This is a copy of our safeguarding policy and procedure:
Safeguarding People at Risk Policy
1. Policy Statement
1.1 CIB’s safeguarding aim is to ensure that people at risk are not harmed in any way whilst accessing our services.
1.2 This policy applies to all service-users, employees, volunteers, and trustees of CIB.
1.3 Any behaviour that is deemed to put people at risk of harm will not be tolerated and action will be taken immediately with referral if necessary to the appropriate statutory agencies. If the incident involves an employee or volunteer internal action as outlined in the Disciplinary Policy and the Volunteer Problem Solving Procedures may be taken.
1.4 All employees, volunteers, and trustees will receive induction training to provide them with information to ensure that they able to safeguard and promote the welfare of people at risk who access our services. More in-depth training will be provided to all those who work directly or have contact with people at risk.
1.5 Safe recruitment practices play a critical role in our aim to ensure that people are suitable to work with people at risk. Therefore any person involved in the recruitment process must refer to the Recruitment and Selection Policy.
1.6 Those engaging volunteers must attend the volunteer management course. And refer to the volunteer recruitment and selection guides.
1.7 This policy and procedural guidance will be reviewed as necessary.
Section 126(1) of the Social Services and Well-being (Wales) Act 2014 defines an adult at risk as an adult who:-
(a) is experiencing or is at risk of abuse or neglect;
(b) has needs for care and support (whether or not the authority is meeting any of those needs); and
(c) as a result of those needs is unable to protect himself or herself against the abuse or neglect or the risk of it.”
This definition of an “adult at risk” applies in relation to the statutory powers and duties included in Part 7 of the Act and, for those purposes, replaces the definition of a “vulnerable adult” included within In Safe Hands (Welsh Assembly Government 2000).
Section 197(1) of the Act provides definitions of “abuse” and “neglect”:
“abuse” means physical, sexual, psychological, emotional or financial abuse (and includes abuse taking place in any setting, whether in a private dwelling, an institution or any other place), and “financial abuse” includes:-
- having money or other property stolen;
- being defrauded;
- being put under pressure in relation to money or other property;
3.1 The aim of the Safeguarding Peoples at Risk policy is to outline the procedures all staff and volunteers must follow to ensure that safeguarding concerns are managed appropriately.
4. Roles and responsibilities
All employees, volunteers, and trustees must comply with this policy by:
- Familiarising themselves with and following the Safeguarding People at Risk Policy.
- Making sure that their own conduct does not lead to safeguarding concerns.
In addition to the above trustees, managers, supervisors, and HR team have the following responsibilities:
- Ensure that those benefiting from, or working with CIB are not harmed in any way through contact with it.
Safeguarding risk owner:
- Ensure that safeguarding processes and resources introduced to reduce the risk of harm are appropriate and compliance is achieved across all services.
Manager and supervisors:
- Make all staff aware of and ensure compliance with safeguarding processes.
- Take all safeguarding allegations / incidents seriously and ensure that they are reported and investigated in line with this policy.
- Develop plans to ensure that actions arising out of investigations are carried out.
- Carry out regular trend analysis of all incidents and develop action plans if necessary.
Human Resources team:
- Support CIB to develop, review and amend HR policies, procedures and training in line with legislation, best practice. guidance, incident analysis and external notifications
- Advise and support managers throughout investigations, disciplinary and capability processes.
- Escalate areas of non compliance with HR processes to senior managers and the safeguarding risk owner.
5. Recognising safeguarding concerns
5.1 It is not always easy to recognise safeguarding concerns and the concerns may at times be unfounded however to reach that conclusion all concerns must be taken seriously and must be investigated.
