Ceredigion County Council website

Our Integrated Impact Assessment is designed to help our decision making and ensure that a proposal:

• is aligned to the Council’s Corporate Well-being Objectives
• complies with the Equality Act 2010, including our socio-economic duty
• complies with the Welsh Language Measure 2011 (Welsh Language requirements)
• contributes to the National Well-being goals of the Well-being of Future Generations (Wales) Act 2015 and incorporates the principles of Sustainable Development
• considers risk management

The Integrated Impact Assessment is categorised into the 7 National Well-being Goals for Wales:

1. A prosperous Wales – where everyone has jobs and there is no poverty
2. A resilient Wales – where we’re prepared for things like floods
3. A healthier Wales – where everyone is healthier and can see the doctor when they need to
4. A more equal Wales – where everyone has an equal chance whatever their background
5. A Wales of cohesive communities – where communities can live happily together
6. A Wales of vibrant culture and thriving Welsh language – where we have lots of opportunities to do different things and where people can speak Welsh if they want to
7. A globally responsible Wales – where we look after the environment and think about other people around the world

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Proposal Details

Title of Policy / Proposal / Initiative

• Draft Positive Behaviour Support and Reducing Restrictive Practice Policy.

Service Area

• Porth Gofal, Direct Services.

Officer completing Integrated Impact Assessment

• Nerys Lewis.

Corporate Lead Officer

• Donna Pritchard.

Please give a brief description of the purpose of the proposal

The proposal introduces a corporate Positive Behaviour Support (PBS) and Reducing Restraint (RR) Policy that aligns with the Welsh Government’s Reducing Restrictive Practices Framework. The purpose is to strengthen safeguarding, enhance person centred practice and embed a consistent organisational approach to preventing and de-escalating behaviours of concern across Social Care, Education and Through Age Wellbeing services.

This policy ensures consistency, dignity, human rights and evidence-based approaches across all settings.

Who will be directly affected by this proposal?

• Children, young people and adults across Social Care, Education and commissioned services.  
• Families, carers, advocates and circles of support. 
• Staff in Direct Services, Learning & Development, Education, residential provision, TAW services and commissioned partners. 
• Multi-disciplinary teams including health, behavioural specialists, and keyworkers. 

Have those who will be affected by the proposal had the opportunity to comment on it? Please provide details.

The policy was co-developed with Education, Through Age Wellbeing (TAW), People & Organisation, and external practice specialists. It was reviewed through TAW, Programme Board and Leadership Group.  

Early engagement with schools, residential care, educational inclusion, SDS, workforce development 

A public consultation will take place June-August 2026.

 

Version Control

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Council Corporate Well-being Objectives

Which of the Council’s Corporate Well-being Objectives does this proposal address and how?

Ceredigion Council Corporate Strategy 2022-27

Boosting the economy, supporting business, and enabling employment

• Builds a trained, confident, safe workforce.
• Reduces staff injury, stress and turnover through preventative practice.
• Encourages a consistent skills pathway and professional development. 

Creating caring and healthy communities

• Safeguarding wellbeing and human rights.
• Reduces the use and harm of restrictive practices.
• Improves quality of life and health outcomes for vulnerable people.

Providing the best start in life and enabling learning at all ages

• Ensures consistency across schools, Pupil Referral Units, Children Services and Education inclusions.
• Supports trauma informed practice and de-escalation in learning environments.

Creating sustainable, greener, and well-connected communities

• Reduces crisis escalation requiring out of county placements.
• Support resilient families and community based preventative work. 

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National Well-being Goal: A Prosperous Wales

An innovative, productive, and low carbon society where everyone has decent work and there is no poverty.

Does the proposal contribute to this goal? Describe the positive or negative impacts.

 

Positive. A consistent PBS approach reduces crisis placements, improves workforce confidence, minimises injury/absence, and supports efficient use of resources across Education and Social Care. Preventative strategies reduce high-cost reactive responses.  

What evidence do you have to support this view?

• Workforce development and PBS competency framework.
• Plan for training and quality assurance 

What action(s) can you take to mitigate any negative impacts or better contribute to this National Well-being Goal?

• Embed a consistent and mandatory PBS/PBM training across roles.
• Develop in house PBM/S coordinator role to reduce commissioning costs.
• Maintain ongoing reflective practice, supervision and data monitoring 

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National Well-being Goal: A Resilient Wales

A society where biodiversity is maintained and enhanced and where ecosystems are healthy and functioning.

