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HCS18-Safeguarding and Protection of Vulnerable Adults Policy

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Registration Number: {{org_field_registration_no}}

Safeguarding and Protection of Vulnerable Adults Policy

Statement of Intent

Purpose: This policy sets out how {{org_field_name}} protects the safety and wellbeing of vulnerable adults in our care. We are fully committed to a zero-tolerance approach to abuse or neglect of any kind. Every adult has the right to be safe, treated with dignity and respect, and to live free from harm or exploitation. Our staff will actively promote a culture that safeguards those at risk, in line with our legal duties and the values of person-centered care. We recognise that safeguarding adults is a fundamental aspect of providing high-quality home care, and we will continuously work to ensure our practices meet and exceed the standards expected by the Care Inspectorate Scotland.

Legal and Ethical Commitment: {{org_field_name}} will comply with all relevant Scottish legislation and guidance relating to adult protection. We uphold the principles of the Adult Support and Protection (Scotland) Act 2007, which provides the legal framework for protecting “adults at risk” of harm. In accordance with this and other laws, we will take every reasonable step to prevent abuse, to respond promptly to any concerns, and to cooperate fully with authorities to protect vulnerable individuals. Our intent is not only to meet regulatory requirements but to create an environment where the rights, choices, and welfare of adults are central to everything we do. All staff are expected to understand this policy and put it into practice to ensure that “I am protected from harm, neglect, abuse, bullying and exploitation by people who have a clear understanding of their responsibilities.” (Health and Social Care Standard 3.20)【27†L469-L475】. We are dedicated to making safeguarding personal – meaning the adult’s wishes and outcomes drive our actions – while never compromising on safety.

Scope and Legal Framework

Scope: This policy applies to all employees, contractors, and volunteers of {{org_field_name}}, across all services we provide. It covers all adults (aged 16 or over) who receive care or support from us, including those who may be temporarily or permanently vulnerable due to age, disability, illness, mental health needs, or any other circumstance. It also outlines how we respond if we encounter or suspect abuse of any adult at risk, whether the source of harm is within our service (e.g. staff or other service users) or external (e.g. family members, friends, or members of the community). The policy is relevant to providers of any size and is designed to remain applicable even as our service user demographics change or fluctuate.

Legal Framework: {{org_field_name}}’s safeguarding practices are informed by and compliant with current Scottish legislation and national guidance, including but not limited to:

Related Policies: This policy should be read in conjunction with other {{org_field_name}} policies, such as our Code of Conduct, Whistleblowing Policy, Recruitment Policy, Confidentiality Policy, and Complaints Policy. These documents collectively reinforce a culture of safety and transparency. For instance, our Complaints process provides service users and families a way to report concerns, and our Code of Conduct outlines the behavior expected of staff to prevent abusive practice. All these policies interlink to support the overarching goal of safeguarding vulnerable adults.

Definitions of Abuse and Harm

Understanding what constitutes abuse or harm is critical for effective safeguarding. For the purposes of this policy, we use the following definitions, consistent with Scottish legislation and good practice guidance:

This list (a–d) from the Act is not exhaustive. In general terms, behaviours that constitute harm to an adult can be physical (including neglect), emotional/psychological, financial, sexual, or any combination of these. Harm can be a single act or repeated acts, and it can be deliberate or result from neglect or recklessness.

Types of Abuse/Harm: The following are the main categories of abuse or harm recognised by {{org_field_name}}. Staff must be familiar with these categories and remain vigilant to signs of each. (Note that multiple types of abuse can occur simultaneously.)

This list is not exhaustive. Any action or inaction that causes harm, distress, or exploitation to a vulnerable adult is of concern. If staff are unsure whether something constitutes abuse or harm, they should err on the side of caution and discuss it with the Safeguarding Lead or a manager. It is better to raise a potential issue and investigate, than to miss a serious problem. Safeguarding is about prevention as well as reaction, so maintaining an open, questioning attitude and being aware of these definitions helps us intervene early and appropriately.

