Safeguarding Policy

Safeguarding Policy

INTRODUCTION

This policy and supporting procedures set out Acumen Community Buildings’ approach to safeguarding the interests of the diverse groups it works with incorporating employees, associates, volunteers, agents, contractors, partners, sub-contractors, Directors, clients and service users. The policy provides principles that must be followed in line with Acumen Community Buildings’ commitment to the safeguarding of children and vulnerable adults. The procedures (Section 2) include:

Detailed explanations of the different types of abuse
Guidelines on how to identify potential of abuse of children and vulnerable adults
The management of risk
What to do if you witness an event/incident relating to safeguarding
What to do in the event of a disclosure

How to make a referral including provision of the relevant forms for reporting a disclosure or incident involving a Acumen Community Buildings employee, associate or volunteer and non-Acumen Community Buildings employees or volunteers.

SCOPE

This policy applies to all established employees, volunteers, agents, contractors, partners, sub-contractors, Directors, clients and service users who are required to adhere to the principles and procedures.

The following table identifies who within Acumen Community Buildings is Accountable, Responsible, Informed or Consulted with regards to this policy. The following definitions apply:

Responsible – the person(s) responsible for developing and implementing the policy.
Accountable – the person who has ultimate accountability and authority for the policy.
Consulted – the person(s) or groups to be consulted prior to final policy implementation or amendment.
Informed – the person(s) or groups to be informed after policy implementation or amendment.

Responsible	Directors/Trustee
Accountable	Directors/Trustees
Consulted	All staff
Informed	All staff and volunteers,

POLICY STATEMENT

Acumen Community Buildings is fully committed to all aspects of safeguarding children and vulnerable adults and places the welfare of their client/user groups as their paramount consideration.

Acumen Community Buildings recognises that they work with diverse client groups and believe that everyone has the right to be respected and protected from all forms of violence, harm, abuse, and loss (material, psychological or physical) or exploitation whether intentional or unintentional. Acumen Community Buildings regards all individuals who are clients/users of their services as being potentially vulnerable and aims to protect their best interests at all times.

This policy has universal application across Acumen Community Buildings and directly or indirectly influences the actions of all employees, associates, volunteers, agents, contractors, partners, sub-contractors, Directors, clients and users of Acumen Community Buildings

This policy places a duty on all employees to fulfil their responsibility to safeguard and protect the welfare of children and vulnerable adults and to report any abuse discovered or suspected.

Acumen Community Buildings will work in co-operation with all relevant statutory services and with appropriate national or local inter-agency guidelines in response to any actual, alleged or suspected instance of violence, harm, abuse, loss or exploitation. Acumen Community Buildings is committed to providing protection for children, young people and vulnerable adults by:

Carrying out its responsibilities in accordance with all relevant legislation, regulations and formal guidance to ensure the protection of children and vulnerable adults.
Adhering to its safeguarding policy and procedure and by ensuring that it has robust policy and procedures in place;
Carefully following the procedures laid down for the recruitment and selection of staff and volunteers;

Providing effective management for staff and volunteers through supervision, support and training;
Implementing clear procedures so that staff and volunteers know how to report and respond to safeguarding issues relating to service users, and involving service users appropriately;
Ensuring general safety and risk management procedures are adhered to;
Proactively and collaboratively working with appropriate local agencies and commissioners to ensure all service delivery demonstrates safeguarding commitments.
Allocating sufficient resources to implement, maintain and review this policy and procedures.

Promoting full participation and having clear procedures for dealing with concerns and complaints;
Managing personal information, confidentiality and information sharing;
Proactively and collaboratively working with appropriate local agencies and commissioners to ensure all service delivery activity demonstrates safeguarding commitments;
Allocating a Designated Person to investigate and deal with allegations against employees;
Communicating and sharing this policy and procedures with all parents/carers of children under 18 with whom Acumen Community Buildings work;

Communicating with children and vulnerable adults the standard of behaviour they can expect from Acumen Community Buildings’ employees and what to do if they experience or suspect abuse, and ,

Safeguarding children, young people and vulnerable adults by implementing a code of behaviour for all involved with the organisation, including visitors.

LEGISLATION

This document is Acumen Community Buildings’ policy and procedures for complying with Safeguarding of Children and Vulnerable Adults and has been drawn up to support the following primary and secondary legislation:

Primary

The Children Act 1989 and 2004

The legislative bases for protecting Children & Young People are the Children Acts of 1989 and 2004. Children & Young People have a legal right to be protected from harm under the Children Act 1989 and also the European Convention of Human Rights. The Children Act 1989 is the legislative basis both for protecting Children & Young People from significant harm and promoting the provision of services for Children & Young People in need.

