{{org_field_logo}}

{{org_field_name}}

Registration Number: {{org_field_registration_no}}

---

Safeguarding Adults Policy

Policy Statement and Principles

{{org_field_name}} is fully committed to safeguarding the welfare and rights of adults using its supported living services. We have a zero-tolerance approach to any form of abuse or improper treatment. All staff are expected to uphold the highest standards of care and respect, ensuring that service users are protected from harm, treated with dignity, and empowered to live safely. Safeguarding is not just about responding to incidents, but also about actively promoting well-being, preventing abuse, and embedding a culture of openness and accountability throughout the organisation. This policy is grounded in the six key principles of adult safeguarding as outlined in the Care Act 2014, which guide how we operate:

• Empowerment: People are supported and encouraged to make their own decisions and give informed consent. We involve individuals in safeguarding processes and seek their wishes and views on desired outcomes.
• Prevention: It is better to take action before harm occurs. We strive to identify and reduce risks early, provide information about abuse, and create an environment where abuse is less likely to happen.
• Proportionality: Our response to any safeguarding concern is appropriate and least intrusive, considering the nature of the risk. We act in line with the level of concern, avoiding over-intrusion into people’s lives while still protecting them.
• Protection: We ensure that support and representation are provided for those in greatest need. We help people to report abuse or neglect, and we respond swiftly to protect those at risk.
• Partnership: We work together with local authorities, healthcare providers, community organisations, and the Safeguarding Adults Board. We share information appropriately and collaborate to prevent and respond to abuse, recognizing that communities and other agencies have a role in safeguarding.
• Accountability: We are transparent and accountable in delivering safeguarding. Roles and responsibilities are clear, we monitor and audit our safeguarding work, and the organisation learns from incidents to improve. Staff understand their duties and are supported through training and oversight.

 

Purpose and Scope

Purpose: This policy outlines how {{org_field_name}} prevents and responds to any allegations or incidents of abuse or improper treatment. It provides clear guidance to staff on their responsibilities and the procedures to follow. It also assures service users, families, and regulators (including the Care Quality Commission) that safeguarding is embedded in our service and that we foster a safe, caring environment.

Scope: This policy applies to all of {{org_field_name}}’s supported living services. It is specifically tailored to adults (age 18 and over, including older adults 65+) with physical disabilities and/or mental health conditions whom we support. (Our service does not currently provide for certain other groups such as individuals with significant learning disabilities, autism, or dementia; thus, this policy focuses on the needs of adults with physical and mental health support needs.) It covers all staff members (full-time, part-time, agency, and volunteers) and anyone working on behalf of {{org_field_name}}. Everyone in the organisation has a duty to uphold this policy. Service users and their families are made aware of the standards of care they should expect and how to report any concerns. This policy is limited to supported living services and is not intended for other service types (such as residential care homes or general domiciliary care not associated with supported living).

 

Legal and Regulatory Framework

{{org_field_name}} adheres to all relevant UK legislation, regulations, and guidance relating to safeguarding adults. Key legislation and standards informing this policy include:

• Care Act 2014: This Act provides the statutory framework for adult safeguarding. The Care Act and its statutory guidance define adult safeguarding as “protecting an adult’s right to live in safety, free from abuse and neglect.” Under Section 42 of the Care Act, local authorities have a duty to make enquiries if an adult (a) has care and support needs, (b) is experiencing or at risk of abuse or neglect, and (c) is unable to protect themselves as a result of those needs. Our policy aligns with the Care Act and the principle of “Making Safeguarding Personal,” ensuring the adult’s wishes, feelings, and well-being are central to any action.
• Health and Social Care Act 2008: This Act established the Care Quality Commission (CQC) and underpins the regulation of health and social care services. Providers of regulated activities must meet fundamental standards of quality and safety. Safeguarding is a core aspect of these fundamental standards. Failing to protect people from abuse or improper treatment can result in regulatory action, including refusal of registration or enforcement measures.
• Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 – Regulation 13: Regulation 13, “Safeguarding service users from abuse and improper treatment,” is one of the CQC’s Fundamental Standards. It requires providers to protect service users from any form of abuse or improper treatment. This includes neglect, degrading treatment, unnecessary or inappropriate restraint, and unlawful discrimination. The regulation mandates that systems and processes be in place to prevent abuse and to immediately investigate or act on any allegation or evidence of abuse. Non-compliance with Regulation 13 is a breach of the law; CQC can prosecute for certain failures that result in avoidable harm or significant risk. {{org_field_name}} meets this regulation by having effective systems to prevent abuse and respond promptly to any concerns.
• Care Quality Commission (Registration) Regulations 2009 – Regulation 18: These regulations require that certain incidents are notified to CQC. In particular, any abuse or allegation of abuse involving a person using the service must be reported to CQC without delay. We comply by ensuring the Registered Manager (or an alternate responsible person, as needed) submits statutory notifications to CQC about safeguarding incidents in line with these requirements.
• Human Rights Act 1998: This Act establishes fundamental rights and freedoms. In the context of safeguarding, key rights include the right to life (Article 2), the right to be free from torture or inhuman or degrading treatment (Article 3), the right to liberty and security (Article 5), and the right to respect for private and family life (Article 8). {{org_field_name}} ensures that our care practices uphold these rights at all times – for example, treating people with dignity, using least-restrictive interventions, and protecting individuals from cruel or degrading treatment.
• CQC Fundamental Standards: The CQC’s fundamental standards are the minimum standards below which care must never fall. Safeguarding overlaps several of these standards (such as safety, dignity, and respect). CQC inspectors will assess how we protect people from abuse, how we empower people, and how we learn from any safeguarding incidents. This policy demonstrates our commitment to those standards and provides guidance that inspectors, staff, service users, and families can refer to for understanding our approach.

(Note: Other relevant guidance includes the Mental Capacity Act 2005 (which we apply when supporting individuals who may lack mental capacity for specific decisions) and the Mental Capacity (Amendment) Act regarding Liberty Protection Safeguards, as well as the Public Interest Disclosure Act 1998 for whistleblowing protections. These are addressed in context below.)

 

Types of Abuse and Improper Treatment

Abuse can take many forms. All staff must be able to recognize the various types of abuse and neglect, as well as signs of improper treatment. Below are definitions and examples of different forms of abuse or harm relevant to adult safeguarding. No form of abuse is acceptable, and staff should be vigilant for any of these:

