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SL173-Safeguarding Adults Policy (PC)

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Registration Number: {{org_field_registration_no}}

Safeguarding Adults Policy – Personal Care (Supported Living)

Organisation: {{org_field_name}}
Service Type: Supported Living (Personal Care) – adults aged 18 and over
Scope: All staff, managers, volunteers, and contractors in {{org_field_name}}. This policy covers safeguarding of adults in supported living services who receive personal care. It does not cover children’s services or other regulated activities not provided by {{org_field_name}}. It is intended as a standalone policy for CQC registration purposes and will be reviewed at least annually.

Policy Statement

{{org_field_name}} is fully committed to safeguarding adults at risk from abuse and neglect. We have a zero-tolerance approach to any form of abuse, unlawful discrimination, or improper treatment of people using our service. This includes neglect, degrading treatment, unnecessary or disproportionate restraint, or unjustified deprivation of liberty. Our aim is to ensure every person receiving personal care in our supported living service is safe, treated with dignity and respect, and protected from harm in line with the Care Quality Commission (CQC) Fundamental Standards.

We will prevent abuse through robust procedures, awareness, and staff training, and respond swiftly and effectively to any concerns or allegations. All suspicions or incidents of abuse will be taken seriously and acted on without delay, with appropriate investigation and referral to external authorities (such as the local authority safeguarding team, police, and CQC) as required. There is no tolerance for inaction or concealment – safeguarding is everyone’s responsibility.

This policy complies with all relevant legislation and CQC requirements, including Regulation 13 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (Safeguarding service users from abuse), the Care Act 2014, the CQC (Registration) Regulations 2009, and the Fundamental Standards. We uphold the six core principles of adult safeguarding from the Care Act 2014 – Empowerment, Prevention, Proportionality, Protection, Partnership, and Accountability – ensuring our approach is person-centred and outcome-focused. We recognize that many people we support have capacity to make their own decisions; having mental capacity does not preclude them from being at risk due to age, frailty or physical disability. We therefore work to protect adults with care and support needs with their consent and involvement whenever possible, while also fulfilling our duty to act when there is a risk of serious harm or where others may be endangered.

Definitions

Safeguarding: In this context, safeguarding means protecting an adult’s right to live in safety, free from abuse and neglect – Safeguarding. It involves proactively preventing abuse, empowering individuals, and responding effectively if harm or abuse occurs.

Adult at Risk: As defined by the Care Act 2014, an “adult at risk” (or adult in need of safeguarding) is a person aged 18 or over who has needs for care and support, is experiencing or at risk of abuse or neglect, and as a result of those care and support needs is unable to protect themselves from the abuse or neglect. This policy is focused on such adults. Note that an adult with full mental capacity can still be an adult at risk if their disability, illness or age-related needs mean they cannot easily protect themselves from harm.

Abuse and Neglect: Abuse is the violation of a person’s human or civil rights by another person or persons. It can be a single or repeated act, and it may be deliberate or the result of negligence or lack of knowledge. Abuse takes many forms – the Care Act 2014 outlines ten categories of abuse:

These categories often overlap (for example, someone experiencing domestic abuse may suffer physical, emotional, and financial abuse together). Improper treatment is also prohibited – this includes any care practice that is degrading or significantly ignores a person’s needs.

Personal Care: Personal care is a CQC-regulated activity defined as providing practical assistance with daily living tasks such as eating, drinking, washing, dressing, toileting, oral care, or care of the skin, hair and nails (excluding cosmetic grooming) for individuals who cannot perform these tasks themselves due to old age, illness, or disability. In our context, personal care is delivered to people in their own homes (supported living settings). It specifically does not include the provision of accommodation as part of care – rather, personal care is provided under a separate agreement from the housing. (For example, our service provides home care to tenants in supported living, unlike a care home where accommodation and care are combined.) Personal care must be delivered where the person is living at the time, and for supported living this means in the person’s flat or home in the community.

Supported Living: A service model in which individuals live in their own home or tenancy (often with a housing agreement) and receive care and/or support separately. In supported living, the landlord (housing provider) is usually a different entity from the care provider, and there are separate agreements for accommodation and for care. Supported living allows people to have control over their housing and receive flexible support to meet their needs. This policy is written specifically for a supported living context – meaning the adults we support are tenants or householders, not residents of a care home, and our regulated activity is the provision of personal care in their own homes.

