Safeguarding Adults at Risk of Abuse Policy
Version: V6
Ratified by: Strategic Safeguarding Group
Date ratified: 27/09/2022
Job Title of author: Interim Head of Safeguarding
Reviewed by Committee or Expert Group Strategic Safeguarding Group
Equality Impact Assessed by: Interim Head of Safeguarding
Related procedural documents
SGPOL09 – Deprivation of Liberty Safeguards Policy
SGPOL10 – Mental Capacity Act Policy
SGPOL02 – Safeguarding Children Policy
SGPOL08 – Domestic Abuse and MARAC policy
IGPOL69 Information Sharing Policy & Procedures
HRPOL01 Freedom to Speak Up Policy
The Care Act 2014
SET Safeguarding Adults Guidelines V7 April 2022
Domestic Abuse Act, 2021 Mental Capacity Act Amendment, 2019
Review date: 27/09/2025
It is the responsibility of users to ensure that you are using the most up to date document template – i.e. obtained via the intranet
In developing/reviewing this policy Provide Community has had regard to the principles of the NHS Constitution
Version Control Sheet
Version Date Author Status Comment
V1 SGPRO6 November 2009 Lead Practitioner Safeguarding Vulnerable Adults Ratified New
V2 SGPRO6 October 2011 Adult Safeguarding Lead Ratified Replaces Joint PCT IGPOL45
V3 SGPRO6 May 2012 Adult Safeguarding Lead Ratified Addition of Honour Based Abuse
V4 SGPRO6 June 2014 Head of Safeguarding Ratified Reviewed and Updated as scheduled in V3
V4.1 SGPRO6 April 2015 Head of Safeguarding Ratified No changes to current Policy. Is being reviewed in line with Care Act 2014 & SET 2015
V1 SGPOL7 October 2015 Adult Safeguarding and Learning Disabilities Lead Ratified Reviewed and updated in line with Care Act 2014 & SET Guidelines 2015 Replaces SGPRO6
V2 October 17 Adult Safeguarding Lead Reviewed in line with SET Safeguarding Adults Guidelines March 2017
V3 April 2018 Quality and Safety Team N/A Formatting, no changes to policy.
V4 October 2019 Adult Safeguarding Lead Reviewed in line with SET Safeguarding Adults Guidelines 2019
V5 January 2022 Adult Safeguarding Lead Updated with Provide Group Safeguarding Assurance Oversight Structure
V6 August 2022 Interim Head of Safeguarding Updated following changes to SET Safeguarding Adults Guidelines V7 and to include all areas and services covered by Provide Community Group
1. Provide Group Safeguarding Assurance Oversight Structure
Provide Group Business Board
Meets Bi -Monthly
• Receives escalations from QSC
• Discusses risks and areas for action where gaps in performance are identified with due regard to risk appetite and tolerance
Provide Group Business Quality & Safety Committee (QSC)
Meets Bi -Monthly
• Receives escalations from QPLT
• Identifies risks and areas for action where gaps in performance are identified
• Escalates exceptions to the Board
Provide Group Quality Provide Leadership Team (QPLT)
Meets Monthly
• Reviews Quarterly Safeguarding Report from SSG quarterly
• Makes recommendations for action and monitors where gaps in performance are identified
• Escalates exceptions to QSC
Provide Group Strategic Safeguarding Group (SSG) Meets Quarterly
• Reviews performance against safeguarding standards and statutory and regulatory compliance
• Devises and maintains oversight of safeguarding strategy for the Provide Group
• Agrees and Ratifies policies and training Produces a quarterly assurance report for QPLT
•
2 Introduction
This policy sets out the roles and responsibilities of Provide Community Group staff, working together with other professionals and agencies in promoting adults’ welfare and safeguarding them from abuse and neglect. Provide Community Group believes that adults have a right to live free from harm and abuse and that all adults have a right to feel safe and protected from any situation or practice that results in them being harmed or at risk of harm.
The Care Act 2014 sets out statutory responsibility for the integration of care and support between health and local authorities to protect adults at risk of abuse or neglect. Local Authorities have statutory responsibility for safeguarding. In partnership with health they have a duty to promote wellbeing within local communities.
The Care Act requires that each Local Authority must:
• Make enquiries, or ensure others do so, if it believes an adult is experiencing, or is at risk of, abuse or neglect.
• An enquiry should establish whether any action needs to be taken to stop abuse or neglect, and if so, by whom.
Provide Community Group is committed to maximising people’s choice, control and inclusion and protecting their human rights as important ways of meeting their individual needs and reducing the potential for abuse.
Provide Community Group is committed to ensuring that: -
• the needs and interests of adults at risk are always respected and upheld;
• the human rights of adults at risk are respected and upheld;
• a proportionate, timely, professional and ethical response is made to any adult at risk who may be experiencing abuse;
• all decisions and actions are taken in line with the Mental Capacity Act 2005;
• each adult at risk maintains:
o choice and control;
o safety;
o health;
o quality of life;
o dignity and respect
• Adults are protected from abuse
• Adults are empowered to and supported to make their own choices following the principles of Making Safeguarding Personal.
Provide Adult Safeguarding policy, procedures and responsibilities are guided by the following 6 principles from the Care Act 2014:
Empowerment: Adults are encouraged to make their own decisions and are provided with support and information.
Prevention: Strategies are developed to prevent abuse and neglect that promotes resilience and self – determination
Proportionality: A proportionate and lease intrusive response is made balanced with the level of risk.
Protection: Adults are offered ways to protect themselves, and there is a co-ordinated response to adult safeguarding
Partnership: Local solutions through services working with their communities. Communities have a part to play in preventing, detecting and reporting neglect and abuse.
Accountability: Accountability and transparency in safeguarding practice.
This Policy also informs all staff within Provide Community Group of statutory responsibilities and expected practice regarding issues related to Domestic Abuse including Coercive control, Honour Based Abuse (HBA), Forced Marriage and Female Genital Mutilation (FGM).
This Policy has been developed in line with Provide Community Group principles of Equality and Diversity and is underpinned by the following standards: -
• An adult’s welfare and safety are everyone’s responsibility.
• Staff must work together, understand and appreciate other professionals’ roles and responsibilities.
• No one must be discriminated against on the grounds of age, race, ethnicity, religion, culture, class, sexual orientation, gender or disability.
At every stage of the safeguarding process consideration must be given to whether the person at risk would benefit from the support of an independent advocate, including an Independent Mental Capacity advocate to express their views
An adult at risk is any person who is aged 18 years or over and at risk of abuse or neglect because of their needs for care and or support.
This policy is intended to support staff working within all areas where Provide Community Group have Services.
