S210. Safeguarding People from the Risk of Closed Cultures

Safeguarding People from the Risk of Closed Cultures

Policy Statement

{{org_field_name}} is committed to promoting the rights and interests of the people we support in line with national and local policies and strategies. This includes the prevention of a closed culture developing, that is “a poor culture that can lead to harm, including human rights breaches such as abuse”.

{{org_field_name}} is committed to ensuring that a closed culture does not develop but also acknowledges that, as a service that supports vulnerable people, there is an inherent risk even in the absence of any other factors.

{{org_field_name}} further recognises that the larger the care setting is, the risk of closed cultures is higher for each unit/ floor, and there is a risk of closed cliques among staff, as well as for the whole home.

It therefore expects staff and managers to take the danger of a closed culture seriously, and to recognise the even the most experienced observers can be deceived.

England

This policy is written in line with the Care Quality Commission’s guidance on closed cultures and with the requirements of Regulation 13: Safeguarding Service Users from Abuse and Improper Treatment of the Health and Social Care Act 2008 (Regulated Activities) 2014.

This policy should be considered alongside {{org_field_name}}’s other polices on safeguarding, human rights and restraint:

S165. Safeguarding People Using a Care Service from Abuse or Harm Overarching

S164. Safeguarding People from Abuse and Harm: Minimising Restraints, Physical Controls and Restrictive Practices

S156. Risk Assessment and Management for People Using a Care Service

S99. Involving People in Their Care

S85. Human Rights and Deprivation of Liberty

S60. Equality, Diversity and Human Rights

Responsabilities

The manager with responsibility for oversight of {{org_field_name}}’s prevention of closed cultures is: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}.

The manager will keep up to date with the guidance on closed cultures and share learning with the team.

An annual (or more frequently according to people’s needs/vulnerability) audit of the risks of closed cultures will be carried out and an action plan developed to address identified concerns. The audit will address the CQC’s identified inherent risk factors for a closed culture.

People’s Experience and Feedback

{{org_field_name}} will ensure that people’s experience of their care is one that affirms their human rights and dignity. This includes ensuring that people who use services have the information they need and practical means to raise concerns about their care, including escalating concerns externally, and that they have the assurance that their concerns will be dealt with properly. {{org_field_name}} will make every effort to receive feedback from everyone who receives services, or at least on their behalf from someone in a position to give a meaningful opinion, to enable this.

If a person has communication needs, we will seek their feedback in line with the communication plan and will ensure that they have accessible information.

{{org_field_name}} will ensure that where a person cannot speak for themselves, that their family members, friends or other chosen representative will be able to instead.

If a person requires a translator, then {{org_field_name}} can use family members to translate for routine matters but when seeking feedback from the person, or discussing concerns, an external translation service should be used.

Where a person doesn’t have a suitable representative, {{org_field_name}} will refer the person to the local authority/local advocacy services in line with our policy on Advocacy.

Restraint and Restrictive Practices (where applicable)

{{org_field_name}} considers that physical restraint represents bad practice in care and should be avoided wherever possible. Staff will use physical restraint only as a last resort or in exceptional circumstances and any instance will be immediately reviewed. (See also {{org_field_name}}s’ policies on restraint.)

The closed cultures audit will include a full review of all restraint and restrictive practices since the last audit. It will include ensuring that any follow up action has been taken as a result of an incident, such as updated behaviour support plans, staff training and information sharing.

Management

{{org_field_name}} recognises that poor management can cause or enable a closed culture. It will ensure that:

staff are aware of the management structure of {{org_field_name}}

the staff is aware of how to escalate concerns to higher management levels

staff know of their responsibility to whistleblow, and up-to-date information on how to raise concerns outside of the organisation is prominently displayed in the office, in the staff handbook.

complaints and concerns are responded to effectively, and in line with agreed timescales

all managers have clearly defined and recorded roles and responsibilities, which in the event of absence or vacancy will be assigned to other staff

there is a specific plan in place for the regulatory responsibilities of the registered manager, such as who is responsible for sending notifications to the CQC, in their absence

recruitment of managers is carried out in a timely manner to prevent long gaps, whilst recognising that it should not be rushed

{{org_field_name}} has a policy in place on nepotism and it is adhered to

there is oversight of staff turnover

managers meet their responsibilities around duty of candour and reporting to the regulator/other official bodies

staff and management are encouraged to increase their knowledge and skills and have ample time for professional development

managers deal with grievances, and allegations of bullying, effectively and efficiently including safeguarding and DBS barring referrals.

Staff

To prevent a closed culture, {{org_field_name}} will ensure that:

mandatory staff training is up to date, including learning disability and autism training (often called “Oliver McGowan training”)

staff have had further training in the specific skills required to support the people receiving services, such as Makaton/positive behaviour support/dementia/ autism, etc in line with the needs of people you support, in line with our training policies

staff shadowing is not rushed, and new staff are able to shadow different members of staff, at different times of day, and on different floors/units if applicable.

staff supervision, appraisals and team meetings happen as they should and are recorded

senior staff and managers are an effective presence around the home

agency and bank staff are given effective handovers and have time to read people’s care and support plans

staff keep records which are accurate and detailed accounts of the care and support they have given people.

External Oversight

{{org_field_name}} recognises that external oversight is vital for all care services.

{{org_field_name}} ensures that any action required as a result of this oversight is properly taken and recorded and included in {{org_field_name}}’s overall improvement plan. All notifications, safeguarding concerns and other external alerts and reports are sent as they should be.

In addition, {{org_field_name}} will ensure that the home is not without oversight between formal external quality checks, for example by encouraging visitors and seeking regular feedback from professionals also involved in people’s care. It will support people who are at risk of social isolation to access the community and maintain relationships with friends and families. Appropriate invitations to the home’s open days and social occasions will be extended to the local authority quality team, inspectors and visiting professionals.

For services that are in an isolated location or far from people’s local areas

Preventing Isolation

{{org_field_name}} recognises that as a geographically remote service, where people may also be far from their local area, there is a particular risk of a closed culture.

To prevent this, {{org_field_name}} will take action to protect people from isolation, including:

ensuring that people coming to live in {{org_field_name}} are made aware of local services, activities and attractions, etc that are relevant to their interests, and that they are supported to visit them

ensuring that people who wish to are supported to “go into town” for routine tasks such as shopping rather than doing this online

ensuring that people are able to maintain their religious/spiritual needs and contact, either through attending local services where possible or arranging regular visits to the home

supporting people to maintain phone/video communication with people who are unable to visit them, and facilitate this with privacy

proactively maintaining communication with commissioning local authorities

appropriately involving the local community in the home, such as through volunteering opportunities and occasions such as fêtes and open days

ensuring that the home has its own accessible and reliable transport for the people living here.

Training

All new staff will receive training on the identification and prevention of closed cultures as part of their induction training, in accordance with the needs of their role.

Training should be refreshed on annual review as required by any changes in {{org_field_name}}’s policies or best practice guidance.

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}}