SAFEGUARDING OF VULNERABLE ADULTS POLICY
Caring Hands in the Community (the working name of a King’s Church Medway project) is a Day Centre that feeds, clothes, provides washing and laundry facilities, advice, and advocacy services to homeless and vulnerably housed people over the age of eighteen, five days per week from 9am-4pm.
As an organisation we recognise the need to provide a safe and caring environment for children, young people and adults. We acknowledge that children, young people and adults can be the victims of physical, sexual and emotional abuse, and neglect. We accept the UN Universal Declaration of Human Rights and the International Covenant of Human Rights, which states that everyone is entitled to “all the rights and freedoms set forth therein, without distinction of any kind, such as race, colour, sex, language, religion, political or other opinion, national or social origin, property, birth or other status”. We also concur with the Convention on the Rights of the Child which states that children should be able to develop their full potential, free from hunger and want, neglect and abuse. They have a right to be protected from “all forms of physical or mental violence, injury or abuse, neglect or negligent treatment or exploitation, including sexual abuse, while in the care of parent(s), legal guardian(s), or any other person who has care of the child.” As an organisation we have therefore adopted the procedures set out in this safeguarding policy in accordance with statutory guidance. We are committed to building constructive links with statutory and voluntary agencies involved in safeguarding.
Regulator: Charity Commission
Insurance Company: Ansvar Insurance (public liability and employee insurance)
The policy and attached practice guidelines are based on recommendations from Homeless Link and CCPAS and prepared in consultation with directors of King’s Church Ministries
Staff in homelessness services work with adults who are at risk of abuse. It is the responsibility of all staff to recognise and respond to the signs of abuse.This guidance sets out the principles and what staff can expect if they raise safeguarding alert.
The Government guidance is contained within section 14 of The Care Act’s statutory guidance, which came into force in April 2015 and was updated in March 2016. The Care Act gives a legal framework for safeguarding adults. Each Local Authority must have a Safeguarding Adults Board (SAB) that includes the local authority, NHS and police. SABs must meet regularly, develop shared safeguarding plans and publish an annual review of progress. SABs will carry out Safeguarding Adults Reviews in some circumstances relating to safeguarding failures. The Act also introduces a responsibility for Local Authorities to make enquiries and take any necessary action if an adult with care and support needs could be at risk, even if that adult isn’t receiving local authority care and support.
DEFINITIONS OF ‘AN ADULT AT RISK’
In safeguarding terms an adult at risk is defined as a person 18 and over who:
• has needs for care and support (whether or not the local authority is meeting any of those needs) and;
• is experiencing, or at risk of, abuse or neglect; and
• as a result of those care and support needs is unable to protect themselves from either the risk of, or the experience of abuse or neglect.
It is important to note that an adult does not need to be in receipt of a care or support delivered by the local authority.
Homelessness in itself does not make people vulnerable. However, circumstances such as homelessness may exacerbate other conditions and impact negatively upon individuals’ ability to care for and protect themselves. They may be isolated from friends and family, have difficulty communicating, or have a mental health problem.
Safeguarding is about responding appropriately and quickly to allegations of abuse or neglect.
What is abuse?
All local authorities have a duty to protect people at risk from abuse. Types of abuse can include:
• psychological or emotional
• financial or material
• neglect and acts of omission
• modern slavery
• domestic violence
• institutional or organisational
Other forms of abuse are sometimes described, for example: bullying, mate crime and cyber abuse, but only the abuse listed in the above bullet points is listed in the statutory guidance.
 The Care Act http://www.legislation.gov.uk/ukpga/2014/23/contents/enacted
Abuse can happen anywhere and can consist of single or repeated acts. An abuser can be anyone that comes into contact with an adult at risk person and is often someone well known or close to them, or someone who is employed to care for them. Abuse often results in a violation of human and civil rights.
People who are experiencing homelessness can be vulnerable to a range of risks factors which increases the risk of abuse. Indicative examples are:
Interpersonal and Personal
• Mental health problems
• Dependent on alcohol or drugs
• Brain damage
• Lack of purposeful activity
• Shows odd or embarrassing behaviour
• Has difficulty in communicating
• Poor or non-existent staff supervision
• Poor or non-existent training
• Staff working in isolation
• Community disengagement, fear and resentment
• Lack of access to safe and adequate housing
• Victim of gatekeeping and inflexible policies
What to do if abuse is suspected or disclosed at Caring Hands
The first priority of all staff is the adults under our care. Caring Hands is committed to ongoing safeguarding training and development opportunities for all workers, developing a culture of awareness of safeguarding issues to help protect everyone. All our workers will receive induction training and undertake recognised safeguarding training on a regular basis.
