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DC13-Safeguarding Adults from Abuse and Improper Treatment Policy

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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

Safeguarding Adults Policy

This policy underpins {{org_field_name}}’s compliance with the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (including Regulation 13: Safeguarding service users from abuse and improper treatment) and the Care Quality Commission (Registration) Regulations 2009 (including Regulation 18: Notification of other incidents) and Regulation 20 (Duty of Candour). It aligns with the Care Act 2014 statutory guidance and local multi-agency procedures of {{org_field_local_authority_authority_name}}.

1. Introduction


Safeguarding means protecting an adult’s right to live in safety, free from abuse and neglect​. It is about preventing harm and enabling adults at risk to maintain control over their lives. Abuse and neglect can have devastating consequences, so safeguarding is a fundamental priority in our care delivery. We recognise that effective safeguarding is essential to providing high-quality care and protecting the dignity and well-being of our service users.

{{org_field_name}} is fully committed to safeguarding adults at risk. We have a zero-tolerance approach to any form of abuse. All staff are expected to uphold this commitment and foster a culture where the safety and human rights of clients are paramount. As the Care Quality Commission (CQC) states, “Safeguarding is everybody’s business.”​

Each member of our team has a responsibility to act on any concerns to protect adults in our care. We will work proactively to prevent abuse, and respond decisively to any safeguarding issues, in line with our legal and moral obligations.

This policy also evidences how we meet the CQC Single Assessment Framework quality statements under Safe (S1, S3) and Well-led (W3, W4) by preventing, identifying, and responding to abuse; learning from incidents; and maintaining open, accountable leadership.

Safeguarding governance and oversight


Overall accountability for safeguarding sits with the board-level equivalent (the Nominated Individual/Director) of {{org_field_name}}. They receive regular assurance reports from the Registered Manager on incidents, themes, training compliance and the effectiveness of systems to prevent and investigate abuse. The Registered Manager is responsible for day-to-day implementation. This ensures robust oversight in line with Regulation 13(1).

2. Scope and Purpose

Scope: This policy applies to all personnel of {{org_field_name}}. That includes full-time and part-time employees, care workers, agency or temporary staff, contractors, volunteers, and anyone else working on behalf of the company. It covers all interactions with adults at risk in the context of the services we provide (domiciliary care in clients’ own homes). Everyone must follow this policy and the related procedures, regardless of role or seniority. We also expect our partners or subcontractors to adhere to equivalent safeguarding standards. The policy is focused on safeguarding adults at risk – i.e. adults who have care and support needs, who may be unable to protect themselves from abuse or neglect (as defined below).

Purpose: The purpose of this policy is to ensure that {{org_field_name}} meets its responsibilities for safeguarding adults as required by law and best practice. It provides a clear framework for preventing and responding to abuse or neglect of adults at risk. By following this policy, all staff will know how to recognise signs of abuse, report concerns appropriately, and take action to keep people safe. The policy is written in accordance with the Care Act 2014 and its statutory guidance, which provides the legal framework for adult safeguarding in England. It also reflects the requirements of our regulator, the Care Quality Commission (CQC), and the standards they expect from care providers. Furthermore, this policy is aligned with the local authority’s safeguarding adult guidelines for {{org_field_local_authority_authority_name}}. We will adhere to the multi-agency safeguarding procedures of the local Safeguarding Adults Board and cooperate fully with the local authority, which is the lead agency for adult safeguarding​. In summary, this policy aims to ensure that {{org_field_name}} provides safe, high-quality care, protects adults from harm, and complies with all relevant legal and regulatory obligations.

How to Contact the Local Authority Safeguarding Adults Team

Authority: {{org_field_local_authority_authority_name}}
Online portal/info: {{org_field_local_authority_information_link}}
Telephone (working hours): {{org_field_local_authority_phone_number}}
Email (if used by LA): {{org_field_local_authority_authority_email}}
Staff must use the LA online portal where required and follow any locality-specific referral forms. Record the referral reference in the person’s record and notify the Registered Manager.

Safeguarding duties apply regardless of who funds the care (local authority, NHS, direct payments, or self-funding). Our duties extend to adults with care and support needs whom we encounter in the course of our work, whether or not we provide a regulated activity at the time.

3. Definitions and Types of Abuse

Safeguarding: In this context, safeguarding refers to all steps taken to protect an adult’s health, wellbeing and rights, enabling them to live free from abuse and neglect​. It is both proactive (preventing abuse before it occurs) and reactive (taking action when concerns arise). Safeguarding is not just about responding to incidents, but also about promoting the person’s welfare, respecting their wishes, and ensuring they receive care in a safe, person-centered manner. It involves individuals and organisations working together to prevent and stop the risk of harm, while also making sure to empower adults to make their own choices (often referred to as Making Safeguarding Personal).

Adult at Risk: An “adult at risk” (sometimes called a vulnerable adult) is a person aged 18 or over who has needs for care and support (whether or not those needs are being met), is experiencing or is at risk of abuse or neglect, and due to their care and support needs is unable to protect themselves from that abuse or neglect​. This definition comes from the Care Act 2014. Adults at risk may include, for example, older people with frailty or dementia, people with physical or learning disabilities, people with mental health needs, or anyone who depends on others for care and is therefore potentially vulnerable to exploitation or harm. In our service, most clients would be considered adults at risk due to their care needs. Safeguarding duties under this policy apply to any such adult who we encounter through our work.

