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Safeguarding People at Risk of Self-Neglect and Hoarding Policy
1. Purpose
The purpose of this policy is to ensure that {{org_field_name}} has robust systems in place to identify, assess, and support individuals at risk of self-neglect and hoarding, in compliance with Welsh safeguarding legislation and CIW regulations. This policy outlines clear intervention strategies to safeguard service users while respecting their rights, dignity, and autonomy.
2. Scope
This policy applies to:
- All service users who may be at risk of self-neglect or hoarding.
- All staff, including care workers, nurses, and management who may come into contact with service users displaying such behaviours.
- External agencies, including safeguarding teams, environmental health officers, and CIW inspectors, involved in risk management and intervention.
It covers:
- Recognition and assessment of self-neglect and hoarding.
- Intervention strategies and support plans.
- Legal frameworks and best practice guidance.
- Multi-agency collaboration for safeguarding purposes.
3. Legal and Regulatory Compliance
This policy must be implemented in accordance with the legislative and regulatory framework applicable to care home services in Wales, including:
- The Social Services and Well-being (Wales) Act 2014, particularly Part 7, which establishes the statutory framework for safeguarding adults at risk and defines an adult at risk of abuse or neglect.
- The Regulation and Inspection of Social Care (Wales) Act 2016, which establishes the regulatory framework for regulated care services in Wales and the functions of Care Inspectorate Wales.
- The Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended, including:
- Regulation 12 – requirements to provide the service in accordance with appropriate and up-to-date policies and procedures;
- Regulation 21 – the requirement to provide care and support in a way which protects, promotes and maintains individuals’ safety and well-being;
- Regulation 26 – the overarching requirement to ensure individuals are safe and protected from abuse, neglect and improper treatment;
- Regulation 27 – requirements relating to safeguarding policies, procedures, immediate protective action, referrals and records;
- Regulation 29 – requirements concerning the appropriate use of control and restraint;
- Regulation 31 – the requirement that an individual must not be deprived of their liberty without lawful authority;
- Regulation 36 – requirements concerning staff induction, training, supervision and development; and
- Regulation 60 and Schedule 3 – requirements relating to notifications that must be made by the service provider.
- Welsh Government Statutory Guidance for Service Providers and Responsible Individuals on Meeting Service Standard Regulations, as amended or replaced from time to time.
- Working Together to Safeguard People, the statutory safeguarding guidance issued under the Social Services and Well-being (Wales) Act 2014, including the guidance relating to adults at risk.
- The Wales Safeguarding Procedures, including the procedures for identifying and reporting an adult at risk of abuse or neglect and the procedures concerning allegations or concerns about practitioners and persons in positions of trust.
- The Mental Capacity Act 2005 and its Code of Practice, including the statutory principles governing capacity, best-interests decision-making and least restrictive intervention.
- The Deprivation of Liberty Safeguards, where applicable, and any other lawful authority required where arrangements amount to a deprivation of liberty.
- The Human Rights Act 1998, including respect for the individual’s rights to dignity, privacy, family life and liberty.
- The Equality Act 2010, including the requirement not to unlawfully discriminate and to make reasonable adjustments where required.
Nothing in this policy gives staff authority to enter an individual’s private space, remove or dispose of their possessions, impose care or treatment, restrict their movement or otherwise override their wishes solely because the individual is self-neglecting or hoarding. Any such intervention must have an appropriate lawful basis and must comply with the Mental Capacity Act 2005, safeguarding requirements and any other applicable legislation.
4. Definitions
4.1 Self-Neglect
Self-neglect is the inability or unwillingness of an individual to meet their own personal, health, or environmental needs, leading to a risk of harm. This may include:
- Neglecting personal hygiene, leading to infections or skin conditions.
- Refusing medication or medical treatment, despite health deterioration.
- Failing to eat or drink adequately, leading to malnutrition or dehydration.
- Living in unsanitary conditions, posing health and safety risks.
4.2 Hoarding Disorder
Hoarding disorder is a recognised mental health condition where individuals excessively collect and fail to discard items, leading to:
- Obstructed living spaces, increasing fire hazards and hygiene concerns.
- Inability to maintain daily routines, such as washing, cooking, or sleeping.
- Health and safety risks, including rodent infestations and fire hazards.
