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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Protection from Radicalisation and Extremism (Prevent Duty) Policy

1. Purpose

The purpose of this policy is to set out how {{org_field_name}} identifies, responds to, records and escalates concerns that a person may be susceptible to radicalisation, extremist ideology or being drawn into terrorism. The organisation recognises radicalisation as a safeguarding issue which must be managed in a lawful, proportionate, person-centred and least restrictive way, with due regard to the person’s rights, wellbeing, protected characteristics, mental capacity, communication needs and desired outcomes.

{{org_field_name}} will work in line with the Counter-Terrorism and Security Act 2015, current Prevent Duty Guidance for England and Wales, current Channel / Prevent Multi-Agency Panel guidance, the Care Act 2014, the Mental Capacity Act 2005, the Human Rights Act 1998, UK GDPR and Data Protection Act 2018, and the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, including Regulation 13 (safeguarding service users from abuse and improper treatment), Regulation 17 (good governance), Regulation 18 (staffing) and Regulation 19 (fit and proper persons employed).

Where {{org_field_name}} is not itself a specified authority under Schedule 6 to the Counter-Terrorism and Security Act 2015, it will nevertheless cooperate appropriately with specified authorities, the local authority, police, health professionals and other safeguarding partners, and will maintain robust internal systems to identify and respond to concerns about radicalisation and extremism.

If the service supports children or young people, this policy must also be read alongside the current version of Working Together to Safeguard Children. If the service supports adults only, adult safeguarding law and guidance will ordinarily be the primary framework for decision-making.

2. Scope

This policy applies to all employees, bank staff, agency workers, volunteers, students, managers, directors and contractors working for or on behalf of {{org_field_name}}. It applies across all supported living settings, outreach support, community-based support, remote contact, transport, digital contact, social media use connected to the service, and any online environment used by people we support or staff in the course of care and support delivery.

The policy applies to concerns involving:

• people receiving support;
• family members, visitors or associates where this presents a safeguarding risk to a person using the service; and
• staff conduct where extremist behaviour, inappropriate sharing of material, discriminatory behaviour, abuse, or unsafe professional boundaries create a risk to people using the service or the reputation and safety of the service.

Overall accountability sits with the Provider / Registered Manager. Day-to-day oversight of Prevent-related safeguarding concerns sits with the Designated Safeguarding Lead or other named senior lead identified by the organisation.

3. Related Policies

• SL07 – Person-Centred Care Policy
• SL13 – Safeguarding Adults from Abuse and Improper Treatment Policy
• SL39 – Mental Capacity and Deprivation of Liberty Safeguards Policy
• SL34 – Confidentiality and Data Protection (GDPR) Policy
• SL42 – Communication and Engagement with Service Users and Families Policy
• SL23 – Lone Working and Staff Safety Policy
• Dignity and Respect Policy
• Consent to Care Policy
• Complaints Policy
• Whistleblowing / Speaking Up Policy
• Equality, Diversity, Inclusion and Human Rights Policy
• Staff Code of Conduct / Professional Boundaries Policy
• Recruitment, Vetting and Safer Employment Checks Policy
• Incident Reporting and Notifications Policy
• Online Safety / Acceptable Use of IT and Social Media Policy
• Risk Assessment Policy
• MCA Best Interests / Restrictive Practice Policy (if separate from SL39)

4. Principles of Prevent Duty

4.1 Understanding Radicalisation and Extremism

Radicalisation is the process by which a person comes to support terrorism or extremist ideologies associated with terrorism, or is otherwise drawn into terrorism. Susceptibility to radicalisation may arise from a combination of personal, social, emotional, psychological, environmental, online and contextual factors.

Extremism, for the purposes of this policy, should be considered in the context of safeguarding people from being drawn into terrorism. Staff must not assume that holding strong political, religious, cultural or philosophical views is, by itself, evidence of radicalisation. Concerns must be based on observable indicators, credible information, changes in presentation, or behaviour that reasonably indicate a risk of harm or exploitation.