Abuse: Abuse is a violation of an individual’s human or civil rights by another person or persons​. It can consist of single or repeated acts. Abuse might be deliberate, or the result of neglectful care or ignorance. Importantly, abuse can occur in any relationship and often involves an imbalance of power. It can be perpetrated by anyone: family members, professional caregivers, friends, strangers, or even other service users. The Department of Health defines abuse as “a violation of an individual’s human and civil rights by another person or persons.”​

Abuse can take many different forms, as described below. Neglect is a related concept, meaning the failure to meet an adult’s basic needs or to protect them from harm. Whether an act is intentional or unintentional, if it harms or risks harming an adult, it may be considered abuse or neglect. All forms of abuse are unacceptable and inexcusable.

Types of Abuse: Under the Care Act 2014 statutory guidance, abuse and neglect can take many forms​. The main categories of abuse we recognise (including those explicitly referenced in law and guidance) include the following:

Controlling or coercive behaviour is a criminal offence, including post-separation abuse; staff must treat disclosures seriously and follow the reporting flow.

Online / Technology-facilitated abuse: Bullying, harassment, stalking, grooming, scams, fraud, or the non-consensual creation/sharing of intimate images via phones, email, messaging or social media. These behaviours often sit within other categories (e.g., psychological, sexual, or financial abuse) but are called out here due to rising prevalence.

Abuse that is carried out via technology and online means. This can include cyber-bullying, online harassment, stalking or exploitation through social media, email or messaging, or the sharing of intimate images without consent. With increasing use of the internet and devices, adults at risk may be targeted by scammers or bullies remotely. Cyber abuse can lead to psychological harm, financial loss (e.g., through online scams), or exploitation. It is often linked to other forms of abuse (for example, an abuser may send threatening messages as part of psychological abuse, or groom someone online for sexual or financial exploitation). Staff should be aware of the risks clients might face via phones, computers, or other devices, and report any concerns (such as a client receiving abusive messages or being defrauded online). Education on safe internet use may be part of prevention. Note: While cyber abuse is not a separate category in the Care Act guidance, we highlight it as an emerging form of harm that staff should be vigilant about.

Note on Patterns and Intent: Abuse can consist of a single act or a repeated pattern over time. It can occur in the person’s own home, in the community, or online. Also, abuse may not always be obvious – it can be subtle or hidden. All staff should stay alert to indicators of possible abuse or neglect, such as unexplained injuries, sudden changes in behavior, withdrawn or fearful demean or, unexplained financial problems, poor living conditions, etc. Remember that abuse is abuse, regardless of whether the person appears to accept it or whether there is intent to harm. The severity or extent of abuse is less important than getting help for the person. Whenever in doubt, it is better to err on the side of caution and report a concern.

No degrading treatment
{{org_field_name}} prohibits any care or treatment that could reasonably be viewed as degrading. Examples include (not exhaustive): leaving a person in soiled clothing or on the toilet without prompt assistance or a way to call; leaving a person undressed or inadequately covered; ridiculing, belittling, or requiring demeaning tasks; or failing to provide necessary help or equipment for continence and personal care. Any report or observation of degrading treatment will be treated as a safeguarding concern and escalated without delay.

Recognising Indicators of Abuse
Staff must be alert to common indicators, including (but not limited to): unexplained injuries or frequent falls; fearfulness, withdrawal, or changes in mood/behaviour; poor hygiene, malnutrition or dehydration; missing medication or repeated errors; sudden changes in finances, unpaid bills, or missing belongings; controlling third parties speaking on someone’s behalf; signs of self-neglect or hoarding; evidence of online scams or threatening messages. Where any indicator is observed, follow the reporting flow immediately. Document facts and observations only, using the person’s words where possible.

Safeguarding Principles, Consent and Information Sharing

We act in line with the six safeguarding principles: Empowerment, Prevention, Proportionality, Protection, Partnership, and Accountability. We follow Making Safeguarding Personal (MSP) by agreeing desired outcomes with the person wherever possible.
We seek consent before sharing information unless doing so would place the person or others at risk, a serious crime is suspected, or there is a legal/public-interest justification. Where a person lacks capacity for the specific decision, we act under the Mental Capacity Act 2005, involve those lawfully acting on their behalf, and offer independent advocacy where required. All decisions and rationales are recorded clearly.

No unlawful discrimination
Care or treatment will never be delivered in a way that discriminates against a person on any protected characteristic under the Equality Act 2010 (age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, sexual orientation). Allegations or indicators of discriminatory practice will be investigated and, where substantiated, corrective action will be taken to prevent recurrence. This includes supporting the person to raise concerns and ensuring they are not victimised for doing so.

4. Roles and Responsibilities

Safeguarding adults is a shared responsibility. Every member of staff at {{org_field_name}} has a duty to act if they suspect an adult is at risk of abuse. This section outlines the general responsibilities of all staff, as well as specific roles for key individuals in our company’s safeguarding structure. We have designated leads to ensure there is always someone accountable and available to manage safeguarding issues. However, this does not reduce the obligation on each staff member to be vigilant and proactive in protecting people from harm.

Safeguarding Lead – {{org_field_safeguarding_lead_name}}
{{org_field_nominated_individual_email}}> | Phone: {{org_field_nominated_individual_phone}} | Out of hours: {{out_of_hours}}

The Safeguarding Lead maintains an up-to-date contact sheet for internal and external safeguarding escalation, including on-call/out-of-hours numbers, and ensures all staff can access it at point of care (paper and digital copies).

Allegations Against Senior Management
If a safeguarding concern involves the Registered Manager or there is a conflict of interest, staff must report directly to the Nominated Individual ({{org_field_nominated_individual_first_name}} {{org_field_nominated_individual_last_name}}; Email: {{org_field_nominated_individual_email}} Phone: {{org_field_nominated_individual_phone}})
We will:
• Refer immediately to {{org_field_local_authority_authority_name}} Adults Safeguarding via {{org_field_local_authority_information_link}}, and notify police/CQC as required.
• Assign an impartial investigating manager who is not implicated and has no line-management conflict.
• Protect whistleblowers and witnesses; no detriment for raising concerns in good faith.
• Record and disclose conflicts of interest and, where required, commission an independent investigation.
Staff may always escalate directly to the local authority, police (999/101) or CQC if internal routes are compromised.