Mental Capacity: The ability to make a specific decision at a specific time. Under the Mental Capacity Act 2005, adults are presumed to have capacity unless assessed otherwise. Many people we support will have capacity to make decisions about their safety and care. Where an adult lacks capacity regarding a safeguarding matter, we will act in their best interests and involve appropriate representatives. Even where an adult has capacity, we will seek consent for raising safeguarding concerns; however, if the adult or others remain at risk of serious harm, or a crime has been committed, we may need to report concerns to authorities regardless of consent, in line with the Care Act statutory guidance on safeguarding (ensuring the person is informed and supported throughout).

Nominated Individual (NI): The senior manager nominated by the provider ({{org_field_name}}) and registered with CQC as responsible for supervising the regulated activity. The NI acts as a main point of contact with CQC and ensures the service meets its legal obligations. They have overall accountability for safeguarding in the organisation at the executive level.

Registered Manager (RM): The person registered with CQC to manage the day-to-day carrying on of the regulated activity (personal care). The RM ({{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}) is responsible for the operational implementation of this policy – they are typically the “Safeguarding Lead” within the service, coordinating safeguarding reports and responses. (In our organisation, the same individual is both the Nominated Individual and Registered Manager – see Conflicts of Interest section below for how we handle any concerns involving this person.)

Staff: All employees, agency workers, bank staff, and volunteers of {{org_field_name}} who provide care or support services. All staff have a responsibility to protect people from harm and to follow this policy and related procedures.

Whistleblowing: “Making a disclosure in the public interest” – i.e. reporting concerns about wrongdoing or poor practice within the organisation (such as abuse, neglect, or regulatory breaches) to those who can address it. A whistleblower (the person raising the concern) has legal protection from retaliation under the Public Interest Disclosure Act 1998. In care settings, staff are encouraged to raise concerns internally or to external bodies if needed, without fear of reprisal (see Whistleblowing section below).

Legal and Regulatory Framework

This policy is guided by and complies with the following key legislation and standards (all references are to the latest versions as of 2025):

All staff are expected to be familiar with these legal provisions. Management will ensure the service stays up-to-date with any changes in laws or guidance (e.g. new statutory guidance from CQC or updates to the Care Act guidance). Compliance with this framework is mandatory, and failure to adhere to safeguarding law or this policy may result in disciplinary action and regulatory consequences.

Roles and Responsibilities

Board of Directors / Registered Provider: The organisation’s governing body (or owner, if a sole provider) holds ultimate accountability for safeguarding. They must foster a culture of safety and ensure resources and systems are in place to protect people. The board (or provider) must approve this policy, review safeguarding performance regularly, and ensure any lessons learned from incidents are implemented. Overall responsibility for safeguarding lies at the highest level of the organisation.

Nominated Individual (NI): {{org_field_nominated_individual_first_name}} {{org_field_nominated_individual_last_name}} is the Nominated Individual for {{org_field_name}}, responsible for supervising the management of our personal care service (as per CQC registration). The NI ensures that the service meets all CQC requirements and relevant legislation on an ongoing basis. Specific responsibilities include: promoting a strong safeguarding culture, making sure robust procedures (like this policy) are implemented, and that safeguarding is discussed at board/management level. The NI liaises with CQC on safeguarding matters and notifications. They must ensure the Registered Manager and all staff are supported and that any safeguarding incident is properly addressed. (In our organisation, the NI and RM roles are held by the same person – see Conflicts of Interest section for how we handle oversight in that scenario.)

Registered Manager (RM): {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}, as the CQC-registered manager, is the designated Safeguarding Lead for daily operations. The RM is responsible for the practical implementation of safeguarding procedures. Key duties include:

If the Registered Manager is unavailable (e.g. on leave), a deputy manager or other senior staff member will be appointed to act as Safeguarding Lead in their absence. All staff will be informed of who is the lead at any given time.

All Staff and Volunteers: Every staff member at {{org_field_name}} has a duty to safeguard the wellbeing of service users. This includes permanent staff, agency staff, and volunteers. Their responsibilities are:

By fulfilling these responsibilities, staff and management work together to create a safe service. We will ensure that safeguarding responsibility is written into job descriptions and discussed in supervision. Regular staff meetings will include safeguarding as a standing agenda item, to reinforce knowledge and discuss any issues or lessons learned.