It does not replace, but is supplementary to the Local Safeguarding Adult Boards (LSAB) Guidelines, which are available at:
Essex: www.essexsab.org
Waltham Forest: www.walthamforest.gov.uk/index/care/adults-and-olderpeople/adultprotect.htm
Cambridge: www.cambridgeshire.gov.uk/social/adultprot
Redbridge: www.redbridge.gov.uk/cms/benefits_care_and_health/adult_social_service/service_a nd_sup port/safeguarding_adults_at_risk.aspx
Peterborough: http://www.peterborough.gov.uk/health_and_social_care/adult_social_care/safeguard ing_ad ults.aspx
Hertfordshire: https://www.hertfordshire.gov.uk/services/adult-social-services/report-a-concernabout-an-adult/hertfordshire-safeguarding-adults-board/hertfordshire-safeguardingadults-board.aspx
Dorset: https://www.dorsetcouncil.gov.uk/care-and-support-for-adults/dorset-safeguardingadults-board/dorset-safeguarding-adults-board
North Yorkshire: https://safeguardingadults.co.uk/
Cheshire East: http://www.stopadultabuse.org.uk/about-us/about-us.aspx
Nottingham: http://www.stopadultabuse.org.uk/about-us/about-us.aspx
Doncaster: https://www.doncaster.gov.uk/services/adult-social-care/safeguarding-adultscontents-page
North Lincolnshire: https://www.northlincssab.co.uk/wp-content/uploads/2022/09/North-Lincolnshire-MAPP-FINAL-07.09.2022.pdf
Derbyshire: https://www.derbyshiresab.org.uk/home.aspx
Staffordshire https://www.ssaspb.org.uk/Guidance/Section-42-Adult-Safeguarding-EnquiryProcedures.aspx
Leicestershire: https://lrsb.org.uk/
This Policy has been developed in line with Provide Community Groups principles of Equality and Diversity and is underpinned by the following values: -
• Adults can access support and protection to live independently and have control over their lives.
• Appropriate safeguarding options should be discussed with the adult according to their wishes and preferences. The options should take proper account of any additional factors associated with the adult’s disability, age, gender, sexual orientation, ‘race’, religion, culture or lifestyle.
• The adult should be the primary focus of decision-making, determining what safeguards they want in place and provided with options so that they maintain choice and control.
• All action should begin with the assumption that the adult is best placed to judge their own situation and knows best the outcomes, goals and wellbeing they want to achieve.
• There is a presumption that adults have mental capacity to make informed decisions about their lives. If someone has been assessed as not having mental capacity to make decisions about their safety, decision-making will be made in their best interests as set out in the Mental Capacity Act 2005 and Mental Capacity Act Code of Practice
• Adults will have access to supported decision-making including advocacy.
• Adults should be given information, advice and support in a form that they can understand and be supported to be included in all forums that are making decisions about their lives. The maxim ‘no decision about me, without me’ should govern all decision making.
• All decisions should be made with the adult and promote their wellbeing They should be reasonable, justified, proportionate and ethical.
• Timeliness should be determined by the personal circumstances of the adult.
• Every effort should be made to ensure that adults at risk are afforded appropriate protection under the law and have full access to the criminal justice system when a crime has been committed.
SET Safeguarding Adult Guidelines V7, 2022
3 Aims of Adult Safeguarding
The Care Act 2014 and supporting statutory guidance describes safeguarding as protecting an adult’s right to live safely, free from abuse and neglect. It is about people and organisations working together to prevent and stop both the risks and experience of abuse or neglect, while at the same time making sure that the adults’ wellbeing is promoted including, where appropriate, having regard to their views, wishes, feelings and beliefs in deciding on any action. This must recognise that adults sometimes have complex interpersonal relationships and may be ambivalent, unclear or unrealistic about their personal circumstances.
The aims of adult safeguarding are to:
• Stop abuse or neglect wherever possible
• Prevent harm and reduce the risk of abuse or neglect
• Safeguard adults in a way that supports them in making choices and having control about how they want to live
• Promote an approach that focuses on improving life for the adults concerned
• Raise awareness so that communities play their part in preventing, identifying and responding to abuse and neglect
• Provide information and support in accessible ways to help adults understand the different types of abuse, how to stay safe and how to raise a concern and
• Address what has caused the abuse.
SET Safeguarding Adult Guidelines V7, 2022
4. Responsibilities
All staff and volunteers working with adults at risk
All staff and volunteers working for Provide Community Group who have contact with adults at risk have a responsibility to be aware of issues of abuse, neglect or exploitation.
All staff and volunteers have a responsibility to act in a timely manner on any concern or suspicion that an adult at risk of is being abused, neglected or exploited and to ensure that the situation is assessed and investigated.
All staff and Volunteers are expected to complete mandatory safeguarding training appropriate for their role in accordance with the Adult Safeguarding: Roles and Competencies for Health, Intercollegiate Document (RCN, 2018).
All staff and volunteers need to know how to:
• recognise, record and report abuse;
• take any immediate action to protect people from further harm;
• access help and advice for the adult at risk.
5. Definitions
Adult
An individual who is 18 years of age or over.
Adult at risk
The Care Act 2014 uses the definition below to highlight who adult safeguarding duties apply to. Within this policy we refer to people who fulfil this definition as adults at risk.
• Adult has care and support needs, and
• Is experiencing, or is at risk of, abuse or neglect and
• Is unable to protect themselves from either the risk of, or the experience of abuse or neglect, because of those needs.
Making Safeguarding Personal (MSP)
Making Safeguarding Personal is a person-centred approach which means that adults are encouraged to make their own decisions about how they live their lives and how they manage their safety and are provided with support and information to empower them to do so. This approach recognises that adults have a general right to independence, choice and self-determination including control over information about themselves. Staff should strive to deliver effective safeguarding consistent with all the above principles. Under MSP the adult is best placed to identify risks, provide details of its impact and whether they find the mitigation acceptable. Working with the adult to lead and manage the level of risk that they identify as acceptable creates a culture where:
• Adults feel more in control
• Adults are empowered and have ownership of the risk
• There is improved effectiveness and resilience in dealing with a situation
• There are better relationships with professionals
• Good information sharing to manage risk, involving all the key stakeholders
• Key elements of the adult’s quality of life and well-being can be safeguarded
Carers
Circumstances in which a carer could be involved in a situation that may require a safeguarding response includes when:
• A carer may witness or speak up about abuse or neglect
• A carer may experience intentional or unintentional harm from the adult they are trying to support or from professionals and organisations they are in contact with
• A carer may unintentionally or intentionally harm or neglect the adult they support on their own or with others
Where there is intentional abuse, raising a concern should always be considered. People caring for someone (whether paid or unpaid), can have a carer's assessment to see what support they may require.
Young Carers
Young carers are children who look after a friend or family member including providing practical or emotional support. Their extra responsibilities often mean they miss out on education and socialising with their friends. It can side-line their whole childhood.
Both the Care Act 2014, and Children and Families Act 2014, offer a joined up legal framework to identify young carers and parent carers and their support needs. Both Acts have a strong emphasis on outcomes and wellbeing. Young carers are entitled to access a carers assessment through the local authority.
Transition
Together the Children and Families Act 2014 and the Care Act 2014, create a comprehensive legislative framework for transition, in preparation for when a child turns 18 (Mental Capacity Act 2007 applies once a person turns 16). Assessments of care needs should include issues of safeguarding and risk. Where there are on-going safeguarding issues for a young person and it is anticipated there will be on reaching the age of 18, safeguarding arrangements should be discussed as part of transition support planning and risk management.
Transition to adulthood can be a particularly challenging and vulnerable time for some young people. Young people experiencing, or who have experienced abuse or harm may often require ongoing support beyond the age of 18. This may be because the harm continues into adulthood or because they need support to recover from the impact of harm and/or trauma. Research has demonstrated that unresolved trauma can increase risks later in adulthood. It is also evidenced that not responding to harm in early adulthood may lead to more extensive support being required later in life.
