The outline below should be used as a checklist to ensure that your organisation has addressed all the issues in respect of policy and procedure for safeguarding adults.
Wiltshire Council has deliberately not provided a pro-forma. It is important that everyone in your organisation ‘owns’ the safeguarding adults policy and procedure document you develop and that it meets the particular requirements of your organisation.
It is often when working together on a safeguarding document that potential issues emerge, providing the opportunity to think them through before having to face them in reality.
Contents
When you are developing your internal policy and procedure guide on safeguarding adults it may help to divide it into the following sections:
Introduction – why you have developed a safeguarding adults - policy and procedure document and when it applies.
Policy – what your organisation intends to do and what it needs to have in place to enable it to do this.
Procedures – the action that you expect trustees/directors, staff and volunteers to take if they have concerns about abuse.
Guidance – what you need to have in place to support your organisation to develop good practice in respect of safeguarding adults.
Introduction
When it applies
The introduction should make clear that your organisation will always employ the policies and procedures stated in this document if a vulnerable person is being abused i.e. being caused significant harm by another person.
It would be helpful to note how the procedures relate to other relevant procedures, such as complaints, critical incidents, employment and whistleblowing.
To whom it applies
You may wish to specify that it applies to all trustees, staff and volunteers and make it clear that they have a duty to report any allegations or suspicions of abuse.
How it relates to local inter-agency procedures
It should be made clear that any organisation’s procedure in safeguarding adults does not stand alone, but needs to be read in conjunction with the booklet “No Secrets in Swindon and Wiltshire” This is a summary of the “Policy and procedure for safeguarding vulnerable adults in Swindon and Wiltshire”.
Definitions
A definition should be included of the actions and behaviours that are considered to be abusive and of who may be an ‘adult at risk of abuse’.
You may need to clarify other terms that you are going to use, for example if the term ‘volunteer’ also covers those people who receive a gratuity and what you mean by a ‘user of the service’.
If you are going to identify a lead officer this could be a good place to make clear what that person’s role will be.
Policy
This section should describe the commitment of your organisation to safeguarding vulnerable adults and you should consider whether you need to include the following:
- recognition that vulnerable adults have the right to be treated in a way that respects their rights, independence and choice, including the right to be safe
- a commitment by your organisation to ‘zero tolerance’ of abuse and an undertaking to ensure that services for which you have a responsibility will be run in a way that recognises these rights and treats people with respect and dignity
- recognition that some people are more likely to be abused and that this places a responsibility on trustees, directors, staff and volunteers to report any allegations or suspicions of abuse in accordance with your organisational procedure and the “Policy and procedure for safeguarding vulnerable adults in Swindon and Wiltshire”
- an agreement to promote actively an organisational culture within which all those who express concern will be treated seriously and will receive a positive response from management
- a commitment to provide support to any trustee, director, member of staff, or volunteer who is involved in an investigation carried out using the “Policy and procedure for safeguarding vulnerable adults in Swindon and Wiltshire”.
- an assurance that confidentiality and information sharing relating to adult safeguarding and the perpetrators of abuse are maintained through agreed protocols in a multi-agency context
- an agreement that your organisation will fund or co-fund services only from organisations that agree to abide by the requirements of the “Policy and procedure for safeguarding vulnerable adults in Swindon and Wiltshire”.
Actions to support your policy
This section should outline the actions that the organisation is going to take to ensure that it is managed in a way that supports the principles of good practice set out in the policy.
A. Working within local safeguarding arrangements
This should include a commitment by the trustees/directors to ensure that everyone in the organisation understands that they:
- have a duty to report any allegations and suspicions of abuse and to whom they should report
- should not carry out their own investigations into any allegations of abuse, but always report their concerns in accordance with the organisation’s safeguarding adults policy, procedures and guidance and the “Policy and procedure for safeguarding vulnerable adults in Swindon and Wiltshire”.
- should inform anyone who reports an allegation or suspicion of abuse that they will have to take action in accordance with the organisation's safeguarding adults policy, procedures and guidance.
- will co-operate with any investigations into allegations of abuse which are undertaken using the “Policy and procedure for safeguarding vulnerable adults in Swindon and Wiltshire”.
- will be offered support by the trustees/directors of the organisation if they are involved in a safeguarding adults’ investigation.
B. Preventing abuse
This section should include information on how the organisation intends to promote a ‘zero tolerance’ of abuse and manage the service in a way that aims to prevent abuse. Areas that should be addressed include:
- the way that the services that are provided by or funded by the organisation will work in a way that respects the rights of service users and promotes their independence
- a commitment to provide the service within a safe environment with due regard given to health and safety guidelines and the management of risk
- where appropriate a reference to guidance on:
- the boundaries of personal relationships with service users
- appropriate physical contact
- assessment of risk
- the handling of money and personal effects
- managing challenging behaviour
- the investigation of complaints
- managing medication
- managing physical interventions (restraint)
- A statement about the organisations’ policy towards managers, staff and volunteers who share doubts and concerns about colleagues; this is sometimes referred to as ‘whistle-blowing’.
- A statement about how the organisation’s complaints procedure relates to the safeguarding policy.
C. Informing and empowering service users
- This section should include information on how the organisation intends to support service users to be safe.
- This includes helping service users to understand what might be abusive behaviour and how they can report this.