Safeguarding Procedures

1. Prevention Measures: We believe prevention of abuse is as important as responding to it. Key preventive measures include:

2. Recognising Abuse: Staff must be vigilant for signs and indicators of abuse or neglect. These can vary by type of abuse, but general warning signs include: unexplained bruises or injuries (possible physical abuse), fearful or withdrawn behaviour (possible emotional abuse), sudden loss of money or basic provisions (financial abuse), untreated medical issues or poor hygiene (neglect), an overly controlling partner or frequent arguments at home (domestic abuse), etc. We provide guidance and training on these indicators. If a service user discloses to a staff member that they are being abused, the staff member will listen calmly and take it seriously. They will reassure the person, avoid probing questions, and not promise to keep secrets (explaining that they will inform the appropriate people to get help). They will then follow the reporting steps below.

3. Reporting a Safeguarding Concern (Internal): When any staff member suspects abuse, witnesses an incident, or receives a disclosure, they must report it immediately to the Registered Manager (or their line manager/designated lead if the RM is not available). This should be done as soon as possible on the same day – ideally in person or by phone for urgency, followed by a written record. Staff should not delay reporting, even if they only have a suspicion or minor concern; we would rather act on false alarms than miss a genuine case of abuse. If the allegation or concern implicates the Registered Manager or Nominated Individual, staff must not report to that person – instead, they should follow the procedure outlined in the “Conflicts of Interest” section of this policy to report directly to an external authority (e.g. local safeguarding team or CQC). All staff are reminded that any form of abuse or allegation of abuse must be reported, regardless of who the alleged perpetrator is (it could be a staff member, another service user, a family member, a visitor, or even abuse by someone not connected to our service like a scammer or neighbour – in all cases, we act to protect the adult).

4. Immediate Actions by Manager: Upon receiving a report or observing an incident, the Registered Manager (or senior on duty) will first ensure the adult’s immediate safety. This may involve separating the alleged perpetrator from the adult at risk (e.g. assigning different staff, or if another service user is causing harm, providing additional supervision). If medical attention is needed, the manager will call a doctor or emergency services. If a crime is suspected (for example, physical assault, sexual abuse, theft, wilful neglect, or domestic abuse), the manager will contact the police immediately, as criminal investigation can be crucial and evidence must be preserved. We will preserve evidence where applicable – e.g. not washing clothes or cleaning up before police advise, keeping records of exactly what was said by whom, etc. The manager documents all immediate actions taken.

5. Referral to External Agencies: The Registered Manager (or delegate) will make a safeguarding referral to the local authority Safeguarding Adults Team as soon as a concern meets the criteria (any suspicion or allegation of abuse or neglect involving an adult with care/support needs). Under the Care Act 2014, the local authority has the lead role in safeguarding enquiries. We will adhere to the locally agreed protocol for making referrals (this typically involves calling the council’s adult safeguarding contact number and/or completing a safeguarding concern form). We will provide all relevant information, including: details of the adult at risk, the alleged incident or concern, immediate safety actions taken, and the views/wishes of the adult (if known). If in doubt about whether to refer, we will err on the side of caution and refer, as the local authority can decide whether it meets Section 42 enquiry criteria. We understand our duty to cooperate fully with the local authority’s enquiry. This may involve attending strategy meetings or providing further information. The RM will also inform other relevant bodies as appropriate – for example, if the person is in a care setting funded by an authority or NHS, we inform the care manager or commissioning body; if a staff member is involved, we may need to inform the DBS or nursing professional bodies in due course.

Simultaneously, we will notify the Care Quality Commission (CQC) of the safeguarding incident or allegation, as required by Regulation 18 of the CQC Registration Regulations. This notification will be submitted without delay (usually within 1-2 working days at most, and sooner if circumstances demand) and include information on the nature of the abuse allegation and actions taken. We recognise CQC is not the primary investigator but needs this information to monitor our compliance. If the police have been notified, this will be included in the CQC notification as well.