The Statutory Guidance issued under the Care Act, published in October 2014, states that adult safeguarding means ‘protecting an adult’s right to live in safety, free from abuse and neglect’ (Section 14.7).
The purpose of adult safeguarding is to prevent harm and reduce the risk of abuse or neglect to adults with care and support needs. The statutory framework introduced under the Care Act applies to any person aged 18 or over whom: -
• has needs for care and support (regardless of the level of need and whether or not the local authority is meeting any of those needs)
• Is experiencing, or is at risk of abuse or neglect, and
• As a result of those needs, is unable to protect themselves against the abuse or neglect or the risk of it. (SET Safeguarding Adult guidelines 2015)
Abuse and neglect can take many forms. It may be an isolated incident, a series of incidents or a long-term pattern of behaviour and could affect one person or more, whether in someone’s home, in public or in an institutional setting. It may be deliberate or the result of negligence or ignorance. The degree or lack of intent will inform the response.
Proportionality
The types and forms of abuse or neglect are broad and it is important that people err on the side of raising concerns. However growing awareness of adult abuse has led to an increase in reports of concerns and subsequent safeguarding work. Many concerns are directed towards the safeguarding system when they should be dealt with through contractual, managerial, complaints or disciplinary procedures. Some concerns require complex social work case management rather than a formal safeguarding response.
All staff should ensure that concerns are addressed proportionately so that the situation is not made worse for the person at the centre of the concerns. Regular small concerns could amount to a higher level of concern and should be recorded and taken into account when deciding whether to complete a safeguarding referral.
Guidance on referral thresholds for Adult Social Care can be found in SET Safeguarding Adult Guidelines, page 14 (March 2017). www.essexsab.org.uk
Where staff are aware that an adult has suffered or is at risk of suffering significant harm, a safeguarding adult referral must be considered. Staff should follow the procedural guidelines associated with this Policy.
Categories of Abuse
The Care Act, 2014 identified categories of abuse for adults:
Physical abuse
Assault, hitting, slapping, pushing, misuse of medication, restraint, inappropriate physical sanctions, unauthorised restraint, physical punishments, making someone purposefully uncomfortable, involuntary isolation and confinement. Domestic violence and abuse Includes acts of coercive control by a family member or intimate partner Physical or sexual abuse, violent or threatening behaviour, controlling or coercive behaviour, economic abuse, psychological, emotional or other abuse; socalled “honour” based abuse, forced marriage and Female genital mutilation
Sexual abuse or exploitation
Rape, sexual assault, indecent exposure, sexual harassment, inappropriate looking or touching, sexual teasing or innuendo, sexual photography, subjection to pornography or witnessing sexual acts, sexual acts to which the adult has not consented or was pressured into consenting.
Sexual exploitation involves exploitative situations, contexts and relationships which can be face to face or online, where adults at risk (or a third person or persons) receive 'something' (e.g. food, accommodation, drugs, alcohol, cigarettes,
Psychological abuse
Financial or material abuse
affection, gifts, money) as a result of them performing, and/or another or others performing on them, sexual activities. It affects men as well as women. People who are sexually exploited do not always perceive that they are being exploited
Emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, cyber-bullying, enforced social isolation, unreasonable and unjustified withdrawal of services or supportive networks.
Theft, fraud, internet scamming, coercion in relation to an adult’s financial affairs or arrangements, including in connection with wills, property, inheritance or financial transactions, or the misuse or misappropriation of property, possessions or benefits, misuse of power of attorney, rogue trading.
Modern slavery
Discriminatory abuse
Encompasses slavery, human trafficking, sex work, forced labour, sexual exploitation, debt bondage and domestic servitude. Traffickers and slave masters use whatever means they have at their disposal to coerce, deceive and force individuals into a life of abuse, servitude and inhumane treatment.
Harassment, verbal abuse, denial of basic needs, unequal treatment based on age, race, gender and gender identity, married or civil partnership, pregnancy, disability, sex, sexual orientation or religion, 'protected characteristics' under the equality act 2010.
Neglect and acts of omission
Self-neglect
Organisational abuse
Pressure Ulcers
Ignoring medical, emotional or physical care needs, failure to provide access to appropriate health, care and support or educational services, withholding of the necessities of life, such as medication, adequate nutrition and heating.
A wide range of behaviour; neglecting to care for one’s personal hygiene, health or surroundings and includes behaviour such as hoarding.
Neglect and poor care practice within an institution or specific care setting, such as a hospital or care home, or in relation to care provided in someone’s own home.
Pressure Ulcers and the interface with a Safeguarding Enquiry DHSC, 2018, offers a national standard protocol to guide health and social care agencies on whether safeguarding procedures should be instigated when concerns have been raised that a pressure ulcer may have developed as a result of neglect. Where a pressure ulcer is one of a number of safeguarding concerns in relation to an individual or setting then there should be a multi-agency approach coordinated by the local authority, with health taking the lead for the clinical investigation. https://www.gov.uk/government/publications/pressure-ulcers-safeguarding-adultsprotocol
Radicalisation
Radicalisation is comparable to other forms of exploitation, such as grooming and Child Sexual Exploitation. The aim of radicalisation is to attract people to their reasoning, inspire new recruits and embed their extreme views and persuade vulnerable individuals of the legitimacy of their cause. This may be direct through a relationship, or through social media.
Prevent is part of the Government Counter Terrorism Strategy, CONTEST and is about safeguarding people and communities from the threat of terrorism and to stop people from becoming terrorists or supporting terrorism. The objectives of the strategy are to:
• Respond to the ideological challenge of terrorism and the threat we face from those who promote it.
• Prevent someone from being drawn into terrorism and ensure that they are given appropriate advice and support
• Work with sectors and institutions where there are risks of radicalisation which we need to address.
• See SGPOL18 Prevent Policy.
Provide Community Group accepts that Safeguarding is everybody’s responsibility and must do everything they can to ensure that adults at risk are protected from abuse, harm and neglect.
Provide Community Group must ensure that those who use their services are safeguarded and that staff are suitably skilled and supported. Provide Community Group has committed to ensure that staff can identify and develop the knowledge and skills relevant to their role as outlined in: Adult Safeguarding: roles and competencies for health care staff (Intercollegiate Document, RCN 2018). All registrants working with adults are expected to complete Level 3 Safeguarding Adults training and renew this every three years.
Provide Community Group accepts the principles of safeguarding adults and has committed to: -
• Take action to identify and prevent abuse from happening
• Respond appropriately when abuse has or is suspected to have occurred
• Ensure that the agreed safeguarding procedures are followed at all times
• Offer/deliver support, advice and resources to staff in responding to safeguarding adult issues
• Inform staff of any local or national issues relating to safeguarding adults
• Ensure staff are aware of their responsibilities to attend training and to support staff in accessing these events
• Ensure that the organisation has a dedicated staff member with an expertise in safeguarding adults
• Ensure staff have access to appropriate consultation and supervision regarding safeguarding adults
• Understand how diversity, beliefs and values of people who use services may influence the identification, prevention and response to safeguarding concerns
• Ensure that information is available for people that use services & family members setting out what to do if they have a concern
• Ensure that all employees who come into contact with adults have the appropriate safer recruitment employment checks in line with the requirements of the Disclosure and Barring Service (DBS 2014)such as obtaining references
• Ensuring that staff will be supported if they make a disclosure under the Public Interest Disclosure Act, 2013
• Job descriptions for staff contain a statement regarding staff responsibility for safeguarding children and adults
All staff must be aware of and understand the risk factors for abuse and what they must do if a person is being abused, suspected of being abused, is at risk of abuse or has been abused (CQC, 7e; March 2010).
