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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Safeguarding Adults from Abuse and Improper Treatment Policy

1. Purpose

The purpose of this policy is to ensure that all staff within {{org_field_name}} understand their responsibilities in safeguarding adults from abuse and improper treatment. This policy provides clear guidance on recognising, reporting, and managing safeguarding concerns while ensuring compliance with Care Inspectorate Wales (CIW) regulations, the Social Services and Well-being (Wales) Act 2014, and the Regulation and Inspection of Social Care (Wales) Act 2016.

2. Scope

This policy applies to all staff, including management, care workers, volunteers, and external contractors engaged in delivering domiciliary care services. It extends to all adults receiving care and support from {{org_field_name}}, particularly those who may be at risk of harm due to disability, age, illness, or other vulnerabilities.

3. Legal and Regulatory Framework

This policy is developed in accordance with:

• Social Services and Well-being (Wales) Act 2014
• Regulation and Inspection of Social Care (Wales) Act 2016
• The Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017
• CIW Safeguarding Policy (2023)
• Wales Safeguarding Procedures

It is essential that all staff understand and comply with these legal and regulatory requirements, as failure to do so could result in serious consequences, including legal action against both individuals and the organisation. Ongoing training and updates will be provided to ensure that staff remain informed of any changes in legislation.

4. Definitions

4.1 Abuse

Abuse can be intentional or unintentional and may result from actions, failures to act, or systemic neglect. The different forms of abuse include but are not limited to:

• Physical abuse: Assault, hitting, slapping, pushing, inappropriate restraint, or misuse of medication.
• Emotional/Psychological abuse: Intimidation, threats, humiliation, controlling behaviour, coercion, and social isolation.
• Financial abuse: Theft, fraud, coercion in relation to financial matters, scams, or misappropriation of benefits.
• Neglect: Failure to provide adequate care, nutrition, hygiene, emotional support, or medical attention.
• Sexual abuse: Any non-consensual sexual activity, exposure to sexually inappropriate materials, grooming, or forced participation.
• Institutional abuse: Rigid routines, inadequate staffing, lack of personal choice, or poor professional practices in a care setting.

4.2 Adults at Risk

An adult at risk is someone who:

• Is experiencing or is at risk of abuse or neglect.
• Has needs for care and support.
• Is unable to protect themselves from abuse or neglect due to their circumstances.

This definition requires staff to remain vigilant at all times and take prompt action when concerns arise.

5. Responsibilities

5.1 Management Responsibilities

• Designated Safeguarding Lead (DSL): Management must appoint a designated safeguarding lead responsible for overseeing safeguarding measures, ensuring staff compliance, and acting as the main point of contact for safeguarding concerns.
• Training and Competency Checks: Regular training and competency checks must be conducted to ensure staff understand their safeguarding obligations.
• Clear Procedures and Policies: Policies must be regularly reviewed and updated to reflect changes in law and best practices.
• Reporting and Documentation: All safeguarding incidents must be logged, and records securely maintained to support investigations and regulatory compliance.

5.2 Staff Responsibilities

• Recognising and Reporting: Staff must be able to recognise different forms of abuse and report any suspicions immediately.
• Maintaining Professionalism: All care must be provided in a manner that upholds dignity, choice, and respect.
• Following Procedures: Staff must adhere to reporting procedures and cooperate fully in any safeguarding investigations.
• Participating in Ongoing Training: Regular attendance in safeguarding training is mandatory to keep up-to-date with current best practices and legal requirements.

6. Recognising and Reporting Abuse

6.1 Recognising Signs of Abuse

All staff must remain vigilant in identifying abuse, which may include:

• Unexplained bruises, burns, or injuries.
• Changes in behaviour such as fearfulness, withdrawal, or aggression.
• Sudden financial difficulties, unpaid bills, or missing belongings.
• Poor hygiene, malnutrition, or untreated medical conditions.
• Increased isolation or avoidance of certain individuals.

