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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Safeguarding People Against the Risk of Closed Cultures Policy

1. Purpose

The purpose of this policy is to ensure that {{org_field_name}} fosters an open, transparent, and person-centred environment, preventing the emergence of closed cultures that may lead to poor care, abuse, or neglect. A closed culture is defined as an environment where poor practice goes unchallenged, staff and residents feel powerless to speak up, and a lack of external scrutiny leads to harm. This policy aligns with the Regulation and Inspection of Social Care (Wales) Act 2016, CIW Safeguarding Standards, the Social Services and Well-being (Wales) Act 2014, and best practices in human rights and person-centred care.

This policy outlines how {{org_field_name}} proactively prevents the conditions that allow closed cultures to develop, ensuring that residents, families, and staff feel safe, empowered, and listened to. It sets out how we identify and respond to early warning signs and the strategies in place to promote transparency, accountability, and a strong safeguarding culture.

2. Scope

This policy applies to all individuals within {{org_field_name}}, including:

• Residents, ensuring they are protected from any restrictive, abusive, or neglectful practices.
• All staff members, ensuring they understand their responsibilities in preventing closed cultures and promoting open, person-centred care.
• Management and senior leadership, ensuring accountability and oversight in care provision.
• Families, friends, and advocates, ensuring they can freely raise concerns and contribute to decision-making.
• CIW inspectors and external professionals, ensuring they can conduct effective scrutiny of care provision.

3. Managing Closed Culture Risks Efficiently

3.1 Recognising the Signs of a Closed Culture

Closed cultures can develop when care environments become insular, hierarchical, and resistant to change or external scrutiny. Staff, residents, and visitors at {{org_field_name}} are trained to identify early warning signs, including:

• Residents having limited control over their lives, with little say in their daily routines, activities, or care decisions.
• Lack of external oversight, where visiting professionals, family members, or inspectors face barriers to access or are discouraged from questioning care practices.
• Staff working in isolation, leading to unchallenged poor practice and a culture of secrecy.
• Over-reliance on restrictive practices, such as unnecessary use of restraint, excessive sedation, or residents being discouraged from making complaints.
• Fear of speaking up, where staff, residents, or visitors feel unable to raise concerns without fear of repercussions.

Regular training sessions help staff, residents, and families identify these warning signs and report concerns immediately. Any concerns must be logged and escalated to the Registered Manager, CIW, or the Local Authority Safeguarding Team.

3.2 Leadership and Management Accountability

Strong leadership is key to preventing closed cultures. The Registered Manager and senior staff at {{org_field_name}} are responsible for ensuring:

• A zero-tolerance approach to poor care and abuse, with swift action taken against any misconduct.
• Regular, unannounced management walkarounds to assess care practices and staff-resident interactions.
• A listening culture, where residents and staff are encouraged to raise concerns and suggest improvements.
• An open-door policy, where staff can speak confidentially to management about concerns without fear of retribution.
• Regular audits and external reviews, ensuring compliance with CIW regulations and safeguarding best practices.

Leadership at {{org_field_name}} fosters a culture of openness, mutual respect, and shared decision-making, ensuring that no resident or staff member feels unheard or powerless.

3.3 Person-Centred Care and Empowering Residents

Residents must always be treated with dignity, autonomy, and respect. To prevent closed cultures, {{org_field_name}} ensures that:

• Residents have full choice and control over their care, including daily routines, activities, and personal preferences.
• Care plans are co-produced with residents and families, ensuring their voices are central in all decisions.
• Residents have access to advocacy services, ensuring they can raise concerns independently of staff or management.
• Regular residents’ meetings are held where they can express concerns, suggest improvements, and provide feedback.
• Staff are trained in human rights-based care, ensuring they uphold the legal and ethical rights of all residents.

No decision about a resident is made without their involvement and consent, ensuring their needs and wishes are always prioritised.

3.4 Promoting an Open, Speaking-Up Culture

Staff at {{org_field_name}} are trained to challenge poor practice and raise concerns in a safe, supportive environment. This is achieved through:

• A clear Whistleblowing (Speaking-Up) Policy, ensuring staff know how to report concerns externally if needed.
• Confidential reporting channels, allowing staff and residents to raise concerns anonymously if preferred.
• Protected time for staff reflection and debriefing, encouraging open discussions about improvements in care practices.
• Recognition and rewards for good practice, ensuring staff feel valued and supported in maintaining high care standards.

No staff member should feel afraid to challenge unsafe or unethical practices, and managers must respond to concerns swiftly and appropriately.

3.5 External Scrutiny and Family Involvement

An open culture is supported by welcoming external scrutiny and ensuring families play an active role in care oversight. {{org_field_name}} promotes transparency by:

• Encouraging frequent visits from families, external professionals, and community representatives.
• Ensuring all areas of the care home are accessible to families and external inspectors.
• Providing families with regular updates on their loved one’s care and involving them in decision-making.
• Encouraging family and visitor feedback, with formal channels for raising concerns or making suggestions.

CIW inspectors are given full access to care documentation, staff training records, and safeguarding reports, ensuring full regulatory compliance.

3.6 Restrictive Practice Oversight

A key risk in closed cultures is the misuse of restrictive practices, including physical restraint, medication use, or seclusion. {{org_field_name}} ensures that:

• Restrictive practices are only used as a last resort, in line with the Mental Capacity Act and CIW guidance.
• All use of restrictive interventions is recorded, reviewed, and independently assessed.
• Residents, families, and advocates are involved in reviewing restrictive practice decisions.
• Staff are trained in positive behaviour support, ensuring de-escalation strategies are always prioritised over restriction.

Any unauthorised or excessive use of restraint or restrictive practices is treated as a safeguarding concern and reported to the relevant authorities.

4. Responsibilities

4.1 Management Responsibilities

• Conducting regular staff training on closed culture risks.
• Responding swiftly and transparently to safeguarding concerns.
• Ensuring external scrutiny and audits are conducted.
• Leading by example, fostering a culture of openness, respect, and accountability.

4.2 Staff Responsibilities

• Providing compassionate, person-centred care at all times.
• Reporting concerns about poor practice or restrictive cultures.
• Supporting residents to have full control over their care and daily lives.
• Ensuring families and visitors feel welcomed and engaged.

4.3 Resident and Family Responsibilities

• Raising concerns about care quality if issues arise.
• Engaging in decision-making about care services.
• Providing feedback to help maintain an open culture.

5. Related Policies

This policy should be read in conjunction with:

• Whistleblowing (Speaking Up) Policy
• Safeguarding Adults from Abuse and Neglect Policy
• Dignity and Respect Policy
• Mental Capacity and Deprivation of Liberty Safeguards Policy

6. Policy Review

This policy is reviewed annually or sooner if new regulatory guidance emerges. The Registered Manager is responsible for ensuring compliance with CIW safeguarding and open culture principles.

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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.