• Physical Abuse: Inflicting physical pain or injury, or causing impairment. Examples include hitting, slapping, pushing, kicking; misuse of medication (e.g. over-medicating or withholding medication); inappropriate restraint or physical sanctions; force-feeding; or any other non-accidental physical harm.
• Emotional / Psychological Abuse: Any action that causes emotional distress, fear, or diminished self-esteem. This includes threats of harm or abandonment, intimidation, humiliation, harassment, verbal abuse (shouting, insults), isolation or withdrawal of companionship, or controlling behavior that limits a person’s independence and choice.
• Financial or Material Abuse: The illegal or improper use of an adult’s money, property, or assets. Examples include theft, fraud, exploitation, pressure in connection with wills or financial documents, misuse of a power of attorney, coercing someone into financial transactions, or withholding access to money or possessions. Exploiting a person’s vulnerabilities for financial gain is a serious form of abuse.
• Sexual Abuse: Any sexual activity where the adult has not given consent, cannot give informed consent, or is coerced into participation. This includes rape, sexual assault, inappropriate touching, indecent exposure, sexual harassment, or forcing someone to view sexual materials. Any sexual activity between a staff member and a service user is strictly prohibited and considered abuse, regardless of apparent consent.
• Neglect and Acts of Omission: Failing to provide necessary care, support, or guidance, resulting in – or risking – serious impairment of health or well-being. Examples include not providing adequate food, hydration, shelter, clothing, medical care, or assistance with basic needs; ignoring a person’s care needs or instructions; leaving someone in unsafe or unsanitary conditions; or failing to respond to emergencies. In supported living, neglect could include not assisting a person who relies on support for daily tasks, or not responding when someone is in distress.
• Self-Neglect: When an adult neglects their own health, hygiene, or environment to a degree that their well-being is severely at risk. This can manifest as refusal of care or treatment, hoarding behavior, poor personal hygiene, not attending to medical conditions, or living in extremely unsafe/unclean conditions. Although the harm is self-directed, staff have a duty to recognize signs of self-neglect and seek appropriate support or interventions (for example, involving social services or health professionals) to protect the individual.
• Domestic Abuse: Any incident or pattern of controlling, coercive, threatening, or violent behaviour between individuals who are or have been intimate partners or family members. This encompasses physical, emotional, sexual, or financial abuse, and includes so-called “domestic violence” as well as controlling or coercive behavior. In a supported living context, staff should be alert to signs that a service user may be experiencing abuse from a partner or family member, even if that abuse occurs off the premises or outside of our service hours. We recognize that older adults and those with disabilities can be victims of domestic abuse, and we will respond appropriately if such concerns arise.
• Discriminatory Abuse: Harassment, slurs, bullying, or unequal treatment based on a person’s protected characteristics (e.g. age, disability, gender, race, religion or belief, sexual orientation). This includes disability-based hate crimes, racism, sexism, homophobic or transphobic abuse, and any other form of harassment or unfair treatment due to who someone is. Denying someone services or opportunities, or treating them as inferior, because of their characteristics is abusive. Staff must ensure that our service is free from discrimination, and any instances of discriminatory abuse are challenged and addressed.
• Modern Slavery: This includes slavery, human trafficking, forced labour, or domestic servitude. It involves exploiting people for personal or commercial gain. Adults with care and support needs might be targeted by traffickers or exploiters (for example, being coerced into work or prostitution). Staff should be aware of signs that a person is being controlled or exploited by others outside the service. Any suspicion of modern slavery is a safeguarding issue and a criminal matter – we will report such concerns to the police and the local authority Safeguarding Adults Team immediately.
• Organisational (Institutional) Abuse: Poor or abusive care practices within an organisation or specific care setting. This can occur when the routines, systems, or culture of a service result in neglect or mistreatment. Examples include: inflexible routines or regimes that disregard individual needs and preferences; inadequate staffing or an unsafe environment leading to neglect or rushed/rough care; inappropriate use of power or punishment by staff; or a culture that accepts sub-standard care or denies people dignity and choice. While {{org_field_name}} provides support in a person’s own home (supported living), we remain vigilant that our staff’s practices do not become routine-driven or disrespectful. Any tendency toward treating service users as “tasks” or using derogatory language, for instance, would be addressed as a form of organisational abuse. We maintain a person-centred culture to prevent this.
• Improper Treatment: Any form of care or treatment that is degrading, inhumane, or otherwise violates a person’s rights and dignity. Under Regulation 13, this includes things like inappropriate or excessive use of restraint or seclusion, providing care that significantly disregards a person’s needs, treating someone in a punitive or coercive manner, or any practice not in the person’s best interest. Improper treatment often overlaps with the abuse types above, but it is highlighted to ensure staff understand that any deviation from proper standards of care is unacceptable and unlawful. Even if something does not neatly fit one of the categories above, if it is disrespectful, undignified or causes harm, it must be reported and addressed.

Recognising Signs: Each type of abuse may have indicators. For example, physical abuse might show as unexplained bruises or frequent “accidents”; financial abuse could be noticed if a person’s bills aren’t paid or they seem anxious about money; emotional abuse might be suspected if a person becomes withdrawn, fearful, or overly submissive. Staff are trained to be observant and to take note of any changes in a service user’s behavior, mood, or physical condition that could suggest something is wrong. A key part of prevention is being alert to early signs and never ignoring “nagging doubts” – it is always better to report a concern that turns out to be unfounded than to miss a real problem.

 

Prevention and Safeguarding Culture

{{org_field_name}} believes that preventing abuse and neglect is as important as responding to it. We strive to foster a culture where safeguarding is everyone’s business and is embedded in daily practice. Key preventative measures include:

• Safer Recruitment: We follow rigorous recruitment and vetting procedures to prevent unsuitable people from working with our service users. This includes verifying employment history and references, conducting an enhanced Disclosure and Barring Service (DBS) check for all staff and volunteers before they start work, and evaluating candidates’ attitudes and values during interviews. We comply with our legal duty to refer staff to the DBS if they have been dismissed (or would have been) for harming or posing a risk of harm to vulnerable adults.
• Training and Awareness: All staff receive adult safeguarding training during their induction, and regular refresher training thereafter. This training covers how to recognize the signs of abuse and improper treatment and the correct procedures for reporting concerns. We also provide role-specific training where appropriate – for example, training on the Mental Capacity Act 2005 and (as applicable) the current Deprivation of Liberty Safeguards – to ensure staff understand how to uphold people’s rights. Staff are provided with up-to-date information on emerging safeguarding issues (such as financial scams targeting adults with disabilities, or new guidance on supporting people with mental health crises). Knowledge is reinforced continuously so that safeguarding remains at the forefront of our work.
• Professional Boundaries and Code of Conduct: We have clear expectations for staff behaviour, set out in our Code of Conduct. Staff must always maintain professional boundaries and respect the dignity, privacy, and rights of service users. It is never acceptable to bully, harass, or take advantage of a person in our care. Any form of belittling, shouting, rough handling, or punitive approach is strictly prohibited. Staff are encouraged to reflect on their practice and seek guidance from supervisors if they are unsure about the right course of action in a situation.
• Supportive Environment (Openness & Whistleblowing): We promote an open and supportive culture where concerns can be raised without fear of reprisal. Management actively encourages staff to speak up about any issues, mistakes, or worries (including concerns about colleagues’ practices) – blame-free reporting of errors or “near misses” is promoted so that we can learn and improve. We have a Whistleblowing Policy that protects staff who raise concerns in good faith. Any staff member who in good conscience reports wrongdoing, poor practice, or abuse is protected by law from retaliation (Public Interest Disclosure Act 1998), and our organisation will not tolerate any victimisation of whistleblowers. Service users and families are also encouraged to speak up about anything they are unhappy about – we treat such reports seriously and do not tolerate any retaliation against someone for reporting a concern. (See the Whistleblowing section below for more detail on external reporting options and protections.)
• Person-Centred Care and Risk Management: We provide individualized, person-centred support. Each service user has a detailed support plan and risk assessments that consider potential risks of abuse or self-harm. By understanding each person’s needs, preferences, communication methods, and vulnerabilities, we can take proactive steps to reduce risks. For example, if a person has a history of exploitation by others, their plan will include measures to monitor visitors or help manage their finances safely. We emphasize choice and empowerment – supporting people to make their own decisions – which can reduce vulnerability by boosting confidence and autonomy. We also routinely involve service users in discussions about what makes them feel safe or unsafe.
• Supervision, Monitoring, and Support for Staff: Managers provide regular supervision and support to staff, including discussions of any challenges or dilemmas they face in their work. Safeguarding is a standing agenda item in team meetings and one-to-one supervisions. We use these forums to reinforce good practice, discuss any incidents or near misses, and identify any signs of staff stress or attitudes that need attention. New or inexperienced staff receive mentoring and closer supervision to ensure they uphold standards. We also observe staff practice (through spot checks or working alongside staff) to monitor how care is delivered and catch any early signs of poor practice.
• Early Intervention: We take early signs of potential issues seriously. For example, if a service user has unexplained bruises, appears fearful of a particular staff member, or if there are multiple low-level complaints about the same issue, managers will look into these promptly rather than waiting for a serious incident. By addressing concerns when they are small (e.g. additional training for staff, adjusting care plans, providing counseling or support to a person in distress), we aim to prevent escalation. Patterns such as frequent medication errors or repeated instances of unsatisfactory care are treated as red flags and trigger a review and remedial action.
• Partnership Working: We maintain links and work in partnership with community professionals and agencies. This includes social workers, community nurses, General Practitioners (GPs), mental health teams, physiotherapists, advocacy organisations, and the Local Safeguarding Adults Board. By working together and sharing relevant information (in line with confidentiality and data protection rules), we create a network of vigilance around the people we support. For example, if a community nurse reports a concern about how a person’s wounds are being cared for, we will immediately investigate and involve the safeguarding team if needed. If issues are identified that we alone cannot resolve (such as suspected abuse by someone outside our service), we will seek help from the appropriate external agencies without delay.

