D i ti f Lib t S f d (D LS)Deprivation of Liberty Safeguards (DoLS)Deprivation of Liberty Safeguards (DoLS)Deprivation of Liberty Safeguards (DoLS)Deprivation of Liberty Safeguards (DoLS)p y g ( )M d l 2 Slid 1Module 2: Slides 1Module 2: Slides 1Module 2: Slides 1Module 2: Slides 1

I d i D S l B k dIntroducing DoLS Legal BackgroundIntroducing DoLS Legal BackgroundIntroducing DoLS, Legal Background,Introducing DoLS, Legal Background, g , g g ,D fi iti P i i l d PDefinitions Principles and ProcessDefinitions Principles and ProcessDefinitions, Principles and ProcessDefinitions, Principles and Process, p

A ti l 5 (1)• Article 5 (1)• Article 5 (1)Article 5 (1)( )Right to liberty and security ofRight to liberty and security ofRight to liberty and security of g y y

N h ll b d i dperson No one shall be deprivedperson. No one shall be deprivedperson. No one shall be deprived f hi lib t ( ithof his liberty (with someof his liberty (with someof his liberty (with some y (

e ceptions)exceptions)exceptions)p )A ti l 5 (4)• Article 5 (4)• Article 5 (4)Article 5 (4) Ri ht t d t tRight to speedy access to a courtRight to speedy access to a courtRight to speedy access to a court g p yfor review of lawfulness offor review of lawfulness offor review of lawfulness of d t tidetentiondetentiondetention

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Th C t th f fi d th t thi b f• The Court therefore finds that this absence of• The Court therefore finds that this absence ofThe Court therefore finds that this absence of d l f d f il t t t i tprocedural safeguards fails to protect againstprocedural safeguards fails to protect againstprocedural safeguards fails to protect against p g p g

bit d i ti f lib t d farbitrary deprivations of liberty on grounds ofarbitrary deprivations of liberty on grounds ofarbitrary deprivations of liberty on grounds of y p y git d tl t l ithnecessity and consequently to comply withnecessity and consequently to comply withnecessity and, consequently, to comply with ecess y a d, co seque y, o co p y

f (1) fthe essential purpose of Article 5(1) of thethe essential purpose of Article 5(1) of thethe essential purpose of Article 5(1) of thethe essential purpose of Article 5(1) of the ConventionConventionConventionConvention

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I h i t th C t l d• In such circumstances the Court concludes• In such circumstances the Court concludesIn such circumstances, the Court concludes ,th t it h t b d t t d th t ththat it has not been demonstrated that thethat it has not been demonstrated that thethat it has not been demonstrated that the

li t h d il bl t hi dapplicant had available to him a procedureapplicant had available to him a procedureapplicant had available to him a procedure pp phi h ti fi d th i t f A ti lwhich satisfied the requirements of Articlewhich satisfied the requirements of Articlewhich satisfied the requirements of Article q

5(4) f th C ti Th h b5(4) of the Convention There has been5(4) of the Convention There has been5(4) of the Convention. There has been ( )h f i l i f hi i itherefore a violation of this provisiontherefore a violation of this provisiontherefore a violation of this provisiontherefore a violation of this provision

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I d t d t i h th th h b• In order to determine whether there has been a• In order to determine whether there has been aIn order to determine whether there has been a d i ti f lib t th t ti i t t bdeprivation of liberty the starting point must bedeprivation of liberty the starting-point must bedeprivation of liberty, the starting point must be p y, g ph i i f h i di id l dthe concrete situation of the individual concernedthe concrete situation of the individual concernedthe concrete situation of the individual concernedthe concrete situation of the individual concerned Account must be taken of a whole range of• Account must be taken of a whole range of• Account must be taken of a whole range ofAccount must be taken of a whole range of gf t i i i ti l h thfactors arising in a particular case such as thefactors arising in a particular case such as thefactors arising in a particular case such as the g pt d ti ff t d ftype duration effects and manner oftype, duration, effects and manner oftype, duration, effects and manner of ypi l t ti f th i tiimplementation of the measure in questionimplementation of the measure in questionimplementation of the measure in questionp qTh di ti ti b t d i ti f d• The distinction between a deprivation of and• The distinction between a deprivation of andThe distinction between a deprivation of, and p ,

t i ti lib t i l f drestriction upon liberty is merely one of degree orrestriction upon liberty is merely one of degree orrestriction upon, liberty is merely one of degree or p , y y gi t it d t f t b tintensity and not one of nature or substanceintensity and not one of nature or substanceintensity and not one of nature or substancey