6. Recording and Documentation: The staff member who first responded will make a factual written record as soon as possible, detailing what they observed or what the adult said (in their own words as far as possible), and any immediate actions taken. The Registered Manager will ensure that all steps taken are recorded in a confidential Safeguarding log. This log will include dates, times, people involved, summary of incident, decisions made (and rationale), referrals made (with names of persons spoken to at external agencies), and any follow-up actions required. All records will be kept secure and only shared with those who have a legitimate need to know. These records may be important for any investigation, so accuracy and detail are important. We comply with data protection law when keeping these records, but note that safeguarding records can be shared for investigative purposes with relevant authorities under Schedule 1 of the Data Protection Act 2018.

7. Internal Investigation and Disciplinary Action: The responsibility for investigating the abuse allegation usually lies with the local authority (and police if criminal). We will not unduly interfere with external investigations – for example, we will not conduct formal interviews with the alleged perpetrator or victim about the abuse before the authorities, as this could compromise evidence. However, we still have a duty to investigate internally as needed for our own management. Typically: if a staff member is accused, we will suspend them on a precautionary basis (on full pay) pending investigation outcomes, to remove any potential risk. We will then conduct an internal investigation (in coordination with the external enquiry) focusing on whether our policies were followed and what changes are needed to prevent recurrence. Disciplinary proceedings against staff will be undertaken once sufficient facts are gathered, and can result in sanctions up to dismissal and DBS referral, irrespective of any police action. If the allegation is against another service user or a member of the person’s family, we will work with the local authority to address risks (for instance, adjusting how we deliver care or involving other agencies to support that other individual). Throughout the process, the adult at risk’s wishes and wellbeing remain central – we involve them (or their advocate) in discussions about next steps, and keep them (and/or their family if appropriate) informed of developments as much as possible.

8. Supporting the Adult at Risk: We ensure the person affected receives appropriate support. This might include emotional support (comfort, reassurance, or referral to counselling), medical attention, or the involvement of an advocate. If the person has communication needs, we will arrange interpreters or other communication support during the process. The adult’s consent and choices will guide what steps are taken – for example, if they have capacity and do not want certain information shared or do not want support, we respect their views to the extent possible, while explaining our responsibilities. (If we must override their wishes to prevent further harm, we will explain and handle this sensitively, focusing on their safety.) We aim to apply the principle of Making Safeguarding Personal, meaning the adult is involved in decisions and their desired outcomes are considered. After an incident, a key worker or manager will check in with the individual regularly and ensure they feel safe and informed about what is happening.

9. Learning Lessons and Ongoing Improvement: After any safeguarding case, once resolved, the Registered Manager and team will reflect on what happened. We will hold a debrief meeting to identify any lessons learned – e.g. could we have spotted signs earlier, do staff need more training, does a particular policy need strengthening? We will implement changes as needed (update procedures, provide additional training or supervision, etc.). All such incidents and learning points will be summarised for our quality assurance and shared with the team so that improvements are made. The Nominated Individual/Board will also review all safeguarding incidents to ensure the management responded appropriately and to provide any additional support or resources needed.

10. Compliance and Audit: The Registered Manager will maintain a safeguarding incidents log and ensure that all notifications to CQC and the local authority have been made. We will periodically audit our safeguarding practices (for example, checking that all staff have up-to-date training, testing staff knowledge in supervision, or doing spot checks that care plans include up-to-date risk assessments). The NI or a senior person not involved in day-to-day care will also audit compliance to ensure objectivity. We will use CQC’s own feedback and inspection reports to improve; safeguarding is a key part of CQC’s assessment under the Safe and Well-Led key questions, so we prepare and act accordingly.

By following these procedures, {{org_field_name}} seeks to ensure that any hint of abuse is swiftly addressed and people in our care are kept safe. Our approach is always to act in the best interests of the adult at risk, using common sense, compassion, and professionalism in line with the law and good practice.

Whistleblowing

{{org_field_name}} is committed to an open and transparent culture where staff feel able to raise any concerns about wrongdoing, risk, or malpractice – including concerns about possible abuse, unsafe practices, or if management is not addressing problems. We have a separate Whistleblowing Policy that provides detailed guidance, but key points are included here as they relate to safeguarding:

In summary, any staff member who is worried that something is wrong – whether it’s potential abuse by a colleague, an unsafe practice like mismanagement of medications, or a cover-up of an incident – should speak up. We guarantee they will be supported and that their concern will be investigated impartially. Whistleblowing is a vital fail-safe in safeguarding adults, ensuring that even if normal processes falter (for example, if a manager inappropriately downplays an incident), there is another route to protect those at risk.