6.2 Reporting Process

1. Immediate Action: If the individual is at immediate risk, call 999 or 112 and take necessary steps to ensure their safety.
2. Internal Reporting: Inform the Designated Safeguarding Lead (DSL) or Care Manager immediately.

1) Verbally

2) Inform the Registered Manager by email: {{org_field_registered_manager_email}}

3) Call the office and inform the Registered Manager or Designated Safeguarding Lead: {{org_field_phone_no}}

4) Out of hours phone number: {{out_of_hours}}

5) Online via our website: {{org_field_website}}

3. Documentation: Complete a safeguarding report with factual details of the incident.
4. External Reporting: The DSL will contact the Local Authority Safeguarding Team and CIW, ensuring legal compliance.
5. Investigation and Follow-up: Follow safeguarding procedures, ensuring that all necessary actions are taken to prevent further harm.

7. Safeguarding Training

• All staff, including volunteers, must complete safeguarding training as part of their induction and annually thereafter.
• Training should cover recognising abuse, reporting procedures, handling disclosures, and understanding legal responsibilities.
• Advanced training should be provided for managers and the DSL, ensuring in-depth knowledge of legislation and regulatory requirements.
• Records of training completion should be maintained and reviewed regularly.

8. Prevention Measures

Prevention is a fundamental aspect of safeguarding adults from abuse and improper treatment. At {{org_field_name}}, we adopt a proactive approach to preventing harm through robust policies, rigorous staff training, and a strong organisational culture that prioritises safety and well-being.

8.1 Recruitment and Employment

To ensure only suitable individuals are employed in roles with access to vulnerable adults, we implement:

• Enhanced Disclosure and Barring Service (DBS) Checks: All prospective employees must undergo a thorough background check before commencing employment.
• Comprehensive Reference Checks: A minimum of two professional references must be obtained and verified.
• Structured Interviews: Safeguarding-related scenarios are included in interviews to assess candidates’ understanding of protecting vulnerable adults.
• Probationary Periods: New employees undergo an assessment period where their conduct and adherence to safeguarding principles are closely monitored.
• Code of Conduct: Employees must sign and adhere to a strict professional code of conduct that emphasises safeguarding responsibilities.

8.2 Safeguarding Training and Awareness

Ongoing training ensures all staff are equipped to prevent and respond to safeguarding concerns effectively. This includes:

• Mandatory Induction Training: All staff receive safeguarding training as part of their induction.
• Annual Refresher Courses: Regular updates on safeguarding policies, legal changes, and best practices.
• Specialised Training: Additional modules on mental capacity, deprivation of liberty safeguards (DoLS), and handling disclosures.
• Scenario-Based Learning: Practical case studies and role-playing exercises to enhance real-world application.
• Supervision and Mentorship: Senior staff provide ongoing guidance to reinforce safeguarding knowledge.

8.3 Promoting a Safeguarding Culture

To embed a strong safeguarding ethos, we encourage:

• Open Communication: Staff and service users are encouraged to voice concerns without fear of reprisal.
• Whistleblowing Protection: Clear procedures for reporting concerns confidentially, with assurances of no retaliation.
• Regular Policy Reviews: Frequent evaluations of safeguarding policies to reflect legislative changes and best practices.
• Multi-Agency Collaboration: Working closely with safeguarding boards, local authorities, and healthcare professionals to enhance protective measures.
• Empowering Service Users: Providing individuals with knowledge and support to recognise and report abuse.

8.4 Monitoring and Quality Assurance

Regular monitoring mechanisms ensure safeguarding practices remain effective. These include:

• Routine Safeguarding Audits: Periodic evaluations of compliance with policies and regulations.
• Incident Reviews: Analysis of reported safeguarding concerns to identify patterns and areas for improvement.
• Staff Performance Reviews: Evaluating staff adherence to safeguarding responsibilities during appraisals.
• Feedback Mechanisms: Gathering input from service users, families, and external agencies to improve safeguarding measures.

