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{{org_field_name}}
Registration Number: {{org_field_registration_no}}
Staff Safety and Abuse Prevention Policy
1. Purpose
This policy outlines {{org_field_name}}’s commitment to ensuring the safety, security, and well-being of all staff while preventing and responding to incidents of abuse. It aligns with CQC regulations, the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, and the Equality Act 2010. The policy aims to foster a culture of safety, respect, and zero tolerance towards abuse in the workplace.
2. Scope
This policy applies to all employees of {{org_field_name}}, including full-time, part-time, bank, agency staff, contractors, and volunteers. It covers the prevention, identification, reporting, and management of abuse against staff members from colleagues, the people we support, visitors, or external parties.
3. Legal and Regulatory Framework
{{org_field_name}} will manage staff safety, violence, aggression, harassment and abuse in accordance with applicable legislation and regulatory requirements, including:
- Health and Safety at Work etc. Act 1974: {{org_field_name}} has a duty, so far as is reasonably practicable, to protect the health, safety and welfare of employees at work and to manage risks arising from its activities that may affect employees and other persons.
- Management of Health and Safety at Work Regulations 1999: {{org_field_name}} will carry out suitable and sufficient assessments of risks to the health and safety of employees and others who may be affected by its activities. This includes foreseeable risks arising from violence, aggression, threats, harassment and lone working. Appropriate preventive and protective measures will be implemented and risk assessments will be reviewed when there is reason to believe they are no longer valid or following a significant change or relevant incident.
- Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR): Work-related incidents, including acts of non-consensual violence, will be reported to the relevant enforcing authority where the statutory reporting criteria are met. Required records of reportable incidents will be retained.
- Equality Act 2010, including section 40A as inserted by the Worker Protection (Amendment of Equality Act 2010) Act 2023: {{org_field_name}} will not discriminate against or unlawfully harass employees and will take reasonable steps to prevent sexual harassment of employees in the course of their employment. This includes considering reasonably foreseeable risks of sexual harassment arising from colleagues and third parties with whom staff come into contact through their work.
- Employment Rights Act 1996 and Public Interest Disclosure Act 1998: Employees and workers will not be subjected to unlawful detriment for raising qualifying concerns or making protected disclosures in accordance with the law.
- Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 – Regulation 13, Safeguarding Service Users from Abuse and Improper Treatment: Regulation 13 protects people using the service from abuse and improper treatment. Where an incident concerning staff also involves a person using the service, {{org_field_name}} will ensure that the person’s rights, safety, dignity and protection from abuse or improper treatment remain fully safeguarded. Any restraint or restriction used in response to an incident must be lawful, necessary and proportionate.
- Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 – Regulation 17, Good Governance: {{org_field_name}} will operate effective systems and processes to assess, monitor and mitigate risks arising from the regulated activity to the health, safety and welfare of people using the service and other persons who may be at risk, including staff.
- Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 – Regulation 18, Staffing: Sufficient numbers of suitably qualified, competent, skilled and experienced staff will be deployed to meet regulatory requirements. Staff employed in the provision of regulated activities will receive the support, training, professional development, supervision and appraisal necessary to enable them to perform their duties safely and effectively.
- Care Quality Commission (Registration) Regulations 2009 – Regulation 18, Notification of Other Incidents: The Registered Person will notify the Care Quality Commission without delay when an incident meets the statutory notification requirements, including relevant abuse or allegations of abuse involving a person using the service and other incidents specified by the Regulations.
- Care Act 2014: Where an incident raises a safeguarding concern about an adult with care and support needs who is experiencing, or is at risk of, abuse or neglect and is unable to protect themselves because of those needs, {{org_field_name}} will follow the applicable local authority safeguarding procedures and statutory safeguarding arrangements.
- Mental Capacity Act 2005: Where an incident involves a person who may lack capacity to make a relevant decision, staff will follow the Mental Capacity Act 2005, including its requirements concerning capacity, best-interests decision-making and lawful restrictions or restraint.
- Data Protection Act 2018 and UK GDPR: Personal information relating to incidents, allegations, investigations and staff support will be processed lawfully, fairly, securely and only for appropriate purposes.
4. Staff Safety Responsibilities
Employer Responsibilities
{{org_field_name}} will:
- Carry out suitable and sufficient risk assessments covering reasonably foreseeable risks of work-related violence, aggression, threats, harassment and abuse.