The Children Act 2004 sets out the vision for Children & Young People in terms of five key outcomes: Staying safe; being healthy; enjoying and achieving; making a positive contribution and achieving economic wellbeing. The staying safe outcome is underpinned by a statutory duty of all agencies working with Children & Young People to promote safeguarding in the way it carries out its function. Section 11 of The Children Act 2004 says that every organisation working with children, young people and parents that receives grant funding must show that they are run safely.

Safeguarding Vulnerable Groups Act 2006

The SVGA provides the legislative framework for the introduction of the new Vetting and Barring Scheme for those working with children and vulnerable adults (in response to the Bichard Enquiry 2004). The aim of the scheme is to bar individuals from working in situations where evidence suggests that they present a risk of harm to children and vulnerable adults.

The Disability Discrimination Act 1995

This Act introduced new laws and measures aimed at ending the discrimination faced by many disabled young people and adult in the fields of employment; access to goods, facilities and services; and the management, buying or renting of property. The discrimination occurs when, for a reason related to an individual’s disability, they are treated less favourably than other people to whom the reason does not apply, and this treatment cannot be justified. It also applies when an employer or service provider fails to make a reasonable adjustment in relation to the disabled person, and the failure cannot be justified.

The Human Rights Act 1998

The rights of vulnerable adults to live a life free from neglect, exploitation and abuse are protected by the Human Rights Act 1998. Specifically, a vulnerable adult’s right to life protected (under Article 2); their right to be protected from inhuman and degrading treatment (under Article 3); and their right to liberty and security (under Article 5).

Secondary

The Sexual Offences Act 2003
The Police Act 1997 Section 115 (4)

The Education Act 2002 Section 175
Independent Safeguarding Authority (ISA) and the Vetting and Barring Scheme (www.isa-gov.uk)
Every Child Matters

National & Local Guidance: Safeguarding responsibilities for all agencies

The government guide to interagency practice for keeping children and young people safe, Working Together to Safeguard Children: A guide to inter-agency working to safeguard and promote the welfare of children (DCSF, 2010), sets out the responsibilities for all agencies, including voluntary and private sector organisations, to make arrangements for safeguarding and promoting the welfare of the children and young people with whom they work. The detail of those responsibilities is contained in paragraph 2.11 of Working Together (DCSF, 2010).

The associated practice guidance, ‘What to Do if you’re worried a child is being abused’ provides information for staff and volunteers about signs and symptoms of abuse and what to do if there are concerns. There are copies in each User Voice office, and on the shared intranet, and they are available from the DOH website.

Safeguarding Children Boards

[Area] Safeguarding Children Boards came into being as a result of the Children Act 2004 that requires all Local Authorities to establish a Children Safeguarding Board. It replaces what used to be known as the Area Child Protection Committees and are now the key legislative body established to ensure that organisations across geographical areas work together.

The board itself is made up of senior managers from statutory organisations and include voluntary sector representation. They aim to work closely and in partnership to make sure that children and young people who use their services not only stay safe, but also achieve better outcomes.

Each area Children’s Safeguarding Board has a website which includes a dedicated Voluntary & Community Sector section as well as key information for organisations, parents, children and young people with useful links as well as multi-agency training schedules that are accessible to voluntary sector organisations that work directly with children/young people.

Sunderland Safeguarding board can be found at: www.sunderlandscb.com

Supporting Internal Policies and Procedures

Recruitment and Selection
GDPR
Health and Safety
ICT Usage

Grievance and Discipline
Whistleblowing

DEFINITIONS

“Safeguarding”: As set out in this policy and procedures; being vigilant in minimising and managing risk of harm and abuse to children and adults who are vulnerable.

“Safeguarding for Children and Young People”: Defined within the Government Working Together to Safeguard Children 2010 Guidance as: “The process of protecting children from abuse or neglect, preventing impairment of their health and development, and ensuring they are growing up in circumstances consistent with the provision of safe and effective care that enables children to have optimum life chances and enter adulthood successfully.”

Which includes:

Protecting Children & Young People from maltreatment
Preventing impairment of Children’s & Young People’s health or development
.Ensuring that Children and Young People grow up in circumstances consistent with the provision of safe and effective care, and
Undertaking that role so as to enable Children & Young People to have optimum life chances and enter adulthood successfully.