Does the proposal contribute to this goal? Describe the positive or negative impacts.

Positive. Reducing crisis interventions and restrictive practices leads to more stable environments, healthier ecosystems of support and reduced reliance on emergency services.

What evidence do you have to support this view?

• Preventative PBS framework.
• Supporting sustained community placements.
• Practice leadership model reducing escalation. 

What action(s) can you take to mitigate any negative impacts or better contribute to this National Well-being Goal?

• Maintain behaviour monitoring tools and early warning systems.
• Strengthen MDT and cross service collaboration pathways.  

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National Well-being Goal: A Healthier Wales

A society where people make healthy choices and enjoy good physical and mental health.

Does the proposal contribute to this goal? Describe the positive or negative impacts.

Strongly positive. PBS is associated with improved mental and physical wellbeing, reduced distress, and improved stability in care and school settings.  

What evidence do you have to support this view?

• Reduction in psychological/physical harm associated with restraint.
• Welsh Government’s RR Framework.
• Evidence from PBS plans and individual outcome reports

What action(s) can you take to mitigate any negative impacts or better contribute to this National Well-being Goal?

• Ensure trauma informed, rights-based practice training for all staff.
• Strengthen debriefing, supervision and reflective practice.
• Promote co-production with individuals and families.

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National Well-being Goal: A More Equal Wales

A society where everyone has an equal chance whatever their background or circumstances.

This section is longer because you are asked to assess the impact of your proposal on each group that is protected by the Equality Act 2010.

If you have identified no greater impact on the groups listed than on the general population, you should select ‘None/Negligible’.

Do you think this proposal will have a positive or a negative impact on people because of their age?

 

Children and Young People up to 18

• Positive

People 18-50

• Positive

Older people 50+

• Positive

Describe the positive or negative impacts.

Reduces harm and promotes dignity, safety and consistency across children, working-age adults and older people.

What evidence do you have to support this?

• Equality duties reflect in the policy.
• Person centred PBS plan model 

What action(s) can you to take to mitigate any negative impacts?

Is there an opportunity to use this proposal to eliminate unlawful discrimination, advance equality of opportunity or encourage good relations between people in this group and the rest of the population?

• On-going workforce training on equality, rights and neurodiversity.
• Co-production and regular engagement with those affected.
• Monitoring of incidents by protected characteristics

Do you think this proposal will have a positive or a negative impact on people because of their disability?

 

Hearing Impairment

• Positive

Physical Impairment

• Positive

Visual Impairment

• Positive

Learning Disability

• Positive

Long Standing Illness

• Positive

Mental Health

• Positive

Describe the positive or negative impacts.

Due to person centred, communication focused preventative approaches.

What evidence do you have to support this?

• Equality duties reflect in the policy.
• Person centred PBS plan model.

What action(s) can you to take to mitigate any negative impacts?

Is there an opportunity to use this proposal to eliminate unlawful discrimination, advance equality of opportunity or encourage good relations between people in this group and the rest of the population?

• On-going workforce training on equality, rights and neurodiversity.
• Co-production and regular engagement with those affected.
• Monitoring of incidents by protected characteristics

Do you think this proposal will have a positive or a negative impact on people who are transgender?

 

Trans Women

• None / Negligible

Trans Men

• None / Negligible

Non-binary people

• None / Negligible

Describe the positive or negative impacts

The policy strengthens equality, rights and non-discrimination.

What evidence do you have to support this?

• Equality duties reflect in the policy.
• Person centred PBS plan model.

What action(s) can you to take to mitigate any negative impacts?

Is there an opportunity to use this proposal to eliminate unlawful discrimination, advance equality of opportunity or encourage good relations between people in this group and the rest of the population?

• On-going workforce training on equality, rights and neurodiversity.
• Co-production and regular engagement with those affected.
• Monitoring of incidents by protected characteristics.

Do you think this proposal will have a positive or a negative impact on people with different sexual orientation?

 

Bisexual

• None / Negligible

Gay Men

• None / Negligible

Gay Women/Lesbian

• None / Negligible

Heterosexual/Straight

• None / Negligible

Describe the positive or negative impacts

The policy strengthens equality, rights and non-discrimination.