All Staff (Employees, Volunteers, Contractors)

Responsibilities of all staff: All staff and volunteers at {{org_field_name}} are responsible for upholding safe practices and reporting any concerns. In particular, every staff member must:

By following these responsibilities, staff help ensure that “people using services are safeguarded” at all times​. Remember, failing to report or ignoring abuse is a serious breach of this policy and could lead to disciplinary action, as well as leaving an individual at risk of harm.

Registered Manager – {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}

Email: {{org_field_registered_manager_email}}

Phone: {{org_field_registered_manager_phone}})

The Registered Manager holds overall accountability for safeguarding within {{org_field_name}}. {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}} is the named Registered Manager for our service, and can be contacted at {{org_field_registered_manager_phone}} or {{org_field_registered_manager_email}} for any safeguarding issues. The Registered Manager’s key safeguarding responsibilities include:

In summary, the Registered Manager is accountable for ensuring that {{org_field_name}} meets its safeguarding responsibilities. {{org_field_registered_manager_first_name}} will be the one to answer to regulators or adult safeguarding boards about how we protect people from abuse. Therefore, {{org_field_registered_manager_first_name}} will always prioritise any safeguarding concern and use the full resources of the company to address it effectively.

Nominated Individual — {{org_field_nominated_individual_first_name}} {{org_field_nominated_individual_last_name}}

The Nominated Individual provides board-level oversight of safeguarding, ensures adequate resources (training, supervision, safe recruitment), reviews themes and learning from incidents, and assures timely statutory notifications and DBS referrals. The Nominated Individual acts where there is any conflict of interest involving the Registered Manager.
Contact: {{org_field_nominated_individual_email}} | {{org_field_nominated_individual_phone}}

Safeguarding Lead – {{org_field_safeguarding_lead_name}}, {{org_field_safeguarding_lead_role}}

{{org_field_name}} has appointed {{org_field_safeguarding_lead_name}} as the Safeguarding Lead, who serves as a dedicated point of expertise and coordination for safeguarding matters. The Safeguarding Lead’s role is to support the team in all aspects of adult safeguarding. Key responsibilities of the Safeguarding Lead include:

The Safeguarding Lead role is essentially about focus – having someone whose primary focus is adult protection ensures that this critical area does not get lost among other operational demands. {{org_field_safeguarding_lead_name}}, in the role of {{org_field_safeguarding_lead_role}}, will collaborate closely with {{org_field_registered_manager_first_name}} to ensure every safeguarding issue is handled effectively. Both the Registered Manager and Safeguarding Lead can be contacted directly by any staff member or service user/family member regarding safeguarding problems.

If at any time you are unsure whom to contact internally, remember: report it to any senior person available. The important thing is not to delay. The above roles are designated for clear responsibility, but in an emergency, any staff member should act to get help — for example, calling emergency services or the local authority — and then inform management as soon as possible.

5. Reporting Concerns

Quick Reporting Flow (all staff)

  1. Immediate danger? Call 999 (police/ambulance). Ensure safety.
  2. Tell the Registered Manager ({{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}} – {{org_field_registered_manager_phone}} / {{org_field_registered_manager_email}}) or the Safeguarding Lead ({{org_field_safeguarding_lead_name}} – {{out_of_hours}} for OOH).
  3. Record facts promptly on the safeguarding/incident form; preserve evidence.
  4. External referral: Manager/Lead reports to {{org_field_local_authority_authority_name}} ({{org_field_local_authority_information_link}}) immediately; police/CQC notified where required.
  5. Support the person and follow protection plan; keep records updated.



If you have a safeguarding concern, you must report it immediately. Early reporting can save lives and prevent further harm. This section explains how staff should raise concerns within {{org_field_name}} and to external agencies. All employees are expected to be familiar with these procedures through training and this policy. We encourage a “speak up” culture: no matter how small a concern might seem, report it. The company will support those who raise concerns and ensure they are addressed appropriately.

Internal Reporting (Within {{org_field_name}})

  1. Ensure Immediate Safety: If the person is in immediate danger or needs urgent medical attention, address this first. For example, if you believe a crime is in progress or someone is at risk of imminent harm, call 999 for emergency services without delay. Similarly, if urgent medical care is required (e.g., the person is injured), call an ambulance. Once emergency actions are taken, you should then proceed with reporting the incident internally. Do not place yourself in harm’s way; call professionals if the situation is dangerous. Removing the adult from immediate danger and securing the situation is the top priority.
  2. Report to Management Without Delay: As soon as it is safe and feasible, inform the Registered Manager or Safeguarding Lead about the concern. Time can be critical in safeguarding, so do not wait until the end of a shift or the next day – report it immediately (even if it’s after hours, contact the on-call manager or Safeguarding Lead).

Out of hours number: {{out_of_hours}}

You may report verbally (in person or via phone) and follow up in writing. Provide as much detail as possible about what you observed or what was disclosed. If the concern involves an allegation against a staff member, and that person is your line manager, you should go directly to the Safeguarding Lead or another senior manager to report (bypassing the usual line management if necessary). You can contact {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}} at {{org_field_registered_manager_phone}} / {{org_field_registered_manager_email}}, or {{org_field_safeguarding_lead_name}} (Safeguarding Lead) at any time. Ensure the words “safeguarding” or “adult protection” are made clear so the urgency is understood.

