Sample policy · Reg 13

Safeguarding Children Policy

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 Children Act 1989, the Children Act 2004, and the statutory guidance Working Together to Safeguard Children 2026. It also engages Regulation 12 (safe care and treatment), Regulation 17 (good governance) and Regulation 19 (fit and proper persons employed). · primary source

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Verivius pack version v1.1, 2026-07-19

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

The purpose of this policy is to make sure that [Service Name] protects children and young people from abuse, neglect, exploitation and avoidable harm.

Safeguarding children is everyone's responsibility. Staff must know how to recognise concerns, respond without delay, record clearly, escalate properly and work with local safeguarding partners.

This policy supports Regulation 13 safeguarding service users from abuse and improper treatment, Regulation 12 safe care and treatment, Regulation 17 good governance, Regulation 19 fit and proper persons employed, and statutory safeguarding guidance.

4. Policy warning

Any concern that a child is suffering, has suffered, or may be at risk of significant harm must be acted on immediately.

Staff must not wait for proof before raising a safeguarding concern.

A child safeguarding concern must not be treated only as a complaint, behaviour issue, family disagreement, data issue or internal HR matter. Safeguarding escalation must happen where the threshold is met or where staff are unsure and need advice.

Failure to report or escalation delay may place a child at further risk and may be treated as a serious conduct matter.

5. Scope

This policy applies where the service:

A child means anyone under the age of 18.

5.1 Local arrangements before adoption

Before adoption, the service records and tests:

Contact details are checked at least quarterly and after any local safeguarding-partnership change.

6. Principles

The service will:

7. Responsibilities

All staff are responsible for recognising and reporting child safeguarding concerns.

The safeguarding lead is responsible for advising staff, supporting referrals, maintaining safeguarding records and monitoring learning.

The Registered Manager is responsible for ensuring that safeguarding systems work, concerns are escalated, staff are trained, referrals are made and actions are completed.

The provider or Nominated Individual is responsible for oversight of safeguarding governance and ensuring that safeguarding has sufficient priority and resources.

8. Types of abuse and harm

Staff must be alert to:

This list is not exhaustive.

9. Signs and indicators

Possible indicators include:

Staff must consider the whole picture, not single signs in isolation.

10. Disclosure and safeguarding response workflow

For every disclosure, observation or third-party concern, staff follow these steps:

  1. Protect immediate safety: call 999 or obtain urgent medical help where needed.
  2. Listen and clarify only what is necessary: do not investigate, promise secrecy or ask leading questions.
  3. Record promptly: use the child's words where possible and separate fact, observation and professional opinion.
  4. Escalate immediately: contact the safeguarding lead, deputy or external route if the internal lead is unavailable or implicated.
  5. Refer or seek advice: the decision-maker applies the local threshold and records the referral, advice or rationale for another action.
  6. Track protection and follow-up: record reference numbers, agreed actions, owner and review date, then chase where expected feedback is not received.
  7. Review linked duties: consider police, LADO or local equivalent, CQC, DBS, professional-regulator, commissioner and incident routes without delaying safeguarding action.

If a child discloses abuse or harm, staff must:

Staff must not investigate the allegation themselves.

11. Immediate danger

If a child is in immediate danger or needs urgent medical help, staff must call 999.

The staff member must then inform the safeguarding lead or Registered Manager as soon as possible.

Emergency action must not be delayed while seeking internal permission.

12. Internal reporting

All child safeguarding concerns must be reported to the safeguarding lead or Registered Manager immediately.

Where the safeguarding lead or Registered Manager is unavailable, staff must follow the on-call or deputy arrangement.

Where internal reporting is not possible, or the staff member believes the concern is not being acted on, they must contact the local authority children's social care, police or NSPCC advice line as appropriate.

13. External referral

The safeguarding lead or Registered Manager must decide whether to make a referral to local authority children's social care, police or another appropriate body.

A referral must be made where:

The decision to refer, seek advice or not refer must be recorded with rationale.

14. Allegations against staff or people working for the service

Any allegation that a staff member, volunteer, agency worker, contractor or professional has harmed a child, may have harmed a child, or may pose a risk to children must be escalated immediately.

The Registered Manager must consider:

Internal investigation must not interfere with police or safeguarding enquiries.

15. Information sharing

The service will share information where necessary and lawful to protect a child.

