Safeguarding Policy
Safeguarding People at Risk Policy
CONTENTS
1 Introduction
2 Policy Statement
3 Key Principles of Safeguarding
4 What is Abuse?
5 Who is an Adult at Risk?
6 Safeguarding Children
7 Mental Capacity Act (MCS)
8 Implementation
8.1. Reporting and Responding to a Concern
8.2. Recruitment and Selection of Staff and Volunteers
8.3. Induction and Training
8.4. Supervision and Support
8.5. Record Keeping
8.6. Monitoring
9 Roles and Responsibilities
10 Information Sharing
11 Communications
12 Monitoring Review
13 Legislation
14 Other relevant Procedural Documents
15 Safeguarding Contacts
16 Amendment History
1 - Introduction
Safeguarding is about keeping adults and children who are at risk safe from harm. It involves identifying and responding to concerns of abuse and neglect, working with the individual/s involved, Local Authorities and other agencies. Age UK South Gloucestershire is committed to safeguarding and protecting people from abuse.
The purpose of this policy and its supporting documents is to provide an overview of types of abuse, to outline the responsibilities of staff and volunteers working on behalf of Age UK South Gloucestershire, to specify the process by which we will respond to safeguarding concerns and to highlight the key arrangements in place to promote and protect the welfare of those we work with.
This document should be read alongside the policies and procedures covering South Gloucestershire which can be found using the links throughout this policy, all of which can be found on South Gloucestershire Councils’ website under Safeguarding (http://sites.southglos.gov.uk/safeguarding/)
2 Policy Statement
Age UK South Gloucestershire is committed to the right of all adults and children to live in safety without fear of abuse, neglect or exploitation, and to have their dignity and preferences respected.
We work to promote the health, safety and wellbeing of all adults with whom we work and that of any children we may come in contact with.
Age UK South Gloucestershire recognises that abuse can be perpetrated by anyone: staff, volunteers, other service users, family or members of the public.
We follow South Gloucestershire Safeguarding Adults Board (SGSAB) and South Gloucestershire Safeguarding Children Boards’ (SGSCB) Safeguarding guidance to ensure that reported concerns and allegations are followed up in a professional, timely and respectful manner.
Age UK South Gloucestershire understands that safeguarding children, young people and adults at risk is a shared responsibility, with the need for effective joint working between agencies and professionals that have different roles and expertise.
3 Key Principles of Safeguarding
The Government has issued a policy statement on adult safeguarding which sets out six principles for safeguarding adults. Whilst not legal duties, these do represent best practice and provide a foundation for achieving good outcomes. As part of staff contracts and volunteer agreements, all workers have agreed to adhere to these principles: The six key principles underpinning all adult safeguarding work are:
1. Empowerment: individualised approach, person-led decisions and informed consent
2. Prevention: It is better to take action before harm occurs
3. Proportionality: the least intrusive response appropriate to the risk presented
4. Protection: support and representation for those in greatest need
5. Partnership: services working with their communities; communities playing a part in preventing, detecting and reporting neglect and abuse
6. Accountability: accountability and transparency in delivering safeguarding
It is essential practice that all staff and volunteers recognise that safeguarding is everyone’s business. No individual can assume that safeguarding issues will be picked up by others.
4 What is abuse?
Abuse can take many forms in both adults and children, including:
• Physical e.g. pushing, slapping, rough handling, hitting, misuse of medication, restraint.
• Sexual e.g. rape, sexual assault, sexual acts to which the adult has not consented or was by coercion; inappropriate touching or looking, indecent exposure, innuendo.
• Psychological e.g. shouting, continual criticism, undermining confidence, humiliation and threats. Emotional abuse such as threats of harm or abandonment, deprivation of contact; coercion, unreasonable and unjustified withdrawal of services or supportive networks.
• Financial or material exploitation e.g. unfairly manipulating someone for profit or personal gain, theft, fraud, coercion in relation to an adult’s financial affairs, including in connection with wills, property, inheritance or financial
transactions, or withholding benefits, ‘borrowing’ and not paying back, misuse or misappropriation of benefits, property and possessions
• Neglect and acts of omission e.g. ignoring / excluding, not offering appropriate medical or physical care; (this can include withholding referral to other agencies e.g. GP, dentistry or welfare rights); the withholding of medication, adequate nutrition or heating
• Discrimination e.g. discrimination on grounds of age, gender, race, disability, sexual orientation, religion or personal prejudice resulting in harassment or slurs.