  1. Provide Information and Record the Details: Be prepared to share all relevant information you have: who is involved (the adult at risk, the person alleged to have caused harm, any witnesses), what exactly happened or what was observed, when and where it occurred, and any immediate actions taken. Stick to the facts as you know them. As soon as possible (ideally immediately after notifying management), write down a factual account of the concern. Use the company’s Safeguarding/Incident Reporting Form if available, or otherwise write a report including dates, times, names, and a description of events or disclosures in the person’s own words. Do not delay reporting to write the report – you can jot down brief notes if needed and then fill in details after you’ve informed the Manager/Lead. Submit your written report to the Manager/Lead for safekeeping. This documentation is important for any investigation.
  2. Preserve Evidence (if applicable): In cases of alleged abuse, there might be physical evidence (for example, bedding or clothing in a sexual assault, financial records in a financial abuse case, emails or texts in cyber abuse). Do your best to preserve any evidence and do not disturb or clean up anything that might be relevant. For instance, do not tidy the environment or wash clothes if you suspect they might contain evidence of a crime. If the abuse is physical or sexual, try to ensure the person does not wash or change clothing until medical examination (if they are amenable and it’s safe). For financial concerns, save documents or screenshots. Your goal is to leave things as they are until professionals can review them. Mention to the Manager/Safeguarding Lead what evidence might exist. They will guide on next steps (and police can advise on evidence preservation if contacted).
  3. Maintain Confidentiality: It is crucial to keep the matter confidential and only discuss it with those who need to know. After reporting to the Manager/Safeguarding Lead, do not share information about the incident with other colleagues or anyone outside the organisation unless authorised. Gossip or unauthorised disclosure can compromise investigations and the privacy of those involved. You can reassure the adult who is the subject of concern that you have reported it to the right people and it will be addressed, but do not promise them secrecy (explain you have to tell those who can help). Likewise, if a colleague or another person asks about the situation, politely say you cannot discuss it. All media or external inquiries should be referred to the Registered Manager. Internally, the Manager/Safeguarding Lead will coordinate who else (if anyone) should be informed.
  4. Follow Manager’s Instructions and Continue Support: Once you have reported, management will take charge of the response. Follow any instructions given by the Registered Manager or Safeguarding Lead. They may ask you for additional information, or ask you to not confront the alleged abuser, etc. Cooperate fully. Continue to support and observe the adult at risk as appropriate – for example, if you are still on duty with them, ensure they are comfortable and safe while the next steps are initiated. If you feel the situation is not being addressed promptly, you should escalate the concern (see Whistleblowing below). But in most cases, your job after reporting is to support any ensuing process and care for the individual’s immediate needs.

Whistleblowing/Internal Escalation: If for any reason you feel that your report is not being taken seriously or appropriate action is not occurring, do not hesitate to escalate. This might mean reporting the concern to a higher level of management (if available) or using the whistleblowing route (contacting external authorities directly).

Our Whistleblowing Policy protects employees who raise concerns in good faith about malpractice, including failure to act on a safeguarding concern. We would rather you go around the normal process than stay silent. Remember that all staff have a duty to safeguard – if the normal chain of command fails, use another route. You will not be penalised for doing so. In fact, regulators expect providers to have effective whistleblowing procedures​, and CQC is receptive to receiving concerns from staff or the public if needed. (Contact details for CQC and the local authority are provided below.)

CQC: Call 03000 616161

Local Authority Adult Safeguarding Team: {{org_field_local_authority_authority_name}}.

Link to safeguarding team contact details or online reporting form: {{org_field_local_authority_information_link}}.

External Reporting and Key Contacts

Authority: {{org_field_local_authority_authority_name}}
Online portal/info: {{org_field_local_authority_information_link}}
Telephone (working hours): {{org_field_local_authority_phone_number}}
Email: {{org_field_local_authority_authority_email}}
Staff must use the LA online portal where required and follow any locality-specific referral forms. Record the referral reference in the person’s record and notify the Registered Manager.

While internal reporting is critical, there are times when concerns need to be raised with external agencies. In many cases, the Registered Manager will take responsibility for this. However, any person can directly report abuse to external authorities if they feel the situation warrants immediate outside intervention or if internal channels might be compromised. Under the Care Act, the local authority is the lead agency for adult safeguarding​, so most external reporting will involve the local authority’s Safeguarding Adults team. Below are the primary external contacts and guidelines:

We submit the current “Allegations of abuse (safeguarding)” statutory notification without delay via the CQC provider portal (or latest prescribed form) for any abuse or alleged abuse concerning a person using our service, including where police or other agencies are involved. We also assess whether the Duty of Candour applies and, where it does, we notify the person/representative, provide a truthful account, apologise, keep records of all communications, and follow up in writing.

When a safeguarding concern is reported externally, {{org_field_name}} will cooperate fully with all agencies. We will attend multi-agency meetings, provide information promptly, and take any interim actions advised (for example, suspending a staff member, increasing observation of a client, etc.). We will never obstruct or cover up information; transparency is essential. Information sharing will be done in line with agreed protocols – normally, confidential details can be shared with the safeguarding team under public interest exemptions in data protection law, as safeguarding an adult at risk is a legitimate reason to share personal data with authorities.

Whistleblowing Protection: To reiterate, if a staff member has reported internally and does not see appropriate action, or feels unable to do so, they should use whistleblowing channels. The law (Public Interest Disclosure Act 1998) protects whistleblowers from unfair treatment. Our Whistleblowing Policy provides guidance and assurance that you can raise concerns without fear. Even if you choose to report externally first, you should inform a senior person in the company as well (unless the allegation is about them), so we can also take action. Ultimately, the safety of the adult is the priority, and all else is secondary.

