Safeguarding Policy

Policy statement
Safeguarding is everyone’s responsibility. Age Cymru Gwent has a duty to prevent and protect adults and children against abuse and harm under the Social Services and Wellbeing (Wales) Act 2014^[1] and also adhere to the Wales Safeguarding procedures^[2].

Age Cymru Gwent is committed to taking all reasonable steps to ensure adults and children are protected from harm, and the right action is taken if a person is at risk of harm. This includes taking action when we have information or concerns that an adult or child who is receiving a service from us is being abused or harmed in the community or at their place of residence.

Age Cymru Gwent recognises the need to provide a safe environment which safeguards anyone who comes into contact with us. This includes beneficiaries, employees and volunteers.

Safeguarding is a fundamental part of Age Cymru Gwent, and this commitment is reflected in our achievement of the Age UK Charity Quality Standards award.

Abuse and neglect can have a devastating effect on individuals, families and wider society. The damage from safeguarding incidents and allegations can impact the reputation of an organisation. Public trust and confidence in the wider sector can be harmed if safeguarding issues are not responded to and reported appropriately.

The purpose of this policy is to provide information to all employees and volunteers of Age Cymru Gwent’s responsibilities surrounding safeguarding adults and children. It will also provide the procedures that should be followed where there is any suspected, potential, or actual abuse of adults or children at risk.

Scope of the policy
This policy will apply to all employees and volunteers working for Age Cymru Gwent. In the application of this policy, everyone must be aware that it applies to abuse in any or all of the following circumstances, and whether the suspected abuser is a member of our staff or a third party where:

• the service user (or adult at risk is not a service user) discloses that they are the victim of abuse
• there is reasonable cause to suspect that a child is a child at risk
• abuse is suspected or observed
• abuse has been reported, and we are supporting the service user

Policy definitions
An adult at risk is a person over the age of 18 who:

• is experiencing or is at risk of abuse or neglect
• has care and support needs (whether or not the authority is meeting any of those care needs), and
• as a result of those care needs are unable to protect themselves against abuse or neglect or the risk of it.

A child at risk is a person under the age of 18 who:

• is experiencing or is at risk of abuse or neglect
• has care and support needs (whether or not the authority is meeting any of those care needs.

Dedicated Safeguarding Trustee - Nick Haynes

Designated Safeguarding Lead (DSL) - Quality and Compliance Lead- Joanne Boyer

Deputy Designated Safeguarding Lead (DDSL) - Department Manager Information and Advice-Angela Knowles Macleod.

The Designated Safeguarding Lead (DSL) is the identified person within the organisation who:

• is available to discuss safeguarding concerns
• should be consulted, when possible, by a line manager as to whether a safeguarding concern is raised with the Local Authority
• help manage any immediate actions required to ensure the individual at risk is safe from abuse
• compile and produce safeguarding reports to the Board of Trustees

In the absence of the Designated Safeguarding Lead (DSL), the Deputy Designated Safeguarding Lead (DDSL) should be contacted.

The need to seek advice should never delay any emergency action needed to protect an individual believed to be at risk.

Roles and Responsibilities

Employees and volunteers
Every individual working for Age Cymru Gwent, irrespective of their role, has a role to play in safeguarding adults and children at risk.

All employees will be expected to:

• complete e-learning in safeguarding vulnerable adults
• undertake Age Cymru Gwent’s bespoke safeguarding training
• attend additional safeguarding training offered through the Gwent Safeguarding Board (GwASB)
• complete a declaration which states that they have read and understood the safeguarding guidance, policy and procedures
• complete safeguarding forms as directed by their line manager or DSL
• ensure all case management records are up-to-date and accurate

All volunteers will be expected to:

• undertake Age Cymru Gwent’s bespoke safeguarding training
• attend additional safeguarding training offered through the Gwent Safeguarding Board (GwASB)
• complete a declaration that states they have read and understood the safeguarding guidance, policy and procedures

Management Team
The Senior Management team will receive and scrutinise reports on safeguarding activity which will be compiled by the DSL.

Line managers will ensure that their employees and volunteers have completed the designated safeguarding training, have opportunities to receive additional safeguarding training and discuss safeguarding at supervisions and team meetings.

Trustees
The Trustees of Age Cymru Gwent have responsibility for the general control, management and administration of the Charity. Trustees of Charities who work with adults or children have a duty of care to their Charity, which includes taking the necessary steps to safeguard those at risk of abuse, managing risks and protecting the reputation of the Charity.