How to respond to a vulnerable adult wishing to disclose abuse:
Ensure the physical environment is welcoming, giving opportunity for the vulnerable adult to talk in private but making sure others are aware the conversation is taking place.
It is especially important to allow time and space for the person to talk
Above everything else listen without interrupting
Be attentive and look at them whilst they are speaking
Show acceptance of what they say (however unlikely the story may sound) by reflecting back words or short phrases they have used
Try to remain calm, even if on the inside you are feeling something different
Be honest and don’t make promises you can’t keep regarding confidentiality
If they decide not to tell you after all, accept their decision but let them know that you are always ready to listen.
Use language that is age appropriate and, for those with disabilities, ensure there is someone available who understands sign language, Braille etc.
• You have done the right thing in telling
• I am glad you have told me
• I will try to help you
• Why didn't you tell anyone before?
• I can't believe it!
• Are you sure this is true?
• Why? How? When? Who? Where?
• I am shocked, don't tell anyone else
• If a colleague is under-performing in a way that could lead to harm or abuse, then it is right to report this to your line manager. The first priority of all staff is the adults under their care.
• Make an accurate written record of what the person said to you as soon as possible, detailing anything you have seen including dates, times, people involved and any observed injuries.
• Do not share information about the disclosure to anyone other than your line manager or the Safeguarding Co-ordinator, and then only share on a ‘need-to-know’ basis
Responding to allegations of abuse
Under no circumstances should a worker carry out their own investigation into an allegation or suspicion of abuse. Follow procedures as below:
The person in receipt of allegations or suspicions of abuse should report concerns as soon as possible to Marty Brogan (hereafter the "Safeguarding Co-ordinator") tel no: 0771 3286190 who is nominated by Kings Church Medway Leadership to act on their behalf in dealing with the allegation or suspicion of neglect or abuse, including referring the matter on to the statutory authorities. If someone is in immediate danger, contact the emergency services on 999. If someone is not in immediate danger but you need help fast, contact the police on 101.
Where the concern is regarding an adult in need of protection, the Safeguarding Co-ordinator will contact Adult Social Services. Before referring potential abuse to Adult Social Care, the consent of the person being abused should be gained. The only circumstances in which this requirement for consent should be overridden would be if (i) there is a high risk to the health and safety of the adult at risk; (ii) the person lacks capacity to consent (see Mental Capacity Act 2005), or (iii) if other people or children could be at risk.
The local Adult Social Services office telephone number (office hours 8:30-5pm) is
03000 41 61 61. The out-of-hours emergency number is 03000 41 91 91.
The Police Protection Team telephone number is dial 101 - ask to speak to the Combined Safeguarding Team
Safeguarding Adults Boards
The Care Act (2014) has introduced a legal obligation for each local authority to have a Safeguarding Adults Board.
Safeguarding of vulnerable adults falls under the remit of Local Authority Social Services departments. Most Social Services Departments’ Safeguarding Adult Boards consisting of experts from various fields such as health professionals, police, social care services, housing, the Crown Prosecution Service, Care Quality Commission and voluntary agencies. These boards are responsible for investigating incidents, monitoring the performance of agencies and services, raising awareness, providing training, sharing good practice and suggesting improvements.
Each Local Authority will have mechanisms in place to respond to adult safeguarding concerns. These should be communicated to all local statutory, voluntary and community agencies and include clear policies and procedures for agencies to refer to. You can find them on the Local Authority’s website: https://www.kent.gov.uk/about-the-council/partnerships/kent-and-medway-safeguarding-adults-board
Confidentiality and sharing information
All organisations should follow clear principles of confidentiality in relation to their service users. However, there will be occasions when it is appropriate to share information about your clients in order to protect their best interests and, therefore, you should never give assurance of absolute confidentiality. It is a legal requirement that agencies and professionals work together around safeguarding issues.
Ensure you have contact details for all other professionals in your clients’ support networks.