Staff must not allow fear of data protection rules to prevent appropriate safeguarding action.

Only relevant information should be shared, with the right person, for the right reason, and recorded.

Where consent to share is not obtained, information may still be shared where this is necessary to protect a child or another person from harm.

16. Recording

Safeguarding records must include:

Records must be factual, clear, dated, attributable and stored securely.

17. Children who attend with adults

Where the service is primarily for adults, staff must still consider children's welfare.

Concerns may arise where:

Adult-focused services must not ignore child safeguarding risks.

18. Consent, confidentiality and young people

Children and young people should be involved in decisions according to their age, understanding and circumstances.

Confidentiality must be explained clearly, including its limits.

Staff must make clear that information may need to be shared where there is a risk of harm to the child or another person.

Where a young person seeks confidential care or advice, staff must follow applicable law, professional guidance and safeguarding procedures.

19. FGM, forced marriage and exploitation

The service must act without delay where there is concern about female genital mutilation, forced marriage, child sexual exploitation, child criminal exploitation, trafficking, modern slavery or other serious harm.

Staff must know the local referral route and the urgent escalation route.

Where a mandatory reporting duty applies to a professional, the professional must comply with that duty and record the action taken.

20. Training

All staff must receive safeguarding children training appropriate to their role.

Training must cover:

Training must be refreshed at intervals set by the service and role risk.

21. Safer recruitment

The service must apply safer recruitment checks for roles involving work with children or access to children.

This includes:

Concerns about suitability to work with children must be acted on immediately.

22. Governance and learning

The Registered Manager must review safeguarding children concerns through governance.

The review must consider:

The service must implement learning from local and national safeguarding reviews where relevant.

22.1 Audit and monitoring cadence

23. Related policies

This policy should be read with:

24. Review

This policy will be reviewed annually, or sooner following a safeguarding incident, local safeguarding procedure change, Working Together to Safeguard Children update, CQC finding, serious case review, child safeguarding practice review, allegation against staff or change in service model.

25. 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.

26. 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.

27. Document control

Version Date Author Changes
v1 2026-06-10 Verivius (sample) Initial sample template, conformed to the Verivius policy standard.
v1.1 2026-07-19 Verivius (sample) Added tested local arrangements, an end-to-end safeguarding workflow and measurable governance review.

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 many services the child is never the patient. The concern arrives sideways, through a parent's appointment, a household glimpsed on a home visit, a sibling in the waiting area, or one sentence a child says once and may never repeat. That makes the opening minutes decisive, because a member of staff who waits for proof, rings the parent to check the account, or files the concern as a behaviour or complaint matter has usually spent the only opening anyone was given. It also makes the record unusually load-bearing. The child's own words, kept apart from staff opinion, may be the earliest account anyone holds, and may be read by children's social care, the police or a court long after the service's involvement has ended. The opposite failure is just as quiet: a concern raised properly and then never chased, so nobody notices that a referral went in months ago and nothing came back. Good evidence here is not an inspection artefact. It is what lets another agency see the pattern you saw, and protect a child you will probably never hear about again.

  1. Staff escalate a child concern immediately rather than gathering proof first or parking it as a complaint, behaviour or human resources (HR) matter, and they do not investigate the allegation themselves.

    Strong evidence: The disclosure and safeguarding response workflow (section 10): escalate immediately, record the child's words with fact, observation and opinion kept separate, and do not investigate; reinforced by the policy warning against waiting for proof (section 4).

    Weak evidence: The concern surfaces first in a complaint log, a behaviour incident form or a clinical note, and the safeguarding record is opened days later, if at all. Other tells are no time recorded against the moment the safeguarding lead was told, so the gap between noticing and escalating cannot be seen, a note saying 'will monitor and review at the next appointment' with no escalation trigger, a staff conclusion written in place of the child's words ('mother's explanation seems plausible'), or a line showing someone rang the parent to check the account before escalating.

    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) and reg 13(3)

  2. An allegation against a staff member, volunteer or contractor runs the full protective route, not just an internal HR process. The local authority designated officer or local equivalent, the Disclosure and Barring Service (DBS) referral duty, the professional-regulator route and the separate CQC notification on the abuse allegation itself are each considered in their own right, and a referral to the local authority is not treated as if it were the CQC notification.