Under the Care Act 2014, Provide Community Group must work collaboratively with other services, teams, individuals and agencies in relation to all safeguarding matters and have safeguarding policies that link with Local Authority policies. It participates in the LSAB where required; has clear procedures which are followed in practice, monitored and reviewed in the context of safeguarding and takes into account relevant guidance set out in the CQC’s schedule of applicable publications.
Responsibilities of All Provide Community Group Staff
• Remain alert at all times to the possibility of abuse
• Follow the safeguarding policies and procedures at all times, particularly if concerns arise about the safety or welfare of an adult with care and support needs
• To know the location and the contents of the Local Safeguarding Adults Board and Provide Community Group Safeguarding Adults Policies and Local guidance
• Participate in safeguarding adults training relevant to post and professional responsibilities and maintain current working knowledge. Line managers are to check training compliance and fitness to practice as part of the annual Personal Development Reviews.
• Ensure that the adult at risk is involved in decision making about any safeguarding concerns. (No decision about me without me/MSP). All adults should be supported to make choices and have control in how they choose to live their lives
• Escalate any concerns about the welfare of an adult with care and support needs to their Line Manager and Provide Safeguarding team. Record any discussion and outcomes in the service user record
• Know how to refer safeguarding concerns to the Hertfordshire Adult Social care and also forward a copy of the completed form to Provide Community Group safeguarding team.
• Contribute to actions required including information sharing and attending meetings relating to the safeguarding adults
• Work collaboratively with other agencies to safeguard and protect the welfare of people who use Provide Wellbeing Ltd services
• Recognise the impact that diversity, beliefs and values of people who use services can have.
Safer Recruitment
All agencies that employ staff or volunteers to work with adults, should ensure their recruitment and vetting procedures are sufficiently stringent and robust, to ensure employees are appropriately qualified and personally suitable for the responsibilities of the role.
Provide Community Group ensure that the principles of Safer Recruitment are achieved by adopting safer recruitment policies and procedures designed to identify and exclude those candidates who may pose a risk of abuse to adults. Safer recruitment includes checking all candidates with the Disclosure and Barring Service before a final offer of employment is made
6.The Legal Framework for Safeguarding Adults
The Care Act 2014, made each local authority establish a Safeguarding Adult Board to help and protect adults in their area by co-ordinating and ensuring effectiveness of what each of its members does. The Care Act 2014 established a new statutory framework for care and support, including adult safeguarding. It also made a duty for local authorities to cooperate with others who provide care and support relating to adults who are experiencing or at risk of abuse or neglect.
According to Care Quality Commission’s (CQC) “Essential Standards of Quality and Safety” all people who use services from a health organisation should be protected from abuse, or the risk of abuse, and their human rights be respected and upheld (CQC 2010).
The first priority should always be to ensure the safety and protection of adults at risk of abuse or neglect. It is the responsibility of all staff to act on any suspicion or evidence of abuse or neglect and to pass on their concerns to a responsible person/agency (Public Interest Disclosure Act 1998).
All those making a complaint or allegation or expressing concern, whether they be staff, Service Users, carers or members of the general public, should be reassured that: -
• They will be taken seriously
• Their comments will usually be treated confidentially but their concerns may be shared if they or others are at significant risk
• Service Users will be given immediate protection from the risk of reprisals or intimidation
• If staff, they will be given support and afforded protection if necessary, e.g.: under the Public Interest Disclosure Act 1998 they will be dealt with in a fair and equitable manner; and They will be kept informed of any action taken and the outcome
Following the Francis Review it was recognised that there needs to be a more open and supportive culture that encourages staff to raise any issues of patient care, quality or safety. Provide supports Freedom to Speak Up and staff who have concerns should raise this firstly with their line manager, with the Executive Director of Finance or NonExecutive Director who has been appointed as the Speak up Guardian, as outlined in the Freedom to Speak Up Policy HRPOL 01 https://improvement.nhs.uk/resources/freedom-to-speak-up-whistleblowing-policy-forthe-nhs
7 Safeguarding Alerts
The guidance that follows does not replace that contained within the Local Safeguarding Adults Guidance; rather it provides a succinct summary of the process.
Initial conversations with the adult at risk
In the majority of cases, unless it is unsafe to do so, each concern will start with a conversation with the adult at risk. The adult at risk and/or their advocate should not have to repeat their story; this doesn’t prevent clarification being sought where necessary. The desired outcome by the adult at risk should be clarified and confirmed at the end of the conversation(s), to:
• Ensure that the outcome is achievable
• Ensure the outcome is realistic
• Balance risk and the adults’ desire for justice and enhance their wellbeing
• Manage any expectations that the adult at risk may have and
• Give focus to the enquiry.
The adult’s views, wishes and desired outcomes may change. There should be an ongoing dialogue and conversation with the adult at risk to ensure their views and wishes are gained as the safeguarding process continues, and enquiries reviewed accordingly.
Where there is immediate risk, you must keep the adult safe and where a crime may have been committed, you must call the Police (either using 999 in an emergency, 101 in non-emergency or the online portal.) Be careful not to interfere with any potential evidence – this includes facilitating a Service User to wash or to have their clothes washed. Ensure your line manager and Provide Safeguarding Team is promptly informed.
If you have concerns that an adult is or may be at risk of significant harm from others then you must complete the appropriate form. These forms can be obtained from LSAB’s website or Provide Community Platform. Completed forms must be sent to the appropriate Local Authority without any delay and a copy of this must be sent to the Provide Safeguarding Team. A Datix incident report should also be completed.
In Southend, Essex and Thurrock, a SETSAF 1 should be completed and sent to the appropriate Social care department as listed on the back of the form. (See Appendix 1) and can also be found in Systm0ne, Communications and letters. A copy of all completed forms must be sent via email to the safeguarding team for information, support and quality assurance purposes. Email:Provide.safeguarding@nhs.net
When completing an alert, it is important to include:
• Demographic and contact details for the adult at risk,
• Details of the person who raised the concern
• Needs including communication and on-going health needs
• Factual details of what the concern is about; what, when, who, where
• Immediate risks and action taken to address risk
• Preferred method of communication
• If reported as a crime include crime reference number, police station etc
• Others at risk e.g. child in household, residents in care home
• If the adult has any cognitive impairment which may impede their ability to protect themselves
• Any information on the person alleged to have caused harm
• Wishes and views of the adult at risk, in particular consent
• Advocacy involvement (includes family/friends)
• Information from other relevant organisations for example, CQC
• Any recent history (if known) about previous concerns of a similar nature or concerns raised Indications where an adult lacks capacity.
Where there is a difference of opinion between Provide Community Group professionals regarding a risk to a Service User, the Provide Community Group Head of Safeguarding and the Assistant Director of the specific service will be contacted. Outside normal working hours, staff should contact the Manager-On-Call for advice.