Accessibility of Safeguarding Reporting Processes

At {{org_field_name}}, we are committed to ensuring that safeguarding concerns can be reported by anyone connected to our service, at any time, and in a way that is accessible and easy to understand. Our reporting processes are designed to be open, inclusive, and clearly communicated to all staff, service users, advocates, those lawfully acting on behalf of service users, and family members or friends involved in their care.

We provide safeguarding information in accessible formats and make reasonable adjustments to meet communication needs; this includes large print, easy-read, translations, and assisted reporting.

How We Ensure Accessibility:

1. Information for Staff:
All staff receive comprehensive safeguarding training during their induction and regular refresher sessions. As part of this training, staff are given detailed instructions on the internal reporting procedures, including who to report concerns to, how to use our reporting forms, and what steps will follow. Copies of the safeguarding policy and reporting flowcharts are made available, both in paper and digital formats. The policy is also accessible in our office and on our policies and procedures platform, ensuring staff can access it at any time.

2. Information for Service Users and Those Close to Them:
We provide every service user, and where appropriate their families, advocates, or legal representatives, with a Service User Guide. This guide includes a clear, step-by-step explanation of how to report a safeguarding concern, including contact details for our Safeguarding Lead, the Local Authority Safeguarding Team, and the CQC. We ensure this information is provided in accessible formats—large print, easy-read, or alternative languages as needed—to meet individual communication needs. Our staff routinely remind service users and their representatives about these procedures during care reviews and meetings.

3. Support to Report Concerns:
We recognise that some individuals may feel anxious or unsure about raising concerns. Staff are trained to support service users and their advocates to express concerns, including offering private discussions and providing reassurance that they will be taken seriously and supported throughout the process. Advocates and those lawfully acting on behalf of service users are encouraged to raise concerns directly with our management team, and we never require concerns to be reported only through staff. Anonymous reporting is also available.

4. Prominent Display of Information:
Contact details for reporting safeguarding concerns, including those for the local authority and CQC, are displayed in our office and in the Service User guide. We also display a simple flowchart summarising the reporting process. This ensures that anyone entering the premises—service users, relatives, professionals—can see how to make a report.

5. Feedback and Assurance:
Whenever a safeguarding concern is raised, we ensure the individual raising it receives confirmation that their concern has been received and is being acted upon. We provide updates as appropriate, while respecting confidentiality.

In summary, act without delay when reporting concerns. Internally, notify the Manager or Safeguarding Lead immediately. Externally, ensure the local authority (and police if needed) are informed quickly – the Registered Manager will do this, but if they are unavailable or the response is lacking, you have a right to contact them yourself. By following these reporting steps, you play a vital part in protecting individuals from harm and triggering the multi-agency response designed to safeguard adults at risk.

Key safeguarding contacts
• Registered Manager: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}} — {{org_field_registered_manager_phone}} / {{org_field_registered_manager_email}}
• Safeguarding Lead: {{org_field_safeguarding_lead_name}}— / Out of Hours: {{out_of_hours}}
• Local Autority Adult Safeguarding ({{org_field_local_authority_authority_name}}): {{org_field_local_authority_phone_number}} / {{org_field_local_authority_authority_email}} / {{org_field_local_authority_information_link}}
• Police: 999 (emergency) / 101 (non-emergency)
• CQC Safeguarding Notifications: 03000 616161

6. Responding to Safeguarding Concerns

When a safeguarding concern is raised, {{org_field_name}} will respond promptly and systematically to protect the adult and address the issue. Our response will be guided by the local authority’s procedures and the principles of good safeguarding (such as ensuring safety, empowerment, proportionality, partnership, accountability, and prevention). The following outlines the steps we take after a concern has been reported, whether internally by a staff member or externally by someone else. The Registered Manager (or Safeguarding Lead) will coordinate these actions:

1. Immediate Action for Safety: Upon becoming aware of any allegation, indication or evidence of abuse, managers will initiate internal fact-finding and make external referrals immediately and without delay in line with local multi-agency procedures, documenting time-stamped actions. If this hasn’t already been done by the reporting staff, management will ensure it now. This might involve calling emergency services (if not already done), arranging medical care for injuries, or separating the adult from the person alleged to be causing harm. For example, if the alleged abuser is a staff member, we will remove them from any care duties (e.g. ask them to go home pending investigation) to prevent further contact. If the incident involves a potentially unsafe environment or equipment, we will take it out of use. The priority is to stop any further abuse or neglect and tend to the victim’s urgent needs (physical and emotional). We will also consider others – if one client is harmed by a staff member, could another client also be at risk from that staff member? We take any necessary actions to secure overall safety.

2. Notification and External Referral: The Registered Manager or Safeguarding Lead will quickly evaluate the information and decide whether the concern meets the criteria for external reporting (in most cases of suspected abuse or neglect it will). Following the reporting guidelines (section 5), we will notify the Local Authority Safeguarding Adults Team immediately. We provide them with a clear account of the concern, actions taken, and the current situation. This is often done by phone initially (especially if urgent), followed by a written referral (using the local authority’s safeguarding referral form or system) within the required timeframe. If not already done, we will also notify the police at this stage if a crime is suspected or alleged – usually the local authority and police coordinate, but we ensure law enforcement is aware as needed (particularly for serious physical assault, sexual abuse, theft/fraud, etc.). We will consult the local authority on informing the police if it hasn’t been done yet. Additionally, the Registered Manager will send a Notification to CQC about the safeguarding incident (via their online portal or email, as per CQC regulations) – this is typically done within 1-2 working days at most, or sooner for serious incidents. We document the date and time of all notifications.