By implementing these prevention measures, {{org_field_name}} aims to foster a safe, respectful, and protective environment where adults receiving care are safeguarded against abuse and improper treatment.

9. Responding to Allegations of Abuse

When an allegation of abuse is made, it is crucial that all staff and management at {{org_field_name}} follow a structured and immediate response to ensure the safety of the individual and compliance with legal obligations. The following steps outline the process:

Step 1: Ensure Immediate Safety

• If the person is in immediate danger, call 999 for emergency assistance.
• Remove the alleged victim from the source of harm if safe to do so.
• Provide immediate medical attention if necessary.
• Offer reassurance and support to the individual, ensuring they feel safe and heard.

Step 2: Report the Allegation

• The staff member who first becomes aware of the abuse must report the concern to the Designated Safeguarding Lead (DSL) or manager immediately.
• If the allegation is against a staff member, the Manager must be informed, and the accused may be suspended pending investigation to ensure safety.
• Maintain confidentiality and do not discuss the allegation with anyone outside the reporting structure.

Step 3: Record the Incident

• Document the allegation as soon as possible, ensuring that all details are factual and objective.
• Include:
  • Date, time, and location of the incident.
  • Names of individuals involved.
  • Description of what was observed or reported.
  • Any immediate actions taken.
  • Signature and date of the person making the report.
• Store records securely, ensuring compliance with GDPR and data protection laws.

Step 4: Escalate to External Authorities

• The Designated Safeguarding Lead (DSL) must contact the Local Authority Safeguarding Team as per local safeguarding procedures.
• Notify Care Inspectorate Wales (CIW) if the abuse involves service provision failures.
• In cases of criminal activity, report to the Police immediately.

Step 5: Internal Investigation and Cooperation

• The Manager will initiate an internal safeguarding review to assess the circumstances and determine any immediate changes needed in service provision.
• The accused staff member may be placed on suspension pending investigation.
• Full cooperation with external agencies, including providing necessary records and evidence.
• Conduct interviews with relevant parties while ensuring a fair and unbiased process.

Step 6: Support for the Victim and Staff

• Ensure the affected individual receives appropriate emotional and psychological support, including referrals to specialist services if needed.
• Keep the individual informed of the progress of the investigation where appropriate.
• Provide guidance and support to staff members who have reported abuse, ensuring protection under the Whistleblowing Policy.

Step 7: Implement Preventative Actions

• Review and strengthen safeguarding procedures to prevent future occurrences.
• Identify any failures in existing policies or training needs and address them promptly.
• Conduct refresher safeguarding training for staff if gaps are identified.
• Implement lessons learned and update policies accordingly.

Following this structured response ensures that {{org_field_name}} upholds its safeguarding responsibilities, maintains compliance with CIW regulations, and fosters a safe and transparent care environment.

10. Handling Allegations Against Staff

At {{org_field_name}}, we are committed to ensuring that all allegations of abuse against staff are treated with the utmost seriousness and managed effectively to safeguard individuals receiving care and to maintain the integrity of the service. The following steps outline the procedures that must be followed when an allegation is made against a staff member:

10.1 Immediate Action and Risk Management

• All allegations, whether verbal or written, must be reported immediately to the Designated Safeguarding Lead (DSL) or Manager.
• If the individual receiving care is in immediate danger, emergency services must be contacted (999 or 112).
• The Manager must conduct an initial risk assessment to determine if the accused staff member should be removed from duties.
• If the allegation is serious and poses a potential risk, the staff member must be immediately suspended on a neutral basis, pending further investigation. Suspension does not imply guilt but ensures a fair investigation can be carried out without interference.
• The service user’s well-being must be prioritised, and appropriate support provided, including a safeguarding plan if required.