These principles and guidelines for adult safeguarding are similar for all areas where services are delivered with some variations in the process. Provide staff working within these areas will need to understand local policies and procedures. If any Provide staff need advice or assistance with regards to the safety of an adult then contact the Safeguarding Team on 0300 303 2642 .
Staff who are aware that a vulnerable adult is subject to a safeguarding adult’s investigation or adult protection plan and fails to attend or is not brought to an appointment with Provide, they should inform the referrer, their line manager and the allocated social worker. They should also consider discussing with the safeguarding team or with the local Police if a welfare check is required.
When a member of staff is not entirely satisfied with the clinical, social or emotional picture that is presentedor where maltreatment is suspected theymust contact Provide Safeguarding Team for advice and support in escalating their concerns or raising a professional disagreement.
Serious Incident, & Safeguarding Adult reviews
When safeguarding alerts are raised consideration should also be given to completing a Datix incident report where internal investigation can be pursued along with the multiagency response. If the safeguarding alert meets the threshold it may be investigated internally as a Serious Incident.
The Local Adult Safeguarding Board must arrange a Safeguarding Adults Review when an adult has died or is still alive but has experienced serious abuse and neglect and there is concern that partner agencies could have worked more effectively to protect the adult.
The purpose of the Review is to determine what the relevant agencies and individuals involved in the case might have done differently that could have prevented harm or death and establish whether there are lessons to be learned and applied to future cases to prevent similar harm occurring. It is not to hold any individual or organisation to account.
8 Consent
Learning from high profile inquiries identified recurrent themes in the failures of care and protection: -
• Patients are not empowered to make choices about their care and protection
• Patient’s voice is not heard
• Neglect and abuse arise in the absence of effective prevention and early warning systems
It is always essential in safeguarding to consider whether the adult at risk is capable of giving informed consent in all aspects of their life. If they are able, their consent should be sought. This may be in relation to whether they give consent to: -
• An activity that may be abusive and consent to abuse or neglect was given under duress (e.g. as a result of exploitation, pressure, fear or intimidation), then staff member must consult with the line manager or Safeguarding Team as in this event consent can be disregarded
• A safeguarding adult’s investigation/assessment in response to a concern that has been raised. Where an adult at risk with capacity has made a decision that they do not want action to be taken and there are no public interest or vital interest considerations, their wishes must be respected. The person must be given information and have the opportunity to consider all risks and fully understand the likely consequences of that decision over the short and long term
• The recommendations of an individual protection plan being put in place
• A medical examination
• An interview
• Certain decisions and actions taken during the safeguarding adult process with the person or with people who know about their abuse and its impact on the adult at risk
If, after discussion with the adult at risk who has mental capacity, they refuse any intervention, their wishes will be respected unless (MCA 2005): -
• There is an aspect of public interest (e.g. not acting will put other adults or children at risk)
• There is a duty of care on a particular agency to intervene for example the Police (if a crime has been or may be committed)
Remember that one of the principles of the MCA is that making an unwise decision does not indicate a lack of capacity. See MCA Policy: SGPRO8
If the Service User lacks capacity to consent to a safeguarding investigation (following the MCA assessment) and is un-befriended or their friend or family is their alleged abuser or alleged victim then an Independent Mental Capacity Advocate (IMCA) must be provided. The IMCA can be accessed by sending the completed MCA form to the Provide Safeguarding Team and informing them of the need for an IMCA referral. Following discussion with the safeguarding team a referral should be made to the IMCA service as advised.
9 Confidentiality & information Sharing
Where there is potential risk to life and limb, the welfare of the adult is paramount. In such circumstances, the duty to maintain confidentiality is over-ridden by a duty in the public interest (Public Interest ACT 1998). Staff have a duty to pass on information relating to suspected adult abuse to Police.
Consent is not required to make a safeguarding referral where:
• There is significant risk of harm for the Service User or other vulnerable adults and seeking permission is likely to increase risk to the adult
• Permission has been refused previously but sufficient professional concern remains to justify disclosure.
• Seeking permission is likely to impede a criminal investigation
• There is significant risk to others (including children and young people under the age of 18)
• Children who may be the subject of abuse
• Failure to disclose information may expose the Service User or others to risk of death or serious harm
The Provide Community Group Information Sharing Policy & Procedures (IGPOL 69) should be followed at all times. Information should be shared on a necessary and proportionate, need to know basis. Staff should consult their line manager or Safeguarding Team for advice if they are unsure.
It is also important that the risks of sharing information are considered. In some cases, such as domestic abuse or hate crime, it is possible that sharing information could increase the risk to the adult. Safeguarding partners need to work jointly to provide advice, support and protection to the adult at risk to minimise the possibility of worsening the relationship or triggering retribution from the person alleged to have caused harm.
Professional Curiosity
Professional curiosity is the capacity and communication skill to explore and understand what is happening within an adult rather than making assumptions or accepting things at face value. Professional curiosity can require practitioners to think ‘outside the box’, beyond their usual professional role, and consider circumstances holistically. Curious professionals will spend time engaging with adults. They will ask questions (in an open way) and seek clarity if uncertain and will be open to the unexpected.
Developing skills in professional curiosity
• Be flexible and open-minded, not taking everything at face value. Check your own emotional state and attitudes. Leave time to prepare yourself for managing risk and uncertainty and processing the impact it has on you.
• Think the unthinkable; believe the unbelievable. Consider how you can articulate ‘intuition’ into an evidenced, professional view.
• Use your communication skills: review records, record accurately, check facts and feedback to the people you are working with and for. Never assume and be wary of assumptions already made.
• Use case history and explore information from the person themselves, the family, friends and neighbours, as well as other professionals (triangulation).
• Pay as much attention to how people look and behave as to what they say.
• Actively seek full engagement. If you need more support to engage the person or their family, think about who in the network can help you. Consider calling a multiagency meeting to bring in support from colleagues in other agencies.
• Take responsibility for the safeguarding role you play, however large or small, in the life of the person in front of you.
Professional curiosity is likely to flourish when practitioners:
• Attend good quality training to help them develop.
• Have access to good management support and supervision.
• Have empathy (‘walk in the shoes’) of the person to consider the situation from their lived experience.
• Remain diligent in working with the person and their family/network, developing professional relationships to understand what has happened and its impact on all involved.
• Always try to see the person separately.
• Listen to people who speak on behalf of the person and who have important knowledge about them.
• Be alert to those who prevent professionals from seeing or listening to the person.
• Do not rely on the opinion of only one person, wherever possible.
• Have an analytical and reflective approach.
• Develop the skills and knowledge to hold difficult conversations.
Holding difficult conversations and challenging Tackling disagreements or hostility, raising concerns or challenge, and giving information that will not be well received are recognised as hard things to do. The following are some tips on how to have difficult conversations.
• Planning in advance to ensure there will be time to cover the essential elements of the conversation.
• Keeping the agenda focused on the topics you need to discuss. Being clear and unambiguous.
• Having courage and focusing on the needs of the service user.
• Being non-confrontational and non-blaming, and sticking to the facts.
• Having evidence to back up what you say. Ensuring decision-making is justifiable and transparent.
• Showing empathy, consideration and compassion – being real and honest.
• Demonstrating congruence - making sure tone, body language and content of speech are consistent.
