Safeguarding Adults Policy

Provider: [Provider Organisation Name] Ltd – CQC-registered adult social care service

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Service type(s) this document applies to	CQC-registered adult social care service
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Scope: This policy applies to all CQC-registered adult social care services provided by [Provider Organisation Name] Ltd, across all regulated settings and for all adults supported by the organisation.
Not in scope: Services or activities outside the remit of CQC registration or those not involving adult social care.

1. Purpose

The purpose of this policy is to ensure that adults at risk of harm or abuse are safeguarded effectively and consistently across all regulated activities provided by the organisation. It establishes a clear framework for recognising, responding to, and preventing abuse and neglect, in line with the legal and regulatory requirements set out in the Care Act 2014, the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, and associated statutory guidance. Safeguarding is a fundamental duty of all staff, and this policy supports the organisation in fulfilling its obligations to protect individuals while promoting their rights, dignity, and autonomy.

Adults who may be at risk of harm include those who, due to their care and support needs, are unable to protect themselves from abuse, neglect, or exploitation. This policy ensures that safeguarding is embedded in every aspect of the organisation’s operations, from frontline care delivery to governance, and that all staff understand their responsibilities. It also ensures that safeguarding practices are person-centred, empowering individuals to lead on decisions about their own safety and wellbeing wherever possible, in line with the principles of Making Safeguarding Personal. Failure to implement robust safeguarding measures can result in significant harm to individuals, reputational damage to the organisation, and regulatory action, including enforcement measures by the Care Quality Commission (CQC).

This policy serves to:

• Provide a structured approach to safeguarding that aligns with the six safeguarding principles outlined in the Care Act 2014: Empowerment, Prevention, Proportionality, Protection, Partnership, and Accountability.
• Ensure that all staff are equipped to identify the signs of abuse and neglect, respond appropriately to safeguarding concerns, and escalate issues through the correct channels, including to the Local Authority safeguarding team.
• Promote a culture of vigilance, transparency, and continuous improvement in safeguarding practices, ensuring that lessons are learned from incidents and that risks are proactively managed.
• Demonstrate compliance with statutory and regulatory requirements, including the duty to notify the CQC of safeguarding incidents under Regulation 13 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014.

By implementing this policy, the organisation aims to create an environment where adults at risk feel safe, respected, and supported, and where safeguarding is understood as everyone’s responsibility. This commitment extends to working collaboratively with external agencies, including Local Authority safeguarding teams, the police, and healthcare providers, to ensure a coordinated and effective response to safeguarding concerns.

Key Objectives of the Policy:

• Prevention of Abuse and Neglect: Establish proactive measures to minimise the risk of harm, including safe recruitment practices, staff training, and robust risk management processes.
• Early Identification and Response: Ensure that staff can recognise the indicators of abuse and neglect and take immediate, appropriate action to safeguard individuals.
• Person-Centred Approach: Place the person we support at the centre of safeguarding processes, respecting their wishes, capacity, and consent wherever possible.
• Compliance and Accountability: Ensure adherence to all relevant legal and regulatory requirements, and maintain clear accountability at all levels of the organisation.
• Continuous Improvement: Regularly review and update safeguarding practices to reflect changes in legislation, guidance, and learning from incidents.

This policy is integral to the organisation’s commitment to delivering safe, high-quality care and support. It underpins the organisation’s broader governance framework and is supported by detailed procedures for recognising, reporting, and managing safeguarding concerns. All staff, volunteers, and contractors are required to familiarise themselves with this policy and adhere to its principles and procedures in their day-to-day work. Evidence of compliance will be monitored through regular audits, training records, and incident reviews, ensuring that safeguarding remains a priority at every level of the organisation.

2. Scope & Applicability

This Safeguarding Adults Policy applies universally across all regulated activities undertaken by [Provider Organisation Name] as a CQC-registered adult social care service. It is designed to ensure that safeguarding responsibilities are understood and upheld by every individual associated with the organisation, regardless of their role or the setting in which they operate. The policy is applicable to all environments where care and support are provided, whether in a person’s own home, supported living arrangements, day services, or other community-based settings. It also extends to any external activities or events facilitated by the organisation.

The policy applies to all individuals who work for or on behalf of [Provider Organisation Name], including but not limited to:

• Permanent employees, whether full-time or part-time.
• Agency staff and relief workers engaged on a temporary basis.
• Volunteers who contribute to the delivery of services or support.
• Contractors and subcontractors providing services or maintenance within the organisation’s premises or to the people we support.
• Consultants and external professionals engaged by the organisation.
• Students or trainees on placement within the organisation.

This comprehensive scope ensures that safeguarding responsibilities are embedded across all levels of the organisation and that no individual or group is excluded from their duty to protect adults at risk of harm. It also ensures that all individuals who may come into contact with the people we support are aware of their obligations to act in accordance with this policy and the relevant legal and regulatory framework.

The policy applies to all adults who use or come into contact with the organisation’s services, whether they are receiving direct care and support, accessing ancillary services, or engaging with the organisation in other ways. It also applies to any interactions with family members, advocates, or other representatives acting on behalf of the people we support.

Regulated Activities Covered

This policy applies to all regulated activities carried out by [Provider Organisation Name], as defined under the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014. These activities may include, but are not limited to:

• Personal care, including assistance with daily living tasks such as washing, dressing, and eating.
• Supported living services, where individuals receive care and support to live independently.
• Residential care services, where applicable, including the provision of accommodation and personal care.
• Community-based services, such as day centres or outreach programmes.
• Any other activities that fall within the scope of the organisation’s CQC registration.

Key Responsibilities

All individuals covered by this policy are required to:

• Familiarise themselves with the content of this policy and understand their role in safeguarding adults at risk.
• Complete mandatory safeguarding training appropriate to their role and responsibilities.
• Report any concerns about abuse, neglect, or exploitation in line with the procedures outlined in this policy.
• Cooperate fully with any safeguarding enquiries or investigations, whether internal or conducted by external agencies such as the local authority or the police.
• Adhere to the principles of confidentiality and information sharing as outlined in this policy and in accordance with the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR).

Multi-Setting Applicability

Given the diverse nature of adult social care services, this policy is designed to be universally applicable across all settings in which the organisation operates. Where specific safeguarding requirements differ by setting, these are addressed in the relevant sections of this policy. For example:

• In a person’s own home: Staff must be particularly vigilant to signs of self-neglect or financial abuse, as these may be less visible in isolated settings.
• In supported living or residential care settings: Staff must ensure that safeguarding measures are integrated into daily routines and that any concerns are promptly escalated to the Designated Safeguarding Lead (DSL).
• In community-based services: Staff must be aware of the potential risks associated with public or group activities and take appropriate steps to mitigate these risks.

Evidence of Compliance

To demonstrate compliance with this policy, the organisation will maintain detailed records, including:

• A register of all staff, volunteers, and contractors, including evidence of completed safeguarding training.
• Documentation of safeguarding concerns raised, including the actions taken and outcomes achieved.
• Records of multi-agency meetings and communications related to safeguarding.
• Evidence of regular policy reviews and updates to reflect changes in legislation or best practice.

By ensuring that this policy is universally applied and rigorously adhered to, [Provider Organisation Name] reaffirms its commitment to safeguarding adults at risk and to fostering a culture of safety, respect, and accountability across all its services.

3. Legal & Regulatory Framework

The safeguarding of adults in CQC-registered adult social care services is underpinned by a robust legal and regulatory framework designed to protect individuals from abuse, neglect, and exploitation. This framework establishes the statutory duties, responsibilities, and expectations for providers, ensuring that all adults, particularly those with care and support needs, are safeguarded effectively. Compliance with these legal and regulatory requirements is not optional; it is a fundamental obligation for all providers and forms a critical component of the Care Quality Commission’s (CQC) assessment of whether services are safe, effective, caring, responsive, and well-led.

Failure to adhere to the legal and regulatory framework can result in significant consequences, including harm to individuals, reputational damage, regulatory enforcement actions, and potential criminal liability. It is therefore essential that all staff understand the key legislation, guidance, and standards that govern safeguarding practices and how these apply to their roles. This section outlines the primary legal and regulatory instruments that guide safeguarding practices in adult social care services, providing the foundation for the organisation’s policies, procedures, and day-to-day operations.

Key Legislation and Regulations

The following laws and regulations form the cornerstone of safeguarding adults in CQC-registered services:

• Care Act 2014 (In force): The cornerstone of adult safeguarding in England, the Care Act 2014 establishes the duty of local authorities to make safeguarding enquiries under Section 42 when an adult:

  • Has needs for care and support (whether or not these are being met).
  • Is experiencing, or at risk of, abuse or neglect.
  • As a result of those needs, is unable to protect themselves from the risk or experience of abuse or neglect. The Act also sets out the six safeguarding principles (Empowerment, Prevention, Proportionality, Protection, Partnership, and Accountability) that must underpin all safeguarding practices.

• Care and Support Statutory Guidance (Statutory Guidance): Issued under the Care Act, this guidance provides detailed instructions on implementing safeguarding duties, including the roles of local authorities, providers, and other stakeholders. It emphasises the importance of Making Safeguarding Personal (MSP), ensuring that the person’s wishes, capacity, and desired outcomes are central to all safeguarding actions.

• Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 — Regulation 13 (In force): This regulation places a legal duty on providers to protect service users from abuse and improper treatment. It requires providers to have systems and processes in place to prevent abuse, respond to allegations, and ensure that care and treatment are provided in a safe and respectful manner.

• Mental Capacity Act 2005 (In force): This Act provides the legal framework for supporting individuals who may lack the capacity to make decisions for themselves. It includes the requirement to act in a person’s best interests and to follow the five statutory principles, including the presumption of capacity and the least restrictive option.

• Children Act 1989 and 2004 (In force): While this policy focuses on adults, it is important to recognise that safeguarding responsibilities may extend to children in certain contexts, such as when adults with care and support needs are also parents or carers. The Children Act outlines the duty to safeguard and promote the welfare of children.

• Equality Act 2010 (In force): This Act protects individuals from discrimination, harassment, and victimisation based on protected characteristics such as age, disability, gender reassignment, race, religion or belief, sex, and sexual orientation. Discriminatory abuse is a recognised form of harm under the Care Act.

• Modern Slavery Act 2015 (In force): This Act addresses modern slavery, including human trafficking, forced labour, and servitude. It places a duty on organisations to report and respond to concerns about modern slavery affecting adults with care and support needs.

• Public Interest Disclosure Act 1998 (In force): This Act underpins whistleblowing protections, ensuring that staff can report safeguarding concerns without fear of detriment or retaliation.

Regulatory Standards and Guidance

In addition to legislation, the following regulatory standards and guidance inform safeguarding practices:

• CQC Fundamental Standards (Regulator Guidance): The CQC’s Fundamental Standards, particularly Regulation 13 (Safeguarding service users from abuse and improper treatment), set out the minimum requirements for safeguarding in regulated services. Providers must demonstrate compliance with these standards during inspections.