Hoarding is not the same as collecting; it is a compulsive behaviour that can impact mental well-being and physical safety.
4.3 Adult at Risk and Safeguarding Threshold
For the purposes of this policy, an adult will be treated as an adult at risk where the criteria in section 126 of the Social Services and Well-being (Wales) Act 2014 are met. This means an adult who:
- is experiencing or is at risk of abuse or neglect;
- has needs for care and support, whether or not those needs are currently being met by a local authority; and
- as a result of those needs is unable to protect themselves against the abuse or neglect or the risk of it.
Self-neglect is recognised within the Wales Safeguarding Procedures as a form of maltreatment and hoarding is recognised as a possible indicator of self-neglect. Self-neglect or hoarding must therefore not be treated solely as a lifestyle choice or environmental issue where the circumstances indicate that the adult-at-risk criteria may be met.
Actual injury, abuse or neglect does not have to have occurred before a safeguarding concern is reported. Where staff know, suspect or have reasonable cause to be concerned that an individual meets the adult-at-risk criteria, they must follow the safeguarding reporting procedure set out in Section 6.3 of this policy.
The individual’s views, wishes, feelings, preferred outcomes and capacity to make the relevant decisions must be considered throughout the safeguarding process. However, a refusal of support or a reluctance to engage does not remove the requirement to consider whether a safeguarding report is necessary.
5. Identifying Signs of Self-Neglect and Hoarding
5.1 Early Warning Signs
Staff should be trained to identify the following signs of self-neglect and hoarding:
- Persistent refusal of care or assistance.
- Unkempt appearance or strong odours.
- Unexplained weight loss, dehydration, or physical weakness.
- Rooms filled with clutter, excessive waste, or unsanitary conditions.
- Reluctance to allow staff into personal spaces.
5.2 Risk Assessment Process
All service users will be assessed upon admission and regularly reviewed for self-neglect and hoarding behaviours. Risk assessments will consider:
- Physical and mental health conditions contributing to self-neglect.
- Capacity to make informed decisions about their living conditions.
- Level of risk posed to the individual and others in the care home.
- Fire safety and infection control concerns.
6. Intervention Strategies
6.1 Person-Centred Approach
Interventions must balance risk management with personal choice, ensuring the service user’s rights and dignity are upheld. Key principles include:
- Building trust and rapport before making changes.
- Engaging service users in discussions about their needs.
- Providing support in small, manageable steps.
- Encouraging autonomy while ensuring safety.
6.2 Care Planning and Individual Support
If a service user is identified as at risk of self-neglect or hoarding, a multi-disciplinary support plan will be developed, including:
- Regular welfare checks and enhanced monitoring.
- Involvement of mental health professionals, where necessary.
- Nutritional support and hydration monitoring.
- Fire safety interventions (e.g., clear escape routes, fire-resistant furnishings).
- Support for decluttering, working at a pace the service user is comfortable with.
6.3 Mental Capacity, Safeguarding and Escalation
Staff must not assume that an individual lacks mental capacity because they self-neglect, hoard, refuse care, decline treatment or make a decision which staff, relatives or professionals consider unwise.
Mental capacity must be considered in accordance with the Mental Capacity Act 2005. The individual must be presumed to have capacity unless it is established otherwise. Where there is reason to doubt capacity, the assessment must relate to the specific decision that needs to be made and to the time at which that decision is required.
Before concluding that an individual is unable to make a decision, all practicable steps must be taken to support them to understand, retain, use or weigh the relevant information and communicate their decision. Appropriate communication support, advocacy or professional input must be obtained where required.
Where the individual has capacity to make the relevant decision, their decision must be respected unless there is another lawful basis for intervention. The individual’s refusal of care or support must be recorded together with the information provided to them, the risks discussed, steps taken to reduce those risks and any agreed contingency arrangements.
Where an individual lacks capacity to make the relevant decision, any decision made or action taken on their behalf must:
- be made in accordance with the Mental Capacity Act 2005;
- be in the individual’s best interests;
- take account of the individual’s past and present wishes, feelings, beliefs and values and the views of relevant persons where required; and
- be the least restrictive available option capable of achieving the intended purpose.