Roles and Responsibilities

Safeguarding adults is everyone’s responsibility at {{org_field_name}}. This section outlines specific roles and accountability for implementing this policy:

By understanding these roles and fulfilling our own, {{org_field_name}} ensures a robust network of protection around vulnerable adults. Internally, every individual from front-line carers to senior management is expected to uphold their responsibilities. Externally, we recognise our limits and the importance of collaborating with the statutory bodies empowered to investigate and protect.

Prevention: Safe Recruitment, Induction, and Supervision

Proactive prevention is a critical component of safeguarding. We embed safeguarding considerations at every stage of the employment cycle and in our day-to-day operations:

By diligently applying safe recruitment, thorough induction, and ongoing supervisory oversight, {{org_field_name}} strives to prevent abusive situations from arising in the first place. We recognise that the quality and integrity of our staff is the first line of defense in safeguarding vulnerable adults.

Training and Competence

High-quality training is essential so that staff have the knowledge and skills to perform their safeguarding role effectively. {{org_field_name}} is committed to providing initial and ongoing training, as well as fostering competence in practice:

Through comprehensive training and a continuous learning approach, our staff build the competence and confidence needed to safeguard adults effectively. This is evidenced by staff being able to articulate their role in protecting individuals and by their prompt actions when issues arise.

Recognising Signs of Abuse or Harm

Staff at {{org_field_name}} must be alert to the various signs and indicators that a vulnerable adult may be experiencing abuse or neglect. Often, adults at risk may not directly tell someone about harm due to fear, shame, or inability to communicate, so it is crucial that we notice red flags. Below are some common signs associated with different types of abuse (this is not an exhaustive list):

Staff are instructed to use their training and intuition – if something feels wrong, or if an explanation for a change in condition doesn’t add up, it is better to check and report than to ignore it. We emphasise that recognising abuse is not always straightforward: it often requires piecing together small signs or noticing patterns over time. One observation in isolation (e.g. a single bruise) might not confirm abuse, but combined with other signs (the person’s behaviour or a series of similar bruises), a concerning picture can emerge. Therefore, staff should always document and communicate any potential indicators, even if they are not sure. By sharing information with the Safeguarding Lead or a manager, a fuller assessment can be made.

In summary, all staff must maintain a professional curiosity – an active interest in the well-being of those they support, and a willingness to question and probe gently when things seem amiss. This does not mean prying invasively into private matters, but it does mean not taking everything at face value if there are signs of distress. Our ethos is: See something, say something. Recognise that your role could be the crucial link in getting an adult the help they need.

Responding to Safeguarding Concerns

When abuse or harm is suspected, witnessed, or disclosed, it is vital that staff respond quickly and appropriately. The actions taken in the first moments can significantly impact the outcome. This section guides staff on what to do (and not do) if they encounter a safeguarding situation:

1. Ensure Immediate Safety: If the adult or anyone else is in immediate danger or needs urgent medical attention, this is the first priority. The staff member should call emergency services without delay – dial 999 for police if a crime is in progress or likely to occur, or for an ambulance if urgent medical care is required. For example, if a service user has serious injuries or is extremely distressed after an incident, or if an alleged perpetrator is present and poses an immediate threat, do not hesitate to get emergency help. Remove the person from harm if possible and safe to do so; this might mean, for instance, guiding them to a safe location or asking a suspected aggressor to leave if that can be done without putting anyone at further risk. Staff should not put themselves in harm’s way either – personal safety is important, and often the best approach is to call the police who are trained to deal with dangerous situations.

2. Stay Calm and Provide Reassurance: If the adult has directly disclosed something (told a staff member about abuse), the staff member should remain calm and listen carefully. It takes great courage for an individual to share abuse, and if met with shock or disbelief, they may shut down. Use a calm and gentle tone. Reassure the person that:

If the person has not directly disclosed but you have observed something (like you walked in during an incident or you notice an injury and they hint at a problem), you should similarly respond with concern and an open ear. Ask open-ended questions if you need to clarify (“Can you tell me what happened?” or “You seem upset, is there anything you want to talk about?”), but avoid pressing for more information than necessary. Do not conduct an in-depth interview; that is the job of trained investigators. Your role is to gather just enough information to understand what immediate action is needed and to report the matter.