• NICE Guidance NG189: Safeguarding Adults in Care Homes (Good Practice): While specific to care homes, this guidance provides evidence-based recommendations on safeguarding practices that can be adapted across settings. It includes advice on recognising abuse, responding to concerns, and supporting individuals.

• Local Safeguarding Adults Board (SAB) Policies and Procedures (Statutory Guidance): Each local authority area has a SAB responsible for coordinating safeguarding activities. Providers must adhere to the multi-agency safeguarding policies and procedures established by their local SAB.

Responsibilities Under the Framework

To ensure compliance with the legal and regulatory framework, the organisation must:

• Implement robust safeguarding policies and procedures aligned with the Care Act 2014 and other relevant legislation.
• Train all staff to understand their safeguarding responsibilities and the legal framework underpinning their actions.
• Establish clear reporting and escalation procedures, ensuring concerns are referred to the Local Authority safeguarding team within [insert local timescale] and, where necessary, the CQC.
• Maintain accurate, detailed, and contemporaneous records of safeguarding concerns, actions taken, and outcomes.
• Regularly review and audit safeguarding practices to ensure alignment with current legislation and guidance.

By embedding these requirements into daily practice, the organisation ensures that safeguarding is not only a legal duty but a core organisational value.

4. Definitions

Clear and consistent definitions are essential to ensure that all staff, volunteers, and stakeholders understand the key concepts underpinning safeguarding practices. This section provides precise definitions of critical terms used throughout this policy, as outlined in the Care Act 2014 (IN_FORCE) and associated statutory guidance (STATUTORY_GUIDANCE). These definitions form the foundation for recognising, responding to, and preventing abuse and neglect in all regulated activities. Misunderstanding or misapplying these terms can lead to failures in identifying safeguarding concerns, delays in intervention, and potential harm to the persons we support.

Adopting a shared understanding of these terms also ensures compliance with legal and regulatory requirements, including the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 — Regulation 13 (IN_FORCE), which mandates the protection of service users from abuse and improper treatment. By embedding these definitions into practice, we promote a culture of vigilance, accountability, and person-centred care, ensuring that safeguarding remains a priority across all settings.

Key Definitions

• Safeguarding: Safeguarding refers to the measures taken to protect an adult’s right to live in safety, free from abuse and neglect. It involves people and organisations working together to prevent and respond to the risk of harm, while ensuring that the person’s wellbeing, wishes, and preferences are central to all actions. Safeguarding is underpinned by the six principles outlined in the Care Act 2014: Empowerment, Prevention, Proportionality, Protection, Partnership, and Accountability.

• Abuse: Abuse is a violation of an individual’s human and civil rights by another person or persons. It can take many forms, including physical, emotional, sexual, financial, and discriminatory abuse, and may involve a single act or repeated acts. Abuse can occur in any relationship and may result in significant harm to, or exploitation of, the person being abused. Abuse can be intentional or unintentional and may arise from neglect or poor practice.

• Neglect: Neglect is the failure to meet an adult’s basic physical, emotional, or social needs, which results in a significant impact on their health, wellbeing, or development. This can include failing to provide adequate food, shelter, clothing, medical care, or social support. Neglect can occur in any setting, including within a person’s own home, a care home, or a hospital.

• Adults at Risk: An adult at risk is defined under the Care Act 2014 as a person aged 18 or over who:

  • Has needs for care and support (whether or not the local authority is meeting those needs);
  • Is experiencing, or is at risk of, abuse or neglect; and
  • As a result of those care and support needs, is unable to protect themselves from either the risk of, or the experience of, abuse or neglect.

Additional Definitions

• Making Safeguarding Personal (MSP): A person-centred approach to safeguarding that ensures the individual is at the heart of the process. MSP focuses on achieving outcomes that are meaningful to the person, respecting their views, wishes, and feelings, and supporting them to make informed decisions about their own safety.

• Significant Harm: A concept used to determine the threshold for intervention in safeguarding cases. It refers to the level of harm that justifies compulsory intervention in family life in the best interests of the adult at risk. Harm may be physical, emotional, sexual, or psychological, or it may arise from neglect or exploitation.

• Capacity: Defined under the Mental Capacity Act 2005 (IN_FORCE), capacity refers to a person’s ability to make a specific decision at a particular time. A person is presumed to have capacity unless it is established that they lack it. Capacity is decision-specific and time-specific, meaning it can vary depending on the decision to be made and the circumstances at the time.

• Best Interests: A principle under the Mental Capacity Act 2005 (IN_FORCE) that requires any decision made on behalf of a person who lacks capacity to be made in their best interests, taking into account their past and present wishes, feelings, beliefs, and values.

• Advocacy: Advocacy involves supporting an individual to express their views, wishes, and feelings, and to make informed decisions. Under the Care Act 2014 (IN_FORCE), local authorities have a duty to arrange independent advocacy for adults who have substantial difficulty in being involved in safeguarding processes and have no appropriate individual to support them.

Practical Application

To ensure these definitions are consistently applied:

• All staff must be familiar with these terms and their implications for practice. This is reinforced through mandatory safeguarding training.
• Any ambiguity or uncertainty about these definitions should be escalated to the Designated Safeguarding Lead (DSL) for clarification.
• Staff should use these definitions as a reference point when identifying and reporting safeguarding concerns, ensuring that their actions align with the legal and regulatory framework.

Common Pitfalls to Avoid

• Misinterpreting the term ‘adult at risk’: Not all adults with care and support needs are at risk of abuse or neglect. Staff must assess whether the individual is unable to protect themselves due to their specific needs.
• Overlooking neglect: Neglect is often less visible than other forms of abuse but can have equally severe consequences. Staff must remain vigilant to indicators such as poor hygiene, malnutrition, or untreated medical conditions.
• Failing to apply Making Safeguarding Personal: Safeguarding is not a one-size-fits-all process. Failing to consider the person’s wishes and desired outcomes can lead to inappropriate or ineffective interventions.

By understanding and applying these definitions, [Provider Organisation Name] ensures a consistent and effective approach to safeguarding, protecting the rights and wellbeing of the persons we support.

5. Recognising Signs of Abuse and Neglect

Recognising the signs of abuse and neglect is a critical responsibility for all staff working within adult social care services. Early identification of potential safeguarding concerns can prevent further harm and ensure timely intervention to protect the person we support. Abuse and neglect can occur in any setting and may be perpetrated by anyone, including family members, friends, professionals, or strangers. It is essential that all staff remain vigilant, understand the various forms of abuse, and are able to identify the associated indicators.

The Care Act 2014 (In force) defines abuse as a violation of an individual’s human or civil rights by any other person or persons. Abuse may be a single act or repeated acts, and it can occur in any relationship where there is an expectation of trust. Neglect, on the other hand, involves the failure to meet a person’s basic needs, which can result in serious harm or distress. Both abuse and neglect can have devastating physical, emotional, and psychological consequences, and it is vital that staff are equipped to recognise the signs and take appropriate action.

Types of Abuse and Neglect

The Care Act 2014 (In force) identifies the following categories of abuse and neglect, which are applicable across all adult social care settings:

• Physical Abuse: Includes hitting, slapping, pushing, misuse of medication, restraint, or inappropriate physical sanctions.
• Domestic Abuse: Encompasses psychological, physical, sexual, financial, or emotional abuse within intimate or family relationships. This includes coercive control, honour-based violence, and forced marriage.
• Sexual Abuse: Includes rape, sexual assault, sexual harassment, inappropriate touching, or any sexual activity where the person has not given consent or lacks the capacity to consent.
• Psychological Abuse: Includes emotional abuse, threats, intimidation, humiliation, isolation, or coercion.
• Financial or Material Abuse: Includes theft, fraud, exploitation, misuse of property or possessions, or coercion in relation to financial affairs.
• Modern Slavery: Includes human trafficking, forced labour, domestic servitude, and other forms of exploitation.
• Discriminatory Abuse: Includes harassment, slurs, or similar treatment based on race, gender, disability, sexual orientation, religion, or other protected characteristics.
• Organisational Abuse: Includes poor care practices, neglect, rigid routines, and a lack of person-centred care within a service.
• Neglect and Acts of Omission: Includes failing to provide necessary care, ignoring medical or physical needs, or withholding essentials such as food, medication, or social interaction.
• Self-Neglect: Includes behaviours such as hoarding, neglecting personal hygiene, or refusing essential care or services.

Indicators of Abuse and Neglect

Staff must be trained to recognise the potential indicators of abuse and neglect, which may vary depending on the type of abuse. The following are examples of signs that may raise safeguarding concerns:

• Physical Abuse: Unexplained injuries, bruises, burns, fractures, or repeated injuries. Signs of restraint, such as marks on wrists or ankles, or a person flinching when approached.
• Domestic Abuse: Frequent injuries with vague or implausible explanations, withdrawal from social interactions, or signs of controlling behaviour by a partner or family member.
• Sexual Abuse: Bruising or bleeding in genital areas, sexually transmitted infections, pregnancy, or changes in behaviour such as withdrawal, fear, or inappropriate sexualised behaviour.
• Psychological Abuse: Low self-esteem, withdrawal, anxiety, depression, confusion, or evidence of coercion or control.
• Financial or Material Abuse: Sudden changes in financial circumstances, unexplained withdrawals from accounts, missing possessions, or unpaid bills despite adequate income.
• Modern Slavery: Signs of malnutrition, poor living conditions, lack of personal possessions, or evidence of coercion or control by others.
• Discriminatory Abuse: Expressions of distress related to discrimination, avoidance of certain people or situations, or signs of exclusion from services or activities.
• Organisational Abuse: Inflexible routines, lack of personalisation in care, poor hygiene, or a high turnover of staff.
• Neglect and Acts of Omission: Malnutrition, dehydration, untreated medical issues, poor personal hygiene, or unsafe living conditions.
• Self-Neglect: Extreme uncleanliness, hoarding, refusal of medical treatment, or living in hazardous conditions.

Staff Responsibilities in Recognising Abuse

All staff have a duty to remain vigilant and to act on any concerns about abuse or neglect. The following steps outline the responsibilities of staff in recognising and responding to potential safeguarding concerns:

• Observation: Staff must actively observe the physical, emotional, and behavioural presentation of the person we support during all interactions. Any changes or signs of distress must be noted and reported.
• Communication: Staff should engage with the person in a supportive and non-judgmental manner, encouraging them to share any concerns or experiences. It is essential to listen carefully and avoid making assumptions.
• Documentation: Any concerns, observations, or disclosures must be documented accurately and promptly in the person’s records. The documentation should include factual details, such as dates, times, and descriptions of observed signs or reported incidents.
• Reporting: All concerns must be reported immediately to the Designated Safeguarding Lead (DSL) or their deputy. If there is an immediate risk of harm, staff must take urgent action to ensure the person’s safety, including contacting emergency services if necessary.