Make sure your organisation has clear policies on information sharing and that you have procedures in place around working with other agencies.
Assess each occasion on a case by case basis.
Only share information on a ‘need to know’ basis and when it is in the best interests of your service users.
Always try to obtain informed consent from your clients before sharing information, however if this is not possible it may be necessary to override this requirement – especially if other adults are at risk. Staff should seek management support to decide whether to share information without consent.
The General Data Protection Regulations (GDPR) allows organisations to share special information (the GDPR term for sensitive information) about clients without their consent in some limited circumstances. They are:
To protect the vital interests of an individual – the vital interests condition also extends to any other individual who might be impacted by the abuse.
Where the individual lacks capacity to give meaningful consent.
Where the use of information for the provision of social care, treatment, system and services.
Organisational operational safeguarding leads should ensure the are familiar with the GDPR, and the Mental Capacity Act. Further information can be found at:
Information Commissioners Office: https://ico.org.uk/for-organisations/
Caldicott Principles: http://www.igt.hscic.gov.uk/Caldicott2Principles.aspx
Homeless Link guidance on using the Mental Capacity Act: www.homeless.org.uk/our-work/resources/guidance-on-mental-capacity-act
As well as following Local Authority procedures, Caring Hands has its own internal policies and procedures relating to adult safeguarding. These go hand in hand with guidance from the Local Authority. While safeguarding procedures may vary slightly between agencies and local authorities, they should all follow the same fundamental process:
1. Make sure the adult at risk is not in immediate danger. If necessary, seek urgent medical treatment.
2. Contact the police if you think a crime has been committed or if someone is in immediate danger.
3. Raise a ‘safeguarding alert’ by informing your line manager or another manager within your organisation.
4. Make a written report recording your concerns and detailing anything you have seen including dates, times, people involved and any observed injuries.
As stated in the Care Act statutory guidance, your organisation’s first priority should always be to ensure the safety and protection of an adult at risk. 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.
Once a safeguarding alert has been raised, service managers will decide how to proceed with the concern. While an incident may fall within internal safeguarding procedures, it will not necessarily fall within Local Authority procedures. It is usually a managerial decision whether to report to local authority safeguarding teams or not.
Action must be taken as soon as possible to minimise any risk of harm or exploitation to individuals concerned. In the absence of management support, raise an alert to the Local Authority rather than doing nothing. In the first instance this will often be via the local Social Services helpline or emergency duty team.
Make sure you know where your safeguarding policies and procedures are saved and that they are accessible.
Ensure that you have an up-to-date list of relevant local contact details to be used if necessary.
Make sure you know where to find your organisation’s whistleblowing policies and procedures, to be followed when reporting any safeguarding concern involving a colleague.
What happens next?
All safeguarding concerns should be fully investigated by the appropriate person i.e. Social Services and/or the responsible manager within your organisation. Where it is suspected that a criminal act has taken place, the Police should be involved immediately as they may conduct their own investigations. If the suspected abuser is another member of staff, suspension or disciplinary proceedings may ensue.
Referrals to the Local Authority are assessed against the published safeguarding thresholds normally rated 1 (not a protection issue) – 4 (adult protection team enquiry is necessary). Referrals assessed as levels 2 and 3 could involve enquiries being made by the homelessness service, adult patch or cluster social workers or other relevant professional.
Both internal and external enquiries should be as broad as necessary, drawing on evidence from all relevant sources.
Staff should be mindful of client confidentiality during the investigation. Support plans and risk assessments should be revised. Staff should look out for any consequences of the investigation on other clients in the service, and take action as a team to manage emerging risks or support needs. The investigation should result in an action plan to stop the abuse and/or to manage the risks that have been identified. For example, the client concerned might be supported to move to more appropriate accommodation; allocated a Social Worker or Community Psychiatric Nurse; or the project could introduce different ways of working to remove or reduce the risks. The Care Act statutory guidance requires staff to listen to and take account of the wishes of a competent client, even if the client’s wishes place them in jeopardy.
Training and continual professional development
All staff and volunteers must be trained in safeguarding, at either an ‘awareness’ level through to organisational strategic and operational leads. Some local authorities require safeguarding training to be delivered by approved training contractors. We advise our members to ensure that any training is delivered by experienced training professionals and takes account of the context of your work. Safeguarding training should be updated and refreshed regularly for all staff.