3. Protecting and Supporting the Adult at Risk: Throughout the process, we focus on the well-being of the adult concerned. We will involve them as much as possible in decisions, respecting their autonomy. If the adult has capacity and expresses certain wishes (for example, they don’t want a particular person involved or they want a friend present), we will communicate these wishes to the safeguarding authorities and do what we can to honor them, consistent with safety. If the adult has difficulties in understanding or communicating, we will ensure they have appropriate support – such as an advocate. If they lack mental capacity to make decisions about their safety, we will make decisions in their best interests (following the Mental Capacity Act) and involve any Power of Attorney or family as appropriate. The adult will be treated with empathy and respect; we will reassure them that the matter is being handled and that they are not to blame. If they need medical attention or counseling, we facilitate that. We might arrange for a trusted relative or friend to be with them if they desire (unless that person is implicated). The key is that the person feels heard, safe, and supported during what can be a traumatic time.

Consent, Information-Sharing and Making Safeguarding Personal (MSP)
We seek the person’s consent before sharing information wherever safe and appropriate. If the person has capacity and refuses consent, we will respect this unless: others are at risk; a serious crime is suspected; or refusal places the person at imminent risk of serious harm. We will explain what will be shared, with whom and why. Where the person lacks capacity for the specific decision, we act under the Mental Capacity Act 2005 in the person’s best interests, involving those lawfully acting on their behalf and independent advocacy as required. In all cases we apply MSP: agree safeguarding outcomes with the person, review these throughout the enquiry, and record outcomes achieved.

4. Internal Fact-Finding (Without Compromising External Inquiry): While the local authority (and possibly police) have primary responsibility to investigate allegations of abuse, {{org_field_name}} also has a duty to gather initial information and secure evidence as a provider. The Registered Manager or Safeguarding Lead will conduct a preliminary fact-finding exercise: this can include obtaining statements from the staff who reported or witnessed the concern, reviewing relevant records (e.g., care notes, MAR charts, time sheets, etc.), and preserving any physical evidence as previously mentioned. However, this is done carefully so as not to interfere with any official investigation – for instance, we will not formally interview the alleged perpetrator or take any action that might alert them beyond removing them from duty, as the police may wish to handle such questioning. We coordinate with the local authority on what steps we can take internally. If the safeguarding team advises us to hold off on certain inquiries (to avoid contamination of evidence), we will comply. Our role is to provide information and make sure nothing is lost or forgotten. All information gathered is documented in a secure file.

Internal Actions Regarding Staff (if applicable): If the allegation involves a member of {{org_field_name}} staff or volunteer as the perpetrator, immediate management action is taken. The staff member in question will be suspended or reassigned to non-client duties pending the outcome of the investigation. This is not a disciplinary sanction nor a presumption of guilt – it is a precaution to protect all parties and ensure a fair investigation. They will be informed of the allegation in general terms (unless police advise to delay informing them) and that a safeguarding process is underway. We will follow our HR procedures for suspension (confirm in writing, on full pay if applicable, etc.). The staff member will be instructed not to contact the client or other staff about the matter. We maintain confidentiality about their identity to those not involved. If the allegation is substantiated, the Registered Manager will take appropriate disciplinary action, up to and including dismissal, and will refer the individual to the Disclosure and Barring Service (DBS) for barring consideration (this is a legal requirement for care providers when staff are fired or resign due to harming vulnerable adults). If the allegation is not substantiated or was malicious, we will support the staff member’s return and address any workplace issues that led to the allegation. In all cases, we treat accused staff fairly and according to policy, while keeping client safety paramount.

DBS referral: Where a staff member or volunteer has been dismissed, removed from regulated activity, or would have been removed had they not resigned, because they harmed or posed a risk of harm to an adult, {{org_field_name}} has a legal duty to refer the individual to the Disclosure and Barring Service (DBS). The Registered Manager (or Nominated Individual) will make the referral and retain evidence of submission.

6. Cooperation with the Safeguarding Enquiry: Once the local authority takes on the case, they may initiate a formal Safeguarding Adults Enquiry (under Section 42 of the Care Act). {{org_field_name}} (through the Registered Manager or Safeguarding Lead) will work in partnership with the authorities. This means attending any multi-agency meetings (such as strategy meetings or case conferences) to share information and plan actions. We will provide a written report if requested, detailing our involvement and knowledge of the situation. If the Safeguarding team creates a protection plan (actions to ensure the person’s safety during and after the enquiry), we will implement all parts of that plan that fall to our service – for example, assigning only certain experienced staff to care for the person, or increasing visit frequency, or installing assistive technology. We will keep the Safeguarding Lead updated on progress and any further incidents. Additionally, if family members or others need to be contacted as part of the enquiry, we coordinate that with the social worker (we usually let the social services handle informing next-of-kin unless agreed otherwise). Essentially, we follow the lead of the multi-agency process, doing what is asked of us promptly and thoroughly. We acknowledge that the local authority may make findings and recommendations at the end of the enquiry, which we will accept and act upon.

6a. Our Approach to Restraint & Restrictive Practices
{{org_field_name}} does not use restraint as a routine part of care. Any restrictive practice (including physical restraint, chemical restraint/PRN for behaviour control, mechanical restraint, seclusion or long-term segregation, and blanket rules) is exceptional, time-limited, and used only when:
• there is an immediate risk of harm to the person or others;
• actions are necessary, proportionate and the least restrictive option; and
• actions are in line with the Mental Capacity Act 2005 (including best-interests decisions where the person lacks capacity for the specific decision).
Before use: consider de-escalation, environmental and relational strategies. During use: keep the person’s dignity and human rights central; use only staff who are trained and competent for the technique; continuously review and stop as soon as the risk reduces. After use: provide support/debrief to the person and staff; record: rationale, type/duration, staff involved, injuries, views of the person/representative, alternatives tried, and review actions. Report incidents internally and, where applicable, to {{org_field_local_authority_authority_name}}, CQC and/or police; update risk assessments and care plans to reduce future use.
We do not use seclusion/long-term segregation in domiciliary settings. Covert medication for behavioural control will not be used unless authorised via MCA best-interests decision-making with pharmacy/GP input and regular review. We operate a restrictive-practice reduction plan, review PRN protocols at least 3-monthly, and audit all incidents to drive down use over time.