What evidence do you have to support this?

• Equality duties reflect in the policy.
• Person centred PBS plan model.

What action(s) can you to take to mitigate any negative impacts?

Is there an opportunity to use this proposal to eliminate unlawful discrimination, advance equality of opportunity or encourage good relations between people in this group and the rest of the population?

• On-going workforce training on equality, rights and neurodiversity.
• Co-production and regular engagement with those affected.
• Monitoring of incidents by protected characteristics.

Do you think this proposal will have a positive or a negative impact on people who are married or in a civil partnership?

 

People who are married

• None / Negligible

People in a civil partnership

• None / Negligible

Describe the positive or negative impacts

There is no evidence to suggest that the PBS and RR Policy impacts people differently because they are married or in a civil partnership. The policy applies universally and focuses on human rights, safeguarding, and consistent, person‑centred approaches to preventing restrictive practices. These benefits apply equally to all individuals regardless of marital status.

What evidence do you have to support this?

• The policy is based on equality duties, human rights principles and person‑centred practice, none of which identify marital or partnership status as a relevant factor influencing risk or the use of restrictive practices.
• No disproportionate impact has been identified through engagement with staff, services, unions or stakeholders.
• Policy expectations, training requirements, and de‑escalation approaches apply equally to all staff and service users irrespective of marital status.

What action(s) can you to take to mitigate any negative impacts?

Is there an opportunity to use this proposal to eliminate unlawful discrimination, advance equality of opportunity or encourage good relations between people in this group and the rest of the population?

• Continue providing training that embeds equality, rights and non‑discrimination across all workforce groups.
• Ensure co‑production and engagement opportunities are accessible to people of all marital or partnership statuses.
• Continue monitoring incident data by protected characteristics to ensure no indirect disadvantage emerges.
• Maintain opportunities for feedback to inform updates to training, practice leadership, and policy implementation.

Do you think this proposal will have a positive or a negative impact on people who are pregnant or on maternity leave?

 

Pregnancy

• None / Negligible

Maternity

• None / Negligible

Describe the positive or negative impacts

There is no evidence to suggest that the PBS and RR Policy impacts people differently because they are pregnant or on maternity leave. The policy is universal and focuses on safeguarding, rights based practice and consistent approaches to preventing restrictive practices. These benefits apply equally to all individuals regardless of pregnancy or maternity status. 

What evidence do you have to support this?

• The policy sets out organisational standards based on human rights, person‑centred practice and equality duties, none of which identify pregnancy or maternity as a factor influencing risk or the use of restrictive practices.
• No disproportionate impact on this group has been identified through engagement with services, staff, or stakeholders.
• Training expectations and de‑escalation approaches apply equally and do not create barriers for people who are pregnant or returning from maternity leave. 

What action(s) can you take to mitigate any negative impacts or better contribute to positive impacts?

• Ensure all staff including those pregnant or returning from maternity leave have equitable access to PBS/PBM training, refreshers, and supervision.
• Provide reasonable adjustments within training delivery (e.g., comfort breaks, seating options, scheduling flexibility) where needed.
• Continue to monitor incidents and workforce data by protected characteristic (including maternity) to ensure no indirect disadvantage emerges.
• Maintain inclusive co‑production opportunities so feedback from all staff groups can inform updates to training, practice leadership, and policy implementation. 

Do you think this proposal will have a positive or a negative impact on people because of their ethnic origin?

 

Asian / Asian British

• None / Negligible

Black / African / Caribbean / Black British

• None / Negligible

Mixed / Multiple Ethnic Groups

• None / Negligible

White

• None / Negligible

Other Ethnic Groups

• None / Negligible

Describe the positive or negative impacts

There is no evidence to suggest that the PBS and RR Policy impacts people differently on the basis of ethnic origin. The policy is universal, rights‑based, and grounded in person‑centred approaches. It strengthens equity, dignity and non‑discrimination by ensuring consistent standards, reducing harmful or restrictive practices, and promoting trauma‑informed practice that is applicable to all individuals regardless of ethnicity. The preventative, relational and communication‑focused nature of PBS supports fairness and reduces the risk of biased or inconsistent responses to behaviours of concern across diverse communities.

What evidence do you have to support this?