10.2 Reporting the Allegation

• The Designated Safeguarding Lead (DSL) must report all serious allegations to:
  • Care Inspectorate Wales (CIW) as required under regulatory obligations.
  • The Local Authority Designated Officer (LADO), who oversees investigations into allegations against people working with vulnerable adults.
  • The Police, if there is any suspicion that a criminal offence has been committed.
• The staff member accused will be informed of the allegation and the process that will follow, ensuring procedural fairness.

10.3 Conducting the Investigation

• A full internal investigation will be initiated under the Disciplinary Policy, ensuring transparency and impartiality.
• All witnesses (staff, service users, or external individuals) will be interviewed, and statements taken where appropriate.
• A case file will be maintained, containing all reports, statements, and findings to ensure a robust record of the process.
• The accused staff member has the right to a fair hearing, to present their account, and to have representation if required.
• If a safeguarding breach is substantiated, appropriate disciplinary action will be taken, which may include dismissal and reporting to professional regulatory bodies where applicable.

10.4 Communication and Support

• The individual making the allegation will be kept informed of the progress of the investigation where possible, while ensuring confidentiality is maintained.
• Support services will be offered to both the affected individual and the accused staff member, recognising the emotional toll of such allegations.
• Whistleblowers who raise concerns will be protected under the Whistleblowing Policy, ensuring they do not face retaliation or victimisation.
• Family members or advocates may be involved in discussions if the individual receiving care lacks capacity.

10.5 Outcome and Post-Investigation Actions

• If the allegation is substantiated:
  • Appropriate disciplinary action will be taken in accordance with employment law.
  • The DBS (Disclosure and Barring Service) may be informed if the individual poses a risk to vulnerable adults.
  • Lessons learned will be incorporated into policy reviews and staff training.
• If the allegation is not substantiated:
  • The accused staff member will be reintegrated into the workforce with support and monitoring if necessary.
  • Strategies will be reviewed to prevent potential future allegations and ensure clarity in safeguarding expectations.
• Regardless of outcome, the case will be reviewed internally to identify any procedural improvements and mitigate risks.

11. Manager’s Responsibility

Managers play a crucial role in ensuring the effective implementation of safeguarding measures within {{org_field_name}}. Their responsibilities include:

• Leadership and Oversight: Ensuring that all safeguarding policies and procedures are implemented, regularly reviewed, and followed by all staff members.
• Training and Development: Making sure that all staff members receive appropriate safeguarding training, including refresher courses, and that training records are up to date.
• Monitoring Compliance: Conducting regular audits and assessments to ensure adherence to safeguarding protocols and identifying any areas for improvement.
• Reporting and Escalation: Overseeing the proper documentation and reporting of safeguarding concerns, ensuring timely escalation to the Designated Safeguarding Lead (DSL), CIW, or local authorities when necessary.
• Staff Support and Guidance: Providing ongoing support to staff members regarding safeguarding concerns, fostering a culture where safeguarding is a priority and staff feel confident in raising issues.
• Engagement with External Agencies: Liaising with CIW, local safeguarding boards, law enforcement, and other relevant agencies to stay informed about best practices and changes in safeguarding regulations.
• Maintaining Confidentiality: Ensuring that all safeguarding matters are handled with the highest level of confidentiality, while still complying with legal and regulatory reporting requirements.
• Continuous Improvement: Implementing lessons learned from safeguarding incidents to improve policies and staff training, reducing the risk of future occurrences.

Managers must act as role models, demonstrating a commitment to safeguarding and maintaining a safe and respectful environment for all service users.

12. Related Policies

• Whistleblowing Policy
• Mental Capacity and Deprivation of Liberty Safeguards Policy
• Complaints and Concerns Policy
• Incident Reporting and Investigation Policy
• Equality, Diversity, and Inclusion Policy

13. Policy Review

This policy will be reviewed annually or sooner if legislation, regulation, or best practices require updates. The latest review date and any amendments will be recorded and communicated to all staff.

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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}}
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