“Child Protection”: Working Together (DCSF, 2010) defines child protection as the: “Process of protecting individual children identified as either suffering, or likely to suffer, significant harm as a result of abuse or neglect.” Child Protection is a part of safeguarding and refers to the specific activity that is undertaken to protect Children & Young People who are suffering, or who are at likely future risk of suffering significant harm.

“A child”: Someone under the age of 18 (Section 60, Safeguarding Vulnerable Groups Act 2006)

“Vulnerable Adult”: Section 59 of the Safeguarding Vulnerable Groups Act 2006 defines a vulnerable adult as follows:

A person is a vulnerable adult if they have attained the age of 18 and:
Is in residential accommodation
Is in sheltered housing
Receives domiciliary care

Receives any form of health care
Is detained in lawful custody
Is by virtue of an order of a court under supervision by a person exercising functions for the purpose of Part 1 of the Criminal Justice and Court Services Act 2000 (c.3)
Receives a welfare service of a prescribed description
Receives any service or participates in any activity [provided specifically for persons who fall within sub-section (9)

Payments are made to them (or to another on their behalf) in pursuance of arrangements under section 57 of the Health and Social Care Act 2001 (c.15), or
They require assistance in the conduct of their own affairs.

RESPONSIBILITIES

All persons and organisations referred to within the scope of this policy are expected to be familiar with the requirements of this policy.

Any person at Acumen Community Buildings, in charge of, or working with children and/or vulnerable adults has a duty of care to each individual. The duty rests upon everyone to take reasonable steps to ensure the safety of children and vulnerable adults involved in and of the activities or interaction for which they are responsible on behalf of Acumen Community Buildings.

Directors: Will ensure the dissemination of safeguarding information and will work with the senior manager to understand and implement the legislative obligations of all services they provide.

6.2.2 Managers: Managers must ensure information in relation to Safeguarding is disseminated across all employees and volunteers. Managers must ensure:

They follow the correct selection and recruitment procedures
New employees undertake safeguarding training within the first two weeks of appointment.
They advise any appointed Safeguarding Officer of any new programme or service that involves young people or vulnerable adults to ensure the correct procedures have been implemented.
They comply with the Designated Person for Safeguarding if an allegation is made against any employee under their supervision.

6.2.3 Employees: All employees are responsible for:

Reading and understanding this policy and procedures and if in doubt contact their line manager.
Undertaking safeguarding training within the first two weeks of appointment.
Know who their Designated Person for Safeguarding is.
Knowing how to deal with someone disclosing.

Knowing the disclosing reporting procedure.
Understanding the process for taking a disclosure

6.2.4 The designated Safeguarding Lead is to:

Chair any special safeguarding group meetings which monitor this policy and also monitor cases of reported allegations, or risk, to ensure their appropriate referral.

Assist with the planning and implementation of safeguarding for new programme, activities and services.
Receive information from any employee (including sub-contractors and volunteers) who have non-disclosure safeguarding concerns and record such concerns.
Assess the most appropriate route for an employee referral and to obtain more information about the matter.
Make a formal referral to police, the ISA or other agency as appropriate.
Support the senior management/Human Resources with safer recruitment practices.

Manage the risk of misplaced or malicious allegations made against individuals who work with young people or vulnerable adults.
Ensure that employers, work placement providers and sub-contractors are risk assessed and have their own exemplary safeguarding policies and procedures.
To receive information relating to Safeguarding disclosures from employees, clients/users and volunteers, appropriately advising them and giving them guidance on the reporting or referral of disclosures in line with Acumen Community Buildings’ reporting guidelines and procedures.
To investigate complaints against employees and volunteers and make appropriate referrals/reports adhering to Acumen Community Buildings’ guidelines and procedures. Where a child protection allegation has been made the designated person will take advice from the main local safeguarding board regarding investigation.
To be the key point of contact for all in matters relating to Safeguarding.

To assess information received promptly and carefully, clarifying ad obtaining more information as appropriate.
To consult in cases of uncertainty with the Safeguarding Officer or statutory Safeguarding agency to seek reassurance.
To refer cases of suspected abuse or allegation of abuse to the relevant investigating authority. Where the abuse involved a child to make a formal referral to Police, ISA or other statutory agency as appropriate.
To maintain confidentiality at all times, based strictly on a need-to-know basis.

