Registration Number: {{org_field_registration_no}}

Safeguarding Adults from Abuse and Improper Treatment Policy

Purpose and Policy Statement

{{org_field_name}} is fully committed to safeguarding the welfare and rights of all adults in our care. This policy outlines our approach to protecting residents from abuse, neglect, and improper treatment in compliance with Welsh law and Care Inspectorate Wales (CIW) requirements. We recognise that every individual – including those living with dementia – has the right to live in safety, free from harm or degrading treatment. In line with Regulation 26 of the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, we provide our service in a way that ensures individuals are safe and protected from abuse, neglect and improper treatment. We operate a zero-tolerance approach to abuse and will take immediate action on any concerns raised.

Scope

This policy applies to all staff members, volunteers, contractors, and any persons involved in the care or support of residents at {{org_field_name}}, regardless of the home’s size or capacity. It covers all residents under our care, including older adults and those with specific conditions such as dementia. The safeguarding principles and procedures outlined in this policy remain consistent whether our home is small or large – abuse is never acceptable under any circumstances. Everyone in our organisation has a responsibility to prevent harm and to act when there are safeguarding concerns.

Legal and Regulatory Framework

This policy is informed by and adheres to all relevant legislation, regulations, and guidance in Wales, including:

Social Services and Well-being (Wales) Act 2014 – Provides the legal framework for safeguarding adults at risk, defining an “Adult at Risk” and establishing duties to report and investigate concerns.
Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017 – Part 8 (Regulations 26-27) requires service providers to protect individuals from abuse, neglect or improper treatment and to have effective safeguarding policies and procedures in place.
Wales Safeguarding Procedures (2019) – National guidance that informs local adult safeguarding procedures. Our safeguarding policy is aligned with current law, national guidance, and local safeguarding board procedures, as required by statutory guidance.
CIW Standards and Guidance – Including the expectation for up-to-date safeguarding policies and a designated safeguarding lead within the service.
Mental Capacity Act 2005 and Human Rights Act 1998 – We uphold individuals’ rights to liberty, dignity, and freedom from degrading treatment. (Improper treatment includes discriminatory abuse or unlawful restraint, such as inappropriate deprivation of liberty.)
Public Interest Disclosure Act 1998 – Protects whistleblowers; this underpins our commitment to support staff reporting concerns in good faith.

Definitions

Adult at Risk: Under Welsh law, an “adult at risk” is any person aged 18 or over who: (a) is experiencing or at risk of abuse or neglect; (b) has needs for care and support; and (c) as a result of those needs is unable to protect themselves against the abuse or neglect or the risk of it. All residents in our care who meet these criteria (including many with dementia) are considered adults at risk, warranting special vigilance and protection measures.

Abuse: Abuse is any act (or failure to act) that harms an adult or violates their rights or dignity. The Social Services and Well-being (Wales) Act 2014 specifies five main categories of abuse (which can overlap or coincide):

Physical abuse – Inflicting physical pain, injury or harm (e.g. hitting, pushing, misuse of medication or inappropriate restraint).
Sexual abuse – Involving an adult in sexual activity without informed consent (e.g. sexual assault, inappropriate touching, or any sexual activity an individual lacks capacity to consent to).
Emotional or Psychological abuse – Causing mental anguish through threats, humiliation, bullying, isolation or coercive control.
Financial abuse – Misuse or theft of a person’s money or property, fraud, or exerting undue pressure around financial affairs, wills, or assets.
Neglect (or Acts of Omission) – Failing to meet an adult’s basic needs or to protect them from harm (e.g. ignoring medical or care needs, withholding food, medication, or assistance with hygiene).

Note: Other forms of harm can fall under these categories. For example, discriminatory abuse (harassment or ill-treatment due to age, disability, race, religion, gender or sexuality) and institutional abuse (systemic poor care or rigid routines in a facility) are also recognised and will be treated with equal seriousness. Self-neglect, while not abuse by a third party, is addressed through our care planning and risk management processes.