I addition to the definition provided in the Social Services and Well-being (Wales) Act, the list below gives examples of events / behaviour that might give rise to safeguarding concerns, however the list is not exhaustive and cannot cover every eventuality and everyone working within CIB must raise concerns if they feel uncomfortable with anything they see or are told about:
- Pressure sores
- Poor nutritional care
- Lack of social inclusion
- Failure to follow safe moving and handling procedures
- Failure to follow safeguarding procedures
- Missed / wrong medication
- Staff / volunteers forming inappropriate relationships with vulnerable people
- Failure to follow care /support / behaviour management plans
- Falsification of references, qualifications or data during the recruitment process
- Inappropriate use of IT systems to access sexually explicit or exploitative material
- A declaration of a criminal conviction or police caution whilst employed or volunteering for CIB
- Missing money or valuables
- Any deprivation of liberty
- Rough treatment, being rushed, shouted at or ignored
- Institutional care
- Physical abuse, bullying and harassment between vulnerable people
6. Responding to safeguarding concerns
6.1 The following process must be followed for all safeguarding concerns except those where shared care arrangements are in place and CIB is not the responsible lead organisation. In these circumstances the concern should be reported to the lead organisation who will then take responsibility for carrying out any action. An accident / incident form should still be completed for analysis purposes.
6.2 Whenever a safeguarding concern is reported / observed the first step must be to consider if any immediate action is necessary to ensure vulnerable people are safeguarded and to carry out that action.
6.3 The concern must then be reported to the person responsible for safeguarding in your service, this may be your line manager, supervisor or local designated safeguarding person.
6.4 If you feel you cannot report your concern to the person responsible for safeguarding in your service then you can email the corporate safeguarding team at [email protected]
6.5 The person responsible for managing safeguarding concerns in your service will consider if the concern meets the criteria for immediate referral to the police or local external safeguarding teams and will refer if necessary.
6.6 If the police or local external safeguarding team accept the referral they will then decide on the next course of action and managers should refer to the child and adult protection policies.
6.7 All concerns must then be reported to the safeguarding, quality and compliance team using the safeguarding email [email protected]
6.8 All concerns must also be recorded on CIB’s accident / incident report.
6.9 The person responsible for managing safeguarding concerns in your service will decide if the concern meets the criteria for reporting to external care / education regulators such as Ofsted and significant others such as family members or sponsoring authorities and will report accordingly.
6.10 If the concern involves a staff member or a volunteer a report must also be forwarded to your HR consultant or the Group Volunteering team whichever is applicable.
6.11 The person responsible for managing safeguarding concerns within your service will then make arrangements to carry out an initial fact finding exercise to determine what the next steps should be.
6.12 Information must then be forwarded to the Safeguarding team. If the concern involves a volunteer or staff member a copy must also be sent to the HR and volunteering team as applicable.
6.13 The Company Secretary will be responsible for reporting concerns to CIB insurer’s and the Charity Commission where the criteria is met for these reports.
6.14 If the initial fact finding suggests that systems in local services such as procedures and safe systems of work need improving to prevent further concerns the manager must record on the fact finding document what action is to be taken and arrange for that action to take place as soon as practicable.
6.15 If the initial fact finding suggests that the concern involves staff then an investigation must take place following the applicable HR processes which will be either the Capability or Disciplinary Procedures.
6.16 If the initial fact finding suggests that the concern involves volunteers then an investigation must take place following procedures given by the Group Volunteering Team.
6.17 Following the process there may be a requirement to make a referral to the Disclossure and Barring Service or other professional bodies. The Safeguarding team will be responsible for carrying out this action.
7. Investigating Officers
7.1 The investigating officer will normally be a member of the reporting services team. However, in the following circumstances the Safeguarding team may undertake the investigation:
- High level of organisational risk
- The safeguarding concern involves the most senior manager of the service
- Inexperienced management teams, where they are new to the service or lack experience and the requisite training in relation to investigations
- Pattern of previous incidents across the service involved an employee with a history of doing something previously
- Concerns around previous local safeguarding investigations.
- Safeguarding referrals accepted by an external agency and then stepped down / passed back to CIB
8.1 All safeguarding investigations should be completed within 20 working days from receipt of the initial concern.
8.2 In the case of disciplinary investigations the disciplining officer should have received the report within 25 working days from receipt of the initial concern.
8.3 The disciplining officer should ensure that people are aware of the outcome of the investigation within 30 working days from receipt of the initial concern.
8.4 In exceptional circumstances where it is not possible to meet these standards all parties involved must be informed of the reason for delay and the revised timescales.
9.1 The Safeguarding team will monitor and evaluate all safeguarding concerns.
9.2 The findings if applicable will be used to improve safeguarding practices across CIB.