Common Pitfalls

• Failure to Act: Assuming that someone else will report a concern or waiting for further evidence before taking action.
• Bias or Assumptions: Dismissing concerns based on assumptions about the person’s circumstances or the perceived credibility of the concern.
• Inadequate Documentation: Failing to record concerns accurately or omitting key details, which can hinder investigations.
• Overlooking Subtle Signs: Focusing only on obvious signs of abuse and neglect while missing more subtle indicators, such as changes in behaviour or mood.

Worked Scenario

A support worker notices that a person they support, who is usually sociable and talkative, has become withdrawn and avoids eye contact. They also observe bruises on the person’s arms that were not present during the previous visit. When gently asked about the bruises, the person appears anxious and provides an unclear explanation. The support worker documents their observations in the person’s records and immediately reports the concern to the DSL. The DSL contacts the Local Authority safeguarding team within the required timescale and ensures that the person’s safety is prioritised while the concern is investigated.

By recognising and acting on the signs of abuse and neglect, staff play a vital role in safeguarding adults and upholding their right to live free from harm.

6. Initial Response to Safeguarding Concerns

When a safeguarding concern arises, the immediate response is critical to ensuring the safety and well-being of the person we support. The Care Act 2014 (Section 42) places a duty on organisations to act promptly and proportionately when abuse or neglect is suspected or disclosed. Failure to take swift and appropriate action can result in further harm to the individual, undermine trust in the service, and lead to regulatory breaches under the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 — Regulation 13 (Safeguarding).

The initial response must prioritise the safety and wishes of the person while adhering to the six safeguarding principles: Empowerment, Prevention, Proportionality, Protection, Partnership, and Accountability. Staff must act in a way that is person-centred, ensuring that the individual’s voice is heard and their desired outcomes are central to the process, in line with the Making Safeguarding Personal approach. This includes assessing the immediate risk, taking protective actions if necessary, and reporting the concern to the appropriate internal and external authorities without delay.

Immediate Actions to Take When a Safeguarding Concern is Identified

When a staff member identifies or suspects abuse or neglect, or when a disclosure is made, the following steps must be taken:

• Ensure Immediate Safety:

  • If the person is in immediate danger, staff must take steps to remove them from harm. For example, this could involve moving the person to a safe location or separating them from the alleged perpetrator if it is safe to do so.
  • If a crime is suspected (e.g., physical assault, sexual abuse, theft), staff must contact the police immediately by dialling 999. Staff must also preserve any evidence (e.g., not washing clothing or cleaning a scene) to support any investigation.
  • Administer first aid if required and call emergency medical services (999) if the person has sustained injuries or requires urgent medical attention.

• Reassure and Support the Person:

  • Speak to the person in a calm, non-judgemental manner, offering reassurance that they are safe and that their concerns are being taken seriously.
  • Avoid asking leading questions or probing for detailed information, as this could compromise any subsequent investigation. Instead, listen carefully and record their exact words as soon as possible.
  • Respect the person’s dignity and privacy throughout the process.

• Report the Concern:

  • Immediately inform the Designated Safeguarding Lead (DSL) or, in their absence, the Deputy DSL. The DSL is responsible for coordinating the safeguarding response and ensuring compliance with legal and organisational procedures.
  • If the concern involves the DSL or another senior staff member, follow the organisation’s whistleblowing policy to report the issue to an appropriate external authority, such as the Local Authority Safeguarding Adults Team or the CQC.
  • Record the concern in the organisation’s safeguarding log or incident reporting system within [insert organisation’s required timescale, e.g., one hour]. Include all relevant details, such as the date, time, location, individuals involved, and actions taken.

• Preserve Confidentiality:

  • Share information only on a need-to-know basis, in line with the principles of confidentiality and data protection under the UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018.
  • Do not discuss the concern with anyone outside the safeguarding process, including colleagues not directly involved or the alleged perpetrator.

Key Roles and Responsibilities

• All Staff:

  • Recognise and respond to safeguarding concerns promptly.
  • Take immediate action to ensure the person’s safety and report concerns to the DSL without delay.
  • Record all actions and observations accurately and contemporaneously.

• Designated Safeguarding Lead (DSL):

  • Coordinate the safeguarding response, including notifying the Local Authority Safeguarding Adults Team within the required timescale (usually within 24 hours, unless immediate action is required).
  • Provide guidance and support to staff handling the concern.
  • Ensure that the person’s wishes and desired outcomes are central to the response.

• Registered Manager:

  • Oversee the safeguarding process to ensure compliance with organisational and regulatory requirements.
  • Notify the CQC of any safeguarding incidents that meet the threshold for statutory notification.

Worked Scenario: Responding to a Disclosure of Financial Abuse

A support worker notices that a person we support, who has capacity to manage their own finances, appears distressed and mentions that a family member has been withdrawing money from their account without permission. The support worker reassures the person, listens carefully, and records their exact words. They immediately inform the DSL, who contacts the Local Authority Safeguarding Adults Team to report the concern. The DSL also advises the person on how to protect their finances, such as contacting their bank to freeze the account. The person’s wishes are respected throughout, and they are supported to decide on the next steps.

Common Pitfalls to Avoid

• Delays in Reporting: Failing to act promptly can expose the person to further harm and result in regulatory non-compliance.
• Inadequate Record-Keeping: Vague or incomplete records can undermine safeguarding investigations and lead to poor outcomes for the person.
• Breach of Confidentiality: Sharing information inappropriately can damage trust and may contravene data protection laws.
• Failure to Preserve Evidence: Cleaning a crime scene or discarding potential evidence can hinder police investigations.

By adhering to these procedures, staff can ensure that safeguarding concerns are addressed effectively, protecting the person’s safety and upholding their rights.

7. Reporting and Escalation Procedures

Timely and effective reporting of safeguarding concerns is critical to ensuring the safety and wellbeing of the person we support, as well as meeting the organisation’s legal and regulatory obligations. Under the Care Act 2014 (In force), all staff have a duty to report any suspicion or knowledge of abuse or neglect, regardless of whether the concern arises from direct observation, a disclosure, or third-party information. Failure to report concerns can result in harm to the person, regulatory breaches, and reputational damage to the organisation. Reporting and escalation procedures must be clear, accessible, and consistently followed to ensure that safeguarding concerns are addressed promptly and appropriately.

Good practice in reporting safeguarding concerns involves recognising the urgency of the situation, ensuring the immediate safety of the person, and following a structured reporting pathway. This includes internal reporting to the Designated Safeguarding Lead (DSL) or their deputy, external reporting to the local authority safeguarding team, and, where required, notifying the Care Quality Commission (CQC). Staff must also be aware of the importance of accurate and contemporaneous record-keeping, as well as the need to respect confidentiality while sharing information appropriately in line with legal and regulatory requirements.

Internal Reporting Process

1. Recognising a Concern

   • Any staff member who identifies or suspects abuse or neglect must act immediately. This includes concerns arising from direct observation, disclosures from the person we support, or information shared by third parties (e.g., family members, other professionals).
   • If the person is in immediate danger, staff must prioritise their safety by contacting emergency services (999) and taking any necessary steps to prevent further harm (e.g., removing the person from the source of danger, if safe to do so).

2. Reporting to the Designated Safeguarding Lead (DSL)

   • All safeguarding concerns must be reported to the DSL or their deputy as soon as possible and no later than the end of the working shift.
   • The DSL for the organisation is the [Registered Manager/Designated Role], and the deputy DSL is [Deputy Role]. Contact details for the DSL and deputy DSL are displayed prominently in all service locations.
   • Staff must provide a factual account of the concern, including the date, time, location, individuals involved, and any actions taken. This must be documented using the organisation’s [Safeguarding Concern Form] and submitted to the DSL.

3. Initial Review by the DSL

   • Upon receiving a report, the DSL will review the information to assess the level of risk and determine the appropriate course of action. This must be completed within 24 hours of the concern being raised.
   • If the DSL is unavailable, the deputy DSL will assume responsibility for the review.

External Reporting Process

1. Reporting to the Local Authority Safeguarding Team

   • If the concern meets the threshold for a safeguarding enquiry under section 42 of the Care Act 2014 (In force), the DSL must make a referral to the local authority safeguarding team without delay.
   • The referral must include all relevant details, including the person’s name, date of birth, address, nature of the concern, and any immediate actions taken.
   • The local authority’s safeguarding team contact details are: [Local Authority Safeguarding Team telephone and email].
   • The referral must be made within 24 hours of the concern being identified.

2. Notifying the Care Quality Commission (CQC)

   • Where the safeguarding concern involves a regulated activity and meets the criteria for a statutory notification under Regulation 18 of the Care Quality Commission (Registration) Regulations 2009 (In force), the DSL must notify the CQC.
   • Notifications must be submitted via the CQC Provider Portal or by email to [CQC notification email], using the appropriate statutory notification form.
   • The notification must be made as soon as practicable and within 24 hours of the concern being identified.

3. Involving the Police

   • If a crime is suspected (e.g., physical assault, sexual abuse, financial exploitation), the DSL must contact the police immediately by calling 101 (or 999 in an emergency).
   • Staff must preserve any evidence (e.g., clothing, photographs of injuries, financial records) to support a potential investigation.

Escalation Procedures

1. Escalating Unresolved Concerns

   • If a staff member believes that a safeguarding concern has not been appropriately addressed by the DSL, they must escalate the matter to the Responsible Individual or use the organisation’s whistleblowing policy.
   • The whistleblowing policy ensures that staff can raise concerns without fear of reprisal. Contact details for the organisation’s whistleblowing lead are: [Whistleblowing contact details].

2. Multi-Agency Escalation

   • If the local authority safeguarding team does not take appropriate action, the DSL must escalate the concern to the Safeguarding Adults Board (SAB) or seek advice from the organisation’s legal or professional safeguarding advisors.

Record-Keeping Requirements

• All safeguarding concerns, actions taken, and decisions made must be documented in the person’s safeguarding file and the organisation’s central safeguarding log.
• Records must be factual, dated, and signed by the staff member making the report and the DSL.
• The organisation must retain safeguarding records for a minimum of [insert retention period] in line with data protection legislation.

Worked Scenario: Reporting a Safeguarding Concern

Scenario: A support worker observes unexplained bruising on a person’s arms and suspects physical abuse.

1. The support worker immediately ensures the person is safe and comfortable.
2. They report the concern to the DSL by the end of their shift, completing the [Safeguarding Concern Form].
3. The DSL reviews the concern and contacts the local authority safeguarding team within 24 hours.
4. The DSL notifies the CQC via the Provider Portal, as the concern involves a regulated activity.
5. The DSL documents all actions taken in the safeguarding log and liaises with the local authority to support the safeguarding enquiry.