Improper Treatment: In a care context, improper treatment refers to any practice that is inappropriate, inhumane or unethical in caring for an individual. According to regulations, “improper treatment” includes discrimination or unlawful restraint, including inappropriate deprivation of liberty. Examples of improper treatment include:

Unlawful or excessive use of restraint or physical interventions without proper justification or authority.
Depriving a resident of their liberty without necessary safeguards (in breach of the Mental Capacity Act’s Deprivation of Liberty Safeguards or forthcoming Liberty Protection Safeguards).
Deliberately ignoring a person’s privacy or dignity (e.g. leaving someone undressed or on the toilet as a means of punishment or control).
Forced care or coercion – treating a person against their will when they have capacity, or not following best-interest decision-making when they lack capacity.
Any other care practice that causes distress, humiliation or harm to the individual.

Roles and Responsibilities

Registered Manager / Designated Safeguarding Lead (DSL): Our Registered Manager ({{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}) serves as the Designated Safeguarding Lead for the home, responsible for overall implementation of this policy. The Registered Manager is the primary point of contact for staff to report safeguarding concerns and is accountable for ensuring appropriate action is taken. In the absence of the Manager, a deputy or senior staff member will act as the deputy safeguarding lead. (The Wales Safeguarding Procedures require all care providers to have a named “designated safeguarding person” in place.) Key responsibilities of the Manager/DSL include:

Promoting a culture of vigilance and zero tolerance for abuse.
Ensuring all staff and volunteers understand this policy and their duty to safeguard.
Receiving and assessing reports of suspected abuse or improper treatment.
Taking immediate action to protect individuals where abuse is suspected (including separating alleged perpetrators from residents if necessary).
Making timely referrals to external authorities (local authority safeguarding team, police, CIW) as required.
Liaising with social services, safeguarding boards and other agencies during investigations (multi-agency working), and attending strategy discussions or meetings as needed.
Ensuring proper record-keeping of all concerns, actions and outcomes.
Reporting significant incidents to CIW as per regulatory requirements.
Reviewing and updating safeguarding practices, and ensuring this policy remains current with legislation.

All Staff and Volunteers: Safeguarding is everyone’s responsibility. Every staff member or volunteer has a duty of care to be vigilant, prevent abuse, and act on any concerns. Staff must:

Understand and follow this policy and related procedures – copies are accessible to all staff and discussed in training.
Treat all residents with respect and dignity, providing high-quality care that protects them from harm.
Remain alert to signs of abuse, neglect or improper care (including subtle changes in behaviour or physical signs in residents, especially those who have dementia and may have difficulty communicating).
Report immediately any suspicion, allegation, or evidence of abuse or improper treatment. Reports should be made to the Manager/DSL without delay. If the concern involves the Manager or you believe it is not being addressed properly, you must escalate the report to the Responsible Individual or directly to external authorities (see Whistleblowing below).
Take immediate protective action if needed – for example, if a resident is in imminent danger, intervene if safe to do so and summon help. This may include calling emergency services in serious situations.
Maintain confidentiality – share information about a suspected case only with the designated persons or authorities involved, and never with unauthorised colleagues or outsiders. (However, remember that confidentiality must not prevent reporting – it is acceptable to share relevant information with safeguarding authorities for protection purposes.)

Staff are supported and required by law to report concerns: under Welsh safeguarding duties, if any staff member suspects an adult is at risk of abuse or neglect, they have a duty to report it to the local authority’s safeguarding team. Failing to report or attempting to cover up abuse is a serious disciplinary matter and could lead to regulatory or legal action.

Responsible Individual (RI): (If applicable) The RI ({{org_field_nominated_individual_first_name}} {{org_field_nominated_individual_last_name}}) provides oversight to ensure the service meets its safeguarding obligations. They support the Manager in maintaining safe practices, address any organisational issues that could lead to abuse (such as staffing levels or training gaps), and ensure incidents are properly reported to CIW and the local safeguarding board. The RI should also ensure this policy is reviewed and implemented effectively.

Residents, Families, and Advocates: We encourage an open environment where residents and their relatives or advocates can voice concerns. On admission and regularly thereafter, we inform residents (and families where appropriate) about our safeguarding policy, how to recognise abuse, and how to report any concerns. We will provide information in suitable formats and offer support (including access to an independent advocate) to anyone who wants to raise a safeguarding concern. All concerns raised by residents or family will be taken seriously and acted upon in line with this policy.

