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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Safeguarding Policy

1. Purpose

The purpose of this policy is to set out {{org_field_name}}’s approach to safeguarding children, young people, adults at risk, and other vulnerable persons in the context of our activities as an employment agency and/or employment business. As a temporary staffing agency, we do not provide care directly. However, we recognise that, through the introduction and supply of candidates and temporary workers to clients, we have important safeguarding responsibilities in recruitment, vetting, suitability assessment, placement decisions, information-sharing, escalation of concerns, and cooperation with clients and statutory agencies.

This policy supports compliance with applicable legislation and statutory guidance, including the Employment Agencies Act 1973, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, the Agency Workers Regulations 2010, the Care Act 2014, the Children Act 1989, the Children Act 2004, Working Together to Safeguard Children 2023, the Safeguarding Vulnerable Groups Act 2006, the Police Act 1997, the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975, the Equality Act 2010, the Immigration, Asylum and Nationality Act 2006, the Working Time Regulations 1998, the National Minimum Wage Act 1998 and National Minimum Wage Regulations 2015, the Health and Safety at Work etc. Act 1974, the UK GDPR, and the Data Protection Act 2018.

For the avoidance of doubt, {{org_field_name}} is not a regulated care provider and does not itself carry on regulated activities requiring CQC registration, unless expressly stated otherwise in separate service documentation. Safeguarding obligations under this policy therefore focus on safer recruitment, lawful supply of workers, suitability checks, escalation of concerns, and cooperation with client safeguarding processes and statutory authorities.

2. Scope

This policy applies to all directors, employees, consultants, temporary workers, agency workers, contractors, and volunteers working for or on behalf of {{org_field_name}}, and to all recruitment, vetting, placement, assignment-management, and compliance activities carried out by the business.

It applies to:
(a) the recruitment, assessment, and engagement of candidates and workers;
(b) the introduction or supply of candidates and workers to clients;
(c) conduct during assignments and work-related contact with clients, service users, patients, residents, children, adults at risk, and other vulnerable persons;
(d) concerns arising before placement, during placement, after placement, or on receipt of information from a client, worker, candidate, third party, or public authority.

This policy is of particular importance where assignments involve work with children, young people, adults at risk, patients, residents, or any person who may be vulnerable by reason of age, illness, disability, mental capacity, dependency, or circumstances.

This policy applies across all sectors in which {{org_field_name}} operates, including healthcare, care, education, supported living, domiciliary settings, community settings, and any other client site to which workers are introduced or supplied.

3. Principles of Safeguarding

• Prevention: Taking proactive measures to prevent harm, including training, risk assessments, and clear policies.
• Protection: Supporting and empowering vulnerable adults and children to protect themselves and ensuring interventions are in place when required.
• Accountability: Ensuring all staff understand their safeguarding responsibilities and follow proper procedures.
• Partnership: Working with other agencies, local authorities, and regulatory bodies to safeguard individuals effectively.
• Proportionality: Ensuring responses to safeguarding concerns are appropriate and not overly intrusive.
• Empowerment: Encouraging individuals to make their own informed choices while ensuring their safety.
• Safer Recruitment and Placement: We will only introduce or supply workers where we have taken proportionate and lawful steps to verify identity, right to work, suitability, qualifications, experience, and, where relevant, safeguarding clearances and references.
• Lawful Information Sharing and Escalation: We will share safeguarding information on a need-to-know basis where necessary to protect children, adults at risk, workers, clients, or the public, and will escalate concerns promptly to clients, local authorities, the police, DBS, or other relevant bodies where appropriate.

4. Types of Abuse Recognised Under this Policy

• Physical Abuse: Hitting, slapping, pushing, misuse of medication, restraint, or inappropriate physical contact.
• Sexual Abuse: Inappropriate touching, sexual harassment, coercion, or non-consensual sexual activity.
• Emotional/Psychological Abuse: Intimidation, humiliation, bullying, threats, isolation, or coercive control.
• Sexual Exploitation / Grooming: Manipulating, coercing, or exploiting a child or adult at risk for sexual purposes, including abuse of trust or abuse facilitated through professional contact.
• Online / Digital Abuse: Abuse, exploitation, grooming, coercion, harassment, stalking, or disclosure of personal images or information through digital, electronic, or online means.
• Financial Abuse: Theft, fraud, exploitation, pressure over financial matters, or misuse of property.
• Neglect and Acts of Omission: Failure to provide care, food, medication, or assistance with personal hygiene.
• Discriminatory Abuse: Harassment or unfair treatment due to race, gender, disability, sexual orientation, religion, or age.
• Domestic Abuse: Coercive control, threats, violence, or economic abuse within a domestic setting.
• Modern Slavery and Labour Exploitation: Forced labour, debt bondage, human trafficking, servitude, coercive recruitment practices, document retention, unlawful deductions, threats, intimidation, or other exploitative labour practices affecting workers or candidates.
• Self-Neglect: An individual neglecting their personal hygiene, health, or surroundings, leading to harm.
• Organisational Abuse: Poor care practices within an institution, such as neglect or rigid routines that compromise an individual’s dignity.