6.3 The designated Safeguarding Lead for Acumen Community Buildings is Kate Welch, Chair of Trustees. Contact details for the Chair are: 0191 386 9785 or 07809 330 102. All correspondence should be addressed to The Old Rectory, The Broadway, Houghton-le-Spring DH4 4BB.

DISCIPLINARY

7.1 Where an allegation against a member of staff regarding a child or vulnerable adult protection issue has been raised a decision will be made regarding the way forward including:

Suspension pending a full investigation – suspension with regards to a safeguarding investigation is not a form of disciplinary action. Management will remain in contact with the employee on as regular basis during any period of suspension and where appropriate keep them updated on the progress of the investigation.
Suspension of contact with the child or vulnerable person.
If appropriate, temporary e redeployment to another role.
Working under direct supervision.

If an allegation is upheld against an employee, Acumen Community Buildings is obligated to inform the Independent Safeguarding Authority.

If Acumen Community Buildings is made aware that an employee is barred by the Independent Safeguarding Authority they will be immediately suspended and investigated for gross misconduct.

In the case of employees, Acumen Community Buildings all instances of criminal activity will be reported to the Police and ISA.

FURTHER INFORMATION AND SOURCES OF REFERENCE

You can find more information on Safeguarding from the following sources:

Working Together to Safeguard Children 2006
Safeguarding Vulnerable Groups Act www.legislation.gov.uk/pga/2006/47/contents
Safeguarding Children and Safer Recruitment in Education (DCSF statutory code of practice 2007.

The Children’s Plan (DCSF).
Ofsted – Common Inspection Framework – Safeguarding and Every Child Matters.
There is also guidance for action to be taken outside work by any citizen contained in the document “What To Do If You Think a Child Is Being Abused”.
There is also protection from bullying and harassment under a range of European and UK laws including the Treaty of Amsterdam and Equality Act 2006: (Age, Race, Disability, Gender and Gender Reassignment, Religion and Belief, and Sexual Orientation). Protection from Harassment Act and the Gender Directive 2008.

REVIEW OF THIS POLICY

9.1 It is the responsibility of the Board of Directors of Acumen Community Buildings, supported by all staff and volunteers, to implement and review this policy. This policy will be reviewed at a minimum on an annual basis.

SECTION 2 – SAFEGUARDING PROCEDURES

WHAT IS SAFEGUARDING?

1.1 Safeguarding is about managing a safe environment for children and young people and vulnerable adults to access. It combines an approach to safety that draws together both reactive and preventative approaches to the management of the vulnerable and their well-being. Safeguarding is not about restricting activities. It is about taking a balanced approach to children and young people’s and adults’ safety and protection. Any organisation that provides or organises activities or interventions for children and young people or vulnerable adults should be able to deal with situations when they arise, but also be able to take all reasonable steps to prevent, wherever possible, situations arising in the first place.

1.2 A Safeguarding system that is shared and used by everyone involved with the organisation will promote confidence and trust. More importantly it will act as a deterrent for those individuals who may wish to harm children, young people and vulnerable adults. It is also about ensuring that the organisations practices and procedures are aligned with national and local frameworks for identifying and reporting abuse when it occurs.

WHAT DOES A SAFEGUARDING SYSTEM LOOK LIKE?

2.1 Safeguarding goes beyond having protection policies and procedures in place. It is about a system of preventative measures that collectively ensure the safety and well-being of any vulnerable person during activities or interventions.

RECOGNISING ABUSE – CHILDREN AND YOUNG PEOPLE

3.1 Children and Young People can be abused either through someone inflicting harm, or failing to act to prevent harm. Any child or young person from any culture, faith or background can be at risk of abuse. Abuse can take place in a family, in an institution or community setting, by telephone or on the Internet. Abuse can be carried out by someone known to the child or young person or by a complete stranger. Extreme care should be taken as misreading signs of abuse can result in significant harm or trauma to the child and their family. In general staff employed in the independent and voluntary sector will not have the expertise to diagnose child abuse but do have a responsibility to be alert and aware of the signs. However, just because a child or young person exhibits one of the signs listed below, this does not necessarily mean that they have been abused.

3.2 Nevertheless, the presence of one or more of the signs, or their repeated presence, might raise concerns and should be used as a prompt for discussion with the designated child protection employee of your organisation without delay. However, where a child or young person has made a direct allegation or there is clear evidence of a child or young person suffering or at risk of suffering significant harm the matter should be referred immediately to Children & Young People’s Services or the Police.