Managing Conflicts of Interest: Nominated Individual and Registered Manager as Same Person

In our organisation, the Nominated Individual (NI) and Registered Manager (RM) roles are fulfilled by the same person ({{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}). We recognize that this could pose a conflict of interest in the unlikely event that a safeguarding concern or allegation involves that individual themselves. This section describes the procedure staff must follow if a concern implicates the person who is both NI and RM, and how we maintain accountability in such a scenario.

1. Reporting Concerns Involving the NI/RM: If any staff member, service user, or other person has a safeguarding concern about the conduct of {{org_field_registered_manager_first_name}} (in their capacity as an individual carer or manager), or a concern that {{org_field_registered_manager_first_name}} has failed to respond appropriately to a safeguarding issue, they must bypass the normal internal reporting route. Do not report the issue to {{org_field_registered_manager_first_name}} (since they are the subject of concern). Instead, the staff member should:

We emphasise to staff that it is not only permissible but expected to go directly to external authorities in this scenario. There will be no adverse consequences for any employee who bypasses the usual line management because the concern implicates the NI/RM.

2. Alternative Internal Contacts: In addition to external notifications, staff should, if possible, inform another senior figure within the organisation about the issue. For example, if we have a deputy manager or another director (even if not registered with CQC), staff can report to them.

3. Removing the Conflict: As soon as an allegation is made against {{org_field_registered_manager_first_name}}, that individual will be removed from any investigative or decision-making role in the safeguarding process. They will likely be suspended from their duties while the matter is looked into (this protects the integrity of the investigation and the safety of service users). The organisation will cooperate fully with the external investigation led by the local authority or police. The alternative designated person (or another appropriate manager brought in, if necessary) will act in place of the RM for all safeguarding matters during this time. This ensures the person accused is not effectively “investigating themselves.”

4. External Oversight: When NI and RM are the same person, external oversight is crucial if they are accused. The Safeguarding Adults Board (through the local authority) will lead the enquiry to ensure impartiality. We would also expect CQC to be involved in monitoring the situation – CQC may carry out an unannounced inspection or require a report on what actions we’ve taken. We will be transparent with inspectors and commissioners about the situation. If needed, the organisation will appoint an interim manager (with CQC approval) to oversee the service while the investigation is ongoing.

5. Staff and Service User Support: We acknowledge that an allegation against the senior manager can be particularly stressful for staff and people using the service. We will ensure that support is available – staff may speak confidentially with the alternate safeguarding lead or an external advisor, and service users will be kept informed (in an appropriate way) about any management changes or any measures affecting them. Advocacy will be provided for any service user who may need help to express their feelings during this process.

6. Decision and Follow-up: The outcome of the safeguarding investigation will be communicated to the relevant parties. If the allegation is substantiated, the organisation will take decisive action: this could include dismissal of {{org_field_registered_manager_first_name}} (Registered Manager) and reporting to the DBS and any professional bodies. The Nominated Individual role would then be reassigned to another suitable person for the long term. If the allegation is not substantiated, we will work to re-establish confidence in management and address any remaining concerns or misunderstandings that led to the allegation. Regardless of outcome, we will review how the situation was handled and identify any improvements in our conflict of interest safeguards. For example, we might decide to appoint a separate Nominated Individual if feasible, to provide more oversight.

In summary, even though our Nominated Individual and Registered Manager is the same person, no one is above safeguarding law or scrutiny. Checks and balances are in place: staff are empowered to escalate concerns beyond that person, and external agencies will be involved immediately to provide independent oversight. This ensures that if the person in charge is ever implicated, the matter will still be handled thoroughly, transparently, and without bias – protecting service users first and foremost.

Conclusion

Safeguarding adults is a fundamental priority for {{org_field_name}}. By adhering to this policy, all members of our team will ensure that adults in our supported living personal care service are safe from abuse, and that if concerns arise, we respond effectively and in compliance with our legal duties. This policy will be kept up-to-date with any changes in legislation or guidance. All staff are required to familiarize themselves with it and to sign an acknowledgment that they understand their responsibilities. Together, we will maintain a culture where abuse is never acceptable, and any concerns are dealt with properly for the protection and well-being of the people we support.

Sources / References:

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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