• Organisational where the culture in an organisation or specific care-setting undermines individual choice and self-determination e.g. where a client is prevented from accessing services and goods to which they are entitled; neglect or poor care practice
• Self-neglect e.g. lack of self-care, squalor or hoarding
• Domestic abuse e.g. physical or sexual violence or threats, controlling behaviour
• Modern slavery e.g. forced labour or domestic servitude
5 Who is an adult at risk?
The Care Act 2014 redefined who may be seen as a ‘vulnerable adult’, and refers instead to ‘adults at risk’. An adult at risk may be any person aged 18 years or over whom:
• has care and support needs and
• is experiencing or is at risk of abuse or neglect and
• is unable to protect themselves because of their care and support needs
6 Safeguarding Children
Age UK South Gloucestershire works with adults, but from time-to-time will come into contact with children under the age of 18, through pupils on work experience placed within the organisation, some volunteers and because there may be children in the household of some families that we support.
If a member of staff or volunteer has any concerns that a child is suffering abuse or is at risk of suffering abuse they will report this to a Safeguarding Coordinator within one working day. If there is an immediate risk of harm the staff member or volunteer should ring 999.
The Safeguarding Coordinator receiving any such concern will decide if it is appropriate to make a referral to the South Gloucestershire Safeguarding Children Board (SGSCB) by phoning 01454 866000 or emailing the First Contact Team (GCSX) . More information on how to make a referral can be found on South Gloucestershire Council's webpage under Safeguarding.
A record of the concern, and action taken or not taken, will be recorded as an electronic copy on Charity Log by the Safeguarding Coordinator who received the concern.
Age UK South Gloucestershire protects school placements and volunteers under the age of 18 by:
• ensuring that they are not in one-to-one situations with clients, carers or members of the public;
• They do not undertake any regulated activity
• They have a named member of staff or senior adult volunteer who provides supervision and a point of contact
7 Mental Capacity Act (MCA) 2005
Having mental capacity means that a person is able to make their own decisions. In some circumstances a person may not be able to make a particular decision at a particular time because their mind or brain is affected by illness or disability. There are many reasons why someone might lack capacity at a particular point – for example due to a stroke or brain injury, a mental health problem, dementia, a learning disability, confusion, drowsiness or unconsciousness because of an illness or the treatment for it or substance misuse.
Lack of capacity may not be a permanent condition. Assessments of capacity should be time- and decision-specific. You cannot decide that someone lacks capacity based upon age, appearance, condition or behaviour alone.
The MCA is designed to protect and restore power to people who lack capacity. It is important that all those working directly with our clients understand the principles of the MCA and how to apply them.
The five underpinning principles state that you must:-
1. Assume the person has capacity unless it is proved otherwise.
2. Not treat people as incapable of making a decision unless you have tried all practicable steps to try to help them.
3. Allow people to make what may seem to you an unwise decision.
4. Always do things, or take decisions for people without capacity in their best interest.
5. Ensure that any act or decision must be the least restrictive option to the person in terms of their rights and freedom of action.
You must use the following test to assess if the person has capacity:-
1. Does the person have an impairment of the mind or brain, or is there some sort of disturbance affecting the way the mind or brain works,
2. If so does that impairment or disturbance mean that the person is unable to make the decision in question at the time it needs to be made?
To have capacity to make a decision someone must be able to:-
1. Understand the information relevant to the decision and
2. Retain the information, and
3. Use or weigh that information as part of the process of the making the decision and
4. Communicate their decision either by talking, signing, or any other means.
Where a person lacks capacity all decisions must be made in the best interest of that person. The bullet points below give some common factors that you must always take into account where a decision is being made, or an act is being done for the person who lacks capacity:
• Involve the person who lacks capacity
• Be aware of the person’s past and present wishes and feelings
• Consult with others who are involved in the care of the person
• Do not make assumptions based solely on the person’s age, appearance, condition or behaviour.
• Consider if the person is likely to regain capacity to make the decision in the future.
If you are required to make a decision, you must record this by completing the MCA Checklist template and keep a record of this using the Safeguarding project on Charity Log as a contact on the clients record.
8 Implementation
8.1. Reporting and responding to a concern
It is the responsibility of all staff and volunteers to ensure that any concerns arising from situations they observe, allegations (reports from third parties) or disclosures (reports from someone about themselves) relating to potential abuse, are reported to a Safeguarding Coordinator immediately (not leaving this until the next working day), even if they are unsure whether the concern is justified.