5. Safeguarding Responsibilities

• Director: Has overall accountability for ensuring that the organisation has effective safeguarding systems, sufficient resources, clear reporting lines, and legally compliant recruitment, vetting, placement, escalation, and record-keeping procedures.
• Designated Safeguarding Lead (DSL): Day-to-day lead responsibility for safeguarding matters sits with {{org_field_safeguarding_lead_name}}, {{org_field_safeguarding_lead_role}}, who is responsible for providing advice to staff, reviewing concerns, making decisions on escalation, liaising with clients and statutory agencies, overseeing safeguarding records, and ensuring lessons learned are acted upon.
• Compliance / Recruitment Team: Is responsible for identity checks, right to work checks, obtaining references where required, verifying qualifications and registrations, arranging DBS checks where legally eligible and relevant, obtaining and recording suitability information, issuing required worker documentation, and ensuring that workers are not introduced or supplied where required checks are incomplete or concerns remain unresolved.
• Line Managers / Consultants / Coordinators: Must recognise safeguarding risks, respond promptly to concerns, report concerns immediately in accordance with this policy, keep accurate records, and cooperate with clients and statutory authorities.
• All Staff and Workers: Must remain vigilant to signs of abuse, neglect, exploitation, unsafe practice, discrimination, or inappropriate behaviour; must follow safeguarding procedures; and must report concerns immediately, whether the concern relates to a service user, child, adult at risk, colleague, candidate, client representative, or another third party.
• Clients / Hirers: Clients remain responsible for safeguarding arrangements within their own services and premises, including local policies, supervision, site induction, incident management, and statutory notifications that fall on the service provider. {{org_field_name}} will cooperate with client safeguarding processes and will escalate externally where required by law or where this is necessary to protect individuals.

6. Recruitment, Vetting, Suitability and Training

6.1 Safer recruitment and suitability

Before introducing or supplying a worker, {{org_field_name}} will take proportionate and lawful steps to assess suitability for the role. Depending on the nature of the assignment, this may include verifying identity, right to work in the UK, employment history, relevant experience, professional qualifications, professional registration, training, conduct history, references, and any legally permissible criminal record information.

6.2 Information to be obtained from the hirer / client

Before introducing or supplying a worker, {{org_field_name}} will obtain sufficient information from the hirer to assess suitability for the role, including the identity of the hirer, the nature of the work, start date, duration, location, hours, known risks to health and safety, any qualifications or authorisations required, and any particular safeguarding or conduct requirements relevant to the assignment.

6.3 Confirmation about the worker

{{org_field_name}} will not introduce or supply a worker unless it has obtained confirmation of the worker’s identity, their experience, training, qualifications and any authorisations required for the role, and their willingness to work in the position concerned.

6.4 Work involving children, adults at risk or other vulnerable persons

Where a role involves working with, caring for, or attending a child, adult at risk, or other vulnerable person, {{org_field_name}} will carry out additional checks and enquiries required by law and by client contract, including verification of suitability for that type of work, relevant references, qualifications, registrations, and, where legally eligible, the appropriate level of DBS check and barred list check.

6.5 DBS checks and criminal record information

DBS checks will only be requested where the role is legally eligible for that level of check. Enhanced DBS checks, and any check of the children’s or adults’ barred list, will only be sought where permitted by law. {{org_field_name}} will not apply a blanket rule requiring enhanced DBS checks for all staff or workers. Criminal record information will be handled fairly, lawfully, confidentially, and in accordance with the Rehabilitation of Offenders Act 1974, the Exceptions Order, the Police Act 1997, DBS guidance, and data protection law.

6.6 Right to work

Before employment or assignment begins, {{org_field_name}} will carry out a compliant right to work check and any required follow-up check in accordance with the Immigration, Asylum and Nationality Act 2006 and current Home Office guidance. Workers will not be employed or supplied where a satisfactory right to work check has not been completed.

6.7 Key Information Document and terms

Where {{org_field_name}} operates as an employment business, it will provide the work-seeker with a Key Information Document before agreeing terms with the work-seeker, and will ensure that required terms with work-seekers and hirers are agreed in accordance with the Conduct Regulations.