3.3 The government identifies four kinds of child abuse:

3.3.1 Physical Abuse

This may involve hitting, shaking, throwing, burning, scalding and suffocating as well as other forms of physical abuse. It can also result when a parent or carer deliberately causes ill health of a child or young person. This is described as fabricated or induced illness. Symptoms that indicate physical abuse include:

Any injury, bruises, bites, burns, fractures, etc., which are not consistent with the explanation given for them.
Injuries which occur to the body in places which are not normally exposed to falls, rough games, etc.

Injures which appear to have been caused by a weapon e.g. cuts, welts, etc.
Injuries which have not received medical attention
Instances where Children or Young People are kept away from the group inappropriately or without explanation
Self-mutilation or self-harm e.g. cutting, slashing, drug abuse

3.3.2 Emotional Abuse

Emotional abuse happens when a child or young person needs for love, security, praise and recognition are not met. It usually co-exists with other forms of abuse but can occur alone. Emotionally abusive behaviour occurs if a parent, carer or authority figure is consistently hostile, rejecting, threatening or undermining. It can result if developmentally inappropriate expectations are placed on a child or young person or if a child or young person is over protected to the extent of being denied contact or opportunities to engage with others. Additionally, Children & Young People who witness or experience domestic violence are subject to emotional abuse. Symptoms include:

Changes or regression in mood and behaviour, particularly where a child or young person withdraws or becomes clinging. Also depression/aggression
Nervousness/inappropriate fear of particular adults e.g. frozen watchfulness

Sudden changes in behaviour e.g. under-achievement or lack of concentration
Inappropriate relationships with peers and/or adults e.g. excessive dependence
Attention-seeking behaviour
Persistent tiredness
Wetting or soiling of bed or clothes by an older child

Eating disorders/various mental health problems
Despondency
Very low self-esteem

3.3.3 Neglect

Neglect is the persistent failure to meet a child or young person’s basic physical and or psychological needs, causing damage to their health and development. It may involve a parent or carer failing to provide adequate food, warmth, shelter, clothing or stimulation. It includes failure to protect a child or young person from harm or danger or failure to seek medical care needed. Symptoms can include:

Regular poor hygiene
Persistent tiredness
Inadequate clothing

A child or young person who is constantly hungry, stealing or gorging food
Failure to thrive e.g. poor weight gain
Consistently being left alone and unsupervised
Lack of stimulation, social contact or education
Failure to seek or follow medical advice so that a child or young person’s life or development is endangered

3.3.4 Sexual Abuse

Sexual abuse involves forcing or enticing a child or young person to take part in sexual activity, whether or not the child or young person is aware of what is happening. This may include physical contact, from inappropriate touching to full penetration, and also non-contact activity such as looking at pornography. Under the Sexual Offences Act 2003, any sexual activity with a child under the age of 13 is a crime. Symptoms of sexual abuse include:

Any direct disclosure made by a child or young person concerning sexual abuse

A child or young person with excessive preoccupation with sexual matters and detailed knowledge of adult sexual behaviour, or who regularly engages in age inappropriate sexual play
Preoccupation with sexual activity through words, play or drawing
A child or young person who is sexually provocative or seductive with adults
Inappropriate bed-sharing arrangements at home
Genital soreness or discomfort

STDs, urinary infections
Nightmares/other disturbances
Eating disorders
Going missing from home/school
Self harm

Drug & or alcohol abuse
Depression and other forms of mental health problems

3.4 Some members of our communities hold beliefs that may be common within particular cultures; Acumen Community Buildings does not condone practices that are harmful to children. Examples include:

Forced Marriages. No faith supports the idea of forcing someone to marry without consent. This should not be confused with arranged marriage between consenting adults.