• Acknowledging ‘gut feelings’, sharing these with other professionals, and seeking evidence.
• Understanding the elements and indicators of behavioral change.
• Holding a healthy skepticism.
• Understanding the complexities of disguised compliance.
• Applying professional judgement.
Barriers to professional curiosity
It is important to note that when a lack of professional curiosity is cited as a factor in a tragic incident, this does not automatically mean that blame should be apportioned. It is widely recognised that there are many barriers to being professionally curious, including:
• Disguised Compliance
• Rule of optimism
• Cumulative effects of a series of incidents
• Normalisation
• Professional deference
10 Historical Abuse Allegation
Adult clients who disclose they have been abused in the past e.g. sexual abuse must be treated sensitively. Service Users should be offered information, support, counselling and any other available services. However, staff must also consider whether the alleged perpetrator may pose a risk to others. Where staff feel a child is at risk of harm then they have a duty to refer to children’s social care. Provide Safeguarding Children & Young People’ (SGPOL2) policy must be followed. In the event of any concern around a child, staff must contact Provide Safeguarding Team without any avoidable delay; out of hours the online manager must be contacted.
Police must be informed about allegations of a crime at the earliest opportunity. Staff should discuss this with the Police Safeguarding team. The local Police’s contact details can be obtained by dialling 101 or from the Local Authority.
For adults who work with children where there are concerns or allegations that the adult may pose a risk to children based on their history, the Local Authority Designated Officer (LADO) should be contacted if the adult has:
• Behaved in a way that has harmed a child, or may have harmed a child
▪ Possibly committed a criminal offence against or related to a child; or
▪ Behaved towards a child or children in a way that indicates they may pose a risk of harm to children. (Working Together to Safeguard Children, 2015)
11 Allegations against Staff
Where there is an accusation of abuse against a Provide Employee, the Assistant Director for the service, Provide Safeguarding Team and Human Resources must be notified. Provide ‘Disciplinary Procedure’ (HRPOL14) must be followed. Appropriate referrals to Adult or Children’s Social Care will be made within the timeframes stipulated.
This can apply when a member of staff has: -
• Behaved in a way that has or may have harmed a vulnerable adult
• Possibly committed a criminal offence against or related to a vulnerable adult
• Behaved towards a Service User in a way which indicates s/he is unsuitable to work with Service Users
If the Employee has allegedly committed a criminal offence: -
• The Line Manager or on call manager must be contacted without delay and if necessary the local Police must be contacted
• If the allegation is against the line manager or the most senior staff on duty, then Assistant Director and Safeguarding Team must be notified
• Where any concerns regarding an employee’s suitability to work with children or vulnerable adults is identified, the employer must refer the case to the DBS (Independent Safeguarding Authority)
Allegation against Non-Substantive Staff
All allegations of abuse made in respect of non-substantive staff, i.e. agency and bank workers, students or contractors will be managed with due regard for this policy. In all cases where allegations are made in respect of non-substantive staff, the appropriate manager within the agency responsible will be alerted to the allegation and action taken by Provide.
Agreement will be reached between appropriate HR business partners in each organisation as to where the primacy of an investigation relating to conduct will rest. As with all investigations, a police/criminal line of enquiry will take precedence above all others.
12 Visiting Vulnerable Service Users
Visits to vulnerable Service Users who may lack capacity to consent to a visit from an alleged perpetrator should only take place following an MCA Assessment and a decision that such a visit would be in the best interests. Decisions to allow such visits should be regularly reviewed. See MCA Policy.
13 Record Keeping
Good record keeping is a vital component of safe practice. When abuse or neglect is raised managers need to look for past incidents, concerns, risks and patterns. We know that in many situations, abuse and neglect arise from a range of incidents over time.
Records (including emails) may be disclosed in courts in criminal or civil actions. Line managers should ensure that staff are clear about their responsibilities when
recording information. Quality recording of adult safeguarding not only safeguards adults, but also protects workers by evidencing decision making based on the information available at the time.
All staff must follow the Provide ‘Record Keeping Policy’ (IGPOL63). All discussions whether, phone calls or meetings, with clear outcomes, decisions and action plans, must be recorded contemporaneously with a date, time, name and signature. All recordings should be based on fact or professional opinion and kept in the client’s records. All assessments must consistently assess and record the racial linguistic and religious identity and needs of the Service User and their family. There should be no abbreviations used and all persons involved should be named in full with any professional designation noted.
The records of clients who are known to be subject to a Safeguarding Management Plan should indicate this clearly.
14 Training
Safeguarding training within Provide is in accordance with Roles and Competencies for Healthcare Staff (the Adult Intercollegiate Document. RCN, 2018).
Please see training map Appendix 2
All staff are expected to complete the appropriate training and to update at their level of competence every 3 years. This includes MCA & DOLs training for all clinical staff who require consent for care or treatment from their service users.
15 Safeguarding Investigations
Where allegations are raised to the Local Authority about the care given by provide staff who may request that an investigation is completed by Provide Safeguarding team within 10 working days of receipt. The Senior management team will be notified as well as the Assistant Director and Team manager/matron. The Team involved is expected to co-operate with the investigation which will include scrutiny of the patient records and interviews with the staff involved. The main purpose of the investigation is to ascertain what happened and whether there are any improvements that can be made to practice in order to mitigate against it happening again. The report will be shared with the Assistant Director and Team manager and be signed off by the Senior Management team prior to returning to the Local Authority.
See Process map in Appendix 3
16 Medication Errors
Medication errors involving one patient would not be seen as a safeguarding issue unless there was significant harm caused to the adult, whether deliberate or unintentional. Provide have a ‘No Blame’ culture for medication incidents and expect that immediate action will be taken to minimise the risk of harm to the patient through escalation to senior nursing and medical colleagues and incident reporting. Where it is established that a medication error does not meet Safeguarding threshold as outlined in Appendix 5 an internal investigation with be carried out to ensure robust prevention measures are in place such as training, supervision and auditing.
