Information Governance, Consent and Data Security in Ageing Well Technology and Telecare
Strong information governance is a non-negotiable foundation for technology, telecare and digital support for ageing well. It is also a common fault line when digital solutions are introduced quickly in response to rising demand, hospital discharge pressure or falls risk. The challenge becomes sharper when technology sits within dementia service models and care pathways, where capacity may fluctuate and “agreement” is not the same as informed consent.
Providers need to show, in day-to-day records and governance, that technology is used lawfully, proportionately and safely. This is not primarily a legal exercise; it is operational practice: how consent is gained, how decisions are reviewed, and how data is protected in real delivery conditions.
What good looks like: consent and data protection as operational routines
In ageing well services, technology frequently involves collecting and sharing personal data: movement patterns, alerts, location, wellbeing check-ins, call logs, and responses. Providers should be able to evidence:
- Why the technology is being used (the purpose and intended outcomes)
- How consent was gained, or how a best-interests decision was made
- Who can access data, and how access is controlled
- How risk is managed when technology fails or is misused
- How the decision is reviewed over time as needs and capacity change
Operational example 1: consent and best-interests decisions for location-enabled devices
Context: A provider supported an older person with dementia who repeatedly left home at night and became disorientated. Family members requested a location-enabled device. Staff were unsure whether the person had capacity to consent and how to evidence a lawful decision.
Support approach: The provider treated the decision as part of support planning, not an informal family agreement. Capacity was assessed in relation to the specific decision (use of a location-enabled device), with input from the GP and community mental health team where appropriate.
Day-to-day delivery detail: Where capacity was lacking, a best-interests decision was completed with documented alternatives considered (increased night support, environmental changes, door sensors without tracking). Staff recorded why the chosen option was proportionate and least restrictive. The care plan included practical guidance on how staff use the data (only when risk thresholds are met) and how to respond without escalating distress.
Evidencing effectiveness: The provider evidenced reduced missing-person incidents and fewer police call-outs, while also demonstrating that use of tracking was time-limited and reviewed. Governance minutes showed periodic review of restrictions, with clear rationale for continuation or step-down.
Operational example 2: preventing inappropriate access to telecare data
Context: A service used a telecare platform that allowed multiple staff to view dashboards. During an audit, managers found access logs were unclear and there was risk of staff viewing information outside their caseload.
Support approach: The provider implemented role-based access controls aligned to job function and caseload. Access rights were tied to HR onboarding and removed immediately on role change or exit.
Day-to-day delivery detail: Team leaders completed monthly access checks as part of supervision. A short “minimum necessary” protocol was introduced: staff only open records for people they are supporting that day or where they are responding to a live alert. Spot checks tested whether staff could explain lawful basis and appropriate use.
Evidencing effectiveness: Audit outcomes improved, access logs became defensible, and the provider could evidence consistent control of sensitive data. Incidents of inappropriate access reduced to zero and were reported through governance as a measurable control.
Operational example 3: managing device failure and safeguarding risk
Context: An older person with falls risk relied on a pendant alarm. One night, the device failed due to low battery and the person was found on the floor the next morning. The incident exposed gaps in battery monitoring, escalation, and communication with family.
Support approach: The provider treated device reliability as a quality and safety risk, not a technical inconvenience. A device-check routine was added to care delivery, and responsibilities were clarified (who checks, how often, what is recorded).
Day-to-day delivery detail: Battery checks were embedded into visit notes with a simple “check and confirm” field. Where low battery was identified, staff followed a defined escalation route: immediate replacement request, interim risk controls (additional welfare checks), and notification to the person and family. Managers reviewed failure incidents through governance, including whether the technology created false reassurance.
Evidencing effectiveness: The provider evidenced fewer device-failure incidents, faster replacement times, and a clear audit trail showing escalation and interim risk controls. The learning was embedded into training and supervision, with competence checks.
Commissioner expectation
Commissioner expectation: Commissioners expect providers to demonstrate lawful and proportionate use of technology, with clear evidence of consent and capacity processes, robust data security controls, and incident management arrangements when technology fails. They will also expect providers to show that data is used to improve outcomes and reduce risk, not simply collected.
Regulator expectation (CQC)
Regulator / Inspector expectation (CQC): The CQC will expect providers to show that technology is used in a person-centred way, aligned to consent and human rights, and supported by robust governance. Inspectors will look for evidence that people understand what technology does, that best-interests decisions are recorded where required, and that providers manage digital risks (including data security and device reliability) through assurance and learning.
Governance and assurance mechanisms that stand up under scrutiny
Providers strengthen defensibility by building a small number of repeatable controls that generate reliable evidence:
- Decision records: a consistent template for consent, capacity and best-interests decisions for technology use
- Access controls: role-based permissions, access logging, and periodic checks
- Incident pathways: defined escalation routes for device failure, missed alerts and data breaches
- Review rhythm: scheduled reassessment of whether technology remains necessary, proportionate and least restrictive
The aim is not to create bureaucracy. It is to ensure technology-enabled care remains safe, trusted and auditable in real delivery conditions.