Prevention Measures

We believe that preventing abuse and improper treatment is as important as responding to concerns. Key preventative measures include:

Safe Recruitment: We follow robust recruitment procedures to deter and screen out unsuitable individuals. This includes verifying references and conducting enhanced Disclosure and Barring Service (DBS) checks for all staff and volunteers who will work with residents. We comply with all requirements regarding barred lists and ensure no one who is legally barred from working with adults at risk is employed.
Staff Training and Awareness: All employees receive safeguarding training as part of their induction and regular refresher training thereafter. Training covers how to identify signs of abuse/neglect, duties to report, dementia awareness, managing challenging behaviours ethically, and understanding our internal procedures. Specialised training is provided on dementia care (given our resident population) so staff can distinguish dementia symptoms from potential abuse signs and respond appropriately. We also train staff on respecting residents’ rights and maintaining professional boundaries.
Staff Supervision and Support: Management provides regular supervision, mentoring, and opportunities for staff to discuss any care difficulties or ethical concerns. By supporting staff and addressing issues like stress or knowledge gaps, we reduce the risk of incidents of frustration or bad practice that could lead to improper care.
Policies and Code of Conduct: We enforce a clear Staff Code of Conduct outlining expected professional behaviour and explicitly prohibiting any form of abuse, harassment, or neglect. Staff are made aware that any breach – especially involving harm to a resident – will result in disciplinary action, up to and including dismissal and referral to professional bodies or the DBS.
Care Practices and Environment: We strive to create a safe, open, and caring environment. This includes adequate staffing levels, person-centred care planning, and risk assessments to minimise situations where abuse could occur. For example, for residents with dementia who may exhibit confusion or aggression, we use de-escalation techniques and positive behaviour support to avoid the need for restraint. Any use of restrictive practice (such as physical restraint or locked doors for safety) is only as a last resort, is lawful, and is documented according to proper protocols – misuse is strictly forbidden (as it would constitute improper treatment).
Resident Empowerment and Engagement: We promote residents’ independence, choice, and involvement in their own care as much as possible. By valuing each person’s voice and encouraging feedback, we empower residents to speak up if something is wrong. Residents (and their families) are informed of their right to complain or raise concerns. We routinely ask for their input on care quality through surveys or meetings, which can help identify issues early.
Community and Family Involvement: Family members and visitors are welcomed and encouraged to be involved in residents’ lives (respecting the resident’s wishes). The regular presence of family and friends can act as an additional safeguard and reassurance for residents. We also engage with community professionals (e.g. GPs, district nurses, social workers) who visit and can observe the standard of care, providing external oversight.
Monitoring and Auditing: Management conducts periodic audits of care quality and reviews any incident reports, complaints or feedback for signs of potential abuse or trends (e.g. multiple unexplained bruises or repeated complaints about a particular staff member). Any such indications trigger closer review or investigation as appropriate. CIW inspections also provide external scrutiny of our safeguards.

By implementing these preventative measures, we aim to foster a culture in which abuse is less likely to occur, and any early warning signs are detected and addressed proactively.

Recognizing Signs of Abuse and Improper Treatment

All staff must be alert to the potential indicators of abuse or neglect. Especially in a dementia care setting, many residents may have difficulty communicating or may not directly disclose abuse, so observation and attentiveness are critical. Possible signs and symptoms include (but are not limited to):

Physical Abuse: Unexplained bruises, burns, fractures or other injuries; repeated “accidental” injuries; evidence of improper restraint (marks on wrists/ankles); a resident flinching or seeming fearful of a particular caregiver. In a resident with dementia, any sudden agitation or fear in the presence of certain individuals could be a warning sign of abuse.
Sexual Abuse: Bruising or bleeding in genital areas; torn or stained undergarments; sexually transmitted infections; panic attacks or withdrawn behavior around certain staff; explicit disclosures or gestures. A resident with dementia might exhibit new discomfort or resistance during personal care without obvious cause.
Emotional/Psychological Abuse: Withdrawal, depression, sudden changes in behaviour or mood; low self-esteem; a resident being unusually nervous or fearful; hesitance to speak openly; rocking, sucking or mumbling to themselves (possible signs of trauma). Residents might say things indicating fear, such as “don’t let them hurt me,” even if it’s not immediately clear what they refer to.
Financial Abuse: Unpaid bills, sudden lack of funds for personal items; missing belongings or cash; residents expressing confusion about finances or reporting money being taken; family complaints of unusual bank withdrawals; staff showing unusual interest in a resident’s assets. Residents with cognitive impairment may be particularly at risk, so any irregular financial activity is investigated.
Neglect: Poor hygiene, dirty or inappropriate clothing; malnutrition, dehydration or unexplained weight loss; untreated medical issues (bedsores, missed medications); unsafe or unsanitary living conditions (e.g. hazards, soiled bedding); indications that staff are not attending to the person’s needs (for example, call bells repeatedly unanswered). In dementia care, neglect may manifest as worsening confusion or health deterioration due to lack of proper social, medical or nutritional support.
Improper Treatment / Institutional Abuse: Residents appearing fearful or overly compliant due to strict or harsh routines; excessive sedation or use of antipsychotic medication without clear medical rationale; individuals being isolated or left without stimulation for long periods; any resident frequently found in distress after encounters with a particular staff member; bullying or derogatory language by staff. Be attentive to colleagues’ attitudes – if any staff member talks about residents in a demeaning way or admits to rough handling “to manage behavior,” this is a red flag.