By implementing these preventative measures, {{org_field_name}} strives to create a service where abuse is less likely to occur, and where any concerns are spotted and addressed early. Our goal is a positive, open culture in which safeguarding is “built-in” to everything we do.

Roles and Responsibilities

Safeguarding is the responsibility of every member of staff at {{org_field_name}}, as well as those in leadership positions. We have clear roles defined to ensure accountability and effective handling of safeguarding issues:

• Designated Safeguarding Lead (Safeguarding Officer):{{org_field_name}} designates a senior staff member as the Safeguarding Lead for the service (sometimes referred to as the Safeguarding Champion or Officer). This individual has overarching responsibility for coordinating safeguarding within our organisation.
  • Safeguarding Lead Name: {{org_field_safeguarding_lead_name}}
  • Role/Position: {{org_field_safeguarding_lead_role}}
  • Contact Phone: {{org_field_phone_no}}
  • Email: {{org_field_email}}

Key responsibilities of the Safeguarding Lead:
– Be the first point of contact for all safeguarding concerns or allegations. They ensure every concern is taken seriously, acted upon immediately, and recorded properly.
– Provide advice and support to staff who report concerns, guiding them through the process as needed. The Safeguarding Lead is knowledgeable about internal procedures and external referral pathways.
– Liaise with external agencies (such as the Local Authority Safeguarding Adults Team, police, and CQC). When a safeguarding concern needs to be formally referred to the local authority or another body, the Safeguarding Lead (or a delegate) will usually make or oversee that referral and ensure proper information sharing.
– Keep secure records of all safeguarding concerns, actions, and outcomes. The Safeguarding Lead maintains a central confidential log of all safeguarding incidents or alerts in the organisation, which is used to track patterns and ensure follow-up.
– Monitor the implementation of any safeguarding plans or actions that result from investigations. For example, if the Local Authority’s safeguarding enquiry leads to an agreed protection plan for a service user, the Safeguarding Lead ensures our staff implement those actions (such as increased monitoring, changes in care, etc.).
– Support the service user affected by a safeguarding incident. This includes ensuring that the person (and, where appropriate, their family or advocate) is kept informed and involved in decisions, consistent with the principle of Making Safeguarding Personal. The Safeguarding Lead seeks the individual’s input about what they want to happen and communicates updates in a sensitive way.
– Promote a safe culture. The Safeguarding Lead takes a lead on reminding everyone that “safeguarding is everyone’s responsibility.” They might organise refresher trainings, share lessons learned from incidents, or circulate new guidance. They also ensure that this policy (and related procedures) are reviewed regularly (at least annually, or whenever there are changes in legislation/guidance) and updated as needed. Any learning from safeguarding cases – things that went wrong or were handled well – is used to improve our practice.

In our supported living service, the Registered Manager also typically fulfills the role of Designated Safeguarding Lead. (If these roles are held by separate people, they work closely together. Important: If the Registered Manager is also the sole Nominated Individual for the service, see further guidance below on handling allegations involving that person.)

• All Staff and Volunteers: Every staff member and volunteer has a duty to protect the people we support from abuse and to uphold this policy. Key responsibilities for everyone include:
  – Vigilance: Remain observant at all times for signs of abuse, neglect, or improper care. Be aware of the potential for abuse in its many forms (as described in this policy). Pay attention to any changes in a service user’s behavior, mood, or physical condition that could indicate something is wrong.
  – Reporting: Immediately report any concern, suspicion, or disclosure of abuse following the procedures in this policy. Never assume that someone else will report it. It is each person’s responsibility to act – even if you only have a “nagging doubt,” report it (it can be assessed and followed up by the appropriate people). If you ever feel that your immediate line manager is not the appropriate person (for example, if they are involved in the concern), you have a responsibility to escalate the report to a higher manager or directly to external authorities – see Reporting Procedures below.
  – Do Not Investigate Alone: Staff should not try to investigate or resolve serious concerns by themselves, nor confront alleged perpetrators on their own. Follow the reporting procedure so that proper investigation can be done in a safe, impartial manner. In the moment, focus on supporting and reassuring the service user and preserving any evidence, rather than trying to interrogate anyone.
  – Cooperation: Work openly with the Safeguarding Lead and any external investigators (such as the local authority or police). This means providing honest accounts of what happened, handing over records or evidence if requested, and attending meetings or interviews as needed.
  – Confidentiality: Maintain confidentiality about safeguarding matters. Do not discuss details openly or with people who have no need to know. You can share information with the appropriate managers or authorities as part of a report – that is not a breach of confidentiality. But beyond that, details should be kept on a need-to-know basis to protect privacy and the integrity of investigations.
  – Respect and Support: Continue to treat the service user involved with compassion and respect. If a person has experienced abuse or raised a concern, they may be anxious or traumatized. All staff should be sensitive to their needs, ensure they feel safe, and not do anything that could be seen as punitive or doubting toward them for having raised an issue.
  – Training: Participate in all required safeguarding training and refresh knowledge regularly. Every staff member must read and understand this Safeguarding Policy and related guidelines. If anything is unclear, or if additional guidance is needed (for example, how to handle a specific scenario), staff should seek advice from a manager or the Safeguarding Lead. Being proactive in learning shows commitment to protecting those in our care.
• Registered Manager: The Registered Manager (who may also be the Safeguarding Lead and is the person CQC holds accountable for day-to-day management) has specific obligations, including ensuring that all safeguarding systems are in place and effective. The Manager must foster the right culture, ensure staff are trained and supervised, liaise with external bodies, and notify CQC and others as required. The Manager reviews all safeguarding reports, ensures appropriate action is taken, and learns from incidents. In our organisation, the Registered Manager and Nominated Individual are the same person ({{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}). Ultimate accountability for safeguarding lies with them. They are responsible for resourcing the safeguarding function (e.g. enough staff, training budget) and for making sure that any recommendations from safeguarding reviews or inspections are implemented. (If an allegation of abuse is made against the Registered Manager/Nominated Individual, they must not be involved in investigating or handling it – see procedures below for alternative reporting routes in that situation.)
• Nominated Individual/Company Directors: The Nominated Individual (NI) for CQC is responsible for supervising the management of the service on behalf of the provider organisation. In our case, the NI is the same person as the Registered Manager. If there were other senior executives or a board of directors, they would be expected to receive regular reports on safeguarding (numbers of concerns, any major incidents, outcomes) and ensure that the organisation as a whole is meeting its safeguarding responsibilities. They would also support the Registered Manager in making any necessary improvements. If the Nominated Individual is implicated in a safeguarding allegation, the organisation will designate an appropriate external person (e.g. an area manager from a sister service, or a consultant) to oversee the case and liaise with authorities, in order to maintain objectivity.

