Sample policy · Adult social care

Safeguarding adults policy (adult social care)

Statutory anchor: Regulation 13 (safeguarding service users from abuse and improper treatment), Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (SI 2014/2936). This policy also engages the Care Act 2014 (section 42), Regulation 18 (staffing and training) and Regulation 20 (duty of candour). · primary source

1. Who this adult social care safeguarding policy is for

This sample policy is for adult social care providers that need a safeguarding adults policy for care homes, nursing homes, supported living, residential care or other regulated adult social care settings. It is written for services where safeguarding risk sits inside daily care, medicines, moving and handling, mental capacity, restraint, staff allegations, local authority safeguarding routes and governance learning.

Use this page when the evidence question is: can we show that adult safeguarding concerns are recognised, made safe, referred through the correct local authority route, recorded, reviewed and turned into learning? It covers Care Act section 42 threshold thinking, abuse categories, referral routes, staff allegations, safeguarding records, training, capacity, consent, deprivation of liberty and post-concern learning.

For a cross-sector starting point, use the generic safeguarding adults policy template. For audit evidence, use the safeguarding adults procedure checklist. For the regulation itself, see the Regulation 13 safeguarding explainer. For the wider sector cluster, see the adult social care guide.

2. What the regulation says

Service users must be protected from abuse and improper treatment in accordance with this regulation. (Reg 13(1) (the headline duty))

Systems and processes must be established and operated effectively to prevent abuse of service users. (Reg 13(2) (prevention systems))

Systems and processes must be established and operated effectively to investigate, immediately upon becoming aware of, any allegation or evidence of such abuse. (Reg 13(3) (investigation systems))

A service user must not be deprived of their liberty for the purpose of receiving care or treatment without lawful authority. (Reg 13(5) (lawful authority for deprivation of liberty))

any behaviour towards a service user that is an offence under the Sexual Offences Act 2003, (Reg 13(6)(a) (sexual offences))

ill-treatment (whether of a physical or psychological nature) of a service user, (Reg 13(6)(b) (ill-treatment))

theft, misuse or misappropriation of money or property belonging to a service user, or (Reg 13(6)(c) (theft / misuse / misappropriation))

neglect of a service user. (Reg 13(6)(d) (neglect))

The full text of the regulation is at https://www.legislation.gov.uk/uksi/2014/2936/regulation/13. Where this policy and the regulation diverge, the regulation wins.

3. Plain-English summary

Service users must be protected from abuse and improper treatment. You need effective systems to prevent abuse, and effective systems to investigate any allegation or evidence of abuse as soon as you become aware of it. Care must not be provided in a way that discriminates, uses disproportionate control or restraint, is degrading, or significantly disregards the service user's needs. Service users cannot be deprived of their liberty without lawful authority.

4. Purpose

This policy sets out how the Service identifies, records, reports and learns from safeguarding concerns involving adults using the Service.

The Service must verify this policy against the current Care Act 2014, Care and Support Statutory Guidance, local safeguarding adults procedures and CQC source material before adoption.

5. Sources to verify before adoption

6. Scope

This policy applies to adults at risk under Care Act 2014 section 42.

It applies where an adult:

The policy applies to concerns involving staff, relatives, friends, visitors, other people using the service, contractors, volunteers or people outside the Service.

7. Categories of abuse

Staff are trained to recognise the categories of abuse and neglect described in Care and Support Statutory Guidance.

The Service records concerns under the following categories:

The Service verifies category definitions against current Care and Support Statutory Guidance and local safeguarding procedures before adoption.

8. Recognising indicators

Staff consider safeguarding action when they identify signs that may indicate abuse or neglect.

Indicators may include:

Staff record facts, words used by the person and immediate action taken. They do not investigate the concern themselves unless the local authority asks the Service to contribute to an enquiry.

9. Referral pathway

The Service keeps a live safeguarding referral sheet for each location or service area.

The sheet includes:

Staff report immediate danger to emergency services. For all other concerns, staff report to the safeguarding lead or Registered Manager on the same working shift unless local procedure requires a different route.

The Registered Manager ensures referral decisions are made against current local authority safeguarding procedures.

10. Role of the safeguarding lead

The safeguarding lead:

The safeguarding lead does not replace the duty of every staff member to act on immediate risk.

11. Allegations against staff

The Registered Manager manages allegations involving staff, agency staff, contractors, volunteers or visiting professionals.

The process includes:

No staff member investigates an allegation about themselves.

12. Record-keeping

The safeguarding record should include:

Records are factual, contemporaneous and stored securely. Access is limited to staff who need the information for safeguarding, care or governance.

13. Links to registers and action tracking

14. Staff training levels

The Service maps safeguarding training to role.

Training records are maintained under Regulation 18 staffing and training expectations. The Service verifies current local authority and CQC training expectations before adoption.

15. Links to MASH and local procedures

The Service does not use a national template in place of local safeguarding procedures.