3. Do Not Promise Confidentiality: It is crucial to gently, but clearly, inform the person that you cannot keep secrets about abuse. If a service user begins to tell you something and says “but you must promise not to tell anyone,” you need to explain that you cannot make that promise. As per our training, say something like: “I understand you want this kept private, and I will only tell people who absolutely need to know, but I do have to share it with a manager because I want to get you help and keep you safe.” This aligns with best practice: “If a disclosure of harm is made by a service user, care should be taken to explain the procedure to them and advise that it may not be possible to maintain confidentiality.”. Being upfront builds trust that you are honest, and it avoids the person later feeling betrayed when others become involved. Remember, confidentiality in safeguarding is limited – information will be handled sensitively, but it must be shared with relevant authorities to protect the individual.

4. Preserve Evidence (if applicable): In cases of physical or sexual assault, or financial exploitation, there may be evidence that could be useful for an investigation. While your primary role is not evidence collection, you can take simple steps to avoid destroying or contaminating evidence:

However, do not delay contacting authorities in order to gather evidence – police and social workers will guide this. Your job is primarily to make sure evidence isn’t lost inadvertently (like cleaning up blood stains or fixing a disturbed scene) and to note what you see.

5. Support the Individual: Ensure the person is as comfortable as possible after a disclosure or incident. This might involve providing first aid (if you are trained and it’s needed), offering a private space to talk if you are in a shared setting, or simply staying with them if they want company. Ask them what they need: “Can I get you a glass of water? Is there someone you would like me to call for you?” Some adults may want a trusted friend or family member with them (provided that person is not the suspect), or they may want an advocate. We will facilitate support such as contacting an independent advocacy service if appropriate. Continue to monitor and reassure them that they are not alone and help is on the way.

6. Do Not Confront the Alleged Abuser: It is natural to feel anger or urgency, especially if the alleged abuser is present (for example, a colleague or a family member of the client). However, confronting them directly could be unsafe and could also jeopardise evidence or future relations. Staff should not accuse or question the alleged perpetrator. Instead, focus on the victim’s safety and reporting the matter to management/police who will take the appropriate actions. In some cases, a staff member might need to take some immediate action that indirectly involves the person (for instance, calmly asking a visiting relative to step out of the house or pausing a care session if they witness something) purely to protect the adult, but any investigative questions or allegations must be left to official channels. If the alleged abuser is another staff member, do not alert them that they are under suspicion; simply ensure the victim is safe and then report to management who will handle next steps (such as suspension of the staff member pending investigation).

After addressing the immediate situation with these steps, the staff member must move on to the formal reporting and documentation process, as outlined in the next section. Acting swiftly in response can save someone from further harm, but it is equally critical to follow through by reporting, so that protective measures and investigations can be initiated by those with the authority to do so.

Reporting and Recording Procedure

All safeguarding concerns, no matter how small they may seem, must be reported internally and externally as appropriate. This procedure ensures a clear, prompt chain of communication from frontline staff to management and onward to statutory agencies. Speed and accuracy in reporting can be lifesaving, while proper documentation preserves the facts for decision-makers. The following steps outline what to do once any immediate danger has been addressed:

A. Internal Reporting (Within {{org_field_name}}):

  1. Immediate Notification: The staff member who has witnessed, been told of, or suspected abuse must inform their line manager or the on-call manager immediately (within the same working shift or as soon as safely possible). If the Safeguarding Lead ({{org_field_safeguarding_lead_name}}) is readily available, they should be contacted directly. Otherwise, inform the next available manager who will then escalate to the Safeguarding Lead. This verbal report should include all essential information: who is involved, what happened (in the staff member’s understanding), when and where it occurred, and any immediate actions taken to protect the individual. We encourage staff to make this report in person or via a phone call – direct communication allows for clarity and immediate guidance. Time is of the essence; do not delay reporting. Even if it’s late at night or a weekend, {{org_field_name}} has an on-call system – call the designated emergency contact number for management.
  2. Alternate Reporting (if needed): If the concern implicates the staff member’s direct line manager or someone in management such that the reporter feels uncomfortable or believes it might not be handled properly, the staff member should go straight to the Safeguarding Lead or another senior leader. In rare cases where a staff member believes no one in the organization can be trusted with the information (for example, if it involves high-level wrongdoing), they should use the Whistleblowing Policy to contact an external authority directly (such as the local Adult Protection Team or Care Inspectorate). However, in the vast majority of cases, internal reporting to a different manager or Safeguarding Lead will be the appropriate first step.
  3. Documenting the Incident: As soon as possible after making the initial notification, the staff member must write a detailed report of what they observed or what was disclosed. We provide a standard Safeguarding Incident Report Form for this purpose. Key points for recording:
    • Use the person’s own words where applicable (especially in disclosures). Quote exactly what the adult said, if you can recall it verbatim, using quotation marks in your report.
    • Stick to the facts and direct observations. Do not include personal opinions or conclusions about what might have happened. For example, write “Mrs. A was crying and said, ‘My son hit me with his cane’” rather than “Mrs. A was abused by her son.” The latter is a conclusion; the former is a factual report of what was seen/heard.
    • Note the time, date, and context of the incident or disclosure (e.g. during morning visit at 10:30 AM, I noticed X…).
    • Include any immediate actions taken (e.g. “I called the emergency duty social worker at 11:00 AM and followed their advice to…”). If emergency services were contacted, record the time and outcome (e.g. police crime reference number, or ambulance crew’s assessment).
    • If there are physical findings (injuries, etc.), describe them in detail (size, color, location of bruises, etc.). If photos were taken per guidance, note that and ensure they are stored securely.
    • Sign and date the report. This report should be treated as confidential and handed to the manager or Safeguarding Lead leading the response. It will be kept in a secure file separate from general care records (accessible only to those involved in the investigation).
  4. Manager’s Initial Assessment: The manager (or Safeguarding Lead) receiving the report will quickly evaluate the information and decide on the next steps. This is not a full investigation, but an initial risk assessment: Is the adult in immediate danger now? Do others need protection (for example, is the alleged perpetrator a staff member who has access to other service users)? The manager will ensure any necessary immediate actions are taken (which might include separating a staff member from duties, arranging necessary medical care for the victim, or providing extra support). Then, the manager will proceed to notify external agencies as required.