Staff must act in a way that is lawful, proportionate, anti-discriminatory and person-centred. No person will be treated less favourably because of religion, race, disability, ethnicity, nationality, political opinion, age, sex, sexual orientation or any other protected characteristic.

Particular care must be taken where a person has cognitive impairment, autism, learning disability, communication needs, trauma, mental ill health, social isolation, dependence on others, exposure to online harms or a history of exploitation, as these factors may affect vulnerability, understanding, communication and decision-making.

4.2 Staff Responsibilities and Awareness

All staff are responsible for remaining alert to safeguarding concerns that may indicate a person is susceptible to radicalisation. Staff must maintain professional curiosity, respond calmly, avoid confrontation, avoid expressing personal views, and record concerns accurately and factually.

Staff should be alert to patterns or combinations of concern, which may include:

• significant changes in behaviour, presentation, mood, association or routine;
• fixation on violence, martyrdom, grievance or conspiracy narratives linked to terrorism;
• repeated use, sharing or possession of extremist material linked to terrorist narratives, including online content;
• statements that appear to justify terrorist violence or encourage harm against particular groups;
• increased secrecy, withdrawal, fearfulness or sudden dependence on a controlling individual or group;
• evidence of exploitation, coercion, grooming, online targeting or indoctrination;
• travel, contact, financial activity or communications that raise a credible safeguarding concern.

Staff must not rely on appearance, faith, ethnicity, diagnosis, political opinions or lifestyle alone as a basis for concern. Concerns must be based on observed facts, professional judgement and safeguarding risk.

Staff must report concerns without delay in line with this policy and the safeguarding procedure.

4.3 Risk Assessment and Safeguarding Measures

Where concerns arise, the service will complete a prompt safeguarding risk assessment. This must consider:

• the nature and immediacy of the risk;
• the source and reliability of the information;
• any evidence of grooming, coercion, exploitation or undue influence;
• the person’s communication needs, mental capacity and ability to understand the concerns;
• risks to the person, other people using the service, staff and the public;
• online risks and access to harmful material;
• protective factors, resilience and support networks; and
• what action is necessary, proportionate and least restrictive.

Risk assessments and care or support plans must be reviewed whenever new information becomes available. The person should be involved as far as possible and appropriate, unless doing so would increase risk or prejudice a safeguarding, police or Prevent process.

Where there is doubt about a person’s ability to understand, weigh or communicate decisions relating to safety planning, the Mental Capacity Act 2005 must be applied and best-interest decision-making followed where required.

Any intervention must be person-centred, rights-based and clearly linked to identified risk. Measures taken by the service must not be punitive or discriminatory.

4.4 Partnership and Multi-Agency Working

{{org_field_name}} will work cooperatively with local authorities, adult social care, children’s services where relevant, police, local Prevent teams, health professionals, commissioners, advocates and other safeguarding partners.

Where concerns indicate that a person may be susceptible to radicalisation, the service will seek advice from the local safeguarding lead, local authority safeguarding team, local Prevent contact or police, as appropriate to the level and type of risk.

The service recognises that Channel is a multi-agency safeguarding process for people who are susceptible to being drawn into terrorism. Where appropriate, referrals will be made through the locally agreed Prevent / police / safeguarding pathway so that the concern can be considered under the relevant multi-agency process.

The service will attend strategy discussions, safeguarding meetings, Prevent meetings or Channel meetings where invited, share relevant information lawfully, and implement agreed actions within care and support planning.

4.5 Promoting Inclusion, Rights, Critical Thinking and Safe Participation

The service will promote dignity, inclusion, equality, mutual respect, freedom of lawful belief and expression, and safe participation in community life. Staff should support people to discuss beliefs, world events and personal concerns in a respectful and non-judgemental way, while remaining alert to signs of exploitation, coercion or harm.