Trustees will ensure that safeguarding is included, where appropriate, in the strategic plans, risk assessments, communications and quality assurance processes of the organisation. In some cases, they will be required to make decisions in relation to complex or serious safeguarding concerns in consultation with the Chief Executive Officer (CEO).

Types of Abuse
Abuse:

• can be physical, sexual, psychological, emotional, or financial (includes theft, fraud, pressure about money, misuse of money)
• can take place in any setting, whether in a private dwelling, an institution, or any other place.

Neglect

• This describes a failure to meet a person’s basic needs physical, emotional, social, or psychological needs, which is likely to result in an impairment of the person’s well-being (for example, an impairment of the person’s health).

It can take place in a range of settings, such as a community setting, private dwelling, residential or day care provision.

Employees and volunteers should be aware that the following behaviours could place individuals at risk of abuse or neglect:

• Violence against women, domestic abuse and sexual violence (VAWDASV). This includes Female Genital Mutilation
• Modern Day Slavery
• Domestic abuse against men
• Criminal exploitation
• Radicalisation
• Child sexual exploitation

It is important to note that this is NOT an exhaustive list. Rather, they are provided to offer some pointers that may alert them to possible abuse or neglect.

The Mental Capacity Act 2005
The Mental Capacity Act (MCA) is designed to protect and empower people who may lack the mental capacity to make their own decisions about their care and treatment. It applies to people aged 16 and over.

It covers decisions about day-to-day things or serious life-changing decisions.

Someone can lack the capacity to make some decisions (for example, to decide on complex financial issues) but still have the capacity to make other decisions (for example, to decide what items to buy at the local shop).

The MCA says:

• Assume a person has the capacity to make a decision themselves, unless it's proved otherwise
• Wherever possible, help people to make their own decisions
• Do not treat a person as lacking the capacity to make a decision just because they made an unwise decision
• If you make a decision for someone who does not have capacity, it must be in their best interests
• Treatment and care provided to someone who lacks capacity should be the least restrictive of their basic rights and freedoms

Where a person lacks the capacity to consent to a safeguarding referral to the Local Authority, this must be referred.

Where a person has the capacity to consent to a safeguarding referral to the Local Authority, consent should be obtained. However, the overriding consideration when you decide whether to try to get consent before making a report is the level of harm present to the adult at risk. GDPR provides a number of bases for sharing personal information. It is not necessary to seek consent to share information for the purposes of safeguarding and promoting the welfare of an adult or child at risk, provided that there is a lawful basis to process any personal information required.

Local Authorities have a duty to ensure that the needs of the person it at the centre of decision-making and will discuss with the individual who was referred as part of the safeguarding process:

• The personal outcomes the person wishes to achieve
• What matters to the individual
• Enable people to determine how they manage risks

If it is identified that a person does not have capacity during the Local Authority safeguarding process, then a best-interest decision will be made.

Internal procedures
When employees or volunteers identify abuse or have grounds for believing that abuse is being, or maybe, perpetrated against an adult or child at risk, they have a duty to take appropriate action. Action will not usually be taken without consulting the Line Manager, the Designated Safeguarding Lead, or Deputy Lead.

Employees and volunteers are not required or expected to deal with safeguarding incidents without help and advice or before referring to their line manager as above. However, the first consideration should be the safety of the adult at risk, and if they are seriously unwell, at risk of harm or in immediate danger, the appropriate emergency service should be contacted immediately by calling 999.

It is essential that any disclosure made is taken seriously and there is no judgement as to the reliability and validity of what has been said. It is up to the investigating body to make this judgement. The responsibility of employees and volunteers is to “Recognise, Record and Report” any abuses that have been witnessed or disclosed.

The use of the term ‘at risk’ means that actual abuse or neglect does not need to occur before practitioners intervene; rather, early interventions to protect an adult or child at risk should be considered to prevent actual abuse and neglect.

Reporting
Action to take by employees and volunteers:

• inform the line manager of the safeguarding incident to discuss the most appropriate course of action
• if the line manager needs further advice, they should contact the Designated Safeguarding Lead or Deputy
• if the line manager is not available or they are the suspected perpetrator, speak to the Designated Safeguarding Lead or Deputy Lead
• the initial record form should be completed as fully as possible, as soon as is practicable following the discovery of suspected, potential, or actual abuse, and a safeguarding reference number allocated by the line manager
• the initial record form must be completed no later than 24 hours after the disclosure or when the concern was identified and provided to the line manager. See appendix (i)
• the line manager will add their comments, agree on actions and sign the form
• the line manager must provide the initial record to the DSL, via the Teams safeguarding channel within 7 days of the initial safeguarding referral
• a GwASB Adult Duty to Report Form will be completed by the employee with support from their line manager if an adult at risk has been identified. Volunteers would work with their line manager to complete the GwASB form. See appendix (ii)
• a GwASB Child Duty to Report Form will be completed by the employee with support from their line manager if a child at risk has been identified. Volunteers would work with their line manager to fill complete the GwASB form. See appendix (iii)
• the line manager will submit the GwASB Duty to Report form to the Local Authority responsible via the email address located at the bottom of the form for the appropriate action to be taken
• the initial record form and the GwASB Duty to report form should be uploaded onto the relevant case management records 