Under-age marriages. In the UK, a young person cannot legally marry nor have a sexual relationship until they are 16.
Female Genital Mutilation (previously known as, or sometimes called Female Circumcision). This is a form of physical abuse and is against the law, although it is known that some communities see it as a cultural requirement. This is an extremely harmful and dangerous practice that carries a severe penalty of imprisonment. It is also illegal for someone to arrange for a child to go abroad with the intention of having her circumcised.
Child Abuse linked to a belief in Spirit Possession or Witchcraft; or in other ways related to spiritual or religious belief. Some faiths believe that spirits and demons can possess children and that they need to be driven out. What should never be condoned is the use of physical violence or other abusive practices to get rid of the spirit. This is a form of abuse and can lead to prosecution even if the intention was to help the child. The Churches Child Protection Advisory Service has worked with Ministers from various faiths, to develop guidance to safeguard children and young people in faith communities. This includes advice on safe prayer practices.
Trafficked Children. Child trafficking is the movement of Children & Young People for exploitation purposes. Children & Young People cannot give informed consent to trafficking. This should not be confused with smuggling. In human smuggling, immigrant & asylum seekers pay people to help them enter the country illegally, after which there is no longer a relationship. Trafficked victims are coerced or deceived by the person arranging their relocation and then forced into exploitation by the trafficker or person into whose control they are delivered or sold.
Abuse through ‘Gang’ membership. This abuse is synonymous with a need for the child or young person to ‘belong’, resulting in a desire to defend territory or reputation. This should not be confused with delinquent behaviour such as knife carrying, which in the main is motivated by fear and not a desire to defend territory or reputation. It should be noted that girls can also be involved as gang members, or as associates (i.e. sisters, friends, and girlfriends of gang members) and may be subject to sexual violence and exploitation within the gang culture.

For further information, guidance and advice please refer to your local Area Safeguarding Board Procedures.

4. RECOGNISING ABUSE – ADULTS

4.1 What constitutes abuse? In drawing up guidance, it needs to be recognised that the term ‘abuse’ can be subject to wide interpretation. The starting point for a definition is the following statement: “Abuse is a violation of an individual’s human and civil rights by any other person or persons”.

4.2 In giving substance to that statement, however, consideration needs to be given to a number of factors. Abuse may consist of a single act or repeated acts. It may be physical, verbal or psychological, it may be an act of neglect or an omission to act, or it may occur when a vulnerable person is persuaded to enter into a financial or sexual transaction to which he or she has not consented, or cannot consent. Abuse can occur in any relationship and may result in significant harm to, or exploitation of, the person subjected to it. A consensus has emerged identifying the following main different forms of abuse:

Physical abuse – including hitting, slapping, pushing, kicking, misuse of medication, restraint, or inappropriate sanctions;

Sexual abuse – including rape and sexual assault or sexual acts to which the vulnerable adult has not consented, or could not consent or was pressured into consenting;

Psychological abuse – including emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, isolation or withdrawal from services or supportive networks;

Financial or material abuse – including theft, fraud, exploitation, pressure in connection with wills, property or inheritance or financial transactions, or the misuse or misappropriation of property, possessions or benefits;

Neglect and acts of omission – including ignoring medical or physical care needs, failure to provide access to appropriate health, social care or educational services, the withholding of the necessities of life, such as medication, adequate nutrition and heating.

Discriminatory abuse – including racist, sexist, that based on a person’s disability, and other forms of harassment, slurs or similar treatment.

Any or all of these types of abuse may be perpetrated as the result of deliberate intent, negligence or ignorance.

4.3 Incidents of abuse may be multiple, either to one person in a continuing relationship or service context or to more than one person at a time. This makes it important to look beyond the single incident or breach in standards to underlying dynamics and patterns of harm. Some instances of abuse will constitute a criminal offence. In this respect vulnerable adults are entitled to the protection of the law in the same way as any other member of the public. In addition, statutory offences have been created which specifically protect those who may be incapacitated in various ways. Examples of actions which may constitute criminal offences are assault, whether physical or psychological, sexual assault and rape, theft, fraud or other forms of financial exploitation, and certain forms of discrimination, whether on racial or gender grounds. Alleged criminal offences differ from all other non-criminal forms of abuse in that the responsibility for initiating action invariably rests with the state in the form of the police and the Crown Prosecution Service (private prosecutions are theoretically possible but wholly exceptional in practice). Accordingly, when complaints about alleged abuse suggest that a criminal offence may have been committed it is imperative that reference should be made to the police as a matter of urgency. Criminal investigation by the police takes priority over all other lines of enquiry.

4.4 Neglect and poor professional practice also need to be taken into account. This may take the form of isolated incidents of poor or unsatisfactory professional practice, at one end of the spectrum, through to pervasive ill treatment or gross misconduct at the other. Repeated instances of poor care may be an indication of more serious problems and this is sometimes referred to as institutional abuse.