Support should focus on wellbeing, social inclusion, trusted relationships, access to advocacy where needed, digital safety, and reducing vulnerability to grooming or misinformation.

The organisation will not use this policy to suppress lawful debate, personal identity, religious practice, political discussion or disagreement. Action under this policy will only be taken where there is a genuine safeguarding concern or risk linked to radicalisation, terrorism or extremist exploitation.

4.6 Staff Training and Development

Staff will receive Prevent-related safeguarding training appropriate to their role, level of responsibility and contact with people using the service. Training must be provided as part of induction and refreshed periodically in line with organisational need, changes in guidance, local risk, staff role and learning from incidents.

Training will include:

• understanding radicalisation as a safeguarding issue;
• recognising indicators of susceptibility, grooming and exploitation;
• professional curiosity and respectful enquiry;
• avoiding discriminatory assumptions and bias;
• recording concerns clearly and factually;
• internal escalation and external referral pathways;
• information sharing, confidentiality and lawful basis for sharing;
• online harms and digital safety;
• mental capacity, consent, communication needs and human rights considerations; and
• the role of supervision, debrief and reflective practice.

Managers and safeguarding leads must receive additional training relevant to triage, decision-making, multi-agency working, record keeping and oversight. The organisation will maintain records of training completion, competence and refresher dates.

4.7 Definitions

For the purpose of this policy:

• Radicalisation means the process by which a person comes to support terrorism or extremist ideologies associated with terrorism, or is otherwise drawn into terrorism.
• Extremist exploitation means the use of manipulation, grooming, coercion, indoctrination or abuse to draw a person toward extremist or terrorist-related beliefs, activity or support.
• Channel / Prevent Multi-Agency Panel means the multi-agency process used to assess and, where appropriate, provide support to people who are susceptible to being drawn into terrorism.
• Specified authority means a body listed in Schedule 6 to the Counter-Terrorism and Security Act 2015 which is directly subject to the statutory Prevent duty.
• Safeguarding concern means information that suggests a person may be at risk of abuse, neglect, exploitation or harm, including harm arising from radicalisation.

5. Reporting Concerns and Referral Process

5.1 Internal Reporting

Any member of staff who has a concern must report it immediately to the Designated Safeguarding Lead, Prevent Lead, line manager or on-call manager, in accordance with local arrangements. If the concern involves that person, staff must escalate to a more senior manager, the Registered Manager, provider lead or through the whistleblowing process.

Staff must make a factual written record as soon as possible, including what was seen, heard or reported, the date and time, the context, who was present, any immediate action taken, the person’s views where known, and the rationale for any decision to share or not share information.

Managers must review concerns promptly, assess immediate risk, consider safeguarding duties, obtain advice where required, and document the rationale for all decisions and actions.

5.2 External Referral Pathways

External action will depend on the level and nature of risk:

• Immediate threat or emergency: call 999.
• Urgent police concern but not an emergency: contact police on 101 or the locally agreed police / Prevent contact route.
• Adult safeguarding concern: refer to the local authority adult safeguarding team where the Care Act safeguarding threshold may be met.
• Child safeguarding concern: refer immediately to children’s social care and follow local child protection procedures, where relevant.
• Prevent / radicalisation concern: seek advice or make a referral through the locally agreed Prevent, police or safeguarding route for consideration under local Prevent / Channel arrangements.

The service must follow locally agreed multi-agency procedures and maintain a clear record of the reason for referral, who it was made to, when it was made, what was shared, and what response was received.

5.3 Supporting Individuals at Risk

Where concerns are identified, the service will support the person in a way that is trauma-informed, person-centred and proportionate. Support may include review of care planning, increased welfare checks, advocacy, family liaison where appropriate, mental health support, social inclusion work, digital safety support, review of environmental risks, and coordinated multi-agency action.