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(1979 80) 2 EHRR 387 ECHR(1979-80) 2 EHRR 387 ECHR(1979 80) 2 EHRR 387 ECHR

Mental disorder established by objective• Mental disorder established by objective• Mental disorder established by objectiveMental disorder established by objective y jdi l timedical expertisemedical expertisemedical expertise p

Di d t l fi t• Disorder warrants compulsory confinement• Disorder warrants compulsory confinementDisorder warrants compulsory confinement p yC ti d fi t d d• Continued confinement depends on• Continued confinement depends onContinued confinement depends on p

i t f di dpersistence of disorderpersistence of disorderpersistence of disorderp

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C i t f i 2000• Came into force in 2000• Came into force in 2000Came into force in 2000 CIncorporates the European Convention on• Incorporates the European Convention on• Incorporates the European Convention onIncorporates the European Convention on

Human Rights into UK lawHuman Rights into UK lawHuman Rights into UK lawHuman Rights into UK law gR i UK t t k li ECHR• Requires UK court to make rulings on ECHR• Requires UK court to make rulings on ECHRRequires UK court to make rulings on ECHR q gi htrightsrightsrights g

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P t d it f t d• Powers to admit for assessment and• Powers to admit for assessment andPowers to admit for assessment and S i 2 3 4treatment Sections 2 3 4 5treatment Sections 2 3 4 5treatment Sections 2, 3, 4, 5treatment Sections 2, 3, 4, 5

Guardianship Section 7• Guardianship Section 7• Guardianship Section 7Guardianship Section 7 pS i d C it T t t S ti• Supervised Community Treatment Section• Supervised Community Treatment SectionSupervised Community Treatment Section p y17A17A17A17A

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A ti f i l f (• Anyone acting as a professional for (or• Anyone acting as a professional for (orAnyone acting as a professional for (or y g p (l d t f t f ) ith temployed to perform acts for) a person withoutemployed to perform acts for) a person withoutemployed to perform acts for) a person without p y p ) p

it t h d t th M t lcapacity must have regard to the Mentalcapacity must have regard to the Mentalcapacity must have regard to the Mental p y gC it A t C d f P tiCapacity Act Code of PracticeCapacity Act Code of PracticeCapacity Act Code of Practice p yTh i l C d f P ti t D LS• There is also a Code of Practice to cover DoLS• There is also a Code of Practice to cover DoLSThere is also a Code of Practice to cover DoLS Th M t l H lth A t C d f P ti• The Mental Health Act Code of Practice• The Mental Health Act Code of Practice• The Mental Health Act Code of Practice e e a ea c Code o ac ce

fcontains guidance on the use of MHAcontains guidance on the use of MHAcontains guidance on the use of MHAcontains guidance on the use of MHA provisionsprovisionsprovisionsprovisions p

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Th D LS d i t d d t k• The DoLS procedures are intended to make• The DoLS procedures are intended to makeThe DoLS procedures are intended to make pE li h d W l h l tibl ith thEnglish and Welsh law compatible with theEnglish and Welsh law compatible with theEnglish and Welsh law compatible with the g pECHRECHRECHRECHR P f i l i l t ith l l ki• Professional involvement with people lacking• Professional involvement with people lackingProfessional involvement with people lacking p p g

it i l t d b th M t l C itcapacity is regulated by the Mental Capacitycapacity is regulated by the Mental Capacitycapacity is regulated by the Mental Capacity p y g y p yAActActActAct

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P l d 18 h d i d f• People aged 18 or over who are deprived of• People aged 18 or over who are deprived ofPeople aged 18 or over who are deprived of p g pth i lib t th itheir liberty so they may receive care ortheir liberty so they may receive care ortheir liberty so they may receive care or y y yt t t i h it l h dtreatment in hospitals or care homes andtreatment in hospitals or care homes andtreatment in hospitals or care homes andp

fPeople who lack capacity as a result of• People who lack capacity as a result of• People who lack capacity as a result ofPeople who lack capacity as a result of mental disorder to consent to themental disorder to consent to themental disorder to consent to themental disorder to consent to the