We analyse every incident to reduce future use of restrictions, report patterns through governance, and evidence improvement against CQC’s quality statements for safety and learning.

Training, competence and review of restrictive practices
All staff receive role-appropriate training at induction and regular refreshers on recognising, preventing and (where unavoidable) safely applying any restrictive practice, consistent with current national guidance and good practice. Only staff trained and deemed competent may use any approved technique. Use of restrictions is monitored via incident review, trend analysis and governance reporting, with actions taken to reduce and, where possible, eliminate use over time.

7. Recording and Confidentiality: Throughout the response, we maintain a clear safeguarding record. The Registered Manager or Safeguarding Lead will maintain a file (physical and/or electronic) that includes: the initial report, any witness statements or reports, records of phone calls (dates/times and summaries of conversations with external agencies), emails or forms sent, meeting minutes, risk assessments, protection plans, and outcomes/resolutions. Every action we take is logged with date and person responsible. These records are kept confidentially – separate from general care records, with restricted access. Only those directly involved in managing the incident (Registered Manager, Safeguarding Lead, possibly a Director or HR for staff issues) and the authorities will have access. Within the service, staff will be informed of updates strictly on a need-to-know basis (for example, the person’s direct caregivers might be briefed that certain precautions are in place, without necessarily knowing all details). All documentation will eventually contribute to any official report required. We recognise that such records may be inspected by CQC or used in legal proceedings, so we ensure they are accurate, timely, and objective. We also respect the privacy of the individuals involved – information is shared internally or externally only for the purpose of protection and investigation. (Relevant internal sharing might include informing the Care Coordinator to adjust the staff rota, etc., without exposing unnecessary details.)

8. Supporting Staff and Others: A safeguarding incident can be stressful for everyone involved. {{org_field_name}} will provide appropriate support. For the adult at risk, as mentioned, we ensure they have emotional support – perhaps a trusted staff member or advocate to talk to, and access to professional counseling if needed. We check in on them regularly to see if they feel safe and if the measures are helping. For the staff member who raised the concern, we reassure them that they did the right thing and encourage them to share any further observations. We offer them support too – for instance, if they are upset by witnessing something, we might offer counseling or time off as needed. We want to encourage a learning culture, so we might debrief with them (management will explain what steps are being taken so they aren’t left anxious). For the staff member who is accused (if applicable), we make sure they understand the process and that they can contact a union or representative. They will have an opportunity to respond to allegations at the appropriate time, and we ensure the process is as transparent as possible. We also consider other clients – if the incident could impact others (say multiple clients cared for by the same worker), we might need to talk to those clients or their families to check if they have any concerns. This will be guided by the safeguarding team’s advice. If the media or other outside parties become aware, we refer to our media policy (not addressed here, but in principle we protect confidentiality and refer enquiries to a senior manager).

9. Outcome and Follow-Up: After the investigation/enquiry, there will be an outcome. The local authority will usually determine whether the allegation was substantiated, inconclusive, or not substantiated (or malicious). Whatever the outcome, {{org_field_name}} conducts an internal review of the case to see what lessons can be learned. If the abuse was substantiated, we ensure any corrective actions are fully carried out: e.g., HR actions on staff, updating the person’s care plan, repairing relationships, providing additional support or compensation if needed, etc. If policies or risk assessments need changes, we do that. If the incident was not substantiated, we still consider whether our staff acted correctly and whether any improvements in practices could prevent misunderstandings. We communicate with the adult at risk (and their representative/family as appropriate) about the outcome in a sensitive manner, making sure they understand what will happen next. We also inform the staff who reported and others in the loop about the case closure, thanking them for their vigilance. CQC notifications are updated with outcomes if required. The Registered Manager will compile a final report on the incident for internal records, and possibly share a summary with higher management or trustees to keep them informed of safeguarding issues in the service.

10. Preventing Recurrence: As part of our follow-up, we focus on prevention of future incidents. This may involve additional training for staff involved or the whole team, tightening of certain procedures, or increased supervision/monitoring in certain areas. For example, if an incident revealed that a staff member was stressed and that contributed to unprofessional behavior, we might enhance our staff support and supervision systems. Or if a particular client was targeted due to isolation, we work on ways to keep them more engaged and observed. We treat every safeguarding case as an opportunity to improve our service and reduce the chance of harm in the future. These preventive actions are recorded in our continuous improvement or action plan and monitored by the Registered Manager for completion.

Throughout all these steps, we adhere to key safeguarding principles: we empower the adult (taking their views into account), we act to prevent further harm, we respond in a proportionate way (least intrusive, but ensuring safety), we seek to protect those in need, we work in partnership with families and professionals, and we maintain clear accountability for our actions. Our actions will always be person-centered, considering the uniqueness of the situation and the individual’s needs and rights.

If at any stage a staff member is unsure what to do, they should consult the Registered Manager or Safeguarding Lead. It is better to ask and clarify than to make a mistake in a safeguarding situation. Also, staff should feel free to suggest ideas to support the person or improve our response – frontline input is valuable.