Each location keeps:

The Registered Manager checks these details at least annually and after local authority route changes.

16. Audit, monitoring and post-incident learning

The Registered Manager or safeguarding lead reviews the safeguarding register at least quarterly, and sooner after a serious concern, repeated theme, staff allegation or delayed external response. The audit checks timeliness, immediate safety, the person's involvement, referral quality, open actions, external-reporting decisions and whether completed actions changed practice.

After a safeguarding concern, the safeguarding lead reviews:

Learning is recorded as an improvement action with an owner and review date.

Policy review cadence: annual or on regulatory change, whichever sooner. Owner: Registered Manager.

17. Capacity, consent and deprivation of liberty

Where a safeguarding concern involves a person who may lack capacity to make a relevant decision, the Service applies the Mental Capacity Act 2005 and works within the current MCA Code of Practice (2007, update in consultation). Capacity is assessed for the specific decision, and any action taken in a person's best interests is recorded.

Regulation 13(5) requires that a service user is not deprived of their liberty for the purpose of receiving care or treatment without lawful authority. The Supreme Court judgment of 2 June 2026 has immediate effect, and CQC confirms that the Mental Capacity Act 2005 and Regulation 11 consent requirements are unchanged. The Service follows DHSC's guidance published on 15 June 2026, which requires a multifactorial assessment and advises referral for review where there is doubt. The republished DoLS Code of Practice does not fully reflect the 2026 judgment. The Service seeks legal advice on uncertain cases rather than relying on this template alone.

This judgment concerns the assessment of deprivation of liberty under Article 5 of the European Convention on Human Rights only. It does not change Regulation 11 consent, Mental Capacity Act capacity assessment, or consent to care and treatment, which remain as before.

18. Related policies in this pack

19. Related guidance

20. Sources and further reading

This template is based on CQC's guidance for providers and managers, the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, and other topic-specific legislation and guidance listed below. It is a starting point for adaptation, not a substitute for legal, clinical, HR, safeguarding or specialist professional advice.

21. When to seek further advice

Seek specialist advice where the issue involves serious harm, safeguarding, deprivation of liberty, restraint, children, professional misconduct, controlled drugs, radiation, termination of pregnancy, infection outbreak, water safety, employment dismissal, DBS barring referral, or regulatory enforcement.

22. Document control

Version Date Author Changes
v1.3 2026-07-21 Verivius (sample) Replaced the pending-guidance wording with current DHSC guidance on the 2026 Supreme Court judgment.
v1.2 2026-07-18 Verivius (sample) Added evidence fields, register-to-action controls, quarterly safeguarding audit and related policies.
v1.1 2026-07-11 Verivius (sample) Added adult-social-care intent guidance and links to the generic safeguarding policy, checklist, Regulation 13 explainer and sector guide. No regulatory claims changed.
v1 2026-06-10 Verivius (sample) Initial sample template, conformed to the Verivius policy standard.

This sample policy template was issued by Verivius. It is a template, not a substitute for legal advice or the provider's own policy-development process. Where this template and live law or regulator guidance diverge, the live source wins.

What good looks like here

Written from an ex-CQC inspector's chair, but the point is safe, well-led care your team can stand behind. Each row shows what strong evidence looks like, what thin evidence looks like, and where the expectation comes from.

In adult social care the person best placed to cause harm, and least likely to be challenged about it, is often the one giving the most intimate care: the same staff member who washes someone, gives their medicines and handles the money kept in their room. That is why concerns here rarely arrive as a clear allegation. They arrive as a bruise nobody can account for, a purse lighter than it should be, or a resident who goes quiet whenever one particular shift comes on. Many people using the service cannot describe what happened to them, so the note a care worker writes at the time, in the person's own words where they used any, is often the only account that will ever exist. A register that holds the immediate safety action, the referral route, the capacity and lawful-authority position and what changed afterwards is what lets a manager see a pattern across shifts and stop it, rather than reading it back later in a serious case review, and it is what shows a family that someone took their relative's account seriously.

  1. The person is made safe and the concern reaches the safeguarding lead or Registered Manager promptly, with the referral decision recorded, rather than a concern simply being logged.

    Strong evidence: Safeguarding register entry showing immediate safety action, the referral route used, reference number, named owner and review date (sections 9, 12, 13).

    Weak evidence: A register line reading "concern raised, manager informed" with no time against it, so nobody can tell whether the person was made safe on that shift or the following morning. The immediate safety action, the referral route used, the reference number, the named owner and the review date are blank, and the staff member's account was written up days later from memory rather than at the time. A record that cannot show when the service became aware cannot show that it acted immediately on becoming aware.

    A legal duty. This comes from legislation that applies to your service, so meeting it is not optional. The exact provision is cited beneath the badge.

    Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, reg 13(2)-(3), with reg 17(2)(c)

  2. The CQC statutory notification decision is taken on the abuse or allegation of abuse itself, separately from the local authority safeguarding referral. The registered provider owns that decision, and making a safeguarding referral to the local authority does not discharge it.