- Consider whether particular activities, locations, times of day or working arrangements create additional risks, including lone working, working at night, responding to distressed or aggressive people, handling medicines or valuables, and situations where staff are required to set boundaries or refuse requests.
- Consider whether any employees may face additional or different risks and ensure that appropriate controls are implemented.
- Assess known risks arising from the behaviour of people using the service and ensure that relevant risk-management measures are incorporated into care planning and communicated to staff who need the information to work safely.
- Introduce preventive and protective measures that are proportionate to the identified risks and reduce risks so far as is reasonably practicable.
- Review risk assessments and control measures following incidents, significant changes in circumstances, emerging patterns or where there is reason to believe that existing measures may no longer be effective.
- Consult employees and, where applicable, recognised safety representatives or other employee representatives about health and safety risks and measures intended to control those risks.
- Ensure that staffing arrangements and skill mix are sufficient to meet the assessed needs of people using the service and to enable staff to provide care safely.
- Provide staff with appropriate information, instruction, training, supervision and support relating to identified risks, including violence and aggression, de-escalation, personal safety, incident reporting and emergency procedures.
- Take reasonable steps to prevent sexual harassment of employees in the course of their employment, including foreseeable sexual harassment by colleagues and third parties such as people using the service, relatives, visitors or contractors.
- Provide accessible routes for staff to report violence, aggression, abuse, harassment or other safety concerns, including an alternative reporting route where the employee’s immediate manager is involved in, or is the subject of, the allegation.
- Record, investigate and review incidents proportionately, identify contributory factors and patterns, and implement any additional control measures or organisational learning required.
- Make statutory notifications, referrals and reports to external bodies where the relevant legal threshold is met.
- Provide appropriate support to employees affected by violence, aggression, abuse or harassment, taking account of the circumstances and the employee’s individual needs.
Employee Responsibilities
Employees must:
- Take reasonable care of their own health and safety and that of other people who may be affected by their acts or omissions at work.
- Co-operate with {{org_field_name}} so that statutory health and safety duties and safety arrangements can be complied with.
- Follow risk assessments, care plans, safe systems of work, emergency arrangements and other reasonable safety instructions.
- Use safety equipment and protective measures provided by {{org_field_name}} correctly and report defects or concerns promptly.
- Report incidents, near misses, threats, violence, aggression, abuse, harassment and unsafe situations promptly through the appropriate reporting procedure.
- Inform a manager where they believe that an existing risk assessment or control measure no longer adequately manages an identified risk.
- Participate in training, supervision and competency assessment relevant to their role.
- Treat colleagues, people using the service, visitors and other persons with dignity, respect and professionalism.
5. Preventing Abuse Against Staff
- Zero-Tolerance Policy: Any form of physical, verbal, emotional, or sexual abuse towards staff will not be tolerated.
- Training and Awareness:
- Staff receive mandatory training on recognising and responding to abuse.
- De-escalation techniques and conflict resolution are included in training programmes.
- Awareness sessions on rights and protections against workplace abuse.
- Secure Working Environment:
- Adequate staffing levels to prevent lone working risks.
- Emergency alarm systems and safe rooms for staff protection.
- CCTV in appropriate areas to deter aggression and violence.
- Code of Conduct: Clear guidelines on expected behaviour from staff, the people we support, and visitors.
6. Identifying Abuse Against Staff
Types of Abuse Staff May Face
- Physical Abuse: Assault, pushing, hitting, spitting, or throwing objects.
- Verbal Abuse: Threats, insults, demeaning language, or aggressive shouting.
- Sexual Harassment or Abuse: Unwanted advances, inappropriate comments, or physical contact.
- Emotional or Psychological Abuse: Bullying, intimidation, or gaslighting.
- Discriminatory Abuse: Harassment based on race, gender, disability, or other protected characteristics.
- Financial Abuse: Pressure to provide financial information, theft, or coercion.
Signs of Abuse Against Staff
- Fear or reluctance to attend work.
- Anxiety, stress, or emotional distress.
- Physical injuries or unexplained absences.
- Changes in performance or behaviour.
7. Reporting and Responding to Abuse
Immediate Response
Where an incident of violence, aggression, abuse, harassment or threatening behaviour occurs, staff must prioritise immediate safety.