Finally, know that reporting a concern is just the beginning – {{org_field_name}} is committed to seeing each case through to resolution and doing everything in our power to achieve a good outcome for the adult at risk. We do not close a case until the risks are managed and the person is as safe as possible. Safeguarding is an ongoing process of learning and improvement.

7. Training and Awareness

Training is mandatory for all members of staff to ensure they are competent and confident in safeguarding adults. {{org_field_name}} invests in regular training and continuous awareness activities because we recognize that knowledgeable staff are key to preventing and detecting abuse. Our commitments regarding training and awareness are as follows:

In conclusion, all staff are well-trained and aware of safeguarding procedures and expectations. Training helps ensure that abuse is recognised early and handled correctly. We remain committed to keeping our knowledge current – if guidelines or laws change (e.g., a new category of abuse or new local protocols), we will update our training materials accordingly. Each staff member is responsible for applying their training in practice and seeking clarity when needed. Safeguarding is a skill set that we continually hone through education, reflection, and experience.

8. Preventative Measures

Preventing abuse or neglect from occurring in the first place is a core part of our safeguarding strategy. {{org_field_name}} is committed to creating an environment and culture where the risk of abuse is minimized and where any potential issues are caught early. We implement a range of preventative measures, including:

All these measures together create a robust safeguarding framework aimed at prevention. While no system can remove all risk, we strive to make abuse or neglect as unlikely as possible in our service. Everyone at {{org_field_name}} should focus not just on reacting to abuse, but on preventing it – by providing excellent care, staying alert, and creating a supportive environment. Through safe recruitment, good training, supportive management, and a caring culture, we minimise opportunities for abuse to occur​. Should any issues start to emerge, our early warning systems (like open communication and monitoring) will hopefully catch them quickly, allowing us to intervene before harm is done. Safeguarding is woven into everything we do, from HR practices to daily care routines.

Blanket Rules: We avoid blanket restrictions. Any house-wide or service-wide rule that limits people’s rights (for example, locking fridges/medication cupboards accessible to people, fixed bedtimes, limiting visitors) requires a written risk assessment, individual consent/capacity consideration, and manager approval, and must be reviewed to ensure it remains the least restrictive option.


Identifying and Authorising Deprivations of Liberty in the Community

Where care arrangements in non-hospital, non-care-home settings (e.g., a person’s own home or supported living) amount to continuous supervision/control and the person is not free to leave, we:

  1. escalate immediately to the Registered Manager/Safeguarding Lead to review and reduce restrictions;
  2. if the person has capacity, obtain informed consent and review regularly;
  3. if the person lacks capacity, we seek Court of Protection authorisation under the Mental Capacity Act 2005 (as the Liberty Protection Safeguards are not yet commenced at the time of this policy); and
  4. work with commissioners and {{org_field_local_authority_authority_name}} to monitor restrictions and ensure timely reviews.
    We record capacity assessments, best-interests decisions, advocacy offered, rationales for restrictions, and legal authorisations. We will update this section when/if LPS is commenced by government.

9. Links to Other Policies

Safeguarding does not stand alone – it is closely related to other policies and procedures within {{org_field_name}}. To ensure a comprehensive approach, this Safeguarding Adults Policy should be read and understood in conjunction with the following policies:

(Note: If the actual policy documents are separate, staff should ensure they read them. The above links are summarized for coherence. In practice, these policies work together: e.g., a staff member concerned about a colleague’s behavior might use the Whistleblowing Policy to report it externally if needed; a client complaining of theft triggers both the Complaints and Safeguarding procedures; a client with dementia refusing care leads us to the Mental Capacity Policy to decide how to act in their best interest and safeguard them.)

All staff must be familiar with these related policies because effective safeguarding may require invoking them. For example, a safeguarding incident may arise from a complaint, require a mental capacity assessment, and lead to a whistleblowing disclosure – all at once. Consistency across policies is maintained; they all reinforce the message that the welfare and rights of adults at risk are paramount.

We also have other relevant documents, such as Health and Safety Policy (to prevent avoidable harm), Disciplinary Policy (to deal with staff misconduct that could include abuse), and Equality and Diversity Policy (to combat discriminatory attitudes) – all of which indirectly support safeguarding aims. By maintaining a strong policy framework, we create multiple layers of defense against abuse. Staff should always consider these policies in conjunction – if unsure, seek guidance from a manager.

In summary, safeguarding adults is not just about one policy – it is embedded in many aspects of our operations. The Whistleblowing, Complaints, and Mental Capacity policies in particular are critical companions to this Safeguarding Adults Policy. They provide additional tools and guidance to ensure concerns are raised, individuals are heard, and people who may not be able to protect themselves are given the protection they need.

10. Review and Monitoring

To keep this policy effective and up-to-date, {{org_field_name}} will ensure it is regularly reviewed and monitored. Safeguarding is a dynamic area, influenced by changes in law, guidance, and learning from cases; thus, our policy must evolve accordingly. The following outlines our approach to reviewing and monitoring the Safeguarding Adults Policy:

After the review process, the policy will have a new review date set (usually one year ahead unless changes dictate sooner). We clearly log the last review date and next review due date.

Accountability: The Registered Manager will report on safeguarding to the organisation’s leadership (owners or board) periodically, including whether the policy is up to date and how safeguarding is being managed generally. This creates accountability at the highest level. Safeguarding is often a standing agenda item in management meetings, ensuring it gets regular attention.

By diligently reviewing and monitoring this policy, we ensure it remains a living document that truly guides best practice. It’s not just a file on a shelf – it’s reviewed, discussed, and improved as needed. Staff can be confident that the procedures they are following are the latest and best. Moreover, regular review demonstrates to regulators and partners that we take safeguarding governance seriously.

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.

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