B. External Reporting (Referral to Agencies):

  1. Adult Protection Referral to Local Authority: In Scotland, the local Social Work authority must be informed of suspected abuse of an adult at risk. {{org_field_name}} will make a formal Adult Support and Protection referral to the relevant council without delay. Typically, the Safeguarding Lead or manager will telephone the Adult Protection Duty line to give an immediate verbal report, and then follow up by submitting the required written referral form (often called an AP1 form) within a set timeframe (usually 1 working day). We adhere to the guidance of “Complete AP1 Form and submit this to the local authority within 24 hours” of the concern arising. The referral will include all pertinent details of the case as known, and our actions so far. Once the referral is made, the local authority has the duty to decide on next steps (inquiry, investigation, multi-agency meeting, etc.). We document the time/date of the referral call and keep a copy of the written referral in our secure file.
  2. Police Involvement: If the situation involves potential criminal activity (which many forms of abuse do), the manager will ensure the police are informed. Often, social work and police work jointly – if we call social work first, they may advise or coordinate with police. However, if there is any doubt or if it’s an emergency, we will contact Police Scotland directly. For example, for an assault, theft, suspected sexual abuse, or immediate risk to life, contacting the police right away is appropriate. We will provide police with all available information and evidence. From that point, we follow police instructions and do not carry out any internal actions that might interfere with their investigation (such as questioning witnesses beyond initial statements). Our role becomes supportive – ensuring the person’s safety and needs are met – while police handle the criminal aspect.
  3. Healthcare Notification: If the adult has sustained injuries or health complications from the abuse, or if they have pre-existing health issues that are relevant, we will liaise with health professionals (e.g. GP, district nurse) with the adult’s consent if possible, or in their best interests if they cannot consent. Medical examination might be necessary for evidence or treatment, and this would typically be arranged via social work or police (for forensic exams) or via normal healthcare channels for general treatment. We share information with health providers on a need-to-know basis to ensure proper care (for instance, letting the GP know there may be safeguarding concerns affecting the patient’s mental health).
  4. Care Inspectorate Notification: As a regulated care service, we are required to notify the Care Inspectorate of certain events including allegations of abuse or actual harm to a service user. The Registered Manager or Safeguarding Lead will complete a Care Inspectorate notification e-form (through the e-portal) usually within 24 hours of the incident or of us becoming aware of it. The notification will outline the basic facts and what actions have been taken (referrals, etc.). We understand that the Care Inspectorate uses these notifications to monitor serious incidents and may follow up with us or during inspections to ensure appropriate management. Notifying them is not a substitute for other actions, but an additional regulatory requirement that we take seriously.
  5. Regulatory Bodies for Staff: If the allegation involves a staff member, we have additional external reporting duties:
    • Scottish Social Services Council (SSSC): Care staff in Scotland are typically required to be registered with the SSSC. If a staff member is accused of harm or has been disciplined/dismissed for misconduct that harmed or placed a service user at risk, we must consider notifying the SSSC. In cases of formal adult protection investigations involving staff misconduct, the SSSC expects to be informed, as this could affect the worker’s registration status. We will follow SSSC guidance on when and how to refer matters of staff conduct to them.
    • Disclosure Scotland (PVG): Should a staff member be dismissed (or would have been dismissed had they not left) due to harming an adult or putting them at risk, {{org_field_name}} has a legal duty to refer that information to Disclosure Scotland for consideration under the PVG barring process. We will make such referrals promptly, usually after any investigation concludes and the staff member’s employment has been terminated on safeguarding grounds. This ensures that a wider protection is in place so the individual cannot simply seek work elsewhere with vulnerable groups. For example, “if a member of staff is dismissed following an ASP investigation, this must be reported to the SSSC, NMC and Disclosure Scotland using their online reporting system.”. We will comply with this requirement in full, understanding its importance in the broader system of keeping adults safe in Scotland.
    • Professional Bodies: If the staff member is a registered healthcare professional (like a nurse with the NMC), we will also report to their professional regulator as required.
  6. Follow-Up with Family/Representatives: With the consent of the adult (if they have capacity and agree) or in their best interests (if they lack capacity or are unable to consent), we will inform a next of kin or personal representative about the concern, unless they are the suspected abuser. This must be done sensitively and in consultation with social work or police if they are involved (sometimes authorities prefer to manage communications with family to avoid alerting a suspect). The purpose is to ensure the person has support from people they trust. If the adult has an appointed Power of Attorney or Guardian, we have a duty to inform that legal representative in most circumstances, as they have authority over the person’s welfare. However, if that person is implicated in the harm, obviously we would not inform them, and that scenario would likely be part of the investigation by authorities.

Throughout this reporting process, confidentiality is maintained in the sense that only those who need to be informed are informed. We do not broadcast details of the case within the organization beyond the involved personnel. All records are kept secure. Staff should not discuss the incident with anyone outside the immediate process, and should refer any external inquiries (e.g. if media or unrelated parties somehow learn of it) to management.

The Safeguarding Lead will maintain oversight, ensuring that once a report is made, it is not lost in the system. They will log the concern in the Safeguarding Log and track the progress: when referral was made, any feedback from social work/police, and the outcomes or next steps planned.

Engagement with External Agencies

{{org_field_name}} recognises that safeguarding adults is a multi-agency endeavor. We are committed to full cooperation and partnership with all relevant external agencies to protect individuals and improve outcomes. Here’s how we engage with key partners:

By engaging proactively and cooperatively with external partners, {{org_field_name}} ensures that our service users benefit from the full protection of Scotland’s safeguarding network. We recognise that we cannot do it alone – agencies like social services, police, and health each bring expertise and statutory powers that are essential to investigate and protect. Our job is to support their work by providing care, information, and follow-through as part of the team focused on the adult’s safety and wellbeing.