Staff must:
- Move away from immediate danger where this can be done safely.
- Summon assistance in accordance with the service’s emergency arrangements.
- Call 999 where there is an immediate threat to life or serious injury, or where urgent police or ambulance assistance is required.
- Ensure that affected people receive appropriate first aid or medical assessment where necessary.
- Take reasonable action to protect other staff, people using the service and visitors from immediate harm.
- Preserve relevant evidence where a criminal offence or serious incident may have occurred, provided that doing so does not compromise immediate safety or necessary care.
Internal Reporting Procedures
All incidents, allegations, threats and relevant near misses must be reported promptly to the appropriate line manager or the Registered Manager.
Reports may be made by:
- Informing the line manager or Registered Manager directly as soon as practicable.
- Sending details to the Registered Manager at: {{org_field_registered_manager_email}}.
- Calling the office and asking to speak to the Registered Manager or designated safeguarding lead at: {{org_field_phone_no}}.
- Where the concern arises outside normal office hours, using the out-of-hours contact number: {{out_of_hours}}.
Where the concern relates to the employee’s line manager, the Registered Manager, or another person normally responsible for receiving the report, the employee must use the next appropriate level of management or the organisation’s whistleblowing procedure.
An internal incident record must be completed as soon as practicable and, under {{org_field_name}}’s internal reporting procedure, normally within 24 hours. The requirement to complete an incident form must never delay emergency action, medical treatment, safeguarding action, police involvement or a statutory notification.
The Registered Manager or delegated competent person must determine:
- Whether immediate or continuing risks remain.
- Whether a risk assessment or care plan requires review.
- Whether a safeguarding referral is required.
- Whether the police should be contacted.
- Whether a CQC statutory notification is required.
- Whether the incident is reportable under RIDDOR.
- Whether any employment, disciplinary, capability or professional process is required.
- What immediate and continuing support should be offered to the affected member of staff.
CQC Notifications
The Registered Person is responsible for ensuring that notifications required by the Care Quality Commission (Registration) Regulations 2009 are submitted to CQC without delay.
An incident involving abuse of, or aggression towards, a member of staff is not automatically notifiable to CQC solely because a member of staff has been affected.
A CQC notification must, however, be made where the statutory criteria are met, including where:
- There is abuse or an allegation of abuse in relation to a person using the service. This may include circumstances in which the person using the service is the victim, alleged victim, alleged perpetrator or is otherwise directly involved in the alleged abuse.
- An incident arising during, or as a consequence of, the carrying on of the regulated activity is reported to or investigated by the police.
- A person using the service sustains an injury that meets the statutory notification threshold.
- Another event specified in the Care Quality Commission (Registration) Regulations 2009 occurs.
Submitting information to another organisation does not remove the Registered Person’s responsibility to make a required CQC notification.
Safeguarding Referrals
Where an incident gives rise to reasonable cause to suspect that an adult with care and support needs is experiencing, or is at risk of, abuse or neglect and is unable to protect themselves because of those needs, the concern must be referred promptly through the relevant local authority adult safeguarding procedure.
The local authority safeguarding adults service or team, rather than the Safeguarding Adults Board itself, will normally receive and coordinate individual safeguarding concerns.
Any required safeguarding referral must be made without unnecessary delay and must not be postponed while an internal employment investigation is undertaken.
Police
The police must be contacted where immediate police assistance is necessary or where required by law.
Where there is reason to believe that a criminal offence may have been committed, the Registered Manager must consider police referral alongside any safeguarding or regulatory reporting requirements.
Internal disciplinary or management procedures must not be used as a substitute for appropriate police referral.
RIDDOR
The person responsible for RIDDOR reporting on behalf of {{org_field_name}} must assess work-related injuries and incidents against the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013.
Acts of non-consensual violence arising out of or in connection with work are capable of being reportable accidents under RIDDOR.
A work-related act of violence must be reported under RIDDOR where it results in:
- The death of a worker.
- A specified reportable injury to a worker.
- A physical injury that prevents a worker from carrying out their normal work duties for more than seven consecutive days, excluding the day of the accident.
Other incidents, diseases or dangerous occurrences must also be reported where they meet the applicable RIDDOR criteria.