t darrangements andarrangements andarrangements andgC t t t i i th i B t• Care or treatment is necessary in their Best• Care or treatment is necessary in their BestCare or treatment is necessary in their Best yI t t d th M t l H lth A tInterests and the Mental Health ActInterests and the Mental Health ActInterests and the Mental Health Act

i t t trequirements are not metrequirements are not metrequirements are not metq

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Th bilit t k d i i• The ability to make a decision• The ability to make a decisionThe ability to make a decision yC it i d i i ifi• Capacity is decision specific• Capacity is decision-specificCapacity is decision specificp y pL f it b t• Loss of capacity may be temporary• Loss of capacity may be temporaryLoss of capacity may be temporaryp y y p yPh i l diti h l ti• Physical conditions such as location can• Physical conditions such as location canPhysical conditions, such as location, can y , ,ff t ’ itaffect a person’s capacityaffect a person s capacityaffect a person s capacity a ec a pe so s capac y

fYou cannot assume lack of capacity because• You cannot assume lack of capacity because• You cannot assume lack of capacity becauseYou cannot assume lack of capacity because of a person’s age ph sical appearanceof a person’s age physical appearanceof a person s age, physical appearance,of a person s age, physical appearance, p g p y pp

diti t f th i b h icondition or an aspect of their behaviourcondition or an aspect of their behaviourcondition or an aspect of their behaviour p

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A ti f it• Assumption of capacity• Assumption of capacityAssumption of capacity p p yAll ti bl t t h l• All practicable steps to help• All practicable steps to helpAll practicable steps to help p p pU i d i i d t i it• Unwise decisions do not mean incapacity• Unwise decisions do not mean incapacityUnwise decisions do not mean incapacity p yA t /d i i t b i b t i t t• Acts/decisions must be in best interests• Acts/decisions must be in best interestsActs/decisions must be in best interests

( )Less restrictive alternative(s) have to be• Less restrictive alternative(s) have to be• Less restrictive alternative(s) have to beLess restrictive alternative(s) have to be consideredconsideredconsideredconsidered

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Th i i l d fi iti f d i ti f lib t• There is no simple definition of deprivation of liberty• There is no simple definition of deprivation of libertyThere is no simple definition of deprivation of liberty p p yTh ti f h th th t t k b t ff• The question of whether the steps taken by staff or• The question of whether the steps taken by staff orThe question of whether the steps taken by staff or q p yi tit ti i l ti t t tinstitutions in relation to a person amount to ainstitutions in relation to a person amount to ainstitutions in relation to a person amount to a pd i ti f th t ’ lib t i lti t ldeprivation of that person’s liberty is ultimately adeprivation of that person s liberty is ultimately adeprivation of that person s liberty is ultimately a dep at o o t at pe so s be ty s u t ate y alegal question and only the courts can determinelegal question and only the courts can determinelegal question, and only the courts can determinelegal question, and only the courts can determine the lawthe lawthe lawthe law (D LS C d f P ti Ch t 2)(DoLS Code of Practice Chapter 2)(DoLS Code of Practice Chapter 2)(DoLS Code of Practice Chapter 2)( p )

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Restraint is used including sedation to admit a• Restraint is used including sedation to admit a• Restraint is used, including sedation, to admit aRestraint is used, including sedation, to admit a gh i i tiperson who is resistingperson who is resistingperson who is resisting p g

St ff i l t d ff ti t l• Staff exercise complete and effective control over• Staff exercise complete and effective control overStaff exercise complete and effective control over pd t f i ifi t i dcare and movement for a significant periodcare and movement for a significant periodcare and movement for a significant period g p

St ff i t l t t t t• Staff exercise control over assessments treatment• Staff exercise control over assessments treatmentStaff exercise control over assessments, treatment, , ,t t d idcontacts and residencecontacts and residencecontacts and residence

A d i i h b t k th t th ld b• A decision has been taken that the person would be• A decision has been taken that the person would beA decision has been taken that the person would be pd f l i if h d i f lprevented from leaving if they made a meaningfulprevented from leaving if they made a meaningfulprevented from leaving if they made a meaningfulprevented from leaving if they made a meaningful

attempt to do soattempt to do soattempt to do soattempt to do so

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A t b f th t b• A request by carers for the person to be• A request by carers for the person to beA request by carers for the person to be q y pdi h d t th i h b f ddischarged to their care has been refuseddischarged to their care has been refuseddischarged to their care has been refusedgTh i bl t i t i i l t t• The person is unable to maintain social contacts• The person is unable to maintain social contactsThe person is unable to maintain social contacts pb f t i ti l d tbecause of restrictions placed on access tobecause of restrictions placed on access tobecause of restrictions placed on access to pth lother peopleother peopleother people p p