    Strong evidence: The allegations-against-staff decision list (section 14): immediate protective action, local authority designated officer route, safeguarding referral, DBS referral duty, professional-regulator referral and CQC notification, with internal investigation not interfering with police or safeguarding enquiries.

    Weak evidence: The allegation lives only in a personnel file as a disciplinary matter, with nothing showing the local authority designated officer or local equivalent was contacted. Or the safeguarding record shows a referral to children's social care and then a single tick against 'reported', with no separate line confirming that the Disclosure and Barring Service (DBS) referral duty, the professional-regulator route and the CQC notification about the abuse or allegation of abuse were each considered in their own right, and no recorded reason where one was judged not to apply. A note reading 'referred, nothing further required' after the person resigned is the classic gap, because a resignation does not close the barring question.

    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.

    Safeguarding Vulnerable Groups Act 2006 s.35; Care Quality Commission (Registration) Regulations 2009, reg 18(2)(e)

  3. The referral decision is recorded with a rationale, including where the decision is not to refer. The no-referral path carries a recorded reason, not silence, and the significant-harm and local thresholds are applied.

    Strong evidence: The external-referral section (section 13), requiring the decision to refer, seek advice or not refer to be recorded with rationale, and the recording fields (section 16) capturing reference numbers, advice sought and referral or rationale for not referring.

    Weak evidence: Only the concerns that ended in a referral have a decision record. Concerns closed as no further action show a status change and nothing else, or a bare phrase such as 'discussed' or 'advice given' with no name of who advised, no date, no reference number and no reasoning against the significant-harm threshold or the local safeguarding partnership's published threshold document. 'Social care said it did not meet threshold' with no record of who said it or when is a rationale nobody can stand behind later, including the person who wrote it.

    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. Protective follow-up is chased rather than assumed complete, so a child is not left unprotected while a referral goes quiet. Reference numbers, agreed actions, owners and review dates are tracked, and referrals where expected feedback has not arrived are chased.

    Strong evidence: The track-protection-and-follow-up step of the workflow (section 10) and the monthly safeguarding-lead review of open concerns, missing outcomes, overdue actions and referrals awaiting feedback (section 22.1).

    Weak evidence: The record stops at the moment of submission. Reference number blank, outcome field reading 'awaiting feedback' for months, no owner and no review date, and nothing anywhere showing a chase was made. Protective actions are listed but carry no completion date, and the monthly review of open concerns produces a count of referrals rather than a named list of the ones that have gone quiet.

    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. An adult-facing part of the service still acts on risk to a child rather than filtering it out as out of scope. A concern that surfaces through an adult patient, such as domestic abuse, parental substance misuse, mental-health crisis or unsafe home conditions, is followed through to the child rather than stopping at the adult in front of staff.

    Strong evidence: The children-who-attend-with-adults section (section 17) and the scope covering adults who are parents, carers or household members of children (section 5).

    Weak evidence: The safeguarding record contains adult concerns only, and the adult notes tell the real story: domestic abuse, parental substance misuse or a mental-health crisis recorded in the history with no line about whether children live in the household, how many, or their ages. Home visit records with no prompt for who else was present, and no example anywhere of a concern that started with an adult patient and ended in a child referral or a call for advice.

    The recognised standard from a professional or clinical body, such as NICE or a royal college. Not a legal duty, but the accepted mark of safe practice, and a departure needs a documented reason.

  6. Safeguarding governance turns themes into tested learning and safe recruitment, not just a concern count. Governance looks at timeliness of referrals, quality of records, allegations against staff, training compliance, and whether learning from local or national reviews became an action evidenced before closure.

    Strong evidence: The governance and learning review (section 22) and the audit cadence (section 22.1: monthly, quarterly and annual checks, with learning after a serious event evidenced before closure), alongside safer-recruitment checks (section 21).

    Weak evidence: Safer-recruitment files carry a DBS certificate date but no full employment history, no written explanation of the gaps in it, and no evidence of conduct in previous work with children. Governance minutes read 'three safeguarding concerns this quarter, all closed' with no timeliness data, no record sampling, no allegations-against-staff figure and no themes. Training compliance appears as a single percentage with no split by role or level. Learning from a child safeguarding practice review is logged as 'circulated to staff by email', with no action owner and nothing showing the change was tested in practice before the item was closed.

    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 19 July 2026