Required RIDDOR reports must be submitted to the relevant enforcing authority using the prescribed reporting arrangements and within the applicable statutory timescale.
Support for Affected Staff
Following an incident, {{org_field_name}} will consider appropriate support based on the circumstances and the employee’s needs. This may include:
- Immediate first aid or medical support.
- Debriefing and management support.
- Access to occupational health, counselling or employee assistance services where available.
- Reasonable temporary adjustment of duties where appropriate.
- Time away from work where clinically necessary or otherwise appropriate.
- Support during police, safeguarding, regulatory or internal investigation processes.
The affected member of staff will be kept appropriately informed about actions arising from the incident, subject to confidentiality, data protection requirements and the rights of other persons involved.
8. Managing Aggressive or High-Risk Individuals
Risk Assessment and Care Planning
Where a person using the service presents a known or reasonably foreseeable risk of violence or aggression, {{org_field_name}} will complete an individual risk assessment and incorporate appropriate risk-management measures into the person’s care plan.
The assessment must take account of relevant factors including:
- Known triggers for distress, aggression or behaviour that may place the person or others at risk.
- The person’s physical health, mental health, cognition and communication needs.
- Pain, infection, delirium or other clinical factors that may contribute to changes in behaviour.
- The effects of medicines, alcohol or other substances where relevant.
- Previous incidents or known patterns of behaviour.
- Environmental or situational factors.
- The risk presented to the person themselves, other people using the service, staff and visitors.
- The most appropriate preventive, de-escalation and support strategies.
Risk assessments and care plans must be reviewed following a significant incident, a material change in the person’s needs or behaviour, or where existing control measures appear ineffective.
Staff who may reasonably be exposed to the identified risk must be given sufficient relevant information to enable them to work safely, while respecting confidentiality and data protection requirements.
Behavioural Expectations and Agreements
Where appropriate, expected standards of behaviour may be explained to people using the service, relatives and visitors.
Any behavioural agreement involving a person using the service must:
- Be appropriate to the person’s circumstances, communication needs and capacity.
- Be consistent with their care plan and assessed needs.
- Not be used as a substitute for appropriate assessment, treatment, care planning or risk management.
- Not impose punitive or discriminatory conditions.
- Not be relied upon to impose a restriction that would otherwise require lawful authority, consent or a best-interests decision.
Where there is reason to doubt a person’s capacity to understand or agree to a relevant arrangement, staff must follow the Mental Capacity Act 2005.
Intervention and De-escalation
Staff must use appropriate prevention and de-escalation strategies wherever reasonably practicable.
Responses to violence or aggression must be individualised and must take account of the person’s needs, known triggers, communication abilities and care plan.
Any restriction, physical intervention or restraint must:
- Have a lawful basis.
- Be necessary in the circumstances.
- Be proportionate to the risk of harm.
- Use the least restrictive approach reasonably available.
- Never be used as punishment, retaliation or solely for staff convenience.
- Comply with Regulation 13 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 and the Mental Capacity Act 2005 where applicable.
Any use of restraint must be documented, reviewed and escalated in accordance with the service’s restraint, safeguarding and incident-reporting procedures.
Where the Service Can No Longer Safely Meet a Person’s Needs
Violent, aggressive or challenging behaviour must not, by itself, result in the arbitrary, punitive or immediate termination of a person’s care.
Where, despite appropriate assessment and risk-management measures, {{org_field_name}} reasonably considers that it can no longer safely meet a person’s assessed needs, the Registered Manager must arrange an urgent review of the placement.
The review must involve, as appropriate:
- The person using the service.
- Their lawful representative, advocate or family member where appropriate.
- The placing local authority or commissioner.
- Relevant health and social care professionals.
- The multidisciplinary team.
- Safeguarding professionals where safeguarding concerns exist.
Any decision to terminate a placement or transfer a person to another service must:
- Follow applicable contractual and legal requirements.
- Be based on an assessment of the person’s needs and identified risks.
- Take account of the person’s rights, wishes and preferences.
- Comply with the Mental Capacity Act 2005 where the person lacks capacity to make relevant decisions.
- Include appropriate continuity and transition planning.
- Avoid abandonment, unsafe discharge or an unlawful eviction.
Where immediate emergency measures are required to prevent serious harm, only necessary and proportionate action may be taken, and appropriate health, safeguarding, commissioning or emergency services must be contacted without delay.
