Sample policy · GP

Safeguarding policy (primary care) (gp)

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 Regulation 18 (staffing) and non-CQC primary legislation named in the sources below: Children Act 1989 (section 47), Care Act 2014 (section 42), Female Genital Mutilation Act 2003 (section 5B), and the Counter-Terrorism and Security Act 2015 (section 26, the Prevent duty).

1. 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.

2. 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.

3. 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.

4. Sources to verify before adoption

5. Scope

This policy applies to:

The Practice does not use this policy in place of local safeguarding children, adult safeguarding, domestic abuse, FGM or Prevent pathways.

6. Safeguarding pathways

Staff follow the correct pathway for the concern identified.

6.1 Child safeguarding disclosure

Where a child safeguarding concern is identified, staff:

The Practice verifies referral thresholds and forms against the current local safeguarding children partnership procedure.

6.2 Adult-at-risk disclosure

Where an adult-at-risk concern is identified, staff:

The Practice verifies the current local authority adult safeguarding procedure before adoption.

6.3 Domestic abuse and IRIS or MARAC pathway

Where a patient discloses domestic abuse or staff suspect domestic abuse, staff:

The Practice keeps local IRIS, domestic abuse and MARAC contacts with this policy where they apply.

6.4 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:

The Practice does not paraphrase the statutory duty in local training. Training material cites the current FGM Act 2003 section 5B source.

6.5 Prevent concern

Where staff identify a Prevent or radicalisation concern, staff:

The Practice verifies local Prevent contacts and thresholds before adoption.

7. Consultation privacy and disclosure handling

Primary care often identifies safeguarding concerns during private consultation.

Staff:

Staff do not investigate safeguarding concerns themselves. They record, report and follow the correct pathway.

8. Staff allegations and escalation

Where a safeguarding allegation involves staff, locums, contractors or visiting professionals, the Registered Manager:

No staff member investigates an allegation about themselves.

9. Responsibilities

10. Recording requirements

The Practice keeps the following records:

Records are factual, contemporaneous and access-controlled.

11. Audit cadence

The Practice uses the following Verivius default audit rhythm unless current source material requires more frequent review:

Audit findings are recorded as improvement actions with an owner and review date.

12. Version control and review date

The Practice keeps a controlled copy of this policy. The footer or document-control table records:

13. Related records

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

14. 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.

On deprivation of liberty: the Supreme Court judgment in AGNI (2 June 2026) overruled the previous "acid test"; deprivation of liberty is now determined by a multifactorial assessment, and a person who lacks capacity under the Mental Capacity Act may still give valid consent to confinement for Article 5 purposes. CQC's statement of 8 June 2026 confirms immediate effect, that providers may need legal advice pending official guidance, and that the Mental Capacity Act 2005 and Regulation 11 (consent) requirements are unchanged. DHSC guidance on Deprivation of Liberty Safeguards (DoLS) and Court of Protection cases is awaited. This change does not alter how the Practice assesses capacity or consent under the Mental Capacity Act or Regulation 11; those requirements are unchanged.

15. 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.

16. Document control

Version Date Author Changes
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 tenant's own policy-development process. Where this template and live law or regulator guidance diverge, the live source wins.

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Last reviewed 10 June 2026