Under-18s and safeguarding policy (sexual health)

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))

The regulation defines abuse to include:

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.

For a sexual health service, this duty sits alongside a young person's right to confidential care. A young person assessed as competent under the Fraser guidelines (for contraception and sexual health) or as Gillick competent can consent to that care, but the service stays alert to exploitation, abuse and coercion, and acts on any safeguarding concern.

3. Purpose

Young people have a right to confidential sexual health care, and that access protects their health. But a young person attending sexual health may also be at risk of exploitation or abuse, and the service may be the only place that risk is seen. This policy sets out how the Service provides confidential care to young people while recognising and acting on safeguarding concerns.

The Service must verify this policy against current GMC 0-18 guidance, the Fraser guidelines, and statutory safeguarding guidance before adoption.

4. Scope

This policy applies to:

• everyone under 18 who attends the Service, and adults who may be at risk
• the assessment of competence, consent and risk
• every clinician and member of staff, who all have a part in recognising and reporting concern

5. Competence and confidential care

• a young person assessed as competent to understand the advice and decision (using the Fraser guidelines for sexual health and contraception) can consent to that care and is owed the same confidentiality as an adult, subject to safeguarding
• the Service encourages a young person to involve a parent or trusted adult, but does not require it where the young person is competent and it is in their best interests
• where a young person is not competent for the decision, the Service acts in their best interests and involves those with parental responsibility as appropriate

6. Recognising risk and exploitation

Every contact with a young person includes thinking about risk. The Service uses a recognised tool (such as the Spotting the Signs proforma) and is alert to indicators of child sexual exploitation, abuse or coercion, including:

• a much older partner, or a partner in a position of power or trust
• alcohol, drugs, money or gifts linked to sex
• secrecy, control, or a partner who is not allowed to be discussed
• repeated infections, terminations or attendances
• signs of grooming, trafficking or county-lines involvement

7. Age thresholds

• a child under 13 cannot in law consent to sexual activity; any disclosure of sexual activity by a child under 13 is a safeguarding matter and is referred
• for a young person aged 13 to 15, sexual activity is assessed for signs of abuse, exploitation or coercion, and the power balance and the partner's age are considered, with referral where concern exists
• a young person aged 16 or 17 may consent to sexual activity, but the Service stays alert to exploitation, abuse of a position of trust, and the young person's vulnerability

The Service confirms the current legal thresholds against the Sexual Offences Act and statutory guidance.

8. Acting on a concern

• a safeguarding concern is shared with the Service's safeguarding lead and referred to the local authority children's social care, or to the police where a child is in immediate danger, following local procedures and timescales
• confidentiality does not prevent a safeguarding referral; the duty to protect a child or an adult at risk overrides the usual confidentiality, and the reason is recorded
• the young person is told what is being shared and why, unless doing so would increase the risk
• concerns about an adult at risk are referred under the Care Act section 42 route

9. Recording

The competence assessment, the risk assessment (including the tool used), the decisions made, and any referral and its outcome are recorded clearly. The record shows that risk was actively considered, not just that care was given.

Operational controls to adapt

Roles and responsibilities

• Registered Manager: owns safeguarding governance, makes sure there is a named lead and deputy, and reviews safeguarding incidents, referrals, training and audit findings.
• Safeguarding lead: advises on under-18 and adult-at-risk concerns, referral thresholds, police or local-authority escalation, and case-review learning.
• Clinician: assesses competence, consent, confidentiality, exploitation risk and immediate safety, and records the rationale for any referral or non-referral.
• Reception and support staff: know how to respond if a young person appears controlled, distressed, accompanied by a concerning adult or unsafe to wait.
• Governance lead: tracks themes, missed checks, referral outcomes and improvement actions through governance.

Under-18 consultation procedure

1. Confirm age and identity. Record age, date of birth, who attended with the young person and any discrepancy or concern.
2. Offer private time. The young person is seen alone for part of the consultation unless there is a recorded reason why this is not possible or safe.
3. Assess competence. Record the Gillick or Fraser assessment, what the young person understood, and why confidential care is or is not appropriate.
4. Screen for exploitation and coercion. Ask about partner age, power imbalance, pressure, gifts, drugs, alcohol, violence, trafficking, online abuse and whether anyone is controlling access to care.
5. Apply age thresholds. Under-13 sexual activity is referred as a safeguarding matter. Ages 13 to 15 require documented risk assessment. Ages 16 to 17 still require vigilance for exploitation or abuse of trust.
6. Decide on confidentiality limits. Explain what can stay confidential and what cannot. Record what is shared, with whom and why.
7. Refer without delay where needed. Immediate danger is escalated to police or emergency services. Other safeguarding concerns follow local-authority and local safeguarding procedures.
8. Track the outcome. Referrals are not left as "sent". The service records acknowledgement, outcome, safety plan and any follow-up action.

Records and register links

The under-18 safeguarding record should include:

• age, identity check, who attended and whether the young person was seen alone
• competence assessment, Fraser or Gillick rationale and consent decision
• confidentiality explanation and any parent, carer, GP, school, police or local-authority sharing decision
• exploitation and coercion screen, including partner age, power imbalance, threats, gifts, substances, online contact or trafficking indicators
• safeguarding threshold applied, referral decision and reason if no referral was made
• immediate safety plan, referral date, destination, named contact, acknowledgement, outcome and follow-up
• linked incident, safeguarding, risk, complaint or improvement-action reference

Any missed under-18 risk assessment, delayed referral, unclear competence record, immediate danger, allegation of abuse, or repeated documentation gap is opened on the safeguarding or incident register and reviewed by governance.

10. Training

Everyone in the Service is trained in safeguarding children and adults to the level their role requires, in recognising exploitation, and in the referral routes, and is refreshed on the required cadence. A named safeguarding lead and deputy are in place. The Service records training and the next refresher dates.

11. Audit cadence

The Service checks, on a stated cadence, that:

• competence and risk were assessed and recorded for under-18 attendances
• the recognised exploitation tool was used and indicators acted on
• age thresholds were applied correctly, with under-13 disclosures referred
• safeguarding concerns were referred promptly under local procedures, with outcomes recorded
• staff safeguarding training and the named lead arrangements are current

The Registered Manager and the safeguarding lead review the results and record the improvement actions that follow.

12. 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.

• CQC Regulation 13: Safeguarding service users from abuse and improper treatment
• CQC Regulation 11: Need for consent
• The Fraser guidelines and Gillick competence (verify the current position)
• GMC, 0-18 years: guidance for all doctors: https://www.gmc-uk.org/professional-standards/professional-standards-for-doctors/0-18-years
• Mental Capacity Act 2005 (where a young person aged 16 or 17 may lack capacity for a decision)
• Montgomery consent principles
• GMC consent and decision-making guidance
• HM Government, Working Together to Safeguard Children 2026: https://www.gov.uk/government/publications/working-together-to-safeguard-children--2
• Keeping Children Safe in Education 2025 (where education-adjacent)
• Local Safeguarding Children Partnership procedures
• BASHH / Brook, Spotting the Signs proforma for child sexual exploitation: https://www.bashh.org/
• Care Act 2014, section 42 (adults at risk): https://www.legislation.gov.uk/ukpga/2014/23/section/42
• Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, Regulation 13 (safeguarding from abuse): https://www.legislation.gov.uk/uksi/2014/2936/regulation/13

Related reading

• Related policy: Safeguarding children policy
• Related policy: Safeguarding adults policy
• Related policy: Confidentiality in sexual health policy
• Related policy: Chaperones and intimate examinations policy
• Related policy: Consent policy

13. 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.

14. Document control

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.