Everyone from frontline support workers to the most senior leader has a part to play. We emphasize that safeguarding is “core business” for all of us – it is not an optional task or something only managers handle. Each role has different duties, but they all interlock to create a strong safety net for the people we support.

Procedures for Reporting and Responding to Safeguarding Concerns

All concerns or suspicions of abuse or improper treatment must be taken seriously and dealt with swiftly and appropriately. The following procedures outline how staff (and others) should raise concerns, and how those concerns are handled within {{org_field_name}}. We emphasize prompt reporting, thorough investigation, and partnership with external authorities at every step. Staff are trained on these procedures, and this section of the policy is available as a quick reference.

Recognising and Raising Concerns

1. Immediate safety first: If you think a person may be in immediate danger or in need of urgent medical attention, act at once to secure their safety. For example, if you find a service user with an injury or in a dangerous situation, ensure they are safe and call emergency services (dial 999) if needed. If a crime is in progress or imminent, call the police immediately. Ensuring the person’s safety is the top priority.

2. Pay attention to your instincts: If something doesn’t seem right – for instance, you notice unexplained bruises, sudden changes in behavior or mood, a service user seems unusually afraid of a particular individual, or any other “red flag” – do not ignore it. It is better to report a suspicion that turns out to be unfounded than to miss a situation of real abuse. Trust your professional curiosity and compassion.

3. Listen and reassure (for disclosures): If an adult directly confides in you that abuse or neglect is happening (this is often called a “disclosure”), stay calm and listen carefully. Let them speak at their own pace. Reassure them that they did the right thing by telling you and that you take them seriously. Do not promise to keep secrets. It is important to explain gently that you will need to report this to people who can help keep them safe, but you will only tell those who absolutely need to know. Avoid asking leading questions or pressuring the person for more details – just gather the basics (who, what, when, where, in their words) and thank them for telling you.

4. Preserve evidence (if applicable): In some cases (especially if a crime may have occurred, such as a physical or sexual assault, or theft), it’s important to preserve any potential evidence. This could include, for example, not tidying up the scene of an incident, keeping any torn clothing, notes, or objects involved, and securing any relevant CCTV footage. Do this only if it does not further distress the person – evidence is secondary to someone’s immediate welfare. If you’re unsure, you can get advice from a manager or the police on how to preserve evidence properly.

Once the immediate safety and initial information gathering steps above have been addressed, the next step is to report the concern internally without delay.

 

Internal Reporting Procedure

As soon as any staff member or volunteer suspects abuse, witnesses an incident, or receives an allegation or disclosure, they must report it internally immediately. Do not wait until the end of your shift or the next day. Our internal reporting pathway is as follows:

• Report to line manager or Safeguarding Lead: Inform your immediate line manager verbally as soon as possible (ideally this should be done immediately when safe to do so, and certainly before you go off duty). If your line manager is not available, or if they are implicated in the concern, report directly to the Designated Safeguarding Lead or another senior manager. The Safeguarding Lead for our service is the Registered Manager (contact details above). In normal circumstances, they should be notified of all safeguarding concerns right away. If the allegation involves your line manager or you have reason to believe your manager may not act on the concern (for example, if the manager or a senior figure is the person accused), you must bypass them and go to the next step – see below.
• If the concern involves the Registered Manager/Nominated Individual (or there is a conflict of interest preventing you from reporting to them), you should not report it to that person. Instead, you must report directly to an external authority. This can be:
  • The Local Authority Safeguarding Adults Team for our area (contact information is provided in this policy). They are the lead agency for safeguarding enquiries and can take the report directly.
  • You may also inform the CQC of your concern (especially if you fear the issue might not otherwise be addressed). CQC has channels for staff whistleblowing and will keep your identity confidential if needed.
  • If a crime is alleged (e.g. an assault by the manager), you should report it to the police as well.

In such a scenario, also consider contacting our organisation’s owner or another director if one exists (in some cases the manager may also be the owner, but if not, an owner or board member should be informed). The key point is that concerns about the most senior person must still be reported – do not allow loyalty or fear to prevent you from reporting. We assure staff that they will not suffer adverse consequences for bypassing the normal chain of command in order to protect service users. (This is supported by whistleblowing law and our own policy.) The Local Authority and CQC expect providers to have this kind of contingency.

• Document the concern: As soon as you are able, and after any immediate verbal report, write down all details of the concern using our Safeguarding Incident Report Form (or appropriate incident report form). Include factual information: what happened or was observed/heard, who was involved (names of the adult at risk, the alleged perpetrator, and any witnesses), when and where it occurred, and any immediate actions you took. Use the person’s own words where applicable (especially for disclosures). Do not include your opinions or conclusions – just the facts and any direct disclosures. Sign and date your report. Remember, the written report should be completed promptly, but do not delay making the initial verbal alert in order to write everything down – do the verbal report first, then the written record shortly afterwards.
• Notify the Safeguarding Lead: If you initially reported to a line manager (and that person is not the Safeguarding Lead), that manager must immediately inform the Designated Safeguarding Lead (unless they are already aware). In practice, staff are encouraged to ensure the Safeguarding Lead/Registered Manager is aware as soon as possible. If the Safeguarding Lead is unavailable (e.g. on leave or it’s after hours), inform the on-call manager or most senior person available. We always want the person in charge of the service to know about any safeguarding matter quickly so they can coordinate next steps.
• Out-of-Hours Reporting: Safeguarding issues can arise at any time, including evenings, nights, or weekends. {{org_field_name}} maintains an on-call system for out-of-hours support. If a concern arises outside of normal office hours, staff should call the on-call phone at {{out_of_hours}}. The on-call manager will respond and guide the immediate actions, including notifying the Registered Manager or Safeguarding Lead as needed. We also have emergency contact details for the local authority’s out-of-hours safeguarding service (usually a duty social worker or emergency duty team) – staff can contact them directly if they cannot reach a manager and the situation is urgent.
• Protect individuals and preserve evidence: If the concern involves a specific staff member or volunteer potentially harming an adult, that person will be removed from any direct contact with service users pending further investigation. This might involve a precautionary suspension (in line with our HR policies) or assignment to duties away from the vulnerable person, in order to ensure everyone’s safety. The Registered Manager/Safeguarding Lead will make this decision immediately upon learning of the allegation. Additionally, as noted, preserve any potential evidence (do not clean up or remove items if an incident just occurred, save any related documents or records, etc.) until guidance is given by investigators. For example, if there was an allegation of theft, secure any financial records; if an alleged physical assault occurred in a room, try to leave that environment undisturbed.
• Initial Management Assessment: The Safeguarding Lead or senior manager who has taken the report will quickly assess the information available and decide on next steps. This is a brief risk assessment and decision point – not a full investigation. The criteria are essentially: Is there reason to suspect abuse or improper treatment? If yes (or if in doubt), they will escalate the concern to external authorities immediately. They will also ensure that any immediate protective measures needed are in place (as described, e.g. staff suspension, medical care, extra supervision for the service user, etc.). They document the rationale for their decisions and actions. If the manager/lead assesses that the situation does not meet safeguarding thresholds (for example, it was not abuse but a service user accident), they will still document it and may handle it through other appropriate processes (like health and safety, care plan review, etc.) – but borderline cases will usually be referred out for safety.