• The policy is aligned with the Equality Act 2010 and explicitly framed around equality, safeguarding, human rights and non‑discrimination.
• No disproportionate impacts relating to ethnic origin were identified during engagement with services, schools, unions or stakeholders.
• PBS is an evidence-based, person-centred framework that applies consistent principles regardless of cultural or ethnic background.
• Practice leadership, reflective supervision and monitoring arrangements help ensure that biases or inequities do not influence practice.

What action(s) can you to take to mitigate any negative impacts?

Is there an opportunity to use this proposal to eliminate unlawful discrimination, advance equality of opportunity or encourage good relations between people in this group and the rest of the population?

• Ensure ongoing equality, cultural awareness and anti‑discriminatory practice training is available and embedded across the workforce.
• Maintain co‑production and engagement opportunities with ethnically diverse groups to ensure experiences and cultural considerations are reflected in practice.
• Monitor incidents, restraint data and outcomes by protected characteristics to identify and address any emerging disparities.
• Ensure bilingual and accessible training materials, resources and plans are available, and ensure interpreters or culturally appropriate communication supports are used where needed.
• Strengthen workforce understanding of culturally informed behaviour patterns, needs and communication styles through reflective practice and supervision. 

Do you think this proposal will have a positive or a negative impact on people with different religions, beliefs, or non-beliefs?

 

Buddhist

• None / Negligible

Christian

• None / Negligible

Hindu

• None / Negligible

Humanist

• None / Negligible

Jewish

• None / Negligible

Muslim

• None / Negligible

Sikh

• None / Negligible

Non-belief

• None / Negligible

Describe the positive or negative impacts

There is no evidence to suggest that the PBS and RR Policy impacts people differently because of their religion, belief, or non‑belief. The policy is universal and grounded in human rights, dignity, and person‑centred practice. It does not introduce any practices, requirements, or expectations that conflict with religious or belief‑based needs. Its focus on consistent, preventative, ethical approaches supports equity and ensures individuals of all faith backgrounds (or none) are treated fairly and respectfully.

What evidence do you have to support this?

• The policy is aligned with the Equality Act 2010 and includes a commitment to non‑discrimination across all protected characteristics, including religion and belief.
• Engagement with staff, unions, schools, services and stakeholders has not identified any religious‑specific barriers or differential impacts.
• PBS is an evidence‑based model that emphasises respect, communication, personalisation and co‑production — all of which support the accommodation of individuals’ cultural, belief‑based or religious needs.
• Practice leadership and reflective supervision further support fair and unbiased practice.

What action(s) can you to take to mitigate any negative impacts?

Is there an opportunity to use this proposal to eliminate unlawful discrimination, advance equality of opportunity or encourage good relations between people in this group and the rest of the population?

• Ensure training on equality, culture and diversity includes religious awareness and respect for belief systems.
• Ensure PBS plans and behaviour support approaches recognise and integrate individuals’ religious or cultural preferences (e.g., routines, dress, dietary requirements, prayer times, holidays).
• Provide accessible communication and co‑production opportunities for individuals and families from diverse religious backgrounds.
• Continue monitoring data to identify and address any indirect or emerging disparities related to religion or belief.
• Use reflective practice and supervision to reinforce culturally sensitive and respectful behaviour‑support approaches.

Do you think this proposal will have a positive or a negative impact on men or women?

 

Men

• None / Negligible

Women

• None / Negligible

Describe the positive or negative impacts

There is no evidence to suggest that the PBS and RR Policy impacts men and women differently. The policy is universal, rights‑based and person‑centred. It focuses on reducing restrictive practices, improving safety, and strengthening safeguarding for all individuals regardless of sex. The approach emphasises consistency, dignity, early intervention and trauma‑informed practice, which benefits men and women equally across care, education and community settings.

What evidence do you have to support this?

• The policy is aligned with equality duties and human‑rights legislation, which require equitable treatment across all protected characteristics.
• Engagement with staff, unions, schools, residential settings and other stakeholders has not identified sex‑specific impacts.
• PBS is an evidence‑based framework that relies on understanding individual behaviour, communication and need—not demographic characteristics such as sex.
• Incident‑monitoring processes within PBS/PBM training and reflective practice frameworks support consistent application across men and women.

What action(s) can you to take to mitigate any negative impacts?