Th h l t t b th• The person has lost autonomy because they• The person has lost autonomy because theyThe person has lost autonomy because they p y yd i i i d lwere under continuous supervision and controlwere under continuous supervision and controlwere under continuous supervision and control e e u de co t uous supe s o a d co t o

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Cheshire West & Chester P [2011]Cheshire West & Chester v P [2011]Cheshire West & Chester v P [2011]Cheshire West & Chester v P [2011] [ ]EWCA Ci 1333EWCA Civ 1333EWCA Civ 1333EWCA Civ 1333EWCA Civ 1333

I d t i i h th t th d i ti• In determining whether or not there was a deprivation• In determining whether or not there was a deprivationIn determining whether or not there was a deprivation g pf lib t it l iti t t h d b th thof liberty it was legitimate to have regard both theof liberty, it was legitimate to have regard both theof liberty, it was legitimate to have regard both the y g gbj ti “ ” h l d dobjective “reason” why someone was placed andobjective reason why someone was placed andobjective reason why someone was placed and j y p

t t d th d l th bj ti “ ”treated as they were and also the objective “purpose”treated as they were and also the objective purposetreated as they were and also the objective purpose y j“ i ” f th l t F d lt ith di bilitior “aim” of the placement For adults with disabilitiesor aim of the placement. For adults with disabilities,or aim of the placement. For adults with disabilities,

h li di t t d b th i iti dwhose lives were dictated by their own cognitive andwhose lives were dictated by their own cognitive andwhose lives were dictated by their own cognitive and th li it ti th ti h th th h d bother limitations the question whether they had beenother limitations, the question whether they had beenother limitations, the question whether they had been

d i d f lib t f ll t b d t i d b ideprived of liberty fell to be determined by comparingdeprived of liberty fell to be determined by comparingdeprived of liberty fell to be determined by comparing th i it ti ith th t f d lt f i il iththeir situation with that of an adult of similar age withtheir situation with that of an adult of similar age with e s ua o a o a adu o s a agethe same capabilities affected b the same conditionthe same capabilities affected by the same conditionthe same capabilities, affected by the same condition p , yor suffering the same inherent mental and physicalor suffering the same inherent mental and physicalor suffering the same inherent mental and physical g p ydisabilities and limitationsdisabilities and limitationsdisabilities and limitations.

M i i lib t d t• Maximise liberty and autonomy• Maximise liberty and autonomyMaximise liberty and autonomy y yP t d• Person centred care• Person centred carePerson centred care I l t f f il f i d d• Involvement of family friends and carers• Involvement of family friends and carersInvolvement of family, friends and carers y,Mi i i i iMinimise restrictions• Minimise restrictions• Minimise restrictionsMinimise restrictions Review frequently• Review frequently• Review frequentlyReview frequently q y

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O er ie of Depri ation of Libert Safeg ardsOverview of Deprivation of Liberty SafeguardsOverview of Deprivation of Liberty Safeguardsp y gHospital or care home managers identify thoseHospital or care home managers identify those

t i k f d i ti f lib t d tat risk of deprivation of liberty and request p y qauthorisation from supervisory body In urgent situationsauthorisation from supervisory body In urgent situations,

a hospital or carea hospital or care home can give anAssessment commissioned by home can give an Assessment commissioned by

i b d IMCA i t t d urgent authorisationsupervisory body. IMCA instructed urgent authorisation f d

p y yfor anyone without representation for seven days for anyone without representation y

while obtaining aAge No refusals while obtaining a Age t

No refusals t standardassessment assessment standard

th i tiauthorisation

EligibilityMental health Eligibility Mental health Mental capacity B t i t t assessmentassessment Mental capacity Best interests assessment assessment

assessment assessmentassessment assessment

Authorisation expires andAuthorisation expires and Any assessment All assessmentsmanaging authority Any assessment All assessments

support authorisationmanaging authority

t f th says no support authorisationrequests further says noqauthorisationauthorisation