The line manager will be responsible for completing the following;

• an anonymised summary of safeguarding referrals within their own services. See appendix (iv)
• this summary will be continuously updated on the designated safeguarding channel on Teams, on a quarterly basis, the spreadsheet must be fully completed within 3 working days of the quarter end
• a nil return will also need to be submitted by each service even if there is no safeguarding to report
• completing a case study of all safeguarding referrals and sending these to the DSL on a quarterly basis. See appendix (v)

Remember, a failure to share information can place an adult or child at risk of abuse and neglect; these are common features of adult and children practice reviews. Whilst information in isolation may seem insignificant, put together with information from other sources, it may become significant to safeguarding the adult or child at risk.

Any employee or volunteer working for the charity needs to be familiar with the internal policies that enable them to report a concern in relation to their own work with the charity. There are a number of policies in place that will provide help and guidance to enable reporting and address and resolve any concerns that may exist in relation to their own employment or work with the charity. In addition to this safeguarding policy, the following are available:

• BK - Whistleblowing
• AC - Grievance Procedure
• AI - Equality, Diversity and Inclusion
• AZ- Bullying and Harassment

Additional support available
It is essential that adults at risk are offered and supported by an independent advocate throughout the process. When employees and volunteers continue supporting an adult at risk, they should discuss whether or not the individual wishes to be referred to an ‘Independent Professional Advocacy Service’. As part of their work, Independent Professional Advocates (IPA’s) are trained and able to provide dedicated support to individuals throughout the safeguarding process. They ensure the adult at risk fully understands the process and is at the centre of all decisions. Adults at risk are unique individuals, whereby the process is done with them, and they are engaged at each step. Advocacy should be considered at all stages of the adult safeguarding process, including the involvement of an Independent Mental Capacity Advocate (IMCA) when required. (Part 10 Code of Practice for Advocacy).

If a child at risk has been identified, the safeguarding referral to the Local Authority will trigger a referral to child advocacy support. 

There are a number of agencies and resources that people can access if a suspected, potential or actual abuse is identified. It is important that individuals are able to access the support they need. These resources can be essential to individuals’ well-being during the safeguarding process. Employees and volunteers can provide those at risk of abuse with a copy of the Safeguarding Contact Sheet noted at the bottom of this document.

Age Cymru Gwent understands that when employees and volunteers are involved in cases where a suspected, potential or actual abuse has taken place, they may need some additional support. The well-being of our employees and volunteers is important to the organisation. When an employee or volunteer identifies and/or raises a concern about an individual, they will be offered a debrief session by their line manager, so they have the opportunity to talk about the situation and identify if any additional support needs to be put in place. See appendix (vii).

Breaches of Policy
Failure to comply with the Age Cymru Gwent safeguarding policy may be managed in a number of ways, depending on the nature and consequences of any incident. In some cases, a combination of responses may be required: 

• disciplinary process – where there are concerns regarding staff misconduct or competence
• a Local Authority coordinated safeguarding investigation – where concerns about the actions or inactions of an employee or volunteer necessitate referral to the adult or child safeguarding team in the area where the abuse is alleged to have taken place. This may also result in referral to Disclosure & Barring Service
• a Police led the investigation – where the actions or inactions of an employee or volunteer appear to be criminal in nature
• serious incident reporting to The Charity Commission, Care Inspectorate Wales and/or the Information Commissioners Office
• additional or repeat training – where the concern does not meet the threshold for the processes outlined above but does indicate a need for further development of safeguarding competence.

Recruitment
Age Cymru Gwent is committed to the safe recruitment of our employees and volunteers in order to protect the vulnerable individuals that we support. All posts are offered subject to satisfactory references, DBS checks where appropriate to the role and with relevant probationary periods taking place.

Safeguarding Contact Sheet
This is designed to provide employees and volunteers with the relevant agencies that can help support a person through a safeguarding issue.

 [1] https://gov.wales/sites/default/files/publications/2019-05/part-2-code-of-practice-general-functions.pdf

[2] https://safeguarding.wales/