Note: These signs do not automatically prove abuse, but they should never be ignored. Staff should use their knowledge of each resident’s typical behavior and condition: any unexplained change or gut feeling of “something is not right” should prompt further attention and, if suspicions persist, a formal report.

Reporting and Responding to Safeguarding Concerns

Immediate Safety: First and foremost, if a resident is in immediate danger or urgent medical attention is needed, staff must act at once to secure safety. This could involve calling emergency services (dial 999) for medical help or police assistance, and providing first aid if required. Ensure the person is safe from the source of harm – this may mean calmly removing them from a situation or, if the threat is from a staff member, suspending that staff member from duties pending investigation. Staff should not put themselves in harm’s way; get help from colleagues if needed. (For example, if a staff member witnesses a colleague physically assaulting a resident, they should intervene only if it is safe, immediately call for help, ensure the resident receives medical attention if needed, and report the incident without delay.)

Internal Reporting Procedure: Any staff or volunteer who observes, suspects, or has evidence of abuse or improper treatment must report it immediately to the Manager/Designated Safeguarding Lead (or their deputy, if the Manager is not available). This includes any allegation made by a resident or third party. Time is of the essence – reports should be made as soon as possible on the same day the concern arises. An oral report should be made in person or by phone to the Manager/DSL without delay, followed by a written report as soon as possible (using the incident report or safeguarding concern form) detailing the nature of the concern, date/time, those involved, what was observed or said, and any immediate actions taken. Factual accuracy is important – record direct quotes when possible, and avoid assumptions or personal conclusions. The Manager/DSL will acknowledge the report and take over the next steps.

How to Report: We provide multiple channels for staff to raise a safeguarding concern, to ensure accessibility and confidentiality. A staff member can:

Report in person – Verbally inform the Manager/DSL (or the senior on duty) immediately.
Report by email – Send an email detailing the concern to the Registered Manager at {{org_field_registered_manager_email}}.
Report by phone – Call the office to inform the Registered Manager at {{org_field_phone_no}}.
Out-of-hours reporting – If the concern arises outside normal hours, call the out-of-hours number: {{out_of_hours}}.
Online – Submit a report via our website ({{org_field_website}}) using the contact form provided.

If the allegation involves a staff member or volunteer: The Manager will immediately remove the person in question from any contact with residents (e.g. by reallocating duties or suspension) while the matter is looked into, to ensure resident safety. The staff member will be informed of the allegation in line with employment procedures (without discussing details that could jeopardise investigations) and treated fairly, but protecting residents is the priority.

Preserving Evidence: If the situation might involve physical evidence (e.g. an unsafe environment, documents, clothing, or injuries), staff should take steps to preserve that evidence, if possible. For example, do not tidy up or clean a room, or wash clothing/bedding, if they might contain evidence of an assault; in cases of physical or sexual abuse, try to leave the scene undisturbed. Take notes on any visible injuries (body maps can be used to mark locations). However, do not investigate the matter yourself beyond securing immediate safety – the goal is simply to preserve facts for official investigators.

Manager/DSL Actions on Receiving a Report: The Designated Safeguarding Lead will immediately evaluate the information and take any further necessary protective action. They will ensure any urgent medical needs are addressed and will prioritise the safety of all residents (for instance, if one resident is alleged to have harmed another, those individuals will be safely separated). The DSL will review whether the concern meets the threshold of an “adult at risk” requiring external referral. In most cases of alleged abuse or neglect, the DSL will contact the local authority Adult Safeguarding team without delay to report the concern, as required by law and local safeguarding procedures. We use the official reporting pathway (such as the Adult Protection referral form or phone contact) to notify social services of the concern, providing all relevant facts.