Best interests assessor recommends Best interestsBest interests assessor recommends i d f hi h d i ti f lib tRequest for

Best interests period for which deprivation of liberty Request for assessor p p y

should be authorisedauthorisation declinedassesso

recommendsshould be authorisedauthorisation declined recommends person to beperson to be

i t dappointed as pprepresentativeAuthorisation is given and representativeAuthorisation is given and

’ t ti i t d Person or theirperson’s representative appointed Person or their p p pprepresentativerepresentative

l t C tappeals to Court ppof Protection

Authorisation implemented byof Protection

Authorisation implemented by which has powersp ymanaging authority

which has powers to terminatemanaging authority to terminate

authorisation orauthorisation or ditivary conditionsy

M i th it t P th iDeprivation of Liberty Managing authority requests Person or their Deprivation of Liberty g g y qreview because circumstances representative requestsSafeguards Code of Practice review because circumstances representative requests g

October 2008 change reviewOctober 2008 change review

19R i 19Review 19Review

M i th itManaging authorityManaging authorityManaging authority g g yNHS h it l• NHS hospital• NHS hospitalNHS hospital pb d ibl f th i f thbody responsible for the running of the– body responsible for the running of thebody responsible for the running of the y p gh it lhospitalhospitalhospital pP i h i l hPrivate hospital or care home• Private hospital or care home• Private hospital or care homePrivate hospital or care home person registered or required to be– person registered or required to be– person registered, or required to beperson registered, or required to be p g q

i t d d P t 2 f th Cregistered under Part 2 of the Careregistered, under Part 2 of the Careregistered, under Part 2 of the Care gSt d d A t 2000Standards Act 2000Standards Act 2000Standards Act 2000

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S i b d f h it lSupervisory body for hospitalsSupervisory body for hospitalsSupervisory body for hospitals p y y pIf PCT i i th l tIf a PCT commissions the relevant care or– If a PCT commissions the relevant care orIf a PCT commissions the relevant care or t t t th t PCTtreatment that PCTtreatment that PCTtreatment, that PCT ,If th N ti l A bl f W l L lIf the National Assembly for Wales or a Local– If the National Assembly for Wales or a LocalIf the National Assembly for Wales or a Local yH l h B d i W l i i hHealth Board in Wales commission theHealth Board in Wales commission theHealth Board in Wales commission theHealth Board in Wales commission the relevant care and treatment in England therelevant care and treatment in England therelevant care and treatment in England, therelevant care and treatment in England, the gNational Assembl for WalesNational Assembly for WalesNational Assembly for WalesNational Assembly for Wales yI th th PCT f th i• In any other case the PCT for the area in• In any other case, the PCT for the area inIn any other case, the PCT for the area in y

hi h th h it l i it t dwhich the hospital is situatedwhich the hospital is situatedwhich the hospital is situated p

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S i b d f hSupervisory body for care homesSupervisory body for care homesSupervisory body for care homes p y yL l th it f th i hi h thLocal authority for the area in which the– Local authority for the area in which theLocal authority for the area in which the y

i di il id tperson is ordinarily residentperson is ordinarily residentperson is ordinarily residentp yH if th i t di il• However if the person is not ordinarily• However if the person is not ordinarilyHowever, if the person is not ordinarily, p y

id i h f l l h i hresident in the area of a local authority theresident in the area of a local authority theresident in the area of a local authority, theresident in the area of a local authority, the supervisory body is the local authority for thesupervisory body is the local authority for thesupervisory body is the local authority for thesupervisory body is the local authority for the y y yarea in hich the care home is sit atedarea in which the care home is situatedarea in which the care home is situatedarea in which the care home is situated

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M i th it t t d d• Managing authority requests standard• Managing authority requests standardManaging authority requests standard g g y qth i ti f i b d (iauthorisation from supervisory body (inauthorisation from supervisory body (inauthorisation from supervisory body (in p y y (

d f d i ti f lib t )advance of deprivation of liberty)advance of deprivation of liberty)advance of deprivation of liberty) p y)U t th i ti i th it• Urgent authorisation managing authority• Urgent authorisation – managing authorityUrgent authorisation managing authority g g g y

th l th i f t 7 dcan themselves authorise for up to 7 dayscan themselves authorise for up to 7 days –can themselves authorise for up to 7 days p yi b d t d thi f f th 7supervisory body may extend this for further 7supervisory body may extend this for further 7supervisory body may extend this for further 7 p y y y

daysdaysdaysdays IMCA appointed (if necessary)• IMCA appointed (if necessary)• IMCA appointed (if necessary)IMCA appointed (if necessary) pp ( y)