5. WHO MAY BE THE ABUSER?

5.1 Vulnerable adult(s) may be abused by a wide range of people including relatives and family members, professional staff, paid care workers, volunteers, other service users, neighbours, friends and associates, people who deliberately exploit vulnerable people and strangers. There is often particular concern when abuse is perpetrated by someone in a position of power or authority who uses his or her position to the detriment of the health, safety, welfare and general wellbeing of a vulnerable person.

5.2 Agencies not only have a responsibility to all vulnerable adults who have been abused but may also have responsibilities in relation to some perpetrators of abuse. The roles, powers and duties of the various agencies in relation to the perpetrator will vary depending on whether the latter is:

a member of staff, proprietor or service manager;
a member of a recognised professional group;
a volunteer or member of a community group such as place of worship or social club
another service user;

a spouse, relative or member of the person’s social network; a carer; ie: someone who is eligible for an assessment under the Carers (Recognition and Services) Act 1996; a neighbour, member of the public or stranger; or
a person who deliberately targets vulnerable people in order to exploit them.

5.3 Stranger abuse will warrant a different kind of response from that appropriate to abuse in an on-going relationship or in a care location. Nevertheless, in some instances it may be appropriate to use the locally agreed inter-agency adult protection procedures to ensure that the vulnerable person receives the services and support that they need. Such procedures may also be used when there is the potential for harm to other vulnerable people.

6. IN WHAT CIRCUMSTANCES MAY ABUSE OCCUR?

6.1 Abuse can take place in any context. It may occur when a vulnerable adult lives alone or with a relative; it may also occur within nursing, residential or day care settings, in hospitals, custodial situations, support services into people’s own homes, and other places previously assumed safe, or in public places.

6.2 Intervention will partly be determined by the environment or the context in which the abuse has occurred. Nursing, residential care homes and placement schemes are subject to regulatory controls set out in legislation and relevant guidance. Day care settings are not currently regulated in this way and require different kinds of monitoring and intervention to address similar risks. Paid care staff in domiciliary services may work with little or no supervision or scrutiny, and unregulated locations such as sheltered housing may require particular vigilance. Personal and family relationships within domiciliary locations may be equally complex and difficult to assess and intervene in.

6.3 Assessment of the environment, or context, is relevant, because exploitation, deception, misuse of authority, intimidation or coercion may render a vulnerable adult incapable of making his or her own decisions. Thus, it may be important for the vulnerable adult to be away from the sphere of influence of the abusive person or the setting in order to be able to make a free choice about how to proceed. An initial rejection of help should not always be taken at face value.

7. PATTERNS OF ABUSE/ABUSING

7.1 Patterns of abuse and abusing vary and reflect very different dynamics. These include:

serial abusing in which the perpetrator seeks out and ‘grooms’ vulnerable individuals. Sexual abuse usually falls into this pattern as do some forms of financial abuse;
long term abuse in the context of an ongoing family relationship such as domestic violence between spouses or generations;
opportunistic abuse such as theft occurring because money has been left around;
situational abuse which arises because pressures have built up and/or because of difficult or challenging behaviour;

neglect of a person’s needs because those around him or her are not able to be responsible for their care, for example if the carer has difficulties attributable to such issues as debt, alcohol or mental health problems;
institutional abuse which features poor care standards, lack of positive responses to complex needs, rigid routines, inadequate staffing and an insufficient knowledge base within the service;
unacceptable ‘treatments’ or programmes which include sanctions or punishment such as withholding of food and drink, seclusion, unnecessary and unauthorised use of control and restraint or over-medication;
failure of agencies to ensure staff receive appropriate guidance on anti-racist and anti-discriminatory practice;
failure to access key services such as health care, dentistry, prostheses;

misappropriation of benefits and/or use of the person’s money by other members of the household;
fraud or intimidation in connection with wills, property or other assets.

8. WHAT DEGREE OF ABUSE JUSTIFIES INTERVENTION?

8.1 In determining how serious or extensive abuse must be to justify intervention a useful starting point can be found in Who decides? Building on the concept of ‘significant harm’ introduced in the Children Act, the Law Commission suggested that:

“‘harm’ should be taken to include not only ill treatment (including sexual abuse and forms of ill treatment which are not physical), but also the impairment of, or an avoidable deterioration in, physical or mental health; and the impairment of physical, intellectual, emotional, social or behavioural development.”

8.2 The seriousness or extent of abuse is often not clear when anxiety is first expressed. It is important, therefore, when considering the appropriateness of intervention, to approach reports of incidents or allegations with an open mind. In making any assessment of seriousness the following factors need to be considered:

the vulnerability of the individual;
the nature and extent of the abuse;

the length of time it has been occurring;
the impact on the individual;
and the risk of repeated or increasingly serious acts involving this or other vulnerable adults.