Is there an opportunity to use this proposal to eliminate unlawful discrimination, advance equality of opportunity or encourage good relations between men and women?

• Continue embedding equality, rights‑based and anti‑discriminatory practice training across the workforce.
• Ensure that staff understand and apply PBS approaches consistently, without assumptions linked to gendered behaviours.
• Continue monitoring incident and outcome data by protected characteristics (including sex) to identify and address any unequal patterns.
• Maintain accessible co‑production, feedback and consultation pathways so the experiences of both men and women inform policy review, training and practice leadership.

Do you think this proposal will have a positive or a negative impact on people from the Armed Forces Community?

Members of the Armed Forces

• None / Negligible

Veterans

• None / Negligible

Spouses

• None / Negligible

Children

• None / Negligible

Describe the positive or negative impacts

There is no evidence to suggest that the PBS and RR Policy impacts members of the Armed Forces community differently to the general population. The policy is universal and applies equally across all groups, focusing on safeguarding, human rights, consistent preventative practice, and person‑centred support. This means that serving personnel, veterans, reservists, and their families will benefit from the same improvements in safety, consistency and dignity as any other service user or staff group.

What evidence do you have to support this?

• The policy is grounded in equality legislation and does not introduce any differential criteria linked to Armed Forces status.
• Engagement with stakeholders across Social Care, Education, TAW services, and workforce groups did not identify any needs, barriers, or risks specific to the Armed Forces community.The preventative, person‑centred and trauma‑informed principles of PBS ensure consistency regardless of background or personal history.
• Training, supervision, incident monitoring, and behaviour support planning processes apply equally across all protected and non‑protected characteristics.

What action(s) can you to take to mitigate any negative impacts?

• Ensure training incorporates awareness of diverse life experiences, including those who may have experienced trauma related to service.
• Maintain inclusive co‑production opportunities so that veterans, serving personnel or their families can contribute feedback if they wish.
• Continue monitoring incident data and outcomes across characteristics to identify any unintentional or emerging disparities.
• Ensure communication is clear, accessible and consistent for all, including families who may move regularly or experience disruption due to service‑related commitments.

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Socio-economic Duty

Socio-economic disadvantage means living on a low income compared to others in Wales, with little or no accumulated wealth, making it more difficult to access basic goods and services.

Family background or where a person is born still affects their life. For example, a child from a wealthy family often does better at school than a child from a poor family, even if the poorer child is more naturally academic. This is sometimes called socio-economic inequality.

Do you think this proposal will have a positive or a negative impact on people experiencing socio-economic disadvantage?

• Positive

Describe the positive or negative impacts

The proposal is likely to have a positive impact on people experiencing socio‑economic disadvantage. Individuals on lower incomes are often more vulnerable to crisis, exclusion, and instability within services. A preventative PBS approach reduces escalation, promotes consistent person‑centred support, and improves access to stable provision across education, social care and community services. By reducing the need for high‑cost, crisis‑driven or out‑of‑county placements, the policy supports greater equity and reduces the disproportionate impact that service disruption can have on low‑income families.

What evidence do you have to support this?

• Evidence in PBS reports shows improved outcomes for families facing multiple disadvantages, including reduced incidents, increased stability and more effective behaviour support planning.
• Community‑based PBS pathways reduce reliance on high‑cost external provision, which is often harder for families with fewer resources to engage with.
• Preventative and relationship‑based practice is associated with improved inclusion, reduced caregiver stress, and better access to mainstream services.
• Scrutiny papers highlight that individuals experiencing disadvantage are at heightened risk during crisis events and benefit most from proactive, consistent support models.

What action(s) can you to take to mitigate any negative impacts?

Is there an opportunity to use this proposal to eliminate unlawful discrimination, advance equality of opportunity or encourage good relations between people in this group and the rest of the population?

• Ensure equitable access to PBS support regardless of income or locality.
• Continue prioritising early intervention and preventative approaches to reduce escalation and avoid costly, destabilising out‑of‑county placements.
• Maintain ongoing engagement with families to ensure the policy responds to the needs of those experiencing socio‑economic disadvantage.
• Monitor outcomes and incident data by socio‑economic indicators (where appropriate and ethical) to identify any emerging disparities.
• Ensure training, information and guidance are accessible in clear language, multiple formats and bilingual formats to avoid exclusion.

