Consent, Capacity and Digital Restrictive Practices in Adult Social Care
Digital safeguarding decisions frequently sit at the boundary between autonomy and protection. In Digital Safeguarding, Online Risk & Technology-Enabled Harm, providers must prevent avoidable harm while avoiding blanket restrictions that undermine rights and independence. This relies on Digital Care Planning that records consent, capacity considerations, and the rationale for any digital restrictions or monitoring as part of a defensible, least-restrictive approach.
This article sets out how services apply consent, capacity and proportionality in everyday practice, including governance mechanisms and inspection-ready evidence.
Why “digital restrictive practice” is a real operational issue
Digital restrictive practice can occur intentionally or by default. Examples include removing a phone, banning social media, controlling internet access, or requiring staff to monitor messages. Sometimes restrictions are necessary, but they become problematic when they are not individualised, not time-limited, or not clearly evidenced.
Providers should treat digital restrictions with the same rigour as any other restrictive practice: clear rationale, least-restrictive options, time limits, review, and the person’s involvement wherever possible.
Building the right assessment baseline
A strong baseline assessment supports consistent decisions and reduces reactive, inconsistent practice across teams. Practical assessment prompts include:
- What digital activities are important to the person’s wellbeing and independence?
- What specific harms are being seen or anticipated (e.g., exploitation, harassment, financial abuse)?
- Does the person understand the risks and consequences, and how stable is that understanding?
- What safeguards already exist (family support, advocacy, platform controls, device settings)?
- What are the least-restrictive options available before any restriction is considered?
Operational example 1: Removing a phone after repeated exploitation attempts
Context: A person supported in the community repeatedly sent money to unknown contacts following online conversations. Staff became concerned and a family member asked the service to remove the phone permanently.
Support approach: The service assessed decision-making specifically in relation to online financial transfers and vulnerability to coercion, rather than assuming a global lack of capacity.
Day-to-day delivery detail: Instead of confiscation, the service implemented step-down safeguards: keyworker check-ins before any online transfers, use of spending limits and payment controls, and coaching sessions on scam recognition. Where the person refused support, staff used a clear escalation route, recording concerns and triggers for safeguarding referral.
How effectiveness is evidenced: Incident logs showed reduced transfer attempts, supervision notes showed consistent staff responses, and safeguarding outcomes recorded a reduction in financial loss while maintaining digital access for social contact.
Commissioner expectation
Commissioners expect providers to apply a least-restrictive, person-centred approach, evidencing how digital safeguards support independence while managing risk, and showing how decisions are reviewed and adjusted over time.
Regulator / Inspector expectation
Inspectors expect restrictive practices to be lawful, proportionate and reviewed, with clear evidence that people are involved in decisions and that capacity and consent are considered in context.
Using the “least-restrictive ladder” in practice
A practical way to reduce overly restrictive responses is to use a stepped ladder, documenting why each lower step is insufficient before moving higher. For example:
- Step 1: Education and coaching (scams, privacy, blocking, reporting)
- Step 2: Device and platform controls (privacy settings, contact approvals, screen-time tools)
- Step 3: Supervised digital activity at specific times (agreed schedules, supported sessions)
- Step 4: Targeted restrictions (specific apps, specific contacts, time-limited controls)
- Step 5: Temporary removal only where necessary, with review dates and clear re-enablement plan
This approach helps teams show proportionality and avoid default bans.
Operational example 2: Monitoring messages as a safeguarding control
Context: A person with learning disability support needs was being pressured by an online “friend” to share personal images. The person agreed they wanted help but felt embarrassed and did not want family involved.
Support approach: The service co-produced a plan focusing on safety and dignity. Monitoring was presented as a temporary safety measure, not a punishment.
Day-to-day delivery detail: Staff agreed defined check-in points where the person would show recent messages for a limited period, with clear boundaries on what staff would and would not view. Staff supported the person to block and report, and to create a safe contact list. The plan included triggers for escalation if threats continued.
How effectiveness is evidenced: Records showed the person remained engaged with support, harmful contact reduced, and reviews documented when the monitoring step was reduced and then ended.
Governance: how to evidence defensible decisions
Digital restrictive decisions should not rely on informal agreement alone. Strong governance includes:
- Clear recording of consent and/or capacity considerations
- Documented rationale linked to specific risks and incidents
- Defined review dates and measurable indicators for step-down or removal
- Manager oversight where restrictions exceed basic device settings
- Audit trails showing consistency across staff and shifts
Providers should be able to demonstrate why the approach is necessary, how it is proportionate, and how it supports the person’s outcomes.
Operational example 3: Restricting internet access in supported accommodation
Context: In supported accommodation, a person repeatedly accessed harmful content late at night, leading to sleep deprivation, increased anxiety and incidents of self-neglect. Staff considered turning off Wi-Fi overnight for the whole house.
Support approach: The provider avoided a blanket restriction and assessed individual triggers and needs. The plan focused on sleep routines, anxiety management and targeted digital controls.
Day-to-day delivery detail: Staff supported the person to use device-level limits and wellbeing settings, agreed a night-time routine, and introduced structured activities earlier in the evening. Where Wi-Fi controls were used, they were applied to a single device and time-limited, with weekly reviews. Staff recorded how the person was involved and what alternatives were tried.
How effectiveness is evidenced: Sleep and wellbeing monitoring improved, incident frequency reduced, and audits showed a clear rationale for targeted controls without restricting other residents.
What good looks like
Good digital safeguarding is not “remove the device” or “ban the app.” It is a structured, person-centred approach that documents consent and capacity in context, uses least-restrictive options, and demonstrates learning and review. Providers that do this well can evidence safety, autonomy and defensible practice in a way that stands up to commissioner scrutiny and inspection.