The person’s wishes, feelings, beliefs, communication needs and desired outcomes must be considered wherever possible. If the person lacks capacity in relation to relevant decisions, the Mental Capacity Act 2005 must be followed.

Any restrictions or changes to support must be necessary, proportionate, time-limited, clearly recorded and subject to review. Support should aim to reduce risk while preserving dignity, independence and rights.

5.4 Staff Conduct, Whistleblowing and Allegations

Any concern that a member of staff, volunteer or contractor has expressed extremist views in a way that affects their suitability to work with people using the service, has shared harmful material, has attempted to influence a person using the service, or has otherwise created a safeguarding risk, must be treated seriously and managed under safeguarding, disciplinary, HR and whistleblowing procedures as appropriate.

The immediate safety of people using the service must be prioritised. Advice must be sought from senior management, HR, safeguarding leads, police or local Prevent contacts where appropriate. All action and rationale must be documented.

5.5 Equality, Human Rights and Least Restrictive Practice

Decisions made under this policy must be compatible with the Human Rights Act 1998, Equality Act 2010, Mental Capacity Act 2005 and person-centred care principles.

Action must be necessary, proportionate, evidence-based and least restrictive. The service will not stigmatise or profile people on the basis of religion, ethnicity, disability, nationality, culture or political opinion.

The service will distinguish between lawful belief or expression and behaviour that creates a genuine safeguarding concern linked to radicalisation or terrorism.

5.6 Online Safety and Digital Risk

The service recognises that radicalisation can occur online as well as offline. Staff must consider internet use, social media activity, messaging platforms, gaming platforms, livestreams and online communities when assessing risk, where this is relevant and lawful.

Support plans may include education about misinformation, safer device use, privacy settings, support with reporting harmful content, and joint working with family or professionals where appropriate.

Any monitoring of digital activity must be lawful, proportionate, clearly justified, and consistent with privacy, capacity and human rights principles.

6. Confidentiality, Information Sharing and Record Keeping

Information relating to concerns about radicalisation or extremism will be handled confidentially and shared only on a need-to-know basis with those who require the information to safeguard the person or others, manage risk, or comply with legal obligations.

Information sharing must comply with UK GDPR, the Data Protection Act 2018 and relevant safeguarding principles. Consent should be sought where appropriate, but lack of consent does not prevent information being shared where there is a lawful basis and sharing is necessary, proportionate and justified for safeguarding or the prevention of crime or serious harm.

Records must be accurate, factual, contemporaneous, secure and auditable. The record must clearly show the concern, the decision-making process, advice obtained, rationale for action taken, referrals made, outcomes and review arrangements.

Records relating to Prevent or radicalisation concerns must be retained in line with the organisation’s record retention schedule and made available for audit, safeguarding review, regulatory inspection or lawful information requests where required.

7. Monitoring, Audit and Governance

The organisation will maintain oversight of Prevent-related safeguarding activity through governance systems that include incident review, supervision, training compliance, audit of records, learning from concerns and near misses, policy review, and thematic analysis of risks and trends.

Prevent-related concerns and outcomes will be reviewed by senior management at planned intervals to assess:

• timeliness and quality of decision-making;
• appropriateness of referrals and information sharing;
• staff confidence and competence;
• whether people were involved appropriately;
• whether actions were proportionate and rights-based; and
• whether changes are needed to training, care planning, staffing or local procedures.

Where required, the provider will notify CQC of reportable incidents in line with the Care Quality Commission (Registration) Regulations and the organisation’s notification procedures.

8. Policy Review

This policy will be reviewed at least annually and sooner if there is:

• a change in legislation, statutory guidance or CQC requirements;
• a relevant safeguarding, Prevent or Channel-related incident;
• learning from audit, complaint, whistleblowing, supervision or inspection; or
• a change to local authority or police referral pathways.

The review must confirm that named leads, referral routes, contact details, associated policies, training arrangements and governance systems remain accurate and effective.

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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}}
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