9. Lone Working Safety Measures
Lone Working Risk Assessment
- Identifying situations where lone working may increase risk.
- Staff given appropriate training in handling difficult situations.
Communication Protocols
- Regular check-ins with managers during lone working shifts.
- Access to panic alarms or emergency response buttons.
Incident Procedures
- Immediate escalation of concerns to management.
- Use of buddy systems where possible.
10. Training and Awareness
- Mandatory Staff Training:
- Conflict resolution and de-escalation techniques.
- Recognising signs of abuse and reporting procedures.
- Personal safety and risk management strategies.
- Refresher Training: Conducted annually or as required based on incident trends.
- New Employee Induction:
- Covers workplace safety, reporting abuse, and professional boundaries.
- Awareness of company policies regarding abuse prevention.
11. Documentation and Compliance
Incident Records
All incidents of violence, aggression, abuse, harassment, threats and relevant near misses must be recorded accurately and in sufficient detail to support appropriate risk management, investigation and organisational learning.
Records must include, where applicable:
- The date, time and location of the incident.
- The persons involved and any witnesses.
- A factual description of what occurred.
- Any injury or harm sustained.
- Immediate actions taken.
- Medical treatment or first aid provided.
- Whether emergency services or the police were contacted.
- Any safeguarding referral made.
- Any CQC notification made.
- Any RIDDOR assessment and report.
- Any changes made to risk assessments, care plans, staffing arrangements or control measures.
- Relevant investigation findings and actions.
Records must be accurate, contemporaneous as far as reasonably practicable, appropriately confidential and stored securely in accordance with the Data Protection Act 2018, UK GDPR and the organisation’s records-management requirements.
CQC Notifications
The Registered Person must ensure that statutory notifications are submitted to CQC without delay where required by the Care Quality Commission (Registration) Regulations 2009.
In relation to incidents covered by this policy, particular consideration must be given to:
- Abuse or allegations of abuse in relation to a person using the service.
- Incidents related to the carrying on of the regulated activity that are reported to or investigated by the police.
- Notifiable injuries sustained by a person using the service.
- Events that prevent, or threaten to prevent, the provider from carrying on the regulated activity safely and in accordance with registration requirements.
The Registered Person remains responsible for ensuring that a required notification has been submitted even where the matter has already been reported to the local authority, police, commissioner or another organisation.
Evidence of the notification and any related correspondence must be retained in accordance with the organisation’s records-management arrangements.
RIDDOR Records and Reports
{{org_field_name}} will assess relevant accidents, injuries, acts of work-related violence, diseases and dangerous occurrences against the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013.
Where an incident is reportable, the responsible person will:
- Submit the required report through the prescribed RIDDOR reporting arrangements within the applicable statutory timescale.
- Retain the required record of the reportable event.
- Record the date and method of reporting and the RIDDOR reference where available.
- Ensure that subsequent information is provided or the report updated where this is required.
An internal incident report does not replace a statutory RIDDOR report.
Monitoring, Audit and Learning
The Registered Manager will ensure that incidents are reviewed to identify:
- Recurring patterns or trends.
- Individual people or circumstances associated with increased risk.
- Environmental or staffing factors.
- Whether existing control measures remain effective.
- Whether further training, supervision or support is required.
- Whether risk assessments or care plans require amendment.
- Whether safeguarding, regulatory or other statutory reporting requirements have been met.
Where weaknesses are identified, proportionate corrective action must be taken and its implementation monitored.
Policy Review and Updates
This policy will be reviewed annually and earlier where:
- Relevant legislation or statutory requirements change.
- CQC requirements or regulatory guidance materially change.
- HSE requirements or relevant health and safety guidance materially change.
- An incident, investigation, audit or risk assessment identifies that the policy or associated procedures are no longer adequate.
Any required amendments will be communicated to affected staff and incorporated into relevant training, supervision or working arrangements.
12. Related Policies
- CH13-Safeguarding Adults from Abuse and Improper Treatment Policy
- CH16-Health and Safety at Work Policy
- CH23-Lone Working and Staff Safety Policy
- CH28-Staff Conduct and Code of Ethics Policy
- CH32-Handling and Prevention of Bullying and Harassment Policy
- CH34-Confidentiality and Data Protection (GDPR) Policy
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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