- This section should also include a commitment to inform carers, relatives and supporters that the organisation will take seriously any concerns about abuse and how they can report abuse or make a complaint.
D. Recruitment
This section should include a description of the way that safeguarding is built into recruitment practices. It should include:
- a commitment by the trustees/directors to ensure that robust recruitment practices for directors, managers, staff and volunteers are adhered to, both in services for which the organisation is directly responsible and those for which they provide funding
- a clear statement on the organisation’s policy in respect of CRB checks, references and the rehabilitation of offenders. www.crb.gov.uk
- how the organisation will comply with the requirements of the Safeguarding Vulnerable Groups Act (2006). http://www.isa-gov.org.uk
E. Training: awareness of abuse
This section should include a description of the training that will be available to enable staff to understand what abuse is, how to prevent abuse and how to report any concerns. This should include a commitment that all trustees/directors, managers, staff and volunteers:
- will be made aware at the time of their induction of their responsibility to report any allegations or suspicions of abuse
- will read “No Secrets in Swindon and Wiltshire” or ’Keeping People Safe in Wiltshire’ (for people who may find it easier to read a more accessible document) and will discuss it with their line manager or volunteer coordinator
- where appropriate will undertake training in safeguarding adults such as that provided by Wiltshire Council.
F. Responding to allegations that a trustee/director, manager, staff member or volunteer has abused a vulnerable adult
- Guidance needs to be developed to make clear what action will be taken in the event of an allegation of abuse being made against a trustee/director, manager, staff member or volunteer. Someone in the organisation needs to be identified to take responsibility to:
- ensure that the appropriate referral has been made using the “Policy and procedure for safeguarding vulnerable adults in Swindon and Wiltshire”.
- consider whether the individual should be required to cease undertaking any duties on behalf of the organisation until any investigation undertaken following the safeguarding adults procedure has been completed
- consider how support can be offered to the person against whom the allegation has been made.
For further guidance see: Section T “Allegations against staff” in the “Policy and procedure for safeguarding vulnerable adults in Swindon and Wiltshire.
Procedure
This section describes the action that should be taken by trustees/directors, staff and volunteers if they become aware that a vulnerable adult is being or may have been abused.
The abuse may have been carried out within your organisation or an incident outside your organisation may be observed or reported to someone within your organisation. The duty to report remains the same in all cases.
It is important to keep the operational procedure simple so that everyone is clear about what action they need to take.
Your organisation’s operational procedure should include guidance on:
- emergency action: staff should be clear that they should contact the emergency services if someone is in immediate danger or requires urgent medical treatment
- reporting a concern: although staff and volunteers are advised to report any concerns to their line manager it is not advisable to develop a system that involves a long line of reporting within the organisation, or reporting only to a single named individual as this may cause undue delay
- referring the concern to Wiltshire Council’s department of community services: it must be made clear whose responsibility it is to report any concerns to Wiltshire Council’s department of community services (DCS). This should be done as soon as possible. Although your organisation may want to designate who would normally make a safeguarding adults’ referral, everyone in the organisation should be aware that they can make a direct referral to DCS, if they have concerns about abuse. This is particularly important if they suspect that their line manager is colluding in the abuse, their concerns are not being taken seriously, or they are unable to contact the person to whom they are required to report.
- undertaking your own investigation: on no account must anyone in the organisation undertake their own investigation into the allegation of abuse. Remember it is not the responsibility of your organisation to investigate the abuse, only to report it.
- responding to a disclosure: your organisation's procedure should make it clear that in all cases the allegation will be taken seriously. The person reporting the allegation must be re-assured that their report is believed. They should be allowed to say what they are concerned about without interruption and without being asked investigative questions.
- what to do if the service user does not want a referral to be made: if the service user does not wish the allegation to be reported, consideration needs to be given as to the seriousness of the allegation, whether they have the mental capacity to make a decision regarding their own safety and whether other people may be at risk. The reason for not making a referral under the safeguarding adults procedures should always be recorded.
- recording: the person to whom the allegation has been reported should write down in detail what they have seen, or what has been reported to them, using the alleged victim’s own words and what action has been taken. In recording what the person has said, facts must be clearly separated from opinion. The record should be signed and dated
- confidentiality: the person reporting the safeguarding concern should not discuss it with anyone else unless it is necessary to protect the vulnerable person, or to secure evidence. On no account should the matter be discussed with the alleged abuser.
- preserving evidence: whilst the first concern will be the immediate well-being of the victim, efforts to preserve evidence may be vital to the investigation of the incident. Do not touch or remove anything unless it is for the immediate well-being of the victim, or the preservation of the evidence.
- supporting someone through an investigation: everyone in the organisation should be prepared to co-operate with the safeguarding investigation. This may include offering support to the person reporting the abuse and the alleged victim and may involve being interviewed by a social worker or police officer.
- responsibility to report concerns about the safety and well-being of a child: even if you provide services only to adult service users, your organisation needs to keep information on how to report concerns about the safety and well-being of a child.
Guidance
It is helpful to gather information on safeguarding that will support the work in your organisation. This could include more information on abuse and on national organisations which provide information and advice.
You may also wish to include details of the level of training that trustees/directors, managers, staff and volunteers will need to support your safeguarding work and how you are going to provide that training.
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Last updated: 2 December 2010