At this point, an internal report has been made and initial actions taken. The next stage often involves external reporting – contacting agencies like the local authority – to ensure a proper safeguarding enquiry is conducted under multi-agency procedures.

External Reporting and Safeguarding Enquiries

{{org_field_name}} works in partnership with the Local Authority and other agencies in accordance with multi-agency safeguarding procedures. Under the Care Act 2014, the Local Authority is the lead agency for coordinating safeguarding enquiries in most cases. We will involve external authorities without delay whenever required. Our procedure for involving external agencies is:

• Referral to the Local Authority Safeguarding Adults Team: The Safeguarding Lead (or in their absence, the senior person in charge) will report the concern to the Safeguarding Adults Team of the Local Authority in the area where the service user lives. This initial referral will be made immediately for any serious incident or urgent concern (by telephone), and certainly within 24 hours of the concern coming to light for all other cases. We will provide full details of the situation, following the local authority’s preferred referral process (some have an online form or a dedicated email/fax for safeguarding alerts, others take referrals by phone). We include all relevant information such as the details of the adult at risk, the nature of the concern, immediate actions taken, and our contact information. Once the referral is made, the Local Authority will decide if the criteria for a Section 42 Safeguarding Enquiry are met and will advise on next steps. We document the time and method of the referral and the name of the person we reported to.
  • Local Authority Name: {{org_field_local_authority_authority_name}}
  • Safeguarding Adults Team Contact – Email: {{org_field_local_authority_authority_email}}
  • Phone: {{org_field_local_authority_phone_number}}
  • Online Reporting Link: {{org_field_local_authority_information_link}}
  • Local Authority out of hours phone: {{org_field_local_authority_out_of_hours_phone_number}}

(The above are the contacts to use if we need to make a safeguarding referral or seek advice. These are kept up-to-date. If the concern arises outside normal hours, we contact the Local Authority’s Emergency Duty Team at their out-of-hours number.)

Important: If the allegation implicates our own management (e.g. the concern is about the Registered Manager), the referral to the Local Authority will be made by whichever staff member or alternate manager received the report, to ensure it is done without bias. We will clearly communicate that conflict of interest to the Local Authority so that any enquiries can be handled appropriately.

• Involving the Police: If a potential crime has been committed – for example, allegations of physical assault, sexual abuse, theft/financial exploitation, or any time a person is at immediate risk of harm – the police must be notified without delay. The Safeguarding Lead or manager will contact the police to report the incident and seek guidance on preserving evidence. For emergencies or crimes in progress, we call 999. For non-emergency situations (where the person is not in immediate danger but a crime is suspected), we can call the police non-emergency line (such as 101 or the local police safeguarding unit). We follow police instructions on what to do next. Staff should avoid disturbing any potential evidence before the police arrive or advise (for instance, do not wash clothing or clean a room if a physical or sexual assault is alleged, until the police say it’s okay). We understand that the police and the Local Authority will coordinate in criminal matters – our role is to report and then cooperate fully.
• Notifying CQC: Management will notify the Care Quality Commission about any safeguarding incident or allegation of abuse in line with regulatory requirements. Specifically, CQC (as our regulator) requires us to submit a statutory notification for incidents of abuse or allegations of abuse involving people using our service. The Registered Manager (or delegated staff if the Manager is unable or is the subject of the allegation) will complete and send the required Notification Form (Regulation 18 notification) to CQC without delay. This is typically done via CQC’s online portal or email, following their guidance. We include details such as what happened, when we notified the local authority, and what actions we are taking. We will also report outcomes to CQC as required. (Note: While CQC does not investigate individual safeguarding incidents, they monitor how we handle them and may use the information to inform inspections or further action.)
• Other Notifications: Depending on the situation, there may be other bodies to notify:
  • If a staff member is implicated and is either a registered professional (e.g. a nurse) or a volunteer with another organisation, we may need to notify their professional body or that organisation.
  • If a crime has occurred, besides police we might need to inform the commissioning authority (if the placement is funded by a council/NHS).
  • If the person involved is subject to Court of Protection or Deputyship, we may inform those authorities as relevant.
  • We will also consider our duty to refer people to the Disclosure and Barring Service (DBS): if a staff member is removed from their role (dismissed or even if they resign) because they harmed, or posed a risk of harm to, an adult, we have a legal obligation to refer that individual to the DBS for potential barring from care work.
• Cooperating with the Safeguarding Enquiry: Once the local authority has been notified, they will typically lead on the safeguarding enquiry (investigation) or decide on a plan of action. {{org_field_name}} will cooperate fully with any requests or directions given as part of this multi-agency process. This may involve:
  • Providing additional information or detailed written reports about the incident or our knowledge of the individuals involved.
  • Attending strategy meetings or case conferences convened by the Safeguarding Adults Team.
  • Carrying out any internal actions or adjustments that are requested. For example, the authorities might ask us to suspend an employee, increase monitoring of a particular service user, or secure certain records.
  • Developing a protection plan for the adult at risk, in conjunction with social workers or other professionals.
  • Contributing to risk assessments or decision-making discussions.
  • Our Safeguarding Lead (or a designated deputy) will act as the liaison person for communications with the local authority and other external bodies. They will ensure that we promptly fulfill any action items assigned to us and will keep the authorities updated on any developments on our side. All staff are expected to assist in the enquiry as needed and to be honest and transparent in all dealings. We understand that our candor and cooperation are essential for the safeguarding process to work effectively.
• Informing Family or Representatives: We recognize the importance that those close to the service user can play in supporting them through a safeguarding issue. With the permission of the adult at risk, and if it does not put anyone at further risk, the Safeguarding Lead or Manager will inform the service user’s next of kin or designated representative that a safeguarding concern has been raised and is being dealt with. We do this sensitively and in consultation with the person. If the adult has capacity and does not want their family informed, we will respect that choice unless there is an overriding duty (for example, others are at risk or a law requires disclosure). If the adult lacks capacity to decide about family involvement, we will make a best interests decision (possibly involving an advocate) about who, if anyone, to inform, considering what the person’s wishes might be and the potential benefit or harm of involving family. In all cases, the priority is the safety and well-being of the adult at risk.
• Consent and the Adult’s Wishes: Whenever possible, safeguarding will be done with the participation and consent of the adult concerned. We will always consider the adult’s consent before reporting a concern. If an adult at risk says they do not want any referral or action taken, the Safeguarding Lead will have a conversation with them to understand why, to explain our duty of care, and to outline what might happen next. There are situations where we may need to override a person’s wish not to report, such as:
  • if others are at risk of harm (e.g. there is a potential threat to other residents or to children),
  • if a serious crime has been committed,
  • or if the person is believed to be under undue influence or coercion preventing them from agreeing.
    We carefully consider these factors and may seek advice from the local authority. If we decide to report against the person’s wishes, we will document the justification (e.g. “decision made in public interest due to risk to others” or “vital interests – life-threatening situation”). We will inform the individual of our decision unless doing so would further endanger them or others. Throughout, we will continue to support them and involve them in as many decisions as possible. Our practice follows the principle of “no decision about me without me” to the fullest extent achievable.
• Follow-Up and Ongoing Support: Throughout any external safeguarding process, {{org_field_name}} continues to monitor and support the well-being of the service user. We do not wait passively for an outcome; we take any additional internal steps needed to ensure the person’s safety and to address their needs. For example, we might implement extra staffing or checks, arrange counseling or emotional support, adjust how we deliver care to better protect the person, or in extreme cases (with multi-agency agreement) help the person move to a temporary place of safety. We keep detailed records of all actions taken, communications with external agencies, and updates on the person’s condition.
• Outcome and Recording: The safeguarding process will conclude with an outcome (substantiated, not substantiated, inconclusive, etc.) after investigation. We cooperate with the local authority in concluding the enquiry. Internally, we will:
  • Take any further action needed (e.g. disciplinary action against a staff member found to have violated rules, changes to procedures, additional staff training).
  • Meet with the service user (and their representative if appropriate) to discuss the outcome, ensuring they understand what was found and what will happen next. This is in line with Making Safeguarding Personal, treating the person with respect and transparency.
  • If no further action by external authorities is taken (say they decide it’s not a safeguarding issue or it doesn’t meet threshold), but we still have concerns, we may conduct our own investigation or review to ensure the person is safe and lessons are learned.
  • Provide feedback to the person who raised the concern (if appropriate and without breaching confidentiality). For staff who reported, we acknowledge their actions and remind them of our support.