6.8 Information to workers and hirers

{{org_field_name}} will provide workers with relevant information about the role, including duties, location, hours, pay arrangements, and relevant health and safety and safeguarding information received from the hirer. {{org_field_name}} will also provide hirers with the information about the worker required by law before introduction or supply.

6.9 Health and safety before assignment

Before the work starts, {{org_field_name}} will liaise with the hirer to identify relevant workplace risks, the competencies required for the role, and the control measures in place. Workers will not be supplied unless {{org_field_name}} is satisfied that appropriate health and safety information has been obtained and passed to the worker.

6.10 Training

All internal staff involved in recruitment, compliance, placement, or assignment management will receive safeguarding training appropriate to their role. Workers supplied into safeguarding-sensitive assignments will receive safeguarding information and training appropriate to the environments in which they are placed. Refresher training will be provided periodically and whenever there is a material legal, regulatory, or operational change.

7. Agency Worker Rights and Assignment Conditions

{{org_field_name}} is committed to ensuring that agency workers are treated lawfully and fairly. This includes compliance with the Agency Workers Regulations 2010, including day-one rights to access collective facilities and amenities and to be informed of relevant employment opportunities with the hirer, and equal treatment in relation to pay and other basic working and employment conditions after the applicable qualifying period in the same role with the same hirer.

{{org_field_name}} will also comply with applicable laws on working time, rest breaks, annual leave, pay, unlawful deductions, equality, and national minimum wage. Concerns about underpayment, excessive hours, unsafe shifts, discriminatory treatment, coercion, or exploitative conditions will be treated seriously and may also be considered safeguarding concerns where vulnerability or risk of harm is present.

8. Right to Work and Prevention of Illegal Working

{{org_field_name}} will carry out right to work checks before employing or supplying a worker and will carry out follow-up checks where a worker has time-limited permission to work. Checks will be completed in accordance with current Home Office guidance and may include manual checks, online checks, use of an Identity Service Provider where permitted, or the Employer Checking Service where applicable.

No candidate or worker will be introduced, supplied, or employed unless {{org_field_name}} is satisfied that the required right to work check has been completed and appropriately recorded. Any concern about false documents, inconsistent identity information, or possible illegal working must be escalated immediately to the Compliance Team and senior management.

9. DBS, Criminal Record Checks and Referrals

{{org_field_name}} will only request criminal record checks where the role is legally eligible for the relevant level of check. We will assess criminal record information fairly, proportionately, and in accordance with the Rehabilitation of Offenders Act 1974, the Exceptions Order, DBS guidance, and data protection law. We will not require applicants to disclose protected cautions or protected convictions.

Where a role is eligible and the legal conditions are met, {{org_field_name}} may request a standard DBS check, enhanced DBS check, and/or a check of the children’s and/or adults’ barred list, depending on the nature of the role.

Where the legal duty to refer is triggered, including in relevant regulated activity and personnel supplier scenarios, {{org_field_name}} will make a referral to the DBS without delay.

10. Modern Slavery, Labour Exploitation and Ethical Recruitment

{{org_field_name}} has zero tolerance for modern slavery, forced labour, human trafficking, debt bondage, document retention, coercive recruitment, unlawful deductions, or any other exploitative labour practice.

We will seek to identify indicators of labour exploitation in recruitment, onboarding, accommodation arrangements, transport arrangements, payroll practices, and assignments, and will investigate and escalate concerns promptly.

Where legally required, {{org_field_name}} will publish an annual slavery and human trafficking statement in accordance with section 54 of the Modern Slavery Act 2015. Whether or not the statutory threshold is met, the organisation will take reasonable steps to prevent exploitation in its own business and supply chains.

11. Reporting, Escalation and Referral of Safeguarding Concerns

If abuse, neglect, exploitation, unsafe practice, or inappropriate behaviour is suspected or disclosed, staff must act without delay.

Recognise: Identify signs, allegations, disclosures, patterns, or indicators of harm, abuse, neglect, exploitation, discrimination, unsafe practice, or risk.

Respond: Stay calm, listen carefully, do not promise absolute confidentiality, do not ask leading questions, and take immediate action if anyone is at imminent risk of harm.

Report internally: Inform the Designated Safeguarding Lead, {{org_field_safeguarding_lead_name}}, {{org_field_safeguarding_lead_role}}, or, if unavailable, a senior manager immediately. Where the concern arises on assignment, the relevant client manager or client safeguarding lead must also be informed promptly unless doing so would increase the risk of harm or compromise an investigation.