Common Pitfalls to Avoid

• Delaying the reporting of concerns, which can place the person at further risk.
• Failing to document the concern accurately, leading to gaps in the safeguarding record.
• Not escalating unresolved concerns, resulting in inaction.
• Breaching confidentiality by sharing information inappropriately.

By adhering to these reporting and escalation procedures, the organisation ensures compliance with its legal and regulatory duties while prioritising the safety and wellbeing of the person we support.

8. Safeguarding Enquiries and Investigations

Under section 42 of the Care Act 2014 (In force), local authorities have a statutory duty to conduct safeguarding enquiries where an adult with care and support needs is experiencing, or at risk of, abuse or neglect, and as a result of those needs is unable to protect themselves. As a CQC-registered adult social care provider, [Provider Organisation Name] has a legal and moral obligation to cooperate fully with local authority safeguarding enquiries and, where appropriate, to conduct internal investigations that align with statutory guidance and local safeguarding adults board (SAB) protocols. Failure to engage effectively in safeguarding enquiries can result in harm to the person we support, regulatory action, reputational damage, and legal consequences for the organisation.

A safeguarding enquiry seeks to establish the facts, ascertain the adult’s views and wishes, assess the risk of harm, and determine what actions are required to protect the individual and prevent further harm. It is essential that all enquiries are person-centred, proportionate, and conducted in a manner that upholds the six safeguarding principles: Empowerment, Prevention, Proportionality, Protection, Partnership, and Accountability. [Provider Organisation Name] is committed to ensuring that the person we support is at the heart of the enquiry process, in line with the principles of Making Safeguarding Personal. This means that the person’s views, wishes, and desired outcomes will guide the enquiry and any subsequent actions, provided this does not place them or others at further risk of harm.

8.1 Cooperation with Local Authority Safeguarding Enquiries

When the local authority initiates a safeguarding enquiry, [Provider Organisation Name] will:

• Nominate a lead contact: The Designated Safeguarding Lead (DSL) will act as the primary point of contact for the local authority and other relevant agencies. The DSL is responsible for ensuring timely and accurate communication and for coordinating the organisation’s response.
• Provide timely information: All requested information, including records, incident reports, risk assessments, and staff statements, will be shared promptly with the local authority, in line with data protection legislation and the principles of confidentiality outlined in section 12 of this policy.
• Attend strategy meetings: The DSL or a delegated senior staff member will attend all multi-agency safeguarding meetings, including strategy discussions, case conferences, and review meetings, as required by the local authority.
• Implement agreed actions: Any actions agreed upon during the enquiry process will be implemented promptly and effectively. This may include changes to care plans, additional staff training, or adjustments to organisational policies and procedures.
• Support the person we support: The organisation will ensure that the person at the centre of the enquiry is kept informed and supported throughout the process. This includes providing access to advocacy services where appropriate.

8.2 Conducting Internal Safeguarding Investigations

In some cases, the local authority may delegate aspects of the safeguarding enquiry to [Provider Organisation Name] or request that the organisation conducts its own internal investigation. In such cases, the following steps will be taken:

1. Appointment of an Investigating Officer: The DSL will appoint a senior staff member, independent of the incident, to act as the Investigating Officer (IO). The IO must have appropriate training and experience in safeguarding investigations.
2. Planning the Investigation: The IO will develop an investigation plan, which will include:
   • The scope and objectives of the investigation.
   • A timeline for completion, ensuring that the investigation is concluded within [local authority timescale] or, where no timescale is specified, within 28 calendar days.
   • A list of individuals to be interviewed, including the person we support, staff members, and any witnesses.
   • A review of relevant documentation, including care plans, incident reports, and training records.
3. Conducting Interviews: Interviews will be conducted in a manner that is respectful, non-judgmental, and supportive. The person we support will be offered the opportunity to have an advocate or representative present.
4. Preserving Evidence: Any physical, digital, or documentary evidence will be preserved and documented in line with organisational procedures and legal requirements. This includes securing CCTV footage, safeguarding records, and communication logs.
5. Reporting Findings: The IO will compile a detailed investigation report, which will include:
   • A summary of the allegations and the context in which they arose.
   • The evidence gathered and the methodology used.
   • An analysis of the findings, including whether the allegations are substantiated, unsubstantiated, or inconclusive.
   • Recommendations for action, including any disciplinary measures, changes to practice, or referrals to external agencies.
6. Review and Approval: The investigation report will be reviewed by the DSL and the Registered Manager before being submitted to the local authority and any other relevant parties.

8.3 Escalation and Oversight

• Escalation to the Local Authority: If, during an internal investigation, it becomes apparent that the person we support is at immediate risk of harm or that a criminal offence may have occurred, the DSL will immediately escalate the matter to the local authority safeguarding team and, if necessary, the police.
• Notification to the CQC: In accordance with Regulation 18 of the Care Quality Commission (Registration) Regulations 2009 (In force), the Registered Manager will notify the CQC of any safeguarding incident that meets the criteria for a statutory notification within 24 hours of becoming aware of the incident.
• Whistleblowing: Staff are encouraged to report any concerns about the conduct of the investigation through the organisation’s whistleblowing policy. Whistleblowers will be protected from victimisation or reprisal in line with the Public Interest Disclosure Act 1998 (In force).

8.4 Common Pitfalls and How to Avoid Them

• Failure to act promptly: Delays in responding to safeguarding concerns can place the person we support at further risk. All concerns must be reported immediately, and enquiries or investigations must adhere to agreed timescales.
• Lack of documentation: Inadequate record-keeping can undermine the integrity of the enquiry. Staff must ensure that all actions, decisions, and communications are documented accurately and contemporaneously.
• Not involving the person: Failing to involve the person we support in the enquiry process can lead to outcomes that do not reflect their wishes. Staff must ensure that the person’s voice is central to the process, in line with Making Safeguarding Personal.

8.5 Worked Scenario

Scenario: A staff member notices unexplained bruising on a person we support during a routine care visit. The person appears withdrawn and reluctant to speak.

Actions:

1. The staff member reports the concern immediately to their line manager and records the observation in the safeguarding log.
2. The DSL reviews the concern and contacts the local authority safeguarding team within the same working day, as required by local protocols.
3. The local authority initiates a safeguarding enquiry and requests information from [Provider Organisation Name]. The DSL provides all requested documentation within 48 hours.
4. The local authority delegates the internal investigation to [Provider Organisation Name]. The DSL appoints an IO, who completes the investigation within 21 days and submits the findings to the local authority.
5. The person we support is kept informed throughout the process and is offered advocacy support to ensure their voice is heard.

By adhering to these procedures, [Provider Organisation Name] ensures compliance with statutory requirements and maintains the safety and dignity of the person we support.

9. Risk Assessment and Management

Effective risk assessment and management are critical components of safeguarding adults, ensuring that individuals are protected from further harm while promoting their safety, dignity, and autonomy. The process of assessing and managing risks must be person-centred, proportionate, and aligned with the six safeguarding principles outlined in the Care Act 2014. A robust risk management approach not only identifies potential or actual risks but also implements measures to mitigate these risks while respecting the rights and wishes of the person we support. Failure to adequately assess and manage risks can lead to further harm, a breach of regulatory requirements, and loss of trust in the service.

Risk assessment and management must be a dynamic and ongoing process, responsive to changes in circumstances, needs, and preferences. It involves collaboration with the person we support, their family or advocates (where appropriate), and relevant professionals or agencies. The process must balance the need to protect individuals from harm with their right to make informed choices, even where those choices involve an element of risk. This is underpinned by the principles of Making Safeguarding Personal, ensuring that the person’s voice is central to all decisions.

Key Steps in Risk Assessment and Management

1. Identifying Risks
   Risks may arise from various sources, including the person’s environment, relationships, behaviours, or external factors. Staff must remain vigilant for indicators of abuse, neglect, or self-neglect, as well as other risks such as financial exploitation, social isolation, or health-related concerns. Risks may be identified through:

   • Observations of the person’s physical or emotional state.
   • Disclosures made by the person or others.
   • Changes in behaviour or circumstances.
   • Reports from family members, advocates, or other professionals.

2. Assessing Risks
   Once a risk is identified, it must be assessed to determine its nature, likelihood, and potential impact. This involves:

   • Engaging with the person to understand their perspective, wishes, and concerns.
   • Considering the person’s capacity to make decisions about their safety, in line with the Mental Capacity Act 2005.
   • Evaluating the severity of the risk, including the potential for immediate or long-term harm.
   • Identifying any protective factors, such as support networks or existing safeguards.
   • Documenting the assessment clearly and comprehensively.

3. Developing a Risk Management Plan
   A risk management plan outlines the actions to be taken to mitigate identified risks while respecting the person’s autonomy. This plan must be:

   • Person-centred: Developed in collaboration with the person and, where appropriate, their family or advocate.
   • Proportionate: Balancing the need for protection with the person’s right to take informed risks.
   • Specific: Detailing the steps to be taken, who is responsible, and the timescales for implementation.
   • Dynamic: Regularly reviewed and updated to reflect changes in circumstances or new information.

4. Implementing Safeguards
   Safeguards may include:

   • Adjusting the person’s environment to reduce risks (e.g., improving lighting, removing trip hazards).
   • Increasing supervision or support where necessary.
   • Facilitating access to advocacy or counselling services.
   • Engaging with external agencies, such as the Local Authority safeguarding team, healthcare providers, or the police, where appropriate.
   • Ensuring staff are aware of and adhere to the risk management plan.

5. Monitoring and Reviewing Risks
   Risk management is an ongoing process. Regular monitoring and review ensure that the measures in place remain effective and appropriate. This includes:

   • Scheduling regular review meetings with the person and relevant stakeholders.
   • Updating the risk assessment and management plan in response to new information or changes in circumstances.
   • Documenting all reviews and any changes made to the plan.

Roles and Responsibilities

• Designated Safeguarding Lead (DSL): Oversees the risk assessment and management process, ensuring compliance with legal and regulatory requirements. The DSL must also provide guidance and support to staff and escalate concerns to external agencies where necessary.
• Staff Members: Responsible for identifying risks, reporting concerns promptly, and implementing the risk management plan as directed.
• Registered Manager: Ensures that risk assessments are completed, documented, and reviewed in line with organisational policies and regulatory standards.
• External Agencies: Where required, the Local Authority safeguarding team, police, or other professionals may be involved in assessing and managing risks.

Documentation and Evidence

All risk assessments and management plans must be documented in the person’s care records. This includes:

• The initial risk assessment, including the identified risks, their likelihood, and potential impact.
• The risk management plan, detailing the actions to be taken, responsible parties, and timescales.
• Records of any reviews or updates to the plan.
• Evidence of the person’s involvement in the process and their consent (or best interest decisions where applicable).