If a Safeguarding Coordinator is not available then a report should be made to the CEO, or at least, to any of the Management Team or a supervisor. See the Safeguarding Procedure and Safeguarding Flowchart which outline fully all escalation routes and timeframes.
The consent of the adult deemed to be at risk will normally be sought, before information is shared, in line with the principles outlined above. In some cases it may not be practical or safe to seek such consent, or the adult may lack capacity in relation to this issue. In these cases a referral, or at least a discussion, may take place without active consent.
In some circumstances an adult with capacity may refuse consent but a referral is still made because it is deemed either that the risk of physical harm is so serious that the withholding of their consent isn’t reasonable, or because another adult or child is at risk, or where there is an overriding public interest. An example of the latter would be an allegation of abuse made against a staff member of an agency providing personal care where the potential risk to other adults would outweigh the lack of consent. The reasons for a referral without consent will be recorded carefully. Age UK South Gloucestershire will seek the advice of the South Gloucestershire Safeguarding Adults or Children Boards where there is doubt or concern about consent or capacity issues.
If the concern raised is regarding children, or if the concern is such that it will impact on any children at the same address (e.g. domestic abuse), the matter must be discussed with South Gloucestershire’s Safeguarding Children Board on 01454 866000. See section 6 above. Again, if it is felt there is immediate danger the police should be contacted.
If a member of staff or a volunteer believes that the Safeguarding Coordinator is involved in, or colluding with, any potential abuse, they should raise their concern with another Safeguarding Coordinator, a Manager, CEO, a trustee or, if none of these is available, with South Gloucestershire Safeguarding Adult or Children Board – 01454 868007 or 01454 866000 respectively. Staff and volunteers raising genuine concerns about colleagues or managers within Age UK South Gloucestershire will be supported and their job/role will be unaffected by such action. Please refer to the Whistleblowing Policy for more detail.
Where the concern is one of potential discrimination or the undermining of choice within Age UK South Gloucestershire’s services it should be reported to the Chief Executive Officer. An investigation of the facts will then follow to decide if any action is required. If it is felt that the matter has not been dealt with appropriately it should be raised with the Chair of Trustees for investigation or, if still not dealt with appropriately, with South Gloucestershire Safeguarding Adults or Children Board for their investigation. The procedure undertaken by the Trustees would be that as laid out in the Complaints Policy.
8.2. Recruitment and Selection of Staff and Volunteers
As part of Age UK South Gloucestershire’s commitment to Safeguarding Adults and Children, recruiting managers shall seek guidance from the DBS coordinator, to determine the level of DBS (formerly CRB) check required for the advertised role. The manager shall ensure clearance is obtained before the applicant commences employment.
8.3. Induction and Training
Age UK South Gloucestershire is committed to have arrangements in place to ensure effective training of all staff. New staff and volunteers receive a thorough induction when they join Age UK South Gloucestershire including attendance at relevant in-house training.
All staff are expected to attend at least basic training in children and adult safeguarding. Volunteers that work in client/public facing roles are also expected to attend the same training.
New staff and volunteers receive and sign for a copy of our Staff Handbook in either hard copy or electronic format. The importance of following the organisation’s safeguarding procedures are emphasised during the induction process and it is made clear that breaches are treated seriously. Updates and changes are communicated through supervision, team meetings and in-house newsletters.
Managers will agree any further levels of safeguarding training required for each employee and volunteer depending on their role and responsibilities.
For safeguarding training, Age UK South Gloucestershire staff and volunteers are directed to South Gloucestershire Council’s Learning and Development service available on South Gloucestershire Council's website.
8.4. Supervision and Support
All staff receive regular, recorded one-to-one sessions, and an annual appraisal so that they receive adequate support and coaching, and opportunities to develop their good practice.
Informal opportunities to seek advice or exchange information with the line manager or another manager are also provided throughout the week.
All volunteers working with clients have a named line manager with whom they liaise about their work; one-to-one or group support is offered as appropriate.
Additional support and supervision will be provided for safeguarding leads within Age UK South Gloucestershire as appropriate and identified through personal development needs.
8.5. Record-keeping
All Age UK South Gloucestershire activity relating to the people we support is recorded on Charity Log . Consent to keep the record and general consent to share is sought and recorded at first assessment. The record allows us to share relevant information across services and to take a holistic approach in providing support as the person’s circumstances change. Where ongoing services (such as Day Services) are accessed, regular reviews with the client ensure that records are kept up to date; and that we are able to contribute positively in multi-agency discussions as appropriate.