The DSL will also consider whether to inform other parties, such as:

Police: If a crime is suspected (e.g. physical assault, sexual abuse, theft) or the adult is in immediate danger, the police must be informed right away. We do not wait for a social services investigation to call the police if a serious crime may have occurred.
Care Inspectorate Wales (CIW): The regulator should be notified of any serious incidents, including allegations of abuse, as part of our regulatory notification obligations. The Manager/RI will send CIW a notification as required (usually within 24 hours of the incident or of us becoming aware of it).
Relatives or Representatives: Unless there are valid reasons not to (for example, if a family member is implicated in the allegation), the resident’s next of kin or representative should be informed that a safeguarding concern has arisen, so they can support the resident. This will be done sensitively and following advice from authorities if needed (sometimes investigators may advise delaying contact if it could interfere with evidence gathering).
Professional Bodies/DBS: If a staff member is alleged to have harmed a resident, we will consider immediate suspension pending investigation. Should the allegation be substantiated and result in dismissal or removal from care duties, we have a duty to refer the individual to the Disclosure and Barring Service for potential inclusion on the barred list, and to any relevant professional registration body (e.g. Social Care Wales).

Recording: The Manager/DSL will keep a clear written record of the concern, all actions taken, decisions made (with justifications), and communications with external agencies. This log is confidential and stored securely, separate from general care records, accessible only to those involved in the investigation. As per regulatory requirements, we document the substance of any allegation, any action taken, and any referrals made. These records may be needed for future legal or regulatory purposes and to evaluate outcomes. All safeguarding referrals and outcomes are also logged to enable oversight and scrutiny of safeguarding within the service – protection of individuals is overseen by the Manager and Responsible Individual and within our governance structure, with arrangements for oversight at board level.

Follow-Up and Investigation: Once a referral is made, the local authority will lead the safeguarding enquiry (investigation) under multi-agency procedures. We will cooperate fully with their investigation and any police investigation:

We may be asked to provide information, documents, or statements from staff; we will do so promptly and transparently.
Our Manager/DSL (and other relevant staff) will attend strategy meetings or case conferences as requested, to share information and plan protective actions. Multi-agency collaboration is key to ensuring the individual’s safety.
We refrain from any actions that could compromise external investigations. Our own internal fact-finding will be guided by the local authority and police – typically, we avoid conducting our own formal interviews with the victim or alleged perpetrator until given clearance to do so, in order to prevent contamination of evidence. However, we will take any internal measures needed for safety (such as staff suspension or increased monitoring).
If the safeguarding team asks us to carry out certain inquiry tasks internally (for example, looking into a minor concern), the Manager/DSL will do so thoroughly and report back findings.

Outcome and Lessons Learned: After the investigation, appropriate actions will be taken based on the findings:

If abuse is substantiated, management will implement any recommendations from the safeguarding authorities (e.g. additional training, changes in procedure or staffing). The priority is to ensure the victim is safe and supported, and that no one else is at risk.
If a staff member is confirmed to have abused or harmed a resident, immediate disciplinary action will occur (up to and including dismissal) and referrals to the DBS and professional bodies will be made as noted above. We will also involve the police if not already done, so the law can take its course.
If the allegation is not substantiated or is found to be unfounded, we will still assess whether improvements are needed to reduce the risk of misunderstandings or false allegations in future. (For example, do we need more staff training on dementia communication if a behaviour was misinterpreted?)

In all cases, we offer support to the resident involved (this could include medical care, counselling, increased supervision, or simply emotional support and reassurance). If a staff member was wrongly accused and cleared, we also support them upon return to work and ensure they are treated fairly, addressing any workplace tensions resulting from the allegation.

Management reviews each incident to identify any lessons learned – this could lead to changes in policy, environmental improvements, or additional safeguards. We treat safeguarding incidents as opportunities to improve our service and prevent recurrence.

Throughout this process, the well-being of the adult at risk is paramount. We ensure they have a voice (through advocacy if needed) in decisions about their safety and future care plan. All actions taken will be person-centred and aimed at the protection and empowerment of the individual.