Throughout this entire process, our guiding principle is that the safety and rights of the adult at risk come first. We will navigate confidentiality and information-sharing in a way that best protects individuals (sharing information with authorities when necessary and permissible under GDPR/Data Protection for safeguarding purposes, as the law allows).

Whistleblowing (Reporting Concerns About the Organisation)

Whistleblowing is the reporting of concerns by staff (or volunteers) about wrongdoing or poor practice within their own organisation. This can include concerns about abuse, negligence, or any breach of professional standards. {{org_field_name}} supports and protects whistleblowers, and we consider whistleblowing an important part of our safeguarding culture. Our stance is that any staff member who discovers or suspects serious wrongdoing – including abuse or cover-ups – has not just the right but the responsibility to report it, and they will be protected when doing so.

Key points of our Whistleblowing approach:

• Internal Whistleblowing: Staff are encouraged to raise concerns internally first, if possible, by reporting to management or using any designated confidential reporting channel we have. This policy and our Whistleblowing Policy give multiple options (line manager, senior manager, or direct to the Registered Manager or Safeguarding Lead) to report concerns. We aim to handle such concerns promptly and fairly, investigating the issues and remedying any confirmed problems. We keep the whistleblower’s identity confidential as far as we can (if they request it), and we will never tolerate any retaliation against someone for making a report in good faith.
• Protection from Retaliation: Staff who whistleblow are protected by law. The Public Interest Disclosure Act 1998 (PIDA) protects workers from being fired or mistreated for raising certain concerns in the public interest. We fully comply with this. Any employee, volunteer, or contractor who raises a genuine concern will not suffer harassment, bullying, or career disadvantage as a result. Any attempt to retaliate against a whistleblower will be treated as a serious disciplinary offense. (This applies even if the concern turns out to be mistaken or unsubstantiated, as long as it was raised in good faith.) We explicitly reassure staff: you will not be penalized for doing the right thing by reporting concerns.
• External Whistleblowing: If a staff member feels unable to raise a concern internally (for example, if the issue involves senior management, or they feel the concern hasn’t been addressed after reporting), they have the right to report concerns to certain external bodies (“prescribed persons”). For care services, key prescribed bodies include:
  • Care Quality Commission (CQC): Staff can contact CQC to report concerns about care quality or safety at our service. CQC has a dedicated whistleblowing team. They can be reached via an online form, by email, or by phone at 03000 616161. CQC will keep the whistleblower’s details confidential if requested and consider the information for regulatory action.
  • Local Authority Safeguarding Team: As described, staff can directly approach the local safeguarding authorities to report abuse, even if it’s about their own employer. The local authority will take action as appropriate regardless of who reports.
  • Police: If the matter is criminal, the police can be contacted directly.
  • Whistleblowing Helpline / Protect: There is an independent, free Whistleblowing Helpline for NHS and Social Care (formerly run via a service called “Speak Up” or by Mencap) at 08000 724 725. Staff can call this helpline for advice. Additionally, the charity Protect (formerly Public Concern at Work) provides confidential legal advice to whistleblowers; they can be reached at 020 7404 6609 or via email. They help staff understand how to raise concerns safely and what protections they have.
  • Local Government & Social Care Ombudsman (for social care) or Professional Bodies: In some cases, depending on the issue, staff might contact the Ombudsman or their professional regulator (if, for example, it concerns misconduct of a nurse or social worker).
• Anonymous Reporting: Staff may choose to report anonymously (not providing their name). While we accept anonymous reports, we encourage people to give their name when possible, because it allows us to ask follow-up questions and provide feedback or protection. However, anonymous complaints will still be reviewed and acted upon to the extent possible.
• Acting in Good Faith: We expect whistleblowers to raise concerns in good faith (meaning they genuinely believe there is an issue). Malicious or knowingly false allegations are not protected by law or our policy and would be taken seriously in terms of disciplinary action. Fortunately, such cases are rare. We focus on creating an environment where honest reporting is welcomed.
• Supporting Whistleblowers: Management will check in with whistleblowers to ensure they are not experiencing negative consequences. If a staff member feels pressure or harassment after raising a concern, they should inform a senior manager or even the CQC. We can, for instance, reassign or suspend anyone who is retaliating against a whistleblower. We may also provide access to confidential counseling or support for the whistleblower if the situation has been stressful.

In summary, our message to staff is: If you see something that troubles you – whether it’s about how service users are treated, safety risks, fraud, or any serious issue – speak up. You can do so without fear. We have both internal mechanisms and external avenues for you to report. It is far better to raise a concern and protect people, than to stay silent and allow harm or bad practice to continue. CQC expects providers to have effective whistleblowing procedures and to make them known to staff, and we fully embrace that expectation.

(For more details, staff should refer to the full Whistleblowing Policy of {{org_field_name}}, which provides additional guidance on how to raise concerns and the process that follows.)

