good-quality care’. They are ‘the backbone of the care system’ without whom ‘the system would collapse’, agrees Ian Hudspeth at the Local Government Association.

The King’s Fund says the system not only needs to make improvements in the quality of care that is provided, but also needs to find more resources. These will be needed to address an estimated additional 1.2million people’s unmet care needs, and to find an expected 700,000 more social-care workers by 2030 as the ageing population continues to grow.

Finding new and innovative ways to care for people

New, more efficient and innovative ways of providing care do need to be found. This needs to go alongside a better way of managing the demand on services, with an approach that is more preventative and also integrated with health, housing and benefits systems. A balance needs to be found between formal support, provided or commissioned by the state, and informal support that comes from family- or community-based care.

These are not just technical questions for the social-care sector to grapple with. They are far bigger than that, touching upon the issue of what kind of society we want to live in, and what we expect of each other. At root, there is the issue of what we regard as individual and collective responsibilities; and what the duties of the young are to the old; and the question of how elderly people come to decide for themselves how they should be cared for later in life.

A pervading sense of negativity towards older people in our society

The bookmakers Paddy Power have been criticised for its adverts portraying old people as zombies, albeit as part of its UK sponsorship deal with the TV series The Walking Dead. It is meant to be a joke, but older people’s charities didn’t find it very funny. Such ‘inaccurate stereotypes’ are described by Independent Age as ‘crass and utterly disrespectful’.

Some of us might be tempted to laugh this off as yet another overreaction from the permanently offended. Ofcom has yet to decide whether the four complainants (yes, four!) about the Paddy Power ad are enough to justify an investigation. And yet, this depiction of old people is not an isolated incident. It reflects a broader prejudice today.

‘Negativity about ageing and older people is pervasive in our society’, says Caroline Abrahams at Age UK. Whether it’s the nasty sentiment that Brexit voters are a bunch of selfish old bigots whose demise can’t come too soon, or that Baby Boomers have been piling up problems for moaning millennials, or that old people are just getting in the way with their ‘bed-blocking’ and their unreasonable expectation that younger folk should subsidise their state pensions, free bus passes, TV licenses and winter fuel allowances – again and again, we see generational disdain for older people.

Add in the damning inspections, abuse scandals, cuts to services, underpaid care workers that have so plagued the social-care sector in recent years, then it is hard to escape the conclusion that elderly people are increasingly regarded as a burden on society and a drain on resources. Once, they were seen as the repositories of wisdom and a source of support for hardworking families – now they are talked about as a barrier to youthful flourishing.

Summary

There is increasing economic evidence and a pervasive negativity in our society that sheds light on how older people are viewed in our modern society. This is not helped by the government of the day continuing to delay its decision on the funding of social care, and failure to acknowledge the valuable contribution of unpaid carers. We need to be wary of some in our society, who have a generational disdain for older people.

Technology and improved working practices in themselves will not solve the question of the kind of society we wish to live in. It seems to me it is incumbent on all of us to recognise the valuable contribution older people can make to our society, and in doing provide a purpose to their life. We need to harness the experience of older people as a resource to the benefit of all who live in our society.

Acknowledgements

Dave Clements adviser to local government and founder of the Academy of Ideas Social Policy Forum.

Albert Cook BA, MA & Fellow Charted Quality Institute
Managing Director
Bettal Quality Consultancy