Record: Make a clear, factual, timed, dated, and signed record of the concern, disclosure, observation, action taken, and persons notified. Records must distinguish fact from opinion and identify any immediate protective steps taken.

Refer / escalate externally: Where appropriate, {{org_field_name}} will refer or escalate concerns to the police, the relevant local authority adult safeguarding team, children’s social care, the Local Authority Designated Officer (LADO), the Disclosure and Barring Service (DBS), a relevant professional regulator, or any other competent authority.

Emergency action: If a person is in immediate danger or a crime may have been committed, emergency services or the police must be contacted without delay.

No victimisation: No worker, candidate, or member of staff will be penalised for making a genuine safeguarding report in good faith.

Where {{org_field_name}} withdraws, removes, or declines to supply a worker from work that is regulated activity, or would have done so had the worker not left, because the worker harmed or posed a risk of harm to a child or vulnerable adult, {{org_field_name}} will consider and, where legally required, make a referral to the DBS.

12. Confidentiality, Data Protection and Record Handling

Safeguarding information will be shared only on a need-to-know basis and only where this is necessary and proportionate for safeguarding, legal compliance, recruitment, employment, placement management, investigation, or referral purposes.

{{org_field_name}} will process personal data in accordance with the UK GDPR and the Data Protection Act 2018. Where safeguarding information includes health data, racial or ethnic origin, religious beliefs, biometric data, or other special category data, {{org_field_name}} will identify a lawful basis under Article 6 UK GDPR and an applicable condition under Article 9 UK GDPR. Where information relates to criminal allegations, offences, convictions, or DBS results, {{org_field_name}} will comply with the separate rules governing criminal offence data and any applicable Schedule 1 DPA 2018 condition.

Safeguarding records will be accurate, relevant, limited to what is necessary, stored securely, access-controlled, and retained only for as long as justified by law, regulatory expectation, safeguarding risk, limitation periods, or the organisation’s retention schedule.

DBS certificate information will be handled in accordance with the DBS Code of Practice and DBS guidance on secure storage, handling, use, retention, and disposal. Certificate information will not be retained for longer than is necessary for the purpose for which it was obtained and, save in exceptional circumstances, will not normally be retained for more than six months after the relevant recruitment or decision process has been completed.

Privacy information provided to workers and candidates will explain how safeguarding-related personal data, criminal offence data, right to work data, and recruitment records are used and shared.

13. Partnership Working and External Agencies

{{org_field_name}} will work cooperatively with clients, local authority adult safeguarding teams, children’s social care, the police, the Local Authority Designated Officer (LADO), the Disclosure and Barring Service (DBS), relevant professional regulators, and other competent authorities where safeguarding concerns arise.

We will also cooperate with the Employment Agency Standards Inspectorate (EAS) and any other enforcement or regulatory body with jurisdiction over our recruitment and supply activities.

Where a safeguarding concern arises within a client’s service, {{org_field_name}} will cooperate with the client’s internal safeguarding and incident procedures, while retaining the right and obligation to escalate concerns independently where required by law, where an immediate risk exists, or where we consider that internal escalation alone is insufficient to protect individuals.

Where appropriate, we will participate in information-sharing, investigations, audits, and lessons-learned processes, subject to legal and confidentiality requirements.

14. Whistleblowing Policy

• Staff are encouraged to report safeguarding concerns without fear of retaliation.
• Reports can be made anonymously through the whistleblowing procedure.
• Retaliation against whistleblowers will result in disciplinary action.
• All concerns will be handled confidentially and investigated thoroughly.

Concerns that may be raised under this section include, without limitation, abuse or neglect, unsafe placements, failures in vetting or reference checking, falsified qualifications or registrations, illegal working, modern slavery or labour exploitation, discrimination, unlawful deductions, suppression of complaints, retaliation against reporters, and any failure to report or escalate a safeguarding concern appropriately. Where appropriate, concerns may also be raised externally with the Employment Agency Standards Inspectorate or another competent authority.

15. Related Policies

This policy should be read in conjunction with the following policies:

• Whistleblowing Policy
• Code of Conduct
• Equal Opportunities Policy
• Health & Safety Policy
• Incident & Accident Reporting Policy
• Data Protection & Confidentiality Policy
• Recruitment & Selection Policy

16. Policy Review

This policy will be reviewed at least annually and sooner where required by a material change in law, statutory guidance, regulator expectations, business activities, client requirements, audit findings, safeguarding incidents, lessons learned, or operational practice. Any amendments will be communicated to relevant staff, workers, and managers, and training and supporting procedures will be updated where necessary.

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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}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.