1. 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.
2. Sources to verify before adoption
- Care Act 2014, section 42: https://www.legislation.gov.uk/ukpga/2014/23/section/42
- Care and Support Statutory Guidance, chapter 14 safeguarding: https://www.gov.uk/government/publications/care-act-statutory-guidance/care-and-support-statutory-guidance
- CQC safeguarding people: https://www.cqc.org.uk/what-we-do/how-we-do-our-job/safeguarding-people
- CQC single assessment framework safeguarding quality statement: https://www.cqc.org.uk/guidance-regulation/providers/assessment/single-assessment-framework/safe/safeguarding
- Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Regulation 13: https://www.legislation.gov.uk/uksi/2014/2936/regulation/13
- Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Regulation 18: https://www.legislation.gov.uk/uksi/2014/2936/regulation/18
- Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Regulation 20: https://www.legislation.gov.uk/uksi/2014/2936/regulation/20
3. Scope
This policy applies to adults at risk under Care Act 2014 section 42.
It applies where an adult:
- has needs for care and support
- is experiencing, or is at risk of, abuse or neglect
- may be unable to protect themselves because of those needs
The policy applies to concerns involving staff, relatives, friends, visitors, other people using the service, contractors, volunteers or people outside the Service.
4. 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:
- physical abuse
- sexual abuse
- financial or material abuse
- psychological or emotional abuse
- neglect or acts of omission
- discriminatory abuse
- organisational abuse
- modern slavery
- domestic abuse
- self-neglect
The Service verifies category definitions against current Care and Support Statutory Guidance and local safeguarding procedures before adoption.
5. Recognising indicators
Staff consider safeguarding action when they identify signs that may indicate abuse or neglect.
Indicators may include:
- unexplained injury, pain, bruising, restraint marks or repeated falls
- fear, distress, withdrawal, change in behaviour or reluctance to speak in front of another person
- sexualised behaviour, genital injury, disclosure or signs of coercion
- missing money, unexplained spending, pressure to change financial arrangements or concern about possessions
- poor hygiene, untreated pressure damage, malnutrition, dehydration or missed care
- repeated medication errors, missed healthcare appointments or unsafe discharge arrangements
- bullying, hate incidents or discriminatory language
- institutional routines that ignore individual needs or choices
- signs that the person is controlled by another person
- unsafe living conditions, hoarding, refusal of essential care or serious deterioration linked to self-neglect
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.
6. Referral pathway
The Service keeps a live safeguarding referral sheet for each location or service area.
The sheet includes:
- local authority adult safeguarding contact
- Safeguarding Adults Board procedure link
- out-of-hours safeguarding contact
- police emergency route
- local MASH or single front door where the local area uses one
- NHS safeguarding lead where relevant
- CQC notification route where required
- advocacy and IMCA contact routes
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.
7. Role of the safeguarding lead
The safeguarding lead:
- receives and triages safeguarding concerns
- makes sure the person is safe
- supports staff to record facts accurately
- makes or oversees local authority referrals
- liaises with the Safeguarding Adults Board process where required
- considers advocacy and capacity issues
- considers CQC notification and duty of candour
- tracks actions and learning
- reports themes to the governance group
The safeguarding lead does not replace the duty of every staff member to act on immediate risk.
8. Allegations against staff
The Registered Manager manages allegations involving staff, agency staff, contractors, volunteers or visiting professionals.
The process includes:
- making the person using the service safe
- preserving records, rotas, care notes and electronic audit trails
- removing the staff member from contact where needed
- contacting the local authority adult safeguarding route
- following the local Person in a Position of Trust process where available
- using the LADO route where the allegation involves a child or local procedure requires LADO advice
- considering police referral where a crime may have been committed
- considering DBS referral, professional regulator referral and employment action
- considering CQC notification and duty of candour
No staff member investigates an allegation about themselves.
9. Record-keeping
Safeguarding records include:
- date and time
- person using the service
- staff member recording
- facts observed
- words used by the person or witness where relevant
- body map or clinical record where injury is visible and recording is within staff competence
- immediate safety action
- capacity and consent considerations
- referral route used
- advice received
- reference number
- actions assigned
- review date
- outcome and learning
Records are factual, contemporaneous and stored securely. Access is limited to staff who need the information for safeguarding, care or governance.
10. Staff training levels
The Service maps safeguarding training to role.
- All staff receive induction on recognising and reporting safeguarding concerns.
- Care staff receive training on indicators, adult-at-risk thresholds, recording and immediate safety action.
- Senior care staff receive training on referral preparation, capacity, advocacy and evidence preservation.
- The safeguarding lead and Registered Manager receive training on enquiry participation, staff allegations, notifications and learning cycles.
Training records are maintained under Regulation 18 staffing and training expectations. The Service verifies current local authority and CQC training expectations before adoption.
11. Links to MASH and local procedures
The Service does not use a national template in place of local safeguarding procedures.
Each location keeps:
- the current local Safeguarding Adults Board procedures
- local MASH or single front door route where used
- adult safeguarding referral form
- escalation process for disagreement or delay
- advocacy and IMCA contacts
- out-of-hours route
- police route for immediate risk or suspected crime
The Registered Manager checks these details at least annually and after local authority route changes.
12. Post-incident learning cycle
After a safeguarding concern, the safeguarding lead reviews:
- whether the person was made safe
- whether referral was made to the correct route
- whether records were complete
- whether capacity, advocacy and consent were considered
- whether CQC notification or duty of candour was considered
- whether staff need support, supervision or training
- whether a policy, staffing or environmental change is needed
Learning is recorded as an improvement action with an owner and review date.
Review cadence: annual or on regulatory change, whichever sooner. Owner: Registered Manager.