Supporting Service Users and Families in Safeguarding

Safeguarding is ultimately about the well-being of the people we support. {{org_field_name}} is committed to ensuring that service users are at the heart of any safeguarding process. We operate under the principle “Nothing about you, without you.” In practical terms, this means:

• Information and Empowerment: We provide all service users (and/or their representatives, such as family or advocates) with information about their right to be safe and how to raise a concern. Upon starting services with us, each person receives information – for example, a user-friendly leaflet or a section in their welcome pack – explaining what abuse is, that they have a right not to be abused, and how they can report anything that worries them. This includes multiple avenues (telling a staff member they trust, contacting the local authority Safeguarding Team directly, calling CQC, or even the police). We explain this in a way the person can understand, taking into account any communication needs. We also periodically remind service users of this information (in meetings or one-to-one chats), especially if we introduce new staff or if there are changes.
• Encouraging People to Speak Up: We actively encourage individuals to speak up if something is wrong. We aim to build trusting relationships so that service users feel comfortable telling staff if they feel unsafe, unhappy with care, or if someone is mistreating them. We reassure service users that they will not get into trouble for reporting a genuine concern or for complaining. If a person has difficulty communicating, we pay attention to non-verbal signs (behavior changes, facial expressions, etc.) and create opportunities for them to express feelings (like using communication aids or involving speech-and-language professionals as needed). We also encourage a culture where peers (other service users) can speak up for each other – e.g. in group settings, promoting that if they see a friend being treated badly, it’s right to report it.
• Involvement in the Process: When a safeguarding concern involves a service user, we involve that individual as much as possible in decisions and safeguarding plans. This is in line with the Care Act’s focus on Making Safeguarding Personal. We ask them what they would like to happen, who (if anyone) they want to support them through the process, and we keep them informed about what is going on. For example, before any formal meetings about them, we explain what the meeting is and could offer to have an advocate or supportive person with them. We check during and after the process how they feel and what outcomes they want. The person’s wishes, feelings, and best interests are central.
• Family/Representative Involvement: With consent, we will involve family members or loved ones in safeguarding discussions. Families often know the person very well and can provide insight or support. We also educate families on signs of abuse and encourage them to report any concerns. We stress that we welcome their input and that raising a concern will not negatively affect the care their relative receives (families sometimes fear complaining might cause repercussions – we dispel that fear). If the alleged abuser is a family member or friend, we handle that delicately: we involve the appropriate external agencies to investigate, while ensuring that the service user’s rights (and the rights of the family member) are respected. Sometimes, difficult decisions (like restricting a harmful family member’s access) have to be made for safety; we do this following multi-agency guidance and legal advice where needed.
• Advocacy: If a service user would benefit from additional support to express their views or exercise their rights during a safeguarding matter, we will help arrange an independent advocate. This could be, for example, connecting them with a local advocacy service or ensuring they have an Independent Mental Capacity Advocate (IMCA) if they lack capacity for key decisions and have no family to represent them (as required by the Mental Capacity Act 2005). The advocate’s role is to support the person’s involvement and voice their wishes. We provide information to the advocate and cooperate so they can do their job. All decisions taken will be explained to the person in a suitable way, and an advocate helps ensure that explanation is understood.
• Transparency and Feedback: We strive to keep the service user (and their chosen representative, if involved) informed about the progress and outcome of any safeguarding concern. We do this in an accessible manner – avoiding jargon, possibly across multiple conversations if needed. At the conclusion of a case, we (often together with the social worker or safeguarding coordinator from the local authority) will meet with the adult to discuss the outcome. We explain what was found, whether abuse was confirmed or not, and what will happen next (for example, “Staff X has been removed from working here” or “We are going to provide extra support at meal times to help you feel safe”). If no further action is taken (say, the investigation found no evidence or the person was mistaken), we will still explain as much as is appropriate about why that decision was made, and check if the person still has any worries we need to address. Our goal is that the person is not left in the dark; being involved helps restore trust and empowerment.
• No Retaliation or Adverse Effect: We assure service users and families that raising a concern will never result in any form of retaliation or reduction in their service. We will continue to support them with the same quality of care (or better, if improvements are needed). Any suggestion that a service user or family member is being treated differently (e.g., ignored, given poorer care, or intimidated) because they made a complaint or report will itself be treated as a serious matter. In fact, if a service user or their relative ever feels they are experiencing negative consequences after reporting something, we encourage them to immediately notify senior management or contact external authorities. We reinforce this message often: people should feel safe to voice concerns.

In essence, we want the individuals we support and their loved ones to feel confident, safe, and listened to. Safeguarding is not a process done to people; it’s done with them. By empowering our service users and their families, we not only respond to issues better but also prevent harm by building a foundation of trust and openness.

 

Managing and Recording Incidents and Complaints

Not all issues will start as an obvious “safeguarding” concern; sometimes they may come to light through an incident report or a complaint. {{org_field_name}} integrates its safeguarding system with its incident reporting and complaints handling to ensure nothing falls through the cracks.

• Incident Reporting: We have an internal Incident/Accident Reporting procedure that all staff must follow for any untoward events (e.g., injuries, medication errors, behavioral incidents). Every incident is documented on an incident form or in our incident log with details of what happened and what actions were taken immediately. These incident reports are reviewed by the Registered Manager (or delegate). If any incident raises or reveals a safeguarding concern, it will be escalated and managed under this Safeguarding Policy without delay, even if simultaneously being addressed as an operational issue. For example, if an incident report shows a pattern of a service user falling frequently due to staff not responding to call bells, that could indicate neglect – we would initiate a safeguarding enquiry into that pattern while also handling the falls via care plan review. We make it clear to staff: checking the “safeguarding” box on an incident form or notifying a manager that an incident might be abuse triggers the safeguarding procedures described above. We don’t wait for a complaint or someone external to notice – we self-refer when needed. Management monitors all incident reports for any trends or red flags that might indicate abuse or risk (such as multiple bruises, several service users having similar complaints about one staff member, etc.). These are discussed in governance meetings (see Monitoring section) to catch issues early.
• Complaints and Safeguarding: We treat all complaints by service users or their representatives seriously and respond according to our Complaints Policy. However, if a complaint includes information suggesting abuse, neglect, or improper treatment, we will invoke the safeguarding procedures immediately. For example, if a family member complains that their father’s money has been going missing in our service, that is not just a complaint about quality – it is a potential financial abuse concern and will be dealt with as such. In practice, this means the Registered Manager (who usually handles complaints) will immediately ensure safety (perhaps suspend a staff member if implicated), report to the local authority safeguarding team, etc., in parallel with giving the complaint response. We will inform the complainant that we have to escalate the issue as a safeguarding matter for the person’s protection. Our complaint response may be put on hold or combined with the safeguarding outcome, to avoid interfering with an investigation. Importantly, making a complaint will never prejudice a person’s access to support or our attitude toward them. We have a duty to welcome complaints as opportunities to improve.

If a person is dissatisfied with the outcome of a complaint or how it was handled, we advise them of external avenues: for example, the Local Government & Social Care Ombudsman can review unresolved complaints about adult social care services. We also inform them that while CQC does not resolve individual complaints, they can be informed of concerns and will use that information in their regulatory oversight. In cases where a complainant might not trust our internal process (e.g., if the complaint is about a high-level person or serious abuse), we would encourage them to go straight to the local authority or police as appropriate – essentially, treating their complaint as a safeguarding referral themselves.

• Complaints Procedure Availability: We give all service users and families a copy of our complaints procedure, which includes contact details for who to complain to internally and externally. This includes the manager’s contact and the local authority/Ombudsman contacts. We ensure it’s in an accessible format. We also display information in communal areas on how to make a complaint or report a concern.
• Using Complaints/Incidents to Improve: In line with CQC guidance, we use incidents and complaints as a source of learning to improve our service and to identify potential abuse. For instance, multiple minor complaints about staff rudeness could indicate a need for culture change or closer supervision, which if unaddressed could escalate into psychological abuse. By addressing patterns seen in complaints/incidents proactively, we strengthen prevention.

