1. Purpose
This policy sets out how the Practice identifies, records and responds to safeguarding concerns in primary-care consultations and patient contact.
It covers child safeguarding, adults at risk, domestic abuse, FGM mandatory reporting, Prevent concerns, staff allegations and learning.
2. Sources to verify before adoption
- Children Act 1989, section 47: https://www.legislation.gov.uk/ukpga/1989/41/section/47
- Care Act 2014, section 42: https://www.legislation.gov.uk/ukpga/2014/23/section/42
- Female Genital Mutilation Act 2003, section 5B: https://www.legislation.gov.uk/ukpga/2003/31/section/5B
- GOV.UK, multi-agency statutory guidance on female genital mutilation: https://www.gov.uk/government/publications/multi-agency-statutory-guidance-on-female-genital-mutilation
- Counter-Terrorism and Security Act 2015, section 26: https://www.legislation.gov.uk/ukpga/2015/6/section/26
- GOV.UK, Prevent duty guidance: https://www.gov.uk/government/collections/prevent-duty-guidance
- GOV.UK, Working Together to Safeguard Children: https://www.gov.uk/government/publications/working-together-to-safeguard-children--2
- GOV.UK, Domestic Abuse Act 2021 statutory guidance: https://www.gov.uk/government/publications/domestic-abuse-act-2021-statutory-guidance
- 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
3. Scope
This policy applies to:
- child safeguarding concerns raised during consultation or patient contact
- adult-at-risk concerns raised during consultation or patient contact
- domestic abuse disclosures
- FGM concerns and mandatory-reporting cases
- Prevent concerns
- safeguarding concerns involving staff, locums, contractors or visiting professionals
- face-to-face, telephone, video and online consultations
- reception, administration and clinical contact
The Practice does not use this policy in place of local safeguarding children, adult safeguarding, domestic abuse, FGM or Prevent pathways.
4. Safeguarding pathways
Staff follow the correct pathway for the concern identified.
4.1 Child safeguarding disclosure
Where a child safeguarding concern is identified, staff:
- make the child safe where immediate action is needed
- listen and record the child's words as closely as possible
- record clinical facts and observations
- avoid promising confidentiality
- inform the safeguarding lead or senior clinician
- follow the local MASH or children's safeguarding route
- call emergency services where there is immediate danger
- consider whether other children may be at risk
The Practice verifies referral thresholds and forms against the current local safeguarding children partnership procedure.
4.2 Adult-at-risk disclosure
Where an adult-at-risk concern is identified, staff:
- make the person safe where immediate action is needed
- assess capacity and consent where relevant
- record the person's words and staff observations
- inform the safeguarding lead or senior clinician
- follow the local authority adult safeguarding route where the threshold appears met
- consider advocacy or IMCA where relevant
- consider whether children or other adults may also be at risk
The Practice verifies the current local authority adult safeguarding procedure before adoption.
4.3 Domestic abuse and IRIS or MARAC pathway
Where a patient discloses domestic abuse or staff suspect domestic abuse, staff:
- speak to the patient alone where safe
- do not confront the alleged perpetrator
- record the patient's words as closely as possible
- check immediate safety
- follow the local domestic abuse route
- use the local IRIS pathway where commissioned
- consider MARAC referral according to local threshold
- consider child safeguarding where children are exposed to domestic abuse
- call emergency services where there is immediate danger
The Practice keeps local IRIS, domestic abuse and MARAC contacts with this policy where they apply.
4.4 FGM mandatory reporting
The Practice treats FGM concerns as safeguarding concerns and follows the current FGM Act 2003, statutory guidance and local safeguarding route.
For section 5B, the exact statutory phrases "in England and Wales", "girl who is aged under 18", "chief officer of police" and "before the end of one month" are load-bearing. Staff check the current legislation.gov.uk text before making or recording a mandatory report.
Where staff identify a known case that appears to meet the mandatory-reporting duty, staff:
- make the child safe
- inform the safeguarding lead or senior clinician
- follow the police mandatory-reporting route
- follow local child safeguarding procedures
- record the report and reference number
- consider whether siblings or other children may be at risk
The Practice does not paraphrase the statutory duty in local training. Training material cites the current FGM Act 2003 section 5B source.
4.5 Prevent concern
Where staff identify a Prevent or radicalisation concern, staff:
- make the person safe where immediate action is needed
- record facts, words used and context
- inform the safeguarding lead or senior clinician
- follow the local Prevent referral pathway
- consider child or adult safeguarding where relevant
- call emergency services where there is immediate danger
The Practice verifies local Prevent contacts and thresholds before adoption.
5. Consultation privacy and disclosure handling
Primary care often identifies safeguarding concerns during private consultation.
Staff:
- create an opportunity to speak to the patient alone where safe
- use professional interpreting where needed
- avoid using family members as interpreters for safeguarding concerns
- record the patient's words and relevant clinical observations
- explain information-sharing limits
- escalate immediately where there is immediate risk
- preserve records where the concern may involve crime, abuse or professional misconduct
Staff do not investigate safeguarding concerns themselves. They record, report and follow the correct pathway.
6. Staff allegations and escalation
Where a safeguarding allegation involves staff, locums, contractors or visiting professionals, the Registered Manager:
- makes the patient safe
- preserves records, rotas, messages and electronic audit trails
- removes the person from contact where needed
- follows the local authority staff-allegation process
- contacts the Local Authority Designated Officer where the allegation concerns a child
- follows adult safeguarding or Person in a Position of Trust route where the allegation concerns an adult at risk
- considers police referral where a crime may have been committed
- considers professional regulator referral, DBS referral, CQC notification and employment action
No staff member investigates an allegation about themselves.
7. Responsibilities
- Registered Manager: owns this policy, ensures safeguarding governance and signs off annual review.
- Safeguarding lead: owns day-to-day safeguarding process, local referral routes, training oversight and record review.
- Lead GP or GP Partner: reviews doctor-only clinical judgement, complex disclosure and medical-record safeguarding decisions.
- Practice Manager: maintains local contact sheets, staff training records and governance reporting.
- All staff: recognise concerns, record facts, take immediate safety action and report through the Practice pathway.
8. Recording requirements
The Practice keeps the following records:
- safeguarding concern record
- patient words where relevant
- clinical observations
- capacity and consent considerations where relevant
- referral decision
- referral form or reference number
- police or Prevent report reference where relevant
- domestic abuse or MARAC action where relevant
- staff allegation record
- CQC notification decision
- learning and improvement action
Records are factual, contemporaneous and access-controlled.
9. Audit cadence
The Practice uses the following Verivius default audit rhythm unless current source material requires more frequent review:
- Monthly: the safeguarding lead reviews open safeguarding actions and urgent route changes.
- Quarterly: the Practice reviews safeguarding themes, FGM and Prevent pathway checks, staff training and referral quality.
- Annually: the Registered Manager audits this policy against local safeguarding procedures, CQC source material and statutory source material.
Audit findings are recorded as improvement actions with an owner and review date.
10. Version control and review date
The Practice keeps a controlled copy of this policy. The footer or document-control table records:
- policy owner
- version number
- date approved
- next review date
- changes made since the last version
- source material checked during the review
11. Related records
- Safeguarding concern register
- Incident register
- Staff training matrix
- Local safeguarding contact sheet
- Domestic abuse pathway
- FGM reporting record
- Prevent referral record
- Staff allegation record
- CQC notification record
- Improvement action register
Review cadence: annual or on regulatory change, whichever sooner. Owner: Registered Manager.