Whistleblowing

We are committed to an open and transparent culture where staff feel safe to report concerns. Whistleblowing refers to a staff member raising a concern about wrongdoing (such as abuse, neglect, or other misconduct) in the service, especially if they feel it is not being properly addressed through normal channels. This policy supports – and is linked to – our separate Whistleblowing Policy (Public Interest Disclosure Policy).

Key points include:

Duty to Raise Concerns: As emphasized above, every staff member has not only a moral but also a professional duty to report any concern of abuse or improper practice. This applies even if the concern involves colleagues or superiors. No one should ever feel it’s “not their business” – safeguarding is everyone’s business.
Multiple Avenues to Report: Normally, staff report internally to the Manager/DSL. However, if a staff member is uncomfortable reporting to management (for example, if they suspect the Manager or leadership is involved in wrongdoing, or if a previous report wasn’t acted upon), they should escalate the concern externally. Options include: contacting the local authority Adult Safeguarding Team directly to report the concern; informing Care Inspectorate Wales (CIW) – CIW can receive whistleblowing disclosures and has powers to investigate care failings; alerting the police if a crime is suspected and you believe it hasn’t been reported; or speaking to an independent advice body (e.g. Protect, formerly Public Concern at Work, or a union) for guidance on raising concerns.
No Retribution or Victimisation: Any staff member who raises a concern in good faith will be protected from retaliation. We do not tolerate any form of punishment, harassment, or unfavourable treatment toward a whistleblower. The Public Interest Disclosure Act protects employees who blow the whistle on malpractice; we fully adhere to this. If a staff member believes they are experiencing negative consequences for speaking up, they should report this immediately to senior management or the Responsible Individual, and it will be treated as a serious disciplinary matter.
Confidentiality: We will respect and, if requested, protect the confidentiality of whistleblowers to the fullest extent possible. Staff can also raise concerns anonymously – anonymous reports will still be taken seriously – though providing a name and cooperation may help facilitate a thorough investigation.
Response to Whistleblowing: Management will investigate whistleblowing claims thoroughly and impartially. If the concern was not raised internally first, we will not hold that against the whistleblower – we focus on addressing the issue. The whistleblower will be informed (as far as is appropriate) of the outcome or actions taken, to assure them that the concern was addressed.
Whistleblowing vs Grievance: We differentiate whistleblowing (reporting wrongdoing that affects others or the public interest, e.g. resident safety) from a personal grievance (e.g. an individual employment dispute). Only genuine safeguarding or improper practice concerns should be raised under whistleblowing in this context. That said, if a personal dispute reveals a wider safeguarding issue, it will still be treated under this policy.

We encourage early reporting – it is far better to raise a potential issue when it is small than to wait for harm to occur. Even if you are not sure whether something is abuse, you should report it so it can be assessed. Managers will thank staff for speaking up, not punish them. By creating an environment where staff can challenge poor practice without fear, we protect our residents more effectively.

Multi-Agency Working and External Referrals

Safeguarding adults is a multi-agency responsibility. We collaborate fully with external agencies to protect our residents:

Local Authority Safeguarding Team: We adhere to the local authority’s safeguarding procedures and will report any adult-at-risk concerns to them promptly. We recognise their lead role in coordinating investigations and developing protection plans. Our designated lead will attend and contribute to multi-agency strategy meetings or case conferences as required. We work in partnership with social workers, safeguarding officers, and other professionals to share information and plan effective interventions. (Our safeguarding policies and procedures are aligned with the Wales Safeguarding Procedures which guide multi-agency practice.)
Police and Emergency Services: In cases of suspected criminal abuse or immediate danger, we do not hesitate to involve the police. We maintain contact information for local police safeguarding units and will preserve evidence for police investigations. We also work with health services (ambulance, GP, hospitals) to ensure any injuries or health concerns resulting from abuse are treated and documented.
Health Professionals: If a resident is also under the care of health or mental health professionals (e.g. community nurses, psychiatrists, dementia specialists), we coordinate with them as part of safeguarding plans. For example, if there are concerns about a resident’s behaviour or capacity, we may consult relevant specialists as part of the protection strategy. Multi-disciplinary input helps ensure outcomes that are in the person’s best interest.
Advocacy Services: Where a resident may have difficulty understanding or participating in the safeguarding process (common with dementia), we ensure they have access to an independent advocate. This could be an Independent Mental Capacity Advocate (IMCA) or other advocacy service to represent the resident’s voice and rights during decision-making.
Regulator (CIW): We cooperate with CIW on any inspections or investigations related to safeguarding. CIW may carry out its own regulatory investigation if concerns indicate breaches of regulations. We provide full access and transparency to inspectors, and we promptly implement any improvement actions identified by CIW to strengthen safeguarding.