The detail of individual safeguarding concerns is also recorded on Charity Log, but under an access limited project so only Safeguarding Coordinators can see the detail. We will additionally record under the more accessible ‘risk assessment’ tab that there is a potential issue, and identify the Safeguarding Coordinator who has responsibility for managing that concern.
8.6. Monitoring
A full report (anonymised) of numbers and type of safeguarding incidents and their resolution will be provided by the CEO to the Board of Trustees each April.
A bi-monthly summary report is also presented to the CEO and the log of all safeguarding concerns raised (including discussions which have not resulted in a concern being raised) is reviewed monthly by the Facilities and Compliance Manager. The CEO provides the Trustees with a summary at, or before, each Board meeting.
Recruitment, Selection, DBS checks/renewals and Induction processes are monitored by the HR and Operations Manager.
Attendance at relevant safeguarding training is also monitored by the HR and Operations Manager, and is reviewed by the Facilities and Compliance Manager at least every six months.
On an annual basis, or more regularly if required, Age UK South Gloucestershire will review this policy, and in addition conduct a short review to ensure:
• The Safeguarding People at Risk system within Age UK South Gloucestershire is working effectively to safeguard children and adults at risk of harm or abuse.
• Age UK South Gloucestershire is meeting any specific safeguarding duties in relation to the services that it provides.
• Robust processes are in place to learn lessons from cases where children or adults are harmed and abuse or neglect is suspected.
9 Roles and Responsibilities
CEO
Age UK South Gloucestershire’s CEO is responsible for providing overall assurance to the Age UK South Gloucestershire Trustee Board on the effectiveness and quality of the safeguarding arrangements.
Trustee Board
Age UK South Gloucestershire‘s Trustee Board fulfils the overall leadership and governance role for safeguarding – setting direction, ensuring compliance with standards, policies and procedures, monitoring progress and managing risks.
All Managers
Managers are given a responsibility to understand this policy to ensure all staff and volunteers are supported, maintaining training and awareness that is appropriate to their role(s).
Safeguarding Coordinators
Act as the main point of contact for safeguarding concerns raised and take the appropriate actions as outlined in both the Safeguarding Procedure and Safeguarding Flowchart. Ensuring that they are available to be contacted during their working hours if a concern needs to be raised.
Safeguarding Coordinators will update Charity Log with any SA1 forms, actions and decisions made relating to concerns raised.
Where any tasks have been delegated to other staff members (see below where this may apply) the Safeguarding Coordinator will remain as the lead responsible person for the safeguarding concern and will be expected to regularly monitor the situation, checking in with the staff member at least once a day until no further action is required by AUKSG.
Delegated staff members
Certain members of staff may be delegated to take on some additional responsibilities relating to safeguarding concerns. Before being considered eligible to take on these responsibilities, staff members must meet the following minimum requirements:
• Have been employed for more than 6 months and passed their probationary period.
• Have completed appropriate additional training beyond the minimum half-day training provided by South Glos Council.
• Have written confirmation from their Line Manager as well as the CEO stating that they are able to take on these responsibilities.
Once these criteria have been met, these staff members will be able to take on the following extra responsibilities only (when directed by a Safeguarding Coordinator):
• Filling out SA1 forms as requested by South Glos Council (note that these will still need to be reviewed and submitted to Charity Log by a Safeguarding Coordinator)
• Liaising with individuals to collect information relating to a concern.
This excludes safeguarding concerns where it is suspected in any way that an AUKSG staff member or volunteer has acted inappropriately or has committed abuse. This also excludes safeguarding concerns where there is already strong evidence to suggest that abuse has been committed by a third party (i.e. not self-neglect).
Delegated staff members must always discuss any safeguarding concerns with a Safeguarding Coordinator before taking on any tasks beyond what other staff would relating to the concern. Additionally, Safeguarding Coordinators will only delegate tasks to these staff members where they have assessed that the risk to the individual/s involved is not severe, and the Coordinator will still remain as the lead responsible person for the concern.
All staff and volunteers
All of our staff and volunteers have a responsibility to achieve and maintain the standards set out in this policy and must report any safeguarding concerns to a Safeguarding Coordinator or if not available, the CEO or a manager, in line with the supporting Safeguarding Procedure and Safeguarding Flowchart.
10 Information Sharing
It is important that all involved remain confident that their personal information is kept safe and secure and that they maintain the privacy rights of the individual.
Staff and volunteers should ensure they are familiar with Age UK South Gloucestershire’s Information Governance policy. This will clarify what information is appropriate to share.