Worked Scenario: Managing Risk in Practice

Scenario: A staff member notices that a person we support, who has a history of self-neglect, has stopped attending medical appointments and is refusing home visits from healthcare professionals.

Actions:

1. The staff member reports their concerns to the DSL immediately.
2. The DSL arranges a meeting with the person to discuss their reasons for refusing support and to understand their wishes.
3. A risk assessment is conducted, identifying the potential for harm due to untreated health conditions.
4. A risk management plan is developed, including actions such as arranging a joint visit with a trusted advocate, providing written information about the importance of medical care, and scheduling regular check-ins.
5. The plan is reviewed weekly, with adjustments made as necessary based on the person’s response and engagement.

Common Pitfalls:

• Failing to involve the person in the risk assessment process, leading to plans that do not reflect their wishes or needs.
• Neglecting to document the risk assessment and management plan, resulting in a lack of evidence for regulatory compliance.
• Delaying action, which may increase the risk of harm.

By following these procedures, [Provider Organisation Name] ensures that risks are managed effectively, safeguarding the individuals we support while respecting their rights and autonomy.

10. Person-Centred Safeguarding

Person-centred safeguarding ensures that the rights, wishes, and dignity of the person we support are at the heart of all safeguarding practices. This approach aligns with the Care Act 2014’s statutory principles, particularly Empowerment, Prevention, and Proportionality, and embeds the ethos of Making Safeguarding Personal (MSP). MSP requires that safeguarding interventions are led by the outcomes the person wants to achieve, respecting their autonomy, capacity, and consent wherever possible. Failure to adopt a person-centred approach risks disempowering individuals, undermining their trust in services, and potentially causing further harm.

In practice, person-centred safeguarding means actively involving the person in decisions about their safety and support, ensuring they feel heard and respected. It requires staff to balance the need to protect individuals from harm with the duty to uphold their rights to make choices about their own lives, even where those choices involve a degree of risk. Good practice involves clear communication, tailored support, and a commitment to working collaboratively with the person, their family (where appropriate), and other professionals to achieve outcomes that are meaningful to them.

Key Principles of Person-Centred Safeguarding

• Respect for Autonomy: The person’s right to make decisions about their life, including decisions others may perceive as unwise, is respected unless they lack capacity under the Mental Capacity Act 2005 (In force).
• Empowerment: The person is supported to understand their options and make informed choices about their safety and well-being.
• Dignity and Respect: Safeguarding practices must uphold the person’s dignity, privacy, and cultural or personal preferences.
• Proportionality: Responses to safeguarding concerns are proportionate to the level of risk and avoid unnecessary intrusion into the person’s life.
• Consent and Capacity: The person’s consent is sought before taking action, unless doing so would place them or others at immediate risk, or they lack capacity to consent.

Steps to Ensure Person-Centred Safeguarding

1. Engagement and Communication

   • Staff must engage with the person in a way that is accessible and meaningful to them. This may involve using communication aids, interpreters, or advocates.
   • The person’s views, wishes, and feelings must be actively sought and documented. Staff should ask open-ended questions, listen without judgment, and avoid making assumptions about what the person wants.
   • Where the person has difficulty expressing their wishes, staff must explore alternative methods of communication and involve an independent advocate if necessary, as required under the Care Act 2014 (Statutory Guidance).

2. Assessment of Risk and Capacity

   • If a safeguarding concern arises, staff must assess the person’s capacity to make decisions about their safety, following the principles of the Mental Capacity Act 2005.
   • Where the person has capacity, their decisions must be respected, even if they choose not to take action to reduce risk. Staff should provide information about potential consequences and offer ongoing support.
   • If the person lacks capacity, decisions must be made in their best interests, involving family members or advocates where appropriate, and considering the least restrictive options.

3. Tailored Safeguarding Plans

   • Safeguarding plans must be co-produced with the person wherever possible, reflecting their priorities and desired outcomes.
   • Plans should include specific actions to address risks while promoting the person’s independence and quality of life.
   • Regular reviews must be conducted to ensure the plan remains relevant and effective, with the person’s input sought at every stage.

4. Multi-Agency Collaboration

   • Staff must work collaboratively with other agencies to ensure a holistic approach to safeguarding. This includes sharing information appropriately and involving the person in multi-agency meetings where feasible.
   • The person’s consent to share information must be obtained unless there is a legal or safeguarding justification for overriding consent.

5. Support and Advocacy

   • The organisation must ensure the person has access to advocacy services where needed, particularly if they have difficulty understanding safeguarding processes or communicating their wishes.
   • Staff must provide emotional support and reassurance throughout the safeguarding process, recognising the potential distress caused by raising or addressing concerns.

Evidence of Person-Centred Safeguarding in Practice

• Records: Detailed records must demonstrate how the person’s views, wishes, and outcomes have been considered and acted upon. This includes documenting any discussions about capacity, consent, and risk.
• Safeguarding Plans: Plans must clearly reflect the person’s priorities and show how these have been balanced with the need to manage risk.
• Feedback Mechanisms: The organisation must have systems in place to gather feedback from the person about their experience of the safeguarding process and use this to improve practices.

Common Pitfalls and How to Avoid Them

• Overriding the Person’s Wishes: Staff must avoid making decisions on behalf of the person without a clear legal or safeguarding justification. Regular training on the Mental Capacity Act 2005 can help prevent this.
• Failure to Communicate Effectively: Using jargon or failing to adapt communication methods can exclude the person from the process. Staff should receive training in accessible communication techniques.
• Neglecting Emotional Impact: Safeguarding processes can be distressing. Staff must provide ongoing emotional support and signpost to counselling services where appropriate.

Scenario: Applying Person-Centred Safeguarding

A person we support, who has capacity, reports financial abuse by a family member but is reluctant to involve the police. The staff member discusses the risks and options with the person, ensuring they understand the potential consequences of not taking action. The person decides they want support to manage their finances independently but does not want to pursue legal action. The staff member respects this decision, helps the person set up a separate bank account, and documents the agreed actions in the safeguarding plan. The person is also informed that they can revisit their decision at any time.

By adopting a person-centred approach, the organisation ensures the person feels empowered and supported, while also addressing the safeguarding concern in a way that respects their autonomy and wishes.

11. Multi-Agency Working

Effective multi-agency working is a cornerstone of safeguarding practice and is essential to ensuring the safety and well-being of the persons we support. The Care Act 2014 places a statutory duty on organisations to cooperate with other agencies, including local authorities, health services, and the police, to protect adults at risk of abuse or neglect. Collaborative working enables the sharing of expertise, resources, and information, ensuring that safeguarding responses are timely, proportionate, and person-centred. Failure to engage effectively with multi-agency partners can lead to fragmented responses, missed opportunities to protect individuals, and non-compliance with statutory obligations, which may result in regulatory action.

Good practice in multi-agency working involves clear communication, defined roles and responsibilities, and adherence to local safeguarding adults board (SAB) protocols. It requires a culture of openness and mutual respect between agencies, underpinned by robust information-sharing agreements that comply with the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR). Staff must understand when and how to escalate concerns to external agencies and how to contribute effectively to safeguarding enquiries, strategy meetings, and case conferences. This section outlines the organisation’s approach to multi-agency working, ensuring compliance with legal and regulatory requirements while prioritising the safety and dignity of the persons we support.

Key Principles of Multi-Agency Working

• Partnership and Collaboration: Building strong relationships with local safeguarding adults boards, local authority safeguarding teams, the police, NHS organisations, and other relevant agencies.
• Information Sharing: Sharing information in a timely and secure manner, in line with statutory guidance and data protection legislation, to safeguard individuals effectively.
• Clarity of Roles: Ensuring all staff understand their responsibilities in multi-agency safeguarding processes and how these align with the roles of external partners.
• Person-Centred Approach: Ensuring that the person we support remains at the centre of all multi-agency discussions and decisions, in line with the principles of Making Safeguarding Personal.

Multi-Agency Safeguarding Procedures

1. Identifying the Need for Multi-Agency Involvement

   • When a safeguarding concern is raised, the Designated Safeguarding Lead (DSL) or their deputy will assess whether the concern requires multi-agency input. This may include situations involving criminal activity, significant risk of harm, or complex needs requiring input from multiple services.
   • The DSL will consult the local safeguarding adults board (SAB) procedures to determine the appropriate course of action.

2. Raising a Safeguarding Concern

   • The DSL will ensure that safeguarding concerns are reported to the local authority safeguarding team within 24 hours of identification, as per the Care Act 2014 and local SAB protocols.
   • If a crime is suspected, the DSL will contact the police immediately and ensure that any evidence is preserved.

3. Participation in Multi-Agency Meetings

   • The DSL or an appropriate representative will attend safeguarding strategy meetings, case conferences, and other multi-agency forums as required.
   • Prior to attending, the DSL will gather all relevant information, including records of the concern, risk assessments, and any actions already taken, to contribute effectively to the discussion.
   • The organisation will ensure that the person we support, their family, or their advocate (where appropriate) is involved in the process and that their views and wishes are represented.

4. Information Sharing

   • Information will be shared with external agencies on a need-to-know basis, ensuring compliance with the Data Protection Act 2018 and UK GDPR.
   • Consent from the person we support will be sought wherever possible, unless doing so would place them or others at increased risk of harm.
   • All information shared will be documented, including the rationale for sharing, the method of sharing, and the recipient agency.

5. Joint Risk Assessment and Action Planning

   • The organisation will work collaboratively with other agencies to assess risks and develop a safeguarding plan that addresses the immediate and long-term needs of the person we support.
   • Actions agreed upon during multi-agency meetings will be documented, and the organisation will ensure that its responsibilities are completed within the agreed timescales.

6. Escalation of Concerns

   • If the organisation believes that a safeguarding concern is not being adequately addressed by a partner agency, the DSL will escalate the matter in line with local SAB escalation procedures.
   • The Registered Manager will be informed of any escalation, and the organisation will maintain a record of all actions taken.

Roles and Responsibilities

• Designated Safeguarding Lead (DSL):

  • Acts as the primary point of contact for multi-agency safeguarding matters.
  • Ensures timely reporting of concerns to the local authority and other relevant agencies.
  • Represents the organisation in multi-agency meetings and ensures that the organisation’s actions are aligned with agreed safeguarding plans.

• All Staff:

  • Report safeguarding concerns to the DSL promptly.
  • Cooperate with multi-agency processes, including providing information and attending meetings when required.

• Registered Manager:

  • Oversees the organisation’s compliance with multi-agency safeguarding requirements.
  • Supports the DSL in escalating concerns and resolving inter-agency disputes.

Records and Documentation

• Records of all multi-agency communications, including referrals, meeting minutes, and action plans, will be maintained securely in the person’s safeguarding file.
• The DSL will ensure that all documentation is accurate, up-to-date, and available for inspection by regulators or safeguarding partners.