By engaging with the wider safeguarding network, we help ensure comprehensive protection for our residents. We understand that sharing information appropriately is crucial; we follow data protection requirements but will share relevant information with safeguarding agencies for the purpose of protecting individuals (overriding confidentiality if necessary for safety, in line with GDPR allowances for safeguarding).

Confidentiality and Information Sharing

Handling safeguarding concerns requires a careful balance between confidentiality and necessary information sharing:

We handle all safeguarding reports with confidentiality. Details are only shared with those who need to know in order to act – typically the Manager/DSL, relevant external authorities, and, in certain cases, the individuals involved (such as the victim and alleged perpetrator, in the context of investigation and support).
Staff are reminded not to gossip or share information about suspected cases with colleagues not involved in the matter. Rumours can cause harm and violate privacy.
When sharing information with external agencies, we follow official protocols. The Data Protection Act 2018 (GDPR) explicitly allows for disclosure of personal information without consent if it is necessary for safeguarding purposes – protecting an individual from harm is a legitimate basis for sharing. We ensure any information shared is accurate, relevant and limited to what is required.
Residents are assured that their personal information will be protected. If a resident confides in a staff member about abuse, the staff member should explain that they will need to tell the Manager/DSL and possibly others in order to help keep them safe, but that it will not be shared beyond those who need to know.
All records relating to safeguarding are kept securely, with restricted access. Electronic records (if used) are password-protected; paper records are kept in a locked file. Such records will be retained in line with our data retention policy for safeguarding records (typically at least 7–10 years, or longer if required due to specific circumstances or legal requirements).

Support for Residents and Staff

Dealing with abuse or allegations can be distressing for all involved. We ensure support is available to those who need it:

Support for the Affected Resident: We provide ongoing care and support to any resident who has experienced abuse or improper treatment. This may include medical attention, counselling or psychological support, increased reassurance and monitoring by staff, and involving family or advocates to comfort them. We develop an interim protection plan to ensure they feel safe (for example, assigning specific staff, more frequent check-ins, or moving them to a different room if that helps them feel more secure). The resident will be kept informed (if they have capacity) about the steps being taken, and their wishes and consent will be central to any decisions.
Support for Other Residents: Sometimes an incident can cause anxiety among other residents (for instance, if they witness an event or hear about it). We will provide general reassurance and, without breaching confidentiality, make it clear to all residents that concerns are being dealt with and that they are safe. If needed, we may arrange a meeting or send communication to residents’ families to address any general worries (again, without revealing personal details).
Support for Staff Raising Concerns: Staff who report abuse (whistleblowers or witnesses) may feel upset or fearful. Management will check on their well-being, reassure them that they did the right thing, and offer any needed support (such as counselling or time off if the situation was traumatic). We appreciate their courage in speaking up and will ensure they face no recrimination.
Support for Staff Accused: An accused staff member will also be treated with fairness and confidentiality. While resident safety is paramount (thus suspension or role changes may be necessary during investigation), we recognize the stress of being accused. The individual will have a named contact person in management or HR for support and will receive information about the process. If they are cleared of wrongdoing, we will help reintegrate them into the team and address any reputational or workplace issues. If they did commit wrongdoing, appropriate action will be taken as described, but even then we ensure they are informed of their rights (e.g. to union representation, to respond to allegations) during the process.
Employee Assistance: We may refer staff to professional counselling or an Employee Assistance Programme if they are dealing with emotional fallout from a safeguarding incident (whether as a victim, reporter, or accused).
Debrief: After a serious incident is resolved, management may hold a debrief session for involved staff to discuss what happened, how it was handled, and to allow people to process emotions in a constructive way. This is done sensitively and with respect for confidentiality. The aim is to facilitate learning and emotional support for staff after difficult situations.