National Well-being Goal: A Wales of Cohesive Communities

A society with attractive, viable, safe, and well-connected communities.

Does the proposal contribute to this goal? Describe the positive or negative impacts.

Positive. Reduces crisis escalation, improves stability in homes, schools, and community settings, and strengthens placement stability.

What evidence do you have to support this view?

• Reduction in out of county placements.
• PBS workforce development.
• Improved relationship and community inclusion.

What action(s) can you take to mitigate any negative impacts or better contribute to the goal?

• Maintain community-based PBS pathways.
• Ensure cross agency involvement in planning and review.

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National Well-being Goal: A Wales of Vibrant Culture and Thriving Welsh Language

A society that that promotes and protects culture, heritage, and the Welsh language and which encourages people to take part in the arts, sports, and recreation.

Does the proposal contribute to this goal? Describe the positive or negative impacts.

Positive. PBS is delivered in people’s preferred language. Training, documentation and plans can be delivered bilingually.

What evidence do you have to support this view?

• Welsh language standards applied across the services.
• PBS plans created in Welsh for individuals.

What action(s) can you take to mitigate any negative impacts or better contribute to the goal?

• Ensure all staff can access bilingual training materials.
• Maintain Welsh medium PBS provision and support 

With reference to the following, do you think this proposal will have a positive or negative effect on the Welsh language?

Opportunities for people to use the Welsh language

• None / Negligible

Treating the Welsh language, no less favourably than the English language

• None / Negligible

What evidence do you have to support this view?

Built on UK and international PBS and human rights framework.

What action(s) can you take to increase the positive impact or mitigate any negative impact on the Welsh language?

• Continue evaluating against best practice and national frameworks.
• Implement governance oversight via Through Age Wellbeing and Leadership Group.

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National Well-being Goal: A Globally Responsible Wales

A society that considers how our actions might impact on other countries and people around the world.

Does the proposal contribute to this goal? Describe the positive or negative impacts.

Positive. Individuals experiencing socio-economic disadvantage are more vulnerable to crises and exclusion. A preventative PBS approach improves access to stable support, reduces the need for high cost placements, and improve equity.

What evidence do you have to support this view?

• Reduction in crisis led placement breakdown.
• PBS six month report showing improvements in outcomes for families.  

What action(s) can you take to mitigate any negative impacts or better contribute to the goal?

• Ensure equitable access to PBS support regardless of income.
• Continue to reduce reliance on high cost restrictive placements.
• Strengthen early intervention and prevention offers.

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Strengthening the Proposal

If you have identified any negative impacts in the above sections, please provide details of any practical changes and actions that could help remove or reduce the negative impacts.

If no action is to be taken to remove or mitigate negative impacts, please justify why. (If you have identified any unlawful discrimination then the proposal must be changed or revised.)

All negative impacts have identifiable mitigation actions.

How will you monitor the impact and effectiveness of the proposal?

• Reporting of PBS data.
• 6 monthly updates to TAW.
• Ongoing incident analysis and training compliance checks.

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Sustainable Development Principle: 5 Ways of Working

Describe below how you have implemented the five ways of working in accordance with the sustainable development principle of the Well-being of Future Generations (Wales) Act 2015.

Long term - balancing short-term needs with long-term need and planning for the future.

• Reduces long-term service demand and high-cost placements by embedding preventative practice.

Collaboration - working together with other partners to deliver.

• Developed jointly with Education, TAW, Social Care Wales training frameworks and behavioural specialists.

Involvement - involving those with an interest and seeking their views.

• Public consultations including service users, families’ schools and Unions.

Prevention - putting resources into preventing problems occurring or getting worse.

• Core aim: preventing escalations, crisis behaviours, and the need for restrictive practices.

Integration
Considering the impact of your proposal on the four pillars of well-being (social, economic, cultural and environment) the objectives of other public bodies and across service areas in the Council.

• Aligns with Education, TAW, Safeguarding, workforce development, Equality Act and Wellbeing of Future Generations duties.

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Risk

Summarise the risk associated with the proposal.

 

 

Data Management

Will the proposal involve any new or significant change to existing processing of data?

Yes, PBS monitoring tools require structured collection of behavioural data, incident forms, and training records.

Is a Small Scale Data Protection Impact Assessment required?

Yes.