There are seven golden rules for information sharing:
1. Remember that the Data protection Act 2018 and UK GDPR regulations are not a barrier to sharing safeguarding information.
2. Keep a record of your decision and the reasons for it. Record what you have shared, with whom and for what purpose.
3. Be open and honest with the person (and/or their family where appropriate) at the outset about why, what, how and with whom information will, or could be shared, and seek their agreement where possible, unless it is unsafe or inappropriate to do so.
4. Seek advice if you are in any doubt, without disclosing the identity of the person where possible.
5. Share with consent where appropriate and, where possible, respect the wishes of those who do not consent to share confidential information. You may still share information without consent if, in your judgement, that lack of consent can be overridden in public interest. You will need to base your judgement on the facts of the case.
6. Consider the safety and wellbeing of the person and others who may be affected by their actions.
7. Make sure you only share what is necessary, proportionate, relevant, accurate, timely and secure.
11 Communications
Any safeguarding issue that may attract media interest should be shared with the CEO, who will share the issue with appropriate members of the Trustee Board. This decision should be made by a Safeguarding Coordinator at the appropriate stage as listed on the Safeguarding Flowchart.
12 Monitoring Review
This policy will be reviewed every year, and in accordance with the following on an as when basis if the following occurs:
• legislative changes;
• good practice guidance;
• case law;
• significant incidents reported;
• new vulnerabilities
• changes to organisational infrastructure.
Where there are no significant alterations required, this Policy shall remain for a period of no longer than one year of the ratification date.
13 Legislation
This policy has been prepared in accordance with:
Care Act 2014 and statutory guidance relating to Safeguarding (chapter 14)
Safeguarding Vulnerable Groups Act 2006
Mental Capacity Act 2005
Children Act, as revised 2004
Statutory Guidance: Working Together to Safeguard Children 2015
South Gloucestershire Safeguarding Adults Board Guidance
14 Other relevant Procedural Documents
• Safeguarding People at Risk Procedure
• Safeguarding Process (Flow Chart)
• Data Protection & Information Security Policy
• Data Breach Policy
• Data Breach Procedure
This list is not exhaustive and further policies and procedures can be found on Age UK’s X: Drive.
15 Safeguarding Contacts
Safeguarding Coordinators
Christine Wedlake – 01454 423813 / 07508994273 (Christine.wedlake@ageuksouthglos.org.uk)
Sarah Dodd – 07548156309 (sarah.dodd@ageuksouthglos.org.uk)
Alternative Safeguarding Coordinator Mark Flower (CEO) – 01454 423811 / 07805 771179 (CEO@ageuksouthglos.org.uk)
South Gloucestershire Safeguarding Boards (Adult / Children / Out of Hours) Adult – 01454 868007 Children - 01454 866000 Out of Hours - 01454 615165 Email – Firstcontactteam@southglos.gcsx.gov.uk Website – http://sites.southglos.gov.uk/safeguarding
16 Amendment History
Version Date Next Review Amendment History
1.0
04/08/14
4 August 2014
Approved by the Trustee Board
1.1
04/04/15
April 2018
Added amendment history, rebranded and added resolution form
1.2
23.04.15
April 2018
Suggested alterations to content such as safeguarding officers to safeguarding co-ordinators, the addition of timescales for the completion of training, altered the safeguarding contact details, etc.
1.3
01/05/15
May 2018
Reviewed – contact details completed
1.4
28/09/18
September 2019
Policy re-write after Care Act introduction
1.5
27/09/19
September 2020
Terminology and abuse definitions updated, recording requirements and responsibilities updated throughout. Reference to new Data Breach Procedure added.
1.6
04/09/20
September 2021
Job title changes throughout.
Clarified volunteer obligations.
Removed references to PIC Service.
Removed references to paper safeguarding file as all new data is recorded electronically only.
1.7
26/03/21
March 2022
Added additional information and guidance on actions for compliance with MCA.
Amended implementation section to correctly reflect timescales and detail listed in Safeguarding Procedure and Flowchart.
Version 1.8
Added detail on additional monitoring now taking place.
Added more detail on roles and responsibilities, detailing difference between Managers who may not also be Safeguarding Coordinators. New Delegated staff member responsibilities added.
References to data protection documents amended.
1.8
15/05/2023
May 2024
Safeguarding Contacts details updated. Safeguarding Alerter Form deleted
Safeguarding Alerter Contents list removed
Safeguarding Alerter Slip Deleted they are no longer required since the records are made electronically.