Worked Scenario

A staff member notices unexplained bruises on a person we support and reports this to the DSL. The DSL determines that the concern meets the threshold for a safeguarding enquiry and contacts the local authority safeguarding team within 24 hours. The local authority convenes a strategy meeting, which the DSL attends, providing detailed records of the concern and the organisation’s initial actions. During the meeting, it is agreed that the police will investigate a potential crime, while the organisation will implement additional safeguarding measures, such as increased staff supervision. The DSL ensures that the person’s views are represented and that all agreed actions are completed within the specified timescales.

Common Pitfalls

• Failing to report safeguarding concerns to the local authority promptly.
• Sharing information without a clear rationale or appropriate consent.
• Not attending or adequately preparing for multi-agency meetings.
• Lack of follow-up on agreed actions, leading to delays in safeguarding responses.

By adhering to these procedures, the organisation ensures robust multi-agency collaboration, fulfilling its statutory duties and prioritising the safety and well-being of the persons we support.

12. Confidentiality and Information Sharing

Confidentiality is a cornerstone of safeguarding practice, ensuring that the privacy and dignity of the person we support are respected while enabling the effective sharing of information to protect them from harm. The organisation is committed to adhering to the legal and ethical principles governing confidentiality, as outlined in the Data Protection Act 2018, the UK General Data Protection Regulation (UK GDPR), the Care Act 2014, and the Caldicott Principles. However, it is equally recognised that safeguarding adults at risk may necessitate the sharing of personal or sensitive information with relevant parties, even without the consent of the person, where there is a risk of significant harm or where it is in the public interest.

The balance between maintaining confidentiality and sharing information appropriately is critical to effective safeguarding. Staff must understand that while confidentiality is important, it is not an absolute duty. The safety and welfare of the person we support take precedence over concerns about sharing information. Failure to share information appropriately can result in missed opportunities to prevent harm, while excessive or inappropriate sharing can lead to breaches of trust, legal consequences, and reputational damage for the organisation. This section provides clear guidance on how to navigate these responsibilities in compliance with legal and regulatory requirements.

Principles of Confidentiality and Information Sharing

The organisation’s approach to confidentiality and information sharing in safeguarding is underpinned by the following principles:

• Lawfulness, fairness, and transparency: Information must be processed lawfully, fairly, and in a transparent manner in relation to the person we support.
• Purpose limitation: Information should only be shared for specific, explicit, and legitimate purposes.
• Data minimisation: Only information that is relevant and necessary for safeguarding purposes should be shared.
• Accuracy: Shared information must be accurate and up to date.
• Storage limitation: Information must not be retained for longer than necessary.
• Accountability: The organisation must demonstrate compliance with data protection laws and safeguarding duties.

Situations Requiring Information Sharing

Information may need to be shared in the following safeguarding scenarios:

• With consent: Where the person we support has the capacity to consent and provides informed consent for their information to be shared.
• Without consent: When there is a reasonable belief that sharing information is necessary to prevent serious harm, protect the person or others, or prevent or detect a crime. This includes situations where the person lacks the mental capacity to make decisions about their own safety, and sharing is in their best interests under the Mental Capacity Act 2005.
• With statutory agencies: When required by law or statutory guidance, such as reporting safeguarding concerns to the Local Authority under the Care Act 2014 or notifying the Care Quality Commission (CQC) of safeguarding incidents under Regulation 13 of the Health and Social Care Act 2008.

Step-by-Step Procedure for Information Sharing

1. Identify the Purpose:

   • Determine the specific safeguarding purpose for which the information needs to be shared.
   • Consider whether the information is necessary, proportionate, and relevant to the identified safeguarding concern.

2. Seek Consent Where Appropriate:

   • If the person we support has the capacity to consent, explain why the information needs to be shared, with whom, and for what purpose.
   • Record their decision, including any reasons for refusal, in their care record.
   • If consent is refused, assess whether there is an overriding public interest or legal obligation to share the information without consent.

3. Assess Capacity:

   • If the person’s capacity to consent is in doubt, conduct a capacity assessment in line with the Mental Capacity Act 2005.
   • If the person lacks capacity, make a best interests decision, involving relevant parties such as family members or advocates, where appropriate.

4. Share Information Securely:

   • Share information only with those who need to know, such as the Local Authority safeguarding team, the police, or other relevant professionals.
   • Use secure methods of communication, such as encrypted emails or password-protected documents, to prevent unauthorised access.

5. Document the Decision:

   • Record the details of the information shared, including what was shared, with whom, the date and time, and the rationale for sharing.
   • Include any consent obtained or the justification for sharing without consent.

6. Follow Up:

   • Ensure that the information shared has been received and understood by the intended recipient.
   • Monitor the situation and provide further information if required.

Escalation and Oversight

• The Designated Safeguarding Lead (DSL) is responsible for overseeing all decisions related to information sharing in safeguarding cases. Staff must escalate any complex or high-risk cases to the DSL for guidance.
• If there is uncertainty about whether to share information, staff should seek advice from the DSL or the Local Authority safeguarding team.
• The organisation’s Data Protection Officer (DPO) must be consulted if there are concerns about potential breaches of data protection laws.

Common Pitfalls and How to Avoid Them

• Failure to share information: Staff may hesitate to share information due to fear of breaching confidentiality. To avoid this, staff must be trained to understand that safeguarding takes precedence over confidentiality when there is a risk of harm.
• Sharing excessive information: Only share what is necessary and relevant to the safeguarding concern. Avoid sharing unrelated or sensitive personal details.
• Inadequate documentation: Failure to record decisions and actions can lead to accountability issues. Always document information-sharing decisions thoroughly.

Worked Scenario

A support worker notices unexplained bruises on a person they support and suspects physical abuse. The person has capacity and initially refuses to allow the information to be shared. The support worker explains the safeguarding duty and the potential risks of not sharing the information. Despite this, the person maintains their refusal. The support worker escalates the concern to the DSL, who assesses the situation and determines that the risk of significant harm justifies sharing the information without consent. The DSL contacts the Local Authority safeguarding team, providing only the necessary details. The decision and rationale are documented in the person’s care record, and the person is informed of the action taken.

By following these procedures, the organisation ensures that safeguarding information is shared appropriately, balancing the need to protect individuals with the duty to maintain confidentiality.

13. Roles & Responsibilities

Safeguarding is a fundamental responsibility shared by all individuals within the organisation, regardless of their role or seniority. Every staff member, volunteer, and contractor has a duty to protect adults at risk of abuse or neglect, as defined under the Care Act 2014. This section outlines the specific safeguarding responsibilities assigned to various roles within the organisation, ensuring clarity and accountability at all levels. A clear delineation of responsibilities is essential to meet regulatory requirements, foster a culture of safeguarding, and ensure timely and effective responses to safeguarding concerns.

The organisation’s safeguarding framework is built on the principles of accountability and partnership, ensuring that safeguarding is embedded in daily practice and decision-making. The Designated Safeguarding Lead (DSL) and senior management team play a pivotal role in providing leadership, oversight, and support, while all staff are expected to remain vigilant and proactive in identifying and reporting concerns. Failure to fulfil safeguarding responsibilities can result in harm to individuals, regulatory breaches, and reputational damage to the organisation. Therefore, this section provides detailed guidance on the roles and responsibilities of all staff, with a focus on ensuring compliance with statutory and regulatory requirements.

13.1 All Staff

All staff, regardless of their role, are responsible for:

• Understanding safeguarding policies and procedures: Staff must familiarise themselves with this policy and attend mandatory safeguarding training at induction and at least annually thereafter.
• Recognising signs of abuse or neglect: Staff must be able to identify potential indicators of abuse, as outlined in Section 5 of this policy.
• Responding appropriately to disclosures or concerns: If a person we support discloses abuse or neglect, staff must listen without judgment, provide reassurance, and avoid probing questions.
• Reporting concerns immediately: Staff must report any safeguarding concerns to their line manager or the DSL without delay. Where a crime may have occurred, staff must ensure the immediate safety of the person and contact emergency services if required.
• Maintaining accurate records: Staff must document safeguarding concerns factually and contemporaneously, using the organisation’s designated safeguarding reporting forms.

13.2 Designated Safeguarding Lead (DSL)

The DSL is a senior member of staff with overall responsibility for safeguarding within the organisation. This role is critical for ensuring compliance with the Care Act 2014 and associated statutory guidance. The DSL’s responsibilities include:

• Providing leadership and expertise: Acting as the primary point of contact for safeguarding concerns and providing guidance to staff on safeguarding matters.
• Managing referrals: Ensuring that safeguarding concerns are referred to the Local Authority Safeguarding Adults Team within 24 hours, or immediately if the risk is urgent.
• Liaising with external agencies: Working collaboratively with local safeguarding boards, the police, healthcare providers, and other relevant agencies to ensure a coordinated response.
• Monitoring and reviewing safeguarding practices: Regularly auditing safeguarding records, reviewing incidents, and identifying trends to improve practice.
• Delivering training and support: Ensuring all staff receive appropriate safeguarding training and providing additional support to staff involved in safeguarding cases.
• Notifying the CQC: Ensuring that the Care Quality Commission is notified of any safeguarding incidents in line with Regulation 18 of the Care Quality Commission (Registration) Regulations 2009.

13.3 Senior Management Team

The senior management team, including the Registered Manager and Responsible Individual, has strategic oversight of safeguarding within the organisation. Their responsibilities include:

• Establishing a safeguarding culture: Promoting a zero-tolerance approach to abuse and embedding safeguarding principles into all aspects of service delivery.
• Allocating resources: Ensuring sufficient resources are available to support safeguarding activities, including training, staffing, and external consultancy where required.
• Policy development and review: Ensuring that safeguarding policies and procedures are up to date, reflect current legislation, and are reviewed at least annually or following significant incidents.
• Governance and accountability: Monitoring safeguarding performance through regular reports from the DSL and ensuring that lessons learned from safeguarding incidents are implemented.
• Supporting the DSL: Providing the DSL with the authority, time, and resources needed to fulfil their role effectively.

13.4 Line Managers

Line managers play a key role in supporting their teams to fulfil their safeguarding responsibilities. Their duties include:

• Supervising staff: Providing regular supervision to discuss safeguarding concerns and ensuring staff understand their responsibilities.
• Escalating concerns: Ensuring that any safeguarding concerns raised by staff are promptly reported to the DSL.
• Monitoring practice: Observing staff interactions with the people we support to identify and address any potential safeguarding risks.
• Supporting staff involved in safeguarding cases: Providing emotional and practical support to staff who may be affected by safeguarding incidents.

13.5 Volunteers and Contractors

Volunteers and contractors working with the organisation must:

• Adhere to safeguarding policies: Understand and comply with the organisation’s safeguarding procedures.
• Report concerns: Immediately report any safeguarding concerns to their organisational contact or the DSL.
• Complete safeguarding training: Attend safeguarding training appropriate to their role and level of contact with the people we support.