Please see Appendix 5
17Contact Telephone Numbers & Access to Further Information
Contacts for Local Authority Safeguarding Teams by area
Local Police non-emergency: 101 or online portal Emergency Services 999
Immigration Advice Service: (available seven days a week): Tel: 0844 887 0111; email: info@iasservices.org.uk Skype: (immigrationadviceservice)
National Domestic Violence Helpline:
Tel: 0808 2000 247 Forced Marriage Unit (for female or male victims)
Tel: 020 7008 0121 (Mon-Fri 09:00-17:00)
Tel: 020 70081500 Out of Hours (emergencies only):
Men’s Advice Line:
Tel: 0808 80 0327
Action on Elder Abuse Response Line: Tel: 0808 808 8141
Galop LGBT Support (Formerly Broken Rainbow)
Tel: 0800 999 5428 Website https://galop.org.uk/
Karma Nirvana – Honour Network Helpline:
Tel: 0800 5999 247, Web: www.karmanirvana.org.uk email: info@karmanirvana.org.uk
Southall Black Sisters: Tel: 080 8571 9595. Web: www.southallblacksisters.org.uk
The Honour Network: Tel: 0800 5999 247
Contacts for Adult Social Care referrals by area:
Area Social care referrals
Essex 0345 603 7630
Out of Hours: 0345 606 1212
SET SAF 1
Email: businesssupport.adultsovas@essex.gov.uk
Thurrock 01375 511000
Out of Hours 01375 372468
SET SAF 1
Email: SafeGuardingAdults@thurrock.gov.uk Southend 01702 215008 (option 1)
Out of hours 0300 123 0778
SET SAF 1
Email: accessteam@southend.gov.uk
Cambridg e 0345 045 5202
Peterboro ugh 01733 234724
http://www.safeguardingpeterborough.org.uk/adultsboard/information-for-professionals/cpsabprocedures/
Waltham Forest 01208 496 3000 safeadults@walthamforest.gov.uk
Norfolk 0344 800 8020
SADSR Form www.norfolk.gov.uk/socialcareenquiry/ Suffolk Multi-Agency Safeguarding Hub 0345 606 1499 (MASH)
Customer First 0808 800 4005
http://www.suffolk.gov.uk
Hertfords hire 0300 123 4042
https://www.hertfordshire.gov.uk click on Adult Social Care
report a concern about an adult make a referral E-mail Adult.Safeguarding@hertfordshire.gov.uk
Dorset 01395 221 016
Out of hours 01305 858 250 https://www.dorsetcouncil.gov.uk/care-and-support-for-adults/dorsetsafeguarding-adults-board/reporting-a-concern
Scarboro ugh & Richmond 01609 780 780 same number for OOH https://www.northyorks.gov.uk/safeguarding-vulnerable-adults
Congleton Cheshire 0300 123 5010
Out of Hours Service on 0300 123 5022 https://www.cheshireeast.gov.uk/livewell/staying-safe/keeping-adultssafe/concerned-about-an-adult.aspx
Worksop Nottingha mshire
Contact MASH 0300 500 80 90
Out of Hours 0300 456 4546
Access online form at: https://forms.nottinghamshire.gov.uk/en/AchieveForms/?form_uri=sa ndbox-publish://AF-Process-0ea0ea06-a980-4af0-a3f2efae946f14df/AF-Stage-19a63a21-cede-4279-91becc71e85f5360/definition.json&redirectlink=%2Fen&cancelRedirectLin k=%2Fen&consentMessage=yes
Doncaster 01302 737063
Out of Hours 01302 796000
https://mosaicportal.doncaster.gov.uk/s4s/FormDetails/FillForm?formI d=184
Brigg North Lincolnshir e 01724 297000
https://www.northlincssab.co.uk/reporting-abuse/ complete referral form and submit the form to: adultprotectionteam@northlincs.gov.uk
Buxton Derbyshire 01629 533190
Out of Hours 01629 532600
email: asch.bshighpeak@derbyshire.gov.uk
Buxton Staffordshi re 0345 604 2719 office hours, out of hours 0345 604 2886
https://www.staffordshire.gov.uk/Advice-support-and-care-foradults/reportabuse.aspx#recognise Loughbor ough Leicesters hire 0116 305 0004
Out of hours 0116 255 1606
Appendix 1: SETSAF 1
SAFEGUARDING ADULT CONCERN FORM - SET SAF
Adult reference no: (Swift/PRN/NHS - if known)
Date form completed:
Please complete as much of the form as possible, if a question is not known put N/K
1. Tell us if the concern is for an adult or an organisation
Name of adult you are concerned about:
Organisation:
Address of adult:
Gender:
Ethnic origin and/or nationality:
Age: DOB:
Telephone No:
Is it safe to make contact? Yes No If no, please give details of how contact could be made safely. Safe time of day? / Would it be safe for the GP or another organisation to make contact?
Does the adult have any communication needs? Yes No If yes, please give brief details:
Are they aware of this concern? Yes No If not, why not?
Have they agreed to this concern being raised? Yes No If not, why not?
Is the adult in receipt of any social or health care services? Yes No If yes, please give brief details:
2 Current situation and details of the incident/concern(s) being raised
Does the adult continue to be at risk of harm? Yes No
Are there other adults who may be at risk of harm? Yes No If the answer to either of the above is yes, please describe the risk that remains and the names of any others potentially at risk. A referral to children services should also take place if there is a child at risk in the household.
3. Details of the concern(s) being raised
Time of incident:
Date of incident: Location of incident:
Concern:
What would the adult like as the outcome of the enquiry?
Brief factual details of the incident. Include a clear factual outline of the concern with details of times, dates, people and places. Please continue on separate sheet if required.
If injuries are present please give a brief/factual description:
Has a body chart been completed? Please attach or forward as soon as possible. Yes No
Details of any medical attention sought:
Doctor informed? Yes No
If yes include name of doctor and include date and time of information given.
Actions taken to date to safeguard the adult:
Are other professionals aware in this alert?
Police involved?
If yes, please state the crime incident number.
4. Relative/name of main carer
Name: Relationship to adult:
Is relative/carer aware of this concern being raised? Yes No
Address:
County: Postcode: Telephone No: Mobile No: Email:
5. Details of person(s) alleged to have caused harm If self-neglect please move on to Q6.
Name:
Gender: D.O.B.
Address:
Do they live with the adult? Yes No
If yes, in what capacity e.g. spouse, fellow resident, carer:
What is the relationship between the person(s) alleged to have caused harm and the adult who is the subject of the concern?
What is the occupation of the person alleged to have caused harm?
Does this person hold any position of trust (paid or voluntary)?
6 Details of the person raising the alert (for professionals this information can only remain confidential in exceptional circumstances)
Can your details be shared with third parties? Yes No
Do you live with the adult you are concerned about? Yes No I would prefer to remain anonymous ? Yes No
If yes, please give your reasons for remaining anonymous:
Name: Date:
Job title and/or relationship to adult referred:
Organisation (if applicable):
Address:
County:
Postcode: Telephone No: Mobile No:
Email:
7. Details of person completing the form (add only if different to box 6)
Name: Date:
Job title and/or relationship to adult referred:
Organisation (if applicable): Address:
County:
Postcode: Telephone No: Mobile No: Email:
Name of safeguarding lead in your organisation: Email of safeguarding lead:
Where appropriate have you informed your safeguarding lead of this concern? For health staff only – Have you completed your local incident form prior to sending this form?
8. Please tick which form of abuse you suspect Physical Sexual Psychological Financial or material Organisational Modern slavery Neglect Discriminatory
Self-neglect Domestic abuse Not determined Vulnerable to radicalisation
Completed forms should be sent to your relevant Local Authority.
Southend
Email: accessteam@southend.gov.uk
Fax: 01702 534794
Essex
Email: businesssupport.adultsovas@essex.gov.uk
Fax: 0345 601 6230
Thurrock
Email:
SafeGuardingAdults@thurrock.gov.uk
Fax: 01375 652760
Raising a concern/enquiry by phone: 01702 215008 (option 1)
Out of hours:
• General public - 0345 606 1212
• Statutory organisations – 0300 123 0778
Raising a concern/enquiry by phone: 0345 603 7630
Out of hours:
• General public - 0345 606 1212
• Statutory organisations – 0300 123 0778
By post to: Social Care Connect, Essex House, 200 The Crescent, Colchester, Essex, CO4 9YQ
Raising a concern/enquiry by phone: 01375 511000
Out of hours:
• Phone: 01375 372468
• Fax: 01375 397080
Appendix 2: Training Map
Appendix
Appendix 4: Best Practice Matrix
Appendix 5 - Medication errors
NOT SAFEGUARDING – NORMAL CARE MANAGEMENT - An adult’s needs can be met through statutory services such as local authority, police, health
• The adult does not receive prescribed medication (missed/wrong dose) on one occasion and no harm occurs
• Minimal harm to the adult but robust prevention measures in place such as training, supervision & auditing
NOT SAFEGUARDING - SERVICE IMPROVEMENT / QUALITY ISSUES - A low level concern that can be dealt with through complaints processes, case reviews, quality process etc.