All incidents and complaints records are kept confidentially and securely. When they involve safeguarding, they are cross-referenced in the safeguarding log. Senior management reviews these records regularly to ensure proper action was taken in each case and to spot any unresolved issues.

 

Monitoring, Review, and Continuous Improvement

Continuous improvement in safeguarding is essential. {{org_field_name}} will monitor the implementation of this policy and ensure accountability at all levels. Key actions we take include:

• Management Oversight of Safeguarding Logs: The Registered Manager and Safeguarding Lead maintain a log of all safeguarding concerns, alerts, and incidents in the service. This log (with due regard to confidentiality) is reviewed frequently. We look for any trends or patterns – for example, repeated incidents at a certain time of day, or multiple concerns involving the same individual or staff member. If patterns are identified, management develops an action plan to address underlying causes (such as additional staff training, adjusting staff rotas, or changing how support is delivered). Trends or lessons are shared with the team so everyone is aware and can help prevent recurrence.
• Quality Audits and Self-Assessment: We conduct periodic audits of our safeguarding practices. For instance, a senior manager (or an external auditor if engaged) will review a sample of safeguarding cases to ensure proper procedure was followed (Was the concern reported promptly? Were notifications made? Were records complete?). We also audit staff training records to verify all staff are up-to-date on safeguarding training. We may utilize tools or checklists provided by the Local Safeguarding Adults Board or our commissioners to self-assess our safeguarding performance. Any findings from these audits are documented and translated into concrete improvement actions, with responsible persons and timelines. For example, an audit might reveal that not all staff knew about the out-of-hours contact – the action would be to re-issue the on-call number card to all staff and post it visibly.
• Feedback from Service Users and Families: We actively seek feedback from those we support about whether they feel safe and how well they feel we respond to concerns. This can be done in tenants’ meetings, annual surveys, or during care plan reviews. We may ask questions like “Do you know who to talk to if you felt unsafe?” and “Do staff listen and respond when you tell them something is wrong?”. If we receive suggestions (e.g., a service user might say they’d prefer more easy-read posters around explaining abuse), we consider and implement these where possible. Involving people in reviewing the effectiveness of safeguarding measures helps ensure our policy is not just words on paper but working in practice.
• Staff Debriefs and Supervision: After any serious incident or safeguarding case, once concluded, we hold debrief sessions with the staff involved and the wider team as appropriate. The goal is to support staff (some events can be traumatic for caregivers too) and to reflect on what happened, what was done well, and what could have been done differently. We promote an atmosphere of learning rather than blame. The insights from these debriefs can inform updates to procedures or additional training needs. Additionally, in routine supervisions and team meetings, safeguarding is a standing agenda item – staff can discuss any low-level concerns or questions. We also share any new guidance or learning from national research (for example, learning from safeguarding adult reviews elsewhere) to keep improving our knowledge.
• Governance and External Accountability: The organisation’s leadership (e.g., if we had a Board of Directors or the Owner) receives regular reports on safeguarding activity. This includes statistics on the number and type of concerns raised, how quickly they were addressed, and outcomes. The leadership uses this to ask questions and ensure proper actions are taken (for instance, if there were any delays or issues, they will want explanations and fixes). Safeguarding is a standing item in higher-level management meetings, reflecting its importance. We also welcome CQC inspections and input – any feedback CQC provides regarding safeguarding (e.g., through inspection reports or conversations) is heeded and acted upon. If an inspection highlights a gap, we rectify it promptly and include it in our continuous improvement plan.
• Policy Review: This Safeguarding Adults Policy is reviewed at least annually, or more frequently if there are changes in legislation, guidance, or if we have significant learning from a case that should be incorporated. The Registered Manager leads the review, with input from staff at all levels (we might discuss the policy in a team meeting for practical feedback) and, where possible, from service users or their families (for instance, checking if the policy’s accessible summaries are understandable). Updated versions of the policy are approved by the organisation’s leadership and shared with all staff. We document the review date and any changes made. Old versions are archived. If changes are significant, we may provide additional training or briefing to staff to ensure they understand the new requirements.

By monitoring our safeguarding work and actively seeking to improve, {{org_field_name}} aims to remain vigilant and effective in protecting people. Safeguarding is not a one-time task but an ongoing process of quality improvement, learning, and adaptation. We recognise that risks and challenges evolve over time, so we too must evolve our practices. Through strong governance and open dialogue, we maintain high standards and a safe service.

 

Accessibility of this Policy

Safeguarding is only effective if everyone can understand and use the procedures. {{org_field_name}} ensures this Safeguarding Policy is accessible to all who need to see it, in various ways:

• Availability: Copies of this policy are readily available to staff (both electronically on the company’s intranet or shared drive, and in hard copy at the service location in the policy manual). New staff are given a copy at induction. Service users and family members can also request to see the policy. We provide it to inspectors or commissioning authorities upon request as well.
• Alternative Formats: We will provide the policy (or a summary of it) in alternative formats upon request, to accommodate different needs. For example, large-print versions can be prepared for individuals with visual impairments. If needed, we can provide an audio recording of the key points for someone who finds listening easier than reading. For individuals whose first language is not English, we will attempt to provide or arrange a translation of essential sections (or use interpreter services to explain it). We recognize that the full policy may be lengthy and technical for service users, so we also produce an “Easy Read” summary with simple language and pictures focusing on what abuse is and how to get help.
• Communication of Key Points: Staff take time to go through key points of the safeguarding policy with service users in a suitable way. For instance, during a resident/tenant meeting, a staff member might remind everyone: “You have the right to be safe. If you ever feel unsafe or unhappy with how someone is treating you, you can tell us or tell these people…”. We may put up a poster or notice in communal areas with short messages like “If you feel unsafe, please speak to [Name] or call this number… You have a right to be safe.” and include pictures/icons. By reinforcing the message regularly, we keep awareness high.
• Staff Understanding: We ensure all staff truly understand the policy, not just have a copy. This includes discussing it in training sessions, quizzing staff during supervision (e.g., “what would you do if…?” scenarios), and fostering an environment where staff feel comfortable asking questions about it. Because we know that lengthy documents can be daunting, we highlight flowcharts or quick-reference guides (for example, a one-page flowchart of “How to report a concern” could be posted on the office wall).
• Review with Service Users: Periodically, we may hold a forum or a one-on-one keyworker session with service users to talk about whether they feel safe and if they know how to raise concerns. Their feedback can be insightful. For example, a service user might tell us that they didn’t understand the term “safeguarding” but they do know what “bullying or abuse” means – so we might adjust our language when talking to them. We treat these conversations as informal audits of how well our policy is working on the ground.

In summary, we strive to make sure the policy is not just a document on a shelf. It’s a living, usable guide for all stakeholders. Everyone – staff, service users, families – should know the basics of how we keep people safe and what to do if they have a concern. If anyone has difficulty accessing or understanding the policy, we take steps to assist them.

(This policy will be reviewed at least annually or sooner if required by changes in law or significant incidents. All updates will be communicated to staff and relevant parties.)

Sources: Care Act 2014; Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Reg.13; CQC Registration Regulations 2009, Reg.18; CQC and SCIE guidance on safeguarding and whistleblowing; Public Interest Disclosure Act 1998.

---

Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.