13.6 Escalation and Whistleblowing

All staff, volunteers, and contractors have a duty to escalate safeguarding concerns if they believe that appropriate action has not been taken. The organisation’s whistleblowing policy provides protection for individuals who raise concerns in good faith, ensuring they are not subject to retaliation or discrimination.

13.7 Evidence of Compliance

To demonstrate compliance with safeguarding responsibilities, the organisation maintains:

• Training records: Documenting attendance at safeguarding training sessions.
• Safeguarding logs: Recording all safeguarding concerns, actions taken, and outcomes.
• Audit reports: Regular audits of safeguarding practices and records.
• Governance meeting minutes: Documenting discussions and decisions related to safeguarding.

By clearly defining roles and responsibilities, the organisation ensures that safeguarding is a shared priority, embedded in practice, and supported by robust systems of accountability.

14. Training & Competence

Ensuring that all staff are adequately trained and competent in safeguarding adults is a fundamental requirement for meeting our legal and regulatory obligations under the Care Act 2014 and Regulation 13 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (In force). Effective safeguarding training equips staff with the knowledge, skills, and confidence to identify, respond to, and escalate safeguarding concerns appropriately. A failure to provide robust training can result in missed opportunities to protect individuals from harm, regulatory breaches, and reputational damage to the organisation.

At [Provider Organisation Name], safeguarding training is mandatory for all staff, regardless of role or seniority, and is tailored to reflect the specific responsibilities and risks associated with their position. Training is designed to ensure that staff understand the six safeguarding principles (Empowerment, Prevention, Proportionality, Protection, Partnership, and Accountability) and can apply them in their daily practice. It also embeds the principles of Making Safeguarding Personal, ensuring that the wishes, capacity, and consent of the person we support are central to all safeguarding actions. Competence is not assumed upon completion of training; it is assessed and monitored through ongoing supervision, reflective practice, and periodic refresher courses.

14.1 Safeguarding Training Requirements

The safeguarding training programme at [Provider Organisation Name] is structured as follows:

• Induction Training:
  All new staff must complete safeguarding adults training as part of their induction. This training must be completed before they undertake any unsupervised work with individuals we support. The induction covers:

  • The legal and regulatory framework for safeguarding adults.
  • Recognising signs of abuse and neglect, including specific indicators for different types of abuse.
  • Immediate actions to take when a safeguarding concern arises, including preserving evidence and reporting routes.
  • The role of the Designated Safeguarding Lead (DSL) and escalation procedures.
  • An introduction to Making Safeguarding Personal and the importance of person-centred approaches.

• Role-Specific Training:
  Staff in roles with additional safeguarding responsibilities, such as managers, team leaders, and the DSL, must complete enhanced safeguarding training. This includes:

  • Conducting safeguarding enquiries under section 42 of the Care Act 2014.
  • Risk assessment and management in safeguarding cases.
  • Multi-agency working and information sharing.
  • Supporting staff involved in safeguarding cases.
  • Legal considerations, including the Mental Capacity Act 2005 and Deprivation of Liberty Safeguards (DoLS).

• Refresher Training:
  All staff must complete safeguarding refresher training at least annually. This ensures that knowledge remains current and reflects any changes in legislation, guidance, or organisational policy. Refresher training includes updates on:

  • Emerging safeguarding risks and trends (e.g., online abuse, financial scams).
  • Lessons learned from safeguarding incidents within the organisation or sector.
  • Updates to local safeguarding board procedures.

• Specialist Training:
  Where relevant, staff may be required to undertake specialist training on specific safeguarding issues, such as domestic abuse, modern slavery, or self-neglect. This is determined based on the needs of the people we support and the risks identified in the service.

14.2 Competency Expectations

Competence in safeguarding is defined as the ability to apply knowledge and skills effectively in practice to protect adults at risk. Competency expectations are as follows:

• All Staff:

  • Understand the organisation’s safeguarding policy and procedures.
  • Recognise signs of abuse and neglect and know how to respond appropriately.
  • Demonstrate the ability to report concerns promptly and accurately.
  • Apply the principles of Making Safeguarding Personal in all interactions.

• Managers and Team Leaders:

  • Lead safeguarding responses within their teams.
  • Support staff in recognising and responding to safeguarding concerns.
  • Conduct initial risk assessments and ensure appropriate escalation.
  • Liaise effectively with external agencies, including local authority safeguarding teams.

• Designated Safeguarding Lead (DSL):

  • Provide expert advice and guidance on safeguarding matters.
  • Oversee safeguarding enquiries and ensure compliance with statutory duties.
  • Deliver internal safeguarding training and support reflective practice.
  • Monitor safeguarding trends and report to senior management and the CQC as required.

14.3 Monitoring and Evidence of Competence

Competence is monitored and evidenced through the following mechanisms:

• Supervision and Appraisal:
  Safeguarding knowledge and practice are reviewed during regular supervision sessions and annual appraisals. Managers assess staff confidence and understanding through reflective discussions and case reviews.

• Observation of Practice:
  Line managers observe staff interactions with individuals we support to ensure safeguarding principles are embedded in practice.

• Training Records:
  Comprehensive records are maintained for all safeguarding training completed by staff, including dates, content, and outcomes. These records are audited quarterly to ensure compliance with training schedules.

• Competency Assessments:
  Staff may be required to complete written or practical assessments following training to demonstrate their understanding and ability to apply safeguarding knowledge.

14.4 Common Pitfalls and Mitigation

• Pitfall: Staff failing to recognise subtle signs of abuse or neglect.
  Mitigation: Enhanced training on recognising less obvious indicators, such as changes in behaviour or financial irregularities.

• Pitfall: Delayed reporting of concerns due to uncertainty about procedures.
  Mitigation: Clear guidance provided during training, supported by accessible flowcharts and on-call support from the DSL.

• Pitfall: Inconsistent application of Making Safeguarding Personal.
  Mitigation: Role-play scenarios and reflective practice sessions included in training to reinforce person-centred approaches.

14.5 Evidence for Regulators

To demonstrate compliance with safeguarding training requirements, [Provider Organisation Name] maintains the following evidence:

• Training schedules and attendance records.
• Certificates of completion for all safeguarding courses.
• Competency assessment results.
• Supervision and appraisal records documenting safeguarding discussions.
• Internal audit reports on training compliance and effectiveness.

By embedding robust training and competency frameworks, [Provider Organisation Name] ensures that all staff are equipped to fulfil their safeguarding responsibilities, protecting adults at risk and maintaining compliance with regulatory standards.

15. Monitoring, Audit & Review

Effective safeguarding practices require continuous monitoring, regular auditing, and systematic review to ensure compliance with statutory requirements, adherence to best practice, and the ongoing protection of the people we support. Monitoring and auditing processes provide the organisation with a clear understanding of how safeguarding policies and procedures are being implemented in practice, identifying areas of strength and opportunities for improvement. Regular reviews ensure that safeguarding arrangements remain fit for purpose, responsive to changes in legislation, guidance, or the needs of the people we support.

The Care Act 2014 (In force) and the Care and Support Statutory Guidance (Statutory Guidance) underline the importance of accountability in safeguarding, requiring organisations to demonstrate that they have robust systems in place to prevent and respond to abuse and neglect. Regulation 13 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (In force) further mandates that providers must protect service users from abuse and improper treatment. Monitoring, auditing, and reviewing safeguarding practices are essential to meeting these legal obligations and to providing evidence of compliance to the Care Quality Commission (CQC) and other regulatory bodies.

Monitoring Safeguarding Practices

Monitoring is an ongoing process that ensures safeguarding practices are being implemented consistently and effectively. It involves the systematic collection and analysis of data to identify trends, gaps, and areas for improvement. Key elements of safeguarding monitoring include:

• Daily Monitoring by Staff: All staff members are responsible for observing and reporting any safeguarding concerns or deviations from established procedures. This includes monitoring the well-being of the people we support, identifying potential risks, and ensuring that safeguarding measures are consistently applied.
• Incident Reporting and Review: All safeguarding incidents, concerns, or allegations must be recorded and reported in line with the organisation’s reporting procedures. The Designated Safeguarding Lead (DSL) will review all incident reports to identify patterns or recurring issues that may require further investigation or action.
• Supervision and Appraisals: Line managers will use regular supervision and appraisal meetings to monitor staff understanding and implementation of safeguarding policies and procedures. Any gaps in knowledge or practice will be addressed through targeted support or training.

Auditing Safeguarding Practices

Auditing is a structured process that evaluates the effectiveness of safeguarding arrangements against defined standards and regulatory requirements. Audits provide an opportunity to assess compliance, identify risks, and implement corrective actions. The organisation will conduct safeguarding audits as follows:

• Internal Audits: The DSL or a delegated senior manager will conduct quarterly safeguarding audits. These audits will review:
  • Incident and concern records to ensure they are complete, accurate, and actioned appropriately.
  • Staff training records to confirm compliance with mandatory safeguarding training requirements.
  • Risk assessments and care plans to verify that safeguarding measures are in place and regularly reviewed.
  • Feedback from the people we support, their families, and advocates to assess the effectiveness of safeguarding practices.
• External Audits: Where appropriate, the organisation will commission independent safeguarding audits to provide an objective assessment of its safeguarding arrangements. Findings from external audits will be used to inform improvements and demonstrate transparency to regulators and stakeholders.

Reviewing Safeguarding Practices

Regular review of safeguarding policies, procedures, and practices ensures that they remain current, effective, and aligned with legal and regulatory requirements. The organisation will undertake the following review activities:

• Annual Policy Review: The Safeguarding Adults Policy will be reviewed annually or sooner if there are significant changes in legislation, guidance, or organisational circumstances. The review will be led by the DSL and approved by the Responsible Individual.
• Post-Incident Reviews: Following any significant safeguarding incident, a review will be conducted to identify lessons learned and implement improvements. This process will include input from staff, the person affected (where appropriate), and relevant external agencies.
• Feedback Mechanisms: The organisation will actively seek feedback from the people we support, staff, and other stakeholders on the effectiveness of safeguarding arrangements. Feedback will be gathered through surveys, meetings, and complaints processes and will inform the review process.

Evidence of Monitoring, Audit, and Review

To demonstrate compliance and continuous improvement, the organisation will maintain detailed records of all monitoring, audit, and review activities. These records will include:

• Completed safeguarding audit reports, including findings, actions taken, and outcomes.
• Records of supervision and appraisal meetings where safeguarding was discussed.
• Documentation of policy reviews, including dates, participants, and changes made.
• Post-incident review reports, including lessons learned and actions implemented.
• Feedback from the people we support and other stakeholders, along with responses and actions taken.