Organisations should consider including safeguarding training as part of continual professional development (CPD) of staff and managers. CPD may include training but could also include many other development activities, for example: personal research, writing briefings, policies and advice notes, keeping a reflective journal or facilitating a discussion group or activity. A useful starting point for CPD activity is an organisations appraisal or supervision process. We have provided a selection of CPD resources below.
Care Act 2014 statutory guidance, Chapter 14 Safeguarding www.gov.uk/government/publications/care-act-statutory-guidance/care-and-support-statutory-guidance
Homeless Link Resources, covering a range of relevant safeguarding issues directly or indirectly, including resources on: Women, Mental Health, Trafficking and Labour exploitation, Hate crime, LGBTQ+ people
Social Care Institute for Excellence, a constantly updated and influential resource on adult safeguarding
London Multi-Agency Adult Safeguarding Policy and Procedures, new guidance for safeguarding people who are homeless is being finalised and will form a new appendix (Appendix 7)
Local Government Association, a range of resources on safeguarding including some specialist content for housing staff
Continual Professional Development – examples of resources available
Manchester Safeguarding Boards has a range of links to many free training and development resources
NSPCC has a useful resource on female genital mutilation www.nspcc.org.uk/preventing-abuse/child-abuse-and-neglect/female-genital-mutilation-fgm/
Virtual College on course on awareness of forced marriage
MOOC List – a clunky but comprehensive search engine for free or pay-for-certificate online learning through world universities
Coursera – A MOOC (Massive Open On-line Course) platform course on Psychological First Aid from John Hopkins University www.coursera.org/learn/psychological-first-aid
EDX – A MOOC platform course on ‘Forced and Precarious Labor in the Global Economy: Slavery by another Name?’ from Wits University www.edx.org/course/forced-labour-and-precarious-labour-in-the-global-economy-slavery-by-another-name
Open Learn – OU MOOC platform course on Modern Slavery www.open.edu/openlearn/people-politics-law/the-law/modern-slavery/content-section-0?activetab=description-tab
IRISS – online course on developing reflective practice www.iriss.org.uk/resources/multimedia-learning-materials/reflective-practice
LEADERSHIP SAFEGUARDING STATEMENT
The Leadership of King’s Church / Caring Hands in the Community recognises the importance of its work with adults at risk and its responsibility to protect everyone entrusted to our care.
The following statement was agreed by the leadership/organisation on: _18 January 2023____and annually reviewed.
This organisation is committed to the safeguarding of adults at risk and ensuring their well-being.
We believe everyone should be valued, safe and happy. We want to make sure that adults at risk that we have contact with know this and are empowered to tell us if they are suffering harm.
Everyone has the right to be treated with respect, to be listened to and to be protected from all forms of abuse.
We recognise that we all have a responsibility to help prevent the physical, sexual, psychological, financial and discriminatory abuse and neglect of adults who have care and support needs and to report any such abuse that we discover or suspect.
We recognise the personal dignity and rights of adults who find themselves victims of forced marriage or modern slavery and will ensure all our policies and procedures reflect this.
We believe all adults should enjoy and have access to every aspect of the life of the organisation unless they pose a risk to the safety of those we serve.
We undertake to exercise proper care in the appointment and selection of all those who will work with adults with care and support needs.
We are committed to:
Following the requirements for UK legislation in relation to safeguarding adults at risk and good practice recommendations.
Implementing the requirements of legislation in regard to people with disabilities.
Ensuring that workers adhere to the agreed procedures of our safeguarding policy.
Keeping up to date with national and local developments relating to safeguarding.
Following any denominational or organisational guidelines in relation to safeguarding adults in need of protection.
Supporting the safeguarding co-ordinator/s in their work and in any action they may need to take in order to protect vulnerable adults.
Ensuring that everyone agrees to abide by these recommendations and the guidelines established by this organisation.
Supporting parents and families
Nurturing, protecting and safeguarding of adults at risk
Supporting, resourcing, training, monitoring and providing supervision to all those who undertake this work.
Supporting all in the organisation affected by abuse.
 The Care Act http://www.legislation.gov.uk/ukpga/2014/23/contents/enacted
 Public Interest Disclosure Act, 1998