• Recurring missed medication or administration errors in relation to the adult that cause no harm
• No ongoing concerns
• Prevention measures in place such as training, supervision and auditing
SAFEGUARDING CONCERN MAY BE REQUIRED - CONTACT YOUR SAFEGUARDING LEAD FOR DISCUSSION - This would include an adult who may be in need of a multi-agency response to manage their risk. Concerns at this point may meet the threshold for adult safeguarding and must be considered on a case-by-case basis. If this affects more than one patient, organisational abuse should be considered
• One off medication error to more than one adult - no harm caused
• Recurring missed medication or errors that affect more than one adult and/or result in harm
• Medication error causing serious or significant harm to the adult, leading to the need for medical intervention
• Previous concerns identified/ongoing ineffectiveness
• Insufficient prevention measures in place such as training, supervision & auditing
SAFEGUARDING CONCERN - REFERRAL TO POLICE SHOULD BE CONSIDERED - The adult has been harmed or placed at harm because of actions, deliberate or unintentional, of others. High level concerns. If there is any suspicion that a criminal act has occurred, then a referral to the Police should be considered using your organisation’s internal escalation processes.
• Deliberate maladministration of medication
• Covert administration without proper medical supervision
SAFEGUARDING CONCERN - REFERRAL TO POLICE REQUIRED - This includes incidents where adult(s) with care and support needs have died as a consequence of harm or neglect. High Level concerns. This includes cases referred on for a Safeguarding Adult Review or Domestic Homicide Review. This must be reported using your organisation’s internal escalation processes.
• Pattern of recurring errors or an incident of deliberate maladministration that results in ill-health or death
• Catastrophic harm to more than one adult leading to hospitalisation/long term effects/death
• Staff misusing their position of power over the adult Over-medication and/or inappropriate restraint used to manage behaviour within an institutional setting
SET guidelines V7 2022
EQUALITY IMPACT ASSESSMENT TEMPLATE: Stage 1: ‘Screening’
Name of project/policy/strategy (hereafter referred to as “initiative”):
Safeguarding Adults at Risk of Abuse Policy
Provide a brief summary (bullet points) of the aims of the initiative and main activities:
This policy provides a reference guide to enable all staff to meet their statutory duties under the Care Act 2014
Project/Policy Manager: Interim Head of Safeguarding Date:12/08/22
This stage establishes whether a proposed initiative will have an impact from an equality perspective on any particular group of people or community – i.e. on the grounds of race (incl. religion/faith), gender (incl. sexual orientation), age, disability, or whether it is “equality neutral” (i.e. have no effect either positive or negative). In the case of gender, consider whether men and women are affected differently.
Q1. Who will benefit from this initiative? Is there likely to be a positive impact on specific groups/communities (whether or not they are the intended beneficiaries), and if so, how? Or is it clear at this stage that it will be equality “neutral”? i.e. will have no particular effect on any group.
Neutral
Q2. Is there likely to be an adverse impact on one or more minority/under-represented or community groups as a result of this initiative? If so, who may be affected and why? Or is it clear at this stage that it will be equality “neutral”?
Neutral
Q3. Is the impact of the initiative – whether positive or negative - significant enough to warrant a more detailed assessment (Stage 2 – see guidance)? If not, will there be monitoring and review to assess the impact over a period time? Briefly (bullet points) give reasons for your answer and any steps you are taking to address particular issues, including any consultation with staff or external groups/agencies.
Neutral
Guidelines: Things to consider
Equality impact assessments at Provide take account of relevant equality legislation and include age, (i.e. young and old,); race and ethnicity, gender, disability, religion and faith, and sexual orientation.
The initiative may have a positive, negative or neutral impact, i.e. have no particular effect on the group/community.
Where a negative (i.e. adverse) impact is identified, it may be appropriate to make a more detailed EIA (see Stage 2), or, as important, take early action to redress this – e.g. by abandoning or modifying the initiative. NB: If the initiative contravenes equality legislation, it must be abandoned or modified.
Where an initiative has a positive impact on groups/community relations, the EIA should make this explicit, to enable the outcomes to be monitored over its lifespan.
Where there is a positive impact on particular groups does this mean there could be an adverse impact on others, and if so can this be justified? - e.g. are there other existing or planned initiatives which redress this?
It may not be possible to provide detailed answers to some of these questions at the start of the initiative. The EIA may identify a lack of relevant data, and that data-gathering is a specific action required to inform the initiative as it develops, and also to form part of a continuing evaluation and review process.
It is envisaged that it will be relatively rare for full impact assessments to be carried out at Provide. Usually, where there are particular problems identified in the screening stage, it is envisaged that the approach will be amended at this stage, and/or setting up a monitoring/evaluation system to review a policy’s impact over time.
EQUALITY IMPACT ASSESSMENT TEMPLATE: Stage 2:
(To be used where the ‘screening phase has identified a substantial problem/concern)
This stage examines the initiative in more detail in order to obtain further information where required about its potential adverse or positive impact from an equality perspective. It will help inform whether any action needs to be taken and may form part of a continuing assessment framework as the initiative develops.
Q1. What data/information is there on the target beneficiary groups/communities? Are any of these groups under- or over-represented? Do they have access to the same resources? What are your sources of data and are there any gaps?
Q2. Is there a potential for this initiative to have a positive impact, such as tackling discrimination, promoting equality of opportunity and good community relations? If yes, how? Which are the main groups it will have an impact on?
Q3. Will the initiative have an adverse impact on any particular group or community/community relations? If yes, in what way? Will the impact be different for different groups – e.g. men and women?
Q4. Has there been consultation/is consultation planned with stakeholders/ beneficiaries/ staff who will be affected by the initiative? Summarise (bullet points) any important issues arising from the consultation.
Q5. Given your answers to the previous questions, how will your plans be revised to reduce/eliminate negative impact or enhance positive impact? Are there specific factors which need to be taken into account?
Q6. How will the initiative continue to be monitored and evaluated, including its impact on particular groups/ improving community relations? Where appropriate, identify any additional data that will be required.
Guidelines: Things to consider
An initiative may have a positive impact on some sectors of the community but leave others excluded or feeling they are excluded. Consideration should be given to how this can be tackled or minimised. It is important to ensure that relevant groups/communities are identified who should be consulted. This may require taking positive action to engage with those groups who are traditionally less likely to respond to consultations, and could form a specific part of the initiative. The consultation process should form a meaningful part of the initiative as it develops, and help inform any future action. If the EIA shows an adverse impact, is this because it contravenes any equality legislation? If so, the initiative must be modified or abandoned. There may be another way to meet the objective(s) of the initiative.
Further information:
Useful Websites www.equalityhumanrights.com Website for new Equality agency www.employers-forum.co.uk – Employers forum on disability www.efa.org.uk – Employers forum on age