Worked Scenario: Monitoring and Audit in Practice

Scenario: During a quarterly safeguarding audit, the DSL identifies a trend of delayed reporting of safeguarding concerns by night staff. The audit reveals that while concerns are being recorded in the communication log, they are not being escalated to the DSL until the following morning.

Actions Taken:

1. The DSL reviews the organisation’s safeguarding reporting procedures with night staff during a team meeting, emphasising the importance of immediate escalation.
2. A targeted training session is arranged for night staff to reinforce their understanding of safeguarding responsibilities and reporting protocols.
3. The DSL introduces a new system for night staff to directly notify the on-call manager of any safeguarding concerns, ensuring timely action.

Outcome: Subsequent audits show that safeguarding concerns are being escalated promptly, reducing delays in protective action and improving outcomes for the people supported.

Common Pitfalls and How to Avoid Them

• Incomplete Records: Failing to maintain accurate and detailed records of safeguarding concerns and actions taken can undermine the organisation’s ability to demonstrate compliance. Staff must be trained on the importance of thorough documentation.
• Infrequent Audits: Conducting audits less frequently than planned can result in missed opportunities to identify and address issues. The organisation must adhere to its audit schedule and allocate sufficient resources to complete audits effectively.
• Failure to Act on Findings: Identifying issues during monitoring or audits without implementing corrective actions can lead to repeated failures. The organisation must ensure that all findings are followed up with clear action plans and regular progress reviews.

By embedding robust monitoring, audit, and review processes into its safeguarding framework, the organisation ensures that safeguarding practices are continuously evaluated, improved, and aligned with its commitment to protecting the people it supports.

16. Records & Documentation

Accurate, timely, and secure record-keeping is a fundamental component of safeguarding practice. It ensures that safeguarding concerns are appropriately documented, actions are traceable, and outcomes are clearly evidenced. This not only supports the protection of the person we support but also demonstrates compliance with legal and regulatory requirements, including the Care Act 2014 (In force) and Regulation 13 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (In force). Poor or incomplete records can compromise the safety of individuals, hinder effective safeguarding responses, and expose the organisation to regulatory breaches or legal challenges.

Good practice in safeguarding documentation requires that all records are factual, objective, and free from bias. Records must detail what was observed or disclosed, the actions taken, and the rationale for decisions made. They must also reflect the principles of Making Safeguarding Personal, ensuring the person’s wishes, capacity, and desired outcomes are central to the safeguarding process. All records must be stored securely to maintain confidentiality and comply with data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (In force).

Key Requirements for Safeguarding Records

1. Content of Safeguarding Records
   Safeguarding records must include the following details:

   • Initial Concern: The nature of the concern, including specific details of what was observed, disclosed, or suspected. This should include dates, times, and locations.
   • Details of the Person: The name, date of birth, and any other relevant identifying information of the person we support.
   • Actions Taken: A clear and chronological record of all actions taken, including:
     • Who was informed (e.g., Designated Safeguarding Lead, Local Authority Safeguarding Team).
     • Any immediate protective measures implemented.
     • Whether the police or other emergency services were contacted.
   • Decision-Making: The rationale for decisions made, including how the person’s wishes and capacity were considered.
   • Outcomes: The result of any safeguarding enquiry or investigation, including any changes to the person’s care plan or risk management strategy.
   • Involvement of the Person: Evidence of how the person was involved in the process and how their views and desired outcomes were taken into account.

2. Roles and Responsibilities in Record-Keeping

   • All Staff: Responsible for promptly recording any safeguarding concerns or disclosures they observe or receive. This must be done as soon as possible and always within 24 hours of the concern arising.
   • Designated Safeguarding Lead (DSL): Responsible for reviewing safeguarding records for accuracy and completeness, ensuring appropriate actions are taken, and maintaining oversight of all safeguarding documentation.
   • Managers: Responsible for auditing safeguarding records to ensure compliance with organisational and regulatory standards.

3. Format and Storage of Records

   • Format: Records must be written in a clear, professional manner, avoiding jargon or subjective language. Where possible, direct quotes from the person or witnesses should be included.
   • Storage: All safeguarding records must be stored securely, either in a locked filing cabinet (for paper records) or within a secure, password-protected electronic system. Access must be restricted to authorised personnel only.
   • Retention: Records must be retained in accordance with the organisation’s data retention policy and statutory requirements. Typically, safeguarding records should be retained for a minimum of eight years after the last contact with the person, or longer if required by law.

4. Confidentiality and Information Sharing

   • Safeguarding records must be treated as confidential. Information should only be shared on a need-to-know basis and in line with the organisation’s confidentiality and information-sharing policy.
   • When sharing information with external agencies, such as the Local Authority Safeguarding Team or the police, ensure that the sharing is lawful, proportionate, and necessary to protect the person or others.

Common Pitfalls in Safeguarding Record-Keeping

• Delays in Recording: Failing to document concerns promptly can result in critical details being forgotten or omitted.
• Subjective Language: Using terms like “seemed upset” without providing factual observations (e.g., “the person was crying and shaking”) can undermine the credibility of the record.
• Incomplete Records: Omitting key details, such as the date and time of the concern or the actions taken, can hinder effective safeguarding responses.
• Failure to Reflect the Person’s Wishes: Not documenting how the person’s views and desired outcomes were considered can result in non-compliance with Making Safeguarding Personal principles.

Worked Scenario: Effective Safeguarding Documentation

A support worker notices bruising on a person’s arm during a routine visit. The person discloses that a family member has been physically aggressive. The support worker immediately informs the DSL and documents the following:

• The date, time, and location of the observation.
• A factual description of the bruising (e.g., “a 5cm purple bruise on the upper left arm”).
• The person’s disclosure, using their exact words where possible.
• The immediate action taken (e.g., informing the DSL, contacting the Local Authority Safeguarding Team).
• The person’s expressed wishes (e.g., “The person stated they do not want the family member to visit them anymore”).
• The DSL’s follow-up actions, including contacting the Local Authority and updating the person’s care plan.

Evidence for Compliance

To demonstrate compliance, the organisation must maintain:

• A centralised safeguarding log, updated in real time.
• Individual safeguarding records for each concern, stored securely and accessible only to authorised personnel.
• Evidence of regular audits of safeguarding records by managers or the DSL.
• Documentation of staff training on safeguarding and record-keeping.

By adhering to these standards, the organisation ensures that safeguarding records are robust, defensible, and supportive of the person’s safety and well-being.

17. References and Live Links

This section provides a comprehensive list of the legal, regulatory, and best practice frameworks that underpin this Safeguarding Adults Policy. These references ensure that the organisation’s safeguarding practices align with current statutory requirements and recognised guidance. Staff must be familiar with these documents to understand the legal and professional obligations that govern their roles. Inspectors and auditors will expect to see evidence of compliance with these frameworks during inspections or reviews.

The following references are categorised by their source and include their current status (e.g., in force, statutory guidance, regulator guidance, or good practice). Where applicable, live links to the full text of these documents are provided to facilitate access. Providers must ensure that all staff have access to and understand these documents as part of their safeguarding training and ongoing professional development.

Primary Legislation

1. Care Act 2014 (In force)

   • Governs the statutory safeguarding duties for adults with care and support needs.
   • Section 42 outlines the duty to make safeguarding enquiries.
   • URL: Care Act 2014

2. Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (In force)

   • Regulation 13 sets out the requirements for safeguarding service users from abuse and improper treatment.
   • URL: Health and Social Care Act 2008 (Regulated Activities) Regulations 2014

3. Mental Capacity Act 2005 (In force)

   • Provides the framework for assessing capacity and making decisions in the best interests of individuals who lack capacity.
   • URL: Mental Capacity Act 2005

4. Equality Act 2010 (In force)

   • Protects individuals from discrimination, harassment, and victimisation, including in the context of safeguarding.
   • URL: Equality Act 2010

5. Children Act 1989 and 2004 (In force)

   • Relevant where safeguarding concerns involve adults who are also parents or carers of children.
   • URL: Children Act 1989
   • URL: Children Act 2004

6. Modern Slavery Act 2015 (In force)

   • Addresses offences of slavery, servitude, forced or compulsory labour, and human trafficking.
   • URL: Modern Slavery Act 2015

Statutory Guidance

1. Care and Support Statutory Guidance (Statutory guidance)

   • Provides detailed guidance on implementing the Care Act 2014, including safeguarding duties and principles.
   • URL: Care and Support Statutory Guidance

2. Working Together to Safeguard Children (2018) (Statutory guidance)

   • Sets out inter-agency working to safeguard and promote the welfare of children, relevant where adults at risk are also parents or carers.
   • URL: Working Together to Safeguard Children

3. Prevent Duty Guidance for England and Wales (2015) (Statutory guidance)

   • Provides guidance on preventing individuals from being drawn into terrorism, relevant to safeguarding in adult social care.
   • URL: Prevent Duty Guidance

Regulator Guidance

1. CQC Regulation 13: Safeguarding Service Users from Abuse and Improper Treatment (Regulator guidance)

   • Outlines the expectations of the Care Quality Commission (CQC) regarding safeguarding practices in regulated services.
   • URL: CQC Regulation 13 Guidance

2. CQC Guidance for Providers on Meeting the Regulations (2015) (Regulator guidance)

   • Explains how to meet the fundamental standards, including safeguarding requirements.
   • URL: CQC Guidance for Providers

Best Practice and Additional Resources

1. NICE Guideline NG189: Safeguarding Adults in Care Homes (2021) (Good practice)

   • Provides evidence-based recommendations for safeguarding adults in care home settings.
   • URL: NICE Guideline NG189

2. Social Care Institute for Excellence (SCIE) Safeguarding Adults Resources (Good practice)

   • Offers a range of tools and resources to support safeguarding practices.
   • URL: SCIE Safeguarding Adults Resources

3. UK Health Security Agency (UKHSA) Guidance on Safeguarding in Health and Social Care (Good practice)

   • Provides public health guidance relevant to safeguarding in adult social care.
   • URL: UKHSA Safeguarding Guidance

Local Authority Safeguarding Adults Board (SAB) Policies

Each Local Authority has its own Safeguarding Adults Board (SAB) with specific policies and procedures. Staff must familiarise themselves with the relevant local SAB guidance and contact details.

• [Insert Local Authority Safeguarding Adults Board URL or contact information here]

Whistleblowing Guidance

1. Public Interest Disclosure Act 1998 (In force)

   • Protects workers who disclose information about malpractice, including safeguarding concerns.
   • URL: Public Interest Disclosure Act 1998

2. National Whistleblowing Helpline for Health and Social Care (Good practice)

   • Provides confidential advice on whistleblowing in health and social care.
   • URL: National Whistleblowing Helpline

Note for Providers

Providers must ensure that all staff have access to these references and are trained to understand their relevance to safeguarding practices. Regular updates to this section are required to reflect any changes in legislation, guidance, or local authority frameworks.