    Strong evidence: A recorded notification decision held against the concern, including a decision not to notify (section 13; checklist row 'CQC statutory notification need is considered for abuse or allegation of abuse').

    Weak evidence: The register carries a single "referred" column holding a local authority reference number, and nothing anywhere shows the separate CQC notification question was asked about the abuse or allegation of abuse itself. The usual weak spots are an assumption that the local authority or the Safeguarding Adults Board notifies CQC on the service's behalf, and decisions not to notify that leave no trace, so a later reviewer cannot tell whether the question was considered and answered or never asked at all.

    A legal duty. This comes from legislation that applies to your service, so meeting it is not optional. The exact provision is cited beneath the badge.

    Care Quality Commission (Registration) Regulations 2009, reg 18(2)(e)

  3. Care Act 2014 section 42 threshold reasoning is recorded, and a decision not to refer explains why, rather than a concern being closed with no reasoning the next person can pick up.

    Strong evidence: Section 42 or local threshold reasoning and not-referred closure reasoning in the safeguarding register, checked at the quarterly audit of external-reporting decisions (section 16; checklist section 3).

    Weak evidence: Concerns closed with "not a safeguarding matter" or "dealt with internally" and nothing recorded about why the adult-at-risk test was thought not to be met: the needs for care and support, the abuse or neglect, and whether the person could protect themselves. Threshold thinking that lives only in a manager's head, or in a phone call with the local authority where nobody wrote down who advised what, cannot be revisited when a second similar concern about the same person arrives.

    Our recommended baseline. Not a legal or regulatory requirement, but a sensible standard we suggest where the rules leave the detail to you. Adapt it to your service.

  4. An allegation against a staff member is handled by someone other than the subject of it, and the records are preserved, so no one is left investigating a concern about themselves.

    Strong evidence: Allegation record showing a separate impartial route, preserved rotas, care notes and electronic audit trails, and consideration of a Disclosure and Barring Service referral, a professional-regulator referral or a commissioner referral, each decided and recorded separately where it applies (section 11; checklist section 4).

    Weak evidence: The statement, the enquiry contribution and the outcome are all written by the senior who was on shift and is named in the concern, with no separate impartial route recorded. Rotas, care notes and electronic audit trails are pulled weeks later from a system that allows silent edits, so nothing shows what the record said at the time. The weakest version is a Disclosure and Barring Service referral question closed with "staff member resigned", because a resignation before a decision does not remove the duty to refer where the person would have been removed from regulated activity because of harm or risk of harm.

    Our recommended baseline. Not a legal or regulatory requirement, but a sensible standard we suggest where the rules leave the detail to you. Adapt it to your service.

  5. Any deprivation of a person's liberty rests on actual lawful authority (a Deprivation of Liberty Safeguards authorisation or a Court of Protection order), with capacity, consent and best-interest decisions recorded, rather than a restriction imposed on a person with no authority behind it.

    Strong evidence: Mental Capacity Act capacity assessment and best-interest note in the safeguarding record, plus the Regulation 13(5) lawful-authority check for any deprivation of liberty (sections 12, 17; checklist section 5).

    Weak evidence: A care plan recording a keypad door, bed rails or constant staff escort with no capacity assessment for that specific decision, no best-interests record and no live authorisation reference, or covert medication given with no capacity assessment and no best-interests decision behind it. Since the judgment in AGNI (2 June 2026) changed how deprivation of liberty is assessed under Article 5, two records are equally thin: a blanket note that "this is not a deprivation" with no reasoning about that person's actual circumstances, and reasoning that still applies the older two-part test mechanically without looking at the whole picture of the person's situation. A Deprivation of Liberty Safeguards application submitted long ago, with nothing recorded about what became of it, leaves the service unable to show lawful authority today.

    A legal duty. This comes from legislation that applies to your service, so meeting it is not optional. The exact provision is cited beneath the badge.

    Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, reg 13(5), with Mental Capacity Act 2005 s.4A and Sch A1 (or s.16(2)(a) Court of Protection order)

  6. The quarterly register review turns repeated themes into a service change, so the next person is not exposed to the same pattern, rather than closing individual concerns one at a time.

    Strong evidence: Quarterly safeguarding register audit of timeliness, referral quality and whether completed actions changed practice, with learning logged in the improvement-actions register with owner and review date (sections 13, 16).

    Weak evidence: Audit notes that count concerns and referral times but record "no themes identified" quarter after quarter, while the same night shift, the same person or the same category, financial abuse or missed care, keeps reappearing in the register. Actions written as "remind staff at handover", with no owner, no due date and no later check that practice actually changed, are the tell, along with an improvement-actions register whose safeguarding entries are all still open.

    Our recommended baseline. Not a legal or regulatory requirement, but a sensible standard we suggest where the rules leave the detail to you. Adapt it to your service.

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Last verified 20 July 2026

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Last reviewed 21 July 2026