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A t *• Age assessment *• Age assessmentAge assessment gN f l t *• No refusals assessment *• No refusals assessmentNo refusals assessment M t l it t *• Mental capacity assessment *~• Mental capacity assessment ~Mental capacity assessment p yM t l h lth t• Mental health assessment ~• Mental health assessment ~Mental health assessment Eli ibilit t *• Eligibility assessment *~• Eligibility assessment *~Eligibility assessment g yB t i t t t *• Best interests assessment *• Best interests assessment *Best interests assessment

*Can be done by best interests assessor*Can be done by best interests assessorCan be done by best interests assessor ~Can be done by mental health assessor~Can be done by mental health assessorCan be done by mental health assessor

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St d d th i ti t t b• Standard authorisation assessments must be• Standard authorisation assessments must beStandard authorisation assessments must be l t d i 21 d f t b icompleted in 21 days of a request beingcompleted in 21 days of a request beingcompleted in 21 days of a request being p y q g

i dreceivedreceivedreceived If i t i b d i• If appropriate supervisory body may issue• If appropriate supervisory body may issueIf appropriate supervisory body may issue pp p p y y y

th i ti f t 12 thauthorisation for up to 12 monthsauthorisation for up to 12 monthsauthorisation for up to 12 months pS i b d tt h diti• Supervisory body may attach conditions• Supervisory body may attach conditionsSupervisory body may attach conditions p y y yS i b d i i• Supervisory body must give notice to• Supervisory body must give notice to• Supervisory body must give notice toSupervisory body must give notice to specified peoplespecified peoplespecified peoplespecified people

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S i b d i t l t ’• Supervisory body appoints relevant person’s• Supervisory body appoints relevant person sSupervisory body appoints relevant person s p y y pp pt tirepresentativerepresentativerepresentative p

IMCA l t th i t ti• IMCA relevant person or their representative• IMCA relevant person or their representativeIMCA, relevant person or their representative , p pt i f th imay request a review from the supervisorymay request a review from the supervisorymay request a review from the supervisory y q p y

b d ibody at any timebody at any timebody at any timebody at any time If dissatisfied they make seek review by the• If dissatisfied they make seek review by the• If dissatisfied they make seek review by theIf dissatisfied they make seek review by the y yCo rt of ProtectionCourt of ProtectionCourt of ProtectionCourt of Protection At i i th it k• At expiry managing authority may seek• At expiry managing authority may seekAt expiry managing authority may seek p y g g y y

l id d it i till trenewal provided criteria are still metrenewal provided criteria are still metrenewal, provided criteria are still met , p

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C it i d fi d i th M t l C it A t• Capacity is defined in the Mental Capacity Act• Capacity is defined in the Mental Capacity ActCapacity is defined in the Mental Capacity Actp y p yD i ti f Lib t (D L) i l l t• Deprivation of Liberty (DoL) is a legal concept case• Deprivation of Liberty (DoL) is a legal concept – caseDeprivation of Liberty (DoL) is a legal concept case p y ( ) g plaw will help in clarifying when DoL is taking placelaw will help in clarifying when DoL is taking placelaw will help in clarifying when DoL is taking placelaw will help in clarifying when DoL is taking placeE ff t h ld b d t id D i ti f• Every effort should be made to avoid Deprivation of• Every effort should be made to avoid Deprivation ofEvery effort should be made to avoid Deprivation of y pLib tLibertyLibertyLiberty yP l ith t it h d itt d t h it l• People without capacity who are admitted to hospitals• People without capacity who are admitted to hospitalsPeople without capacity who are admitted to hospitals or care homes should be regularly reviewed to checkor care homes should be regularly reviewed to checkor care homes should be regularly reviewed to check g y

h th D L i iwhether DoL is occurringwhether DoL is occurringwhether DoL is occurring gWh D L i i thi d t b f ll• sWhere DoL is occurring this needs to be formally• sWhere DoL is occurring this needs to be formallysWhere DoL is occurring this needs to be formally g y

th i dauthorisedauthorisedauthorised

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