Where arrangements for care or risk management may amount to a deprivation of liberty, the service must ensure that appropriate lawful authority is sought and maintained. The individual must not be deprived of their liberty for the purpose of receiving care and support without lawful authority.
Safeguarding reporting
Where a member of staff knows, suspects or has reasonable cause to be concerned that an individual is an adult at risk of abuse or neglect, including as a result of self-neglect or hoarding, the member of staff must report the concern immediately to the Registered Manager or designated safeguarding person and the concern must be reported to the relevant local authority social services department in accordance with the Wales Safeguarding Procedures.
A safeguarding report must not be delayed until actual harm has occurred or until the risk becomes an emergency.
Safeguarding reports must be made as soon as possible and, in accordance with the Wales Safeguarding Procedures, within 24 hours of the concern being identified. Where an initial report is made by telephone, it must be confirmed in writing within 24 hours using the relevant local authority reporting arrangements.
Where there is an immediate risk to life or serious harm, staff must take immediate action to protect the individual and contact emergency services where required. Where there is reason to suspect that a criminal offence has been committed, the police must be contacted in accordance with the Wales Safeguarding Procedures.
Staff should seek the individual’s consent to make a safeguarding report where it is appropriate and safe to do so and must take account of the individual’s wishes and preferred outcomes. Consent is not, however, an absolute requirement for making a safeguarding report. Where a safeguarding report is required without the individual’s consent, the reason for proceeding without consent must be clearly recorded and the individual should be informed that the report has been made unless doing so would increase risk or otherwise be inappropriate.
Any uncertainty about whether the safeguarding threshold has been met must be discussed promptly with the Registered Manager, designated safeguarding person or relevant local authority safeguarding service. Seeking advice must never delay emergency action required to protect an individual.
Where the concern relates to the conduct of a member of staff, volunteer, professional or other person in a position of trust, the service must additionally follow its Safeguarding Adults Policy, Whistleblowing Policy and the current Wales Safeguarding Procedures concerning allegations or concerns about practitioners and persons in positions of trust.
7. Multi-Agency Collaboration
Self-neglect and hoarding require a multi-agency approach. {{org_field_name}} will work closely with:
- Local Authority Adult Safeguarding Teams.
- Environmental Health Officers, if hoarding poses a health risk.
- Mental Health Services, for therapeutic support.
- Fire and Rescue Services, for home safety assessments.
- CIW Inspectors, ensuring regulatory compliance.
8. Fire and Health & Safety Measures
8.1 Fire Risk Reduction
Hoarding increases fire hazards. {{org_field_name}} will:
- Conduct fire risk assessments for service users at risk.
- Ensure clear escape routes in case of an emergency.
- Install additional smoke detectors in high-risk rooms.
- Train staff in fire safety interventions for hoarded spaces.
8.2 Infection Control Measures
For cases of severe self-neglect or hoarding, infection control procedures will include:
- Regular deep cleaning of living spaces.
- Safe disposal of waste and perishable items.
- Use of PPE by staff where contamination is a risk.
9. Staff Training and Awareness
The service provider must ensure that staff have the knowledge, skills and competence required to recognise and respond appropriately to self-neglect, hoarding and associated safeguarding risks.
All staff must:
- receive safeguarding training appropriate to their role as part of their induction;
- receive ongoing safeguarding training at appropriate intervals in accordance with the requirements of the service, current Wales Safeguarding Procedures and the applicable Social Care Wales safeguarding training, learning and development standards;
- understand the signs and indicators of self-neglect and hoarding and when these may indicate that an individual is an adult at risk;
- understand the statutory adult-at-risk threshold and their responsibility to report safeguarding concerns;
- know how and where to report a concern internally and to the relevant local authority social services department;
- understand when emergency services or the police must be contacted;
- understand the principles of the Mental Capacity Act 2005, including the presumption of capacity, decision-specific assessment, best-interests decision-making and least restrictive intervention, insofar as these are relevant to their role;
- understand that an individual’s refusal of care or an apparently unwise decision does not, by itself, establish a lack of mental capacity;
- understand the service’s procedures for recording and escalating concerns; and
- understand their responsibilities under the service’s Safeguarding Adults Policy and Whistleblowing Policy.