Risk Assessment and Risk Management

Safeguarding is closely tied to risk management. From the moment a person starts using our service, through every review and any incident, we continuously assess risks of harm and take steps to mitigate them. Our approach balances protecting the person with empowering them – recognizing the person’s right to make choices, even if they involve some risk, but ensuring they are informed and not put in unreasonable danger.

All this information feeds into an Individual Risk Assessment document and their Care Plan. If any potential or actual risks of abuse are identified, the care plan will include specific measures to reduce those risks.

In summary, risk assessment is not a one-off checkbox; it’s an ongoing process integrated with care. By identifying risk factors early and reviewing them often, we can put preventive measures in place and adjust them as needed. When new risks emerge or something does go wrong, we respond quickly to fortify the situation. Our aim is to anticipate and prevent harm whenever possible, and when not possible, to react in a way that limits any further harm and safeguards the future.

Support for Service Users Affected by Abuse

When a service user has experienced abuse or a safeguarding incident, {{org_field_name}} is committed to supporting them through the aftermath and recovery, in partnership with other agencies. Our approach to supporting victims (or potential victims) is compassionate, person-centered, and respectful of their rights and wishes:

In all these support efforts, the person’s own wishes guide us. Some individuals may want intensive support and to talk about the experience; others may just want to “move on” and not discuss it. We respect their coping style while gently ensuring they have information about options should they later decide to seek help. Ultimately, our role is to stand by them, make them feel safe under our care, and help restore their trust – both in care services and in their own power to make decisions. By doing so, we honor a truly person-centred and rights-based approach in our safeguarding practice.

Continuous Improvement and Learning from Incidents

{{org_field_name}} is committed to learning from every safeguarding concern or incident to continually improve our practices. We treat mistakes or problems not as incidents to hide, but as opportunities to get better and prevent future harm. Our continuous improvement process includes:

Ultimately, our goal is a learning culture. We acknowledge that despite best efforts, incidents may occur, but we are determined not to have repeat incidents from the same causes. By reflecting on each case and embracing a mindset of continuous improvement, {{org_field_name}} strives to strengthen its safeguarding practices year on year. This proactive approach not only improves safety but also instills confidence in our staff, service users, and external inspectors that safeguarding is truly at the heart of our service.

Person-Centred and Rights-Based Approach

At the core of this policy and all our safeguarding activities is a commitment to person-centred, rights-based care. This means that in protecting adults, we also empower them, respect their autonomy, and uphold their rights. Safeguarding should never be done to people in a way that ignores their voice; it should be done with people, keeping their life goals and preferences at the forefront (whenever possible).

In essence, safeguarding is not just about reacting to danger – it’s about affirming the person’s right to live their life free from fear and with their choices respected. {{org_field_name}} embeds this philosophy at every level. We protect and empower. We keep people safe and uphold their freedom. By doing so, we aim to not only prevent harm, but also to enable those we support to thrive and live fulfilling lives.

Conclusion and Review

This Safeguarding and Protection of Vulnerable Adults Policy is approved by the management of {{org_field_name}} and is in effect for all staff and volunteers to follow. It provides a comprehensive framework to ensure that any risk of harm to adults in our care is identified, addressed, and monitored in line with Scottish laws and Care Inspectorate expectations. All employees are required to adhere to this policy; any deviation that compromises a service user’s safety will be treated as a serious matter.

Review: The policy will be reviewed on an annual basis, or sooner if there are changes in legislation, guidance, or if an incident indicates that improvements are needed. The Safeguarding Lead {{org_field_safeguarding_lead_name}} ({{org_field_safeguarding_lead_role}}) is responsible for initiating reviews and consulting with staff for input. Updated versions will be re-issued with clear communication of what has changed. We also welcome feedback on the policy at any time – staff and service users (and their families) can suggest enhancements based on their experiences.

By following this policy, {{org_field_name}} strives to create a safe, caring, and responsive service where vulnerable adults are protected from abuse and neglect. We want our service users to not only be safe, but to feel safe and respected at all times. Through vigilance, compassion, professionalism, and partnership working, we will continuously uphold the trust placed in us to care for some of the most vulnerable members of our community. Our commitment is that safeguarding is woven into everything we do – it is truly everyone’s responsibility and foremost in our values.

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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