Training and Competence

Maintaining staff competence in safeguarding is vital:

All staff (including temporary agency staff and volunteers) must complete basic adult safeguarding training at induction. This training covers understanding types of abuse, signs to watch for, duties to report, and our specific policy procedures.
Staff receive regular refresher training (at least annually, or more frequently as required) to keep knowledge current. Training is updated when laws or guidance change, or when internal learning suggests we need to reinforce certain topics.
Specialised training is provided based on roles:
- Dementia care training for those working directly with our residents, focusing on communication strategies, managing challenging behaviour positively, and understanding how dementia might mask or mimic signs of abuse.
- Mental Capacity Act and DoLS (Deprivation of Liberty Safeguards) training for relevant staff, to ensure any restrictive practices are lawful and that we always seek the least-restrictive options.
- Whistleblowing training or briefings, so staff know how to escalate concerns and feel confident to do so.
- Management training in handling allegations, conducting internal investigations, and coordinating with multi-agency partners.
We keep training records and ensure no staff member is allowed to work unsupervised with residents until they have completed safeguarding training.
We also conduct periodic drills or scenario-based discussions in team meetings – for example, “What would you do if you saw X?” – to keep safeguarding fresh in everyone’s mind and to identify any knowledge gaps.
The effectiveness of training is evaluated through supervision and observation. If staff do not demonstrate proper understanding (e.g. if someone fails to report an issue that they should), additional coaching or training is provided immediately.

Through ongoing education, we aim to create a confident staff team that can prevent and tackle abuse in any form.

Related Policies and Procedures

This Safeguarding Adults policy interlinks with several other internal policies, which should be read and followed in conjunction with it:

Whistleblowing Policy – Procedures for staff to report concerns confidentially, outside the normal chain of command.
Complaints Policy – How residents or their representatives can formally complain about any aspect of the service (noting that some complaints may reveal safeguarding issues).
Recruitment and Selection Policy – Our safe recruitment practices (DBS checks, vetting) to prevent hiring individuals who may pose a risk.
Staff Training and Development Policy – Ensuring staff are trained in safeguarding, dementia care, etc., and kept up-to-date.
Staff Disciplinary Policy – How allegations of staff misconduct, including abuse, are handled fairly and firmly.
Mental Capacity Act & DoLS Policy – Guidelines on supporting those who cannot make decisions, and ensuring any restrictions on liberty are lawful and necessary (relevant to preventing “improper treatment” through unlawful restraint).
Equality and Diversity Policy – Promoting respect and non-discrimination, thereby addressing potential discriminatory abuse.
Incident Reporting Policy – Procedures for documenting and reporting accidents, incidents, and near-misses (some of which can overlap with safeguarding incidents).
Data Protection/Confidentiality Policy – How personal information is protected, with noted exceptions for safeguarding disclosures where safety overrides consent.
Medication Management Policy – Safe handling of medications (to prevent misuse of medication that could amount to abuse or neglect).

All staff should be familiar with these related documents, as they collectively support a safe and caring service.

Policy Review

This policy will be reviewed at least annually, and more frequently if there are changes in legislation, guidance, or significant learning from incidents. The review process will involve the Registered Manager (DSL), the Responsible Individual, and input from staff and service users where appropriate, to ensure it remains practical and effective. We also incorporate any recommendations from the local Safeguarding Board or CIW. Any updates to the policy will be communicated to all staff, and training will be provided on new procedures or changes as necessary.

Sources

Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017 – Regulation 26 & 27 (Safeguarding requirements).
Statutory Guidance for Service Providers and Responsible Individuals of Care Home and Domiciliary Support Services (Welsh Government, updated March 2024) – Safeguarding requirements and guidance on meeting the regulations .
Wales Safeguarding Procedures (2019) – National framework requiring designated safeguarding persons and alignment of policies to local procedures.
Social Services and Well-being (Wales) Act 2014 – Definition of “Adult at Risk” and categories of abuse.
Public Health Wales “Duty to Report” Guidance – Emphasises staff duty to report adult at risk concerns to the local authority.
Legislation.gov.uk – Definition of “improper treatment” (discrimination or unlawful restraint, etc.) in care settings.
Internal best-practice guidance and resources (including SCIE and Social Care Wales materials on safeguarding adults).

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Reviewed on: {{last_update_date}}
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CHW13-Safeguarding Adults from Abuse and Improper Treatment Policy