Safeguarding practice and staff understanding must be revisited through supervision. Where supervision, incident review, safeguarding activity or audit identifies a gap in an individual staff member’s knowledge or competence, appropriate additional training, supervision or other action must be provided.
The service provider must maintain records of safeguarding training, learning and development undertaken by staff and must monitor whether required training remains current.
10. Documentation and Reporting
All concerns relating to self-neglect or hoarding must be recorded accurately, contemporaneously and in sufficient detail to demonstrate the assessment, decision-making and actions taken to safeguard the individual.
Records must include, where applicable:
- the date and time the concern was identified;
- the nature and source of the concern;
- factual observations and relevant information provided by the individual or others;
- the individual’s views, wishes, feelings and preferred outcomes;
- identified risks to the individual and to other people;
- immediate protective action taken;
- relevant risk assessments and any revisions made;
- any consideration or assessment of the individual’s mental capacity, including the specific decision concerned;
- any best-interests decision made and the rationale for that decision;
- discussions with the Registered Manager, designated safeguarding person, health professionals, local authority, police, fire and rescue service or other relevant agencies;
- whether the adult-at-risk threshold was considered to be met and the reasons for that decision;
- any safeguarding report made to the local authority, including the date, time, person making the report and information supplied;
- whether the individual’s consent was sought or obtained and, where a report was made without consent, the reasons for doing so;
- any referral or report to the police or another relevant agency;
- the substance of any allegation or evidence of abuse, neglect or improper treatment;
- action taken in response to any allegation or evidence;
- the outcome of safeguarding referrals and multi-agency processes, where known;
- amendments required to the individual’s personal plan, risk assessment or support arrangements;
- agreed monitoring and review arrangements; and
- the rationale for any decision that no further safeguarding action is required.
A lack of complete information must not delay the making of a safeguarding report where there is a concern that an adult is at risk.
Records relating to safeguarding referrals and their outcomes must be maintained so that the Registered Manager, Responsible Individual and service provider can exercise appropriate oversight of safeguarding practice within the service.
Where a safeguarding concern results in changes to the individual’s assessed needs, risks or required support, the individual’s provider assessment, personal plan and relevant risk assessments must be reviewed and revised as necessary.
10.1 Notifications to Care Inspectorate Wales
Safeguarding reporting to the local authority and notification to Care Inspectorate Wales are separate requirements. Making a safeguarding report does not remove the service provider’s responsibility to determine whether a statutory notification to Care Inspectorate Wales is also required.
The service provider must make notifications to Care Inspectorate Wales in accordance with Regulation 60 and Schedule 3 of the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended.
In the context of self-neglect and hoarding, the Registered Manager and service provider must consider whether the circumstances include a notifiable event, including:
- abuse or an allegation of abuse involving the service provider, a member of staff or a volunteer;
- an allegation of misconduct by a member of staff;
- a serious accident or injury to an individual meeting the relevant notification threshold;
- an incident which has been reported to the police;
- an event which prevents, or could prevent, the service provider from continuing to provide the service safely;
- where accommodation is provided, the death of an individual and the circumstances; or
- a request made to a supervisory body in relation to an application under the Deprivation of Liberty Safeguards.
Unless the Regulations specify otherwise, required notifications must be made without delay, in writing and in the manner and form required by Care Inspectorate Wales. Current CIW notification arrangements must be followed, including use of CIW Online where applicable.
A record must be retained of:
- the event giving rise to the notification;
- the legal or regulatory notification category considered;
- whether a notification was required;
- the date on which the notification was submitted;
- the person who submitted it;
- the information supplied to Care Inspectorate Wales; and
- any subsequent correspondence or action required.
Where there is uncertainty as to whether an event is notifiable, the Registered Manager must escalate the matter promptly to the Responsible Individual or service provider and obtain advice from Care Inspectorate Wales where necessary. Uncertainty about notification requirements must not delay any immediate safeguarding or protective action.
11. Related Policies
This policy should be read alongside:
- Safeguarding Adults Policy (CHW13).
- Risk Management and Assessment Policy (CHW18).
- Infection Prevention and Control Policy (CHW17).
- Health and Safety at Work Policy (CHW16).
- Fire Safety and Evacuation Policy (CHW20).
12. Policy Review
This policy will be reviewed annually or sooner if legislative changes or operational needs require amendments.
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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