8.3 What this means in practice is working through a process of assessment to evaluate:

Is the person suffering harm or exploitation?

Does the person suffering or causing harm/exploitation meet the NHS and Community Care Act (1990) eligibility criteria?
Is the intervention in the best interests of the vulnerable adult fitting the criteria and/or in the public interest?
Does the assessment account for the depth and conviction of the feelings of the person alleging the abuse?

INTER-AGENCY PROCEDURES

All areas have Inter-Agency Partnership Procedures that work within a shared framework for the protection of vulnerable adults. NB. User Led Groups and Services are also bound by this framework.

When an allegation of abuse is made, Acumen Community Buildings must always notify the appropriate regulatory body, within any stipulated time limits, and also any other authority who may be using the services of Acumen Community Buildings.

An effective response to the abuse of vulnerable adults requires not only effective inter-agency and inter-professional collaboration but also similar collaboration at all levels within agencies. Roles and responsibilities should be clear, and collaboration should take place at all the following levels:

operational;
supervisory line management;
senior management staff;

Operational level

Operational staff are responsible for identifying, investigating and responding to allegations of abuse. There needs to be a common understanding about what constitutes abuse and what the initial response to an allegation or suspicion of abuse should be and a shared understanding about assessment and investigation processes and joint arrangements for decision making.

Supervisory line management level

Managers with responsibility for overseeing and supervising the investigation of, and response to, adult abuse are responsible for ensuring that all appropriate agencies are involved in the investigation and the provision of support, and that good standards of practice are maintained.

Senior management level

A senior manager should be identified in each agency to take the lead role with regard to the development of the policy and strategy, issuing operational guidance, promoting good practice, making policy recommendations and negotiating with other agencies within an inter-agency framework.

You can find more details in the following guidance:

Department of Health – No secrets: guidance on developing and implementing multi-agency policies and procedures to protect vulnerable adults from abuse.”
Safeguarding Vulnerable Adults: A Shared Responsibility. Standards & Guidance for Good Practice in Safeguarding Vulnerable Adults (Volunteer Now)

10 THE MANAGEMENT OF RISK

10.1 Risk management in the context of safeguarding for Acumen Community Buildings employees is to understand the different forms of abuse, recognising signs of abuse, how to act on them and how to report. Management of risk is a crucial part of Acumen Community Buildings’ safeguarding policy and should be minimised by undertaking the following procedures:

10.1.1 Safer Recruitment: Acumen Community Buildings’ selection and recruitment policy reflects the requirements of safeguarding including a recognition that certain jobs within the organisation require in-depth vetting and verification of applicants. This will require DBS disclosures.

10.1.2 Employees: Employees need to be aware of placing themselves in situations where safeguarding or abuse allegations can arise. Particular attention should be given when:

Working in one-to-one situations with a client or other vulnerable person.
Transporting clients or volunteers by car on a one-to-one basis.

Undertaking home visits on your own.
Using outreach venues for one-to-one meetings with a client or other vulnerable person.
Working in a room with no internal vision panel.

10.1.3 Clients, Young Persons and Volunteers; Clients and volunteers must undergo a comprehensive and easily understood induction that covers health and safety, diversity and inclusion and safeguarding which must include:

Safeguarding awareness and how to recognise abuse, discrimination, bullying and harassment including cyber-bullying and what action to take if they, or other young persons, clients or volunteers are subject to such treatment.
The complaints and grievance procedure for a young person, client or volunteer including explanations on what they should do if they have complaints about safety-related matters.
Reinforcement of messages made at progress reviews under Health and Safety

10.1.4 Host Employers and Sub Contractors: Host employers must be made aware of Acumen Community Buildings’ safeguarding and Health and Safety requirements. This will help to ensure that young people, clients or volunteers understand the concepts of harassment and abuse and know where to go to get help. Safeguarding questions will be included in the workplace assessments carried out prior to placing clients with host organisations.

10.1.5 On line Safety/ICT Usage: Acumen Community Buildings’ ICT Usage Policy ensures all employees are responsible for the prevention of loss misplacement or unauthorised access to confidential information including client details. Children and vulnerable adults can be susceptible to exploitation or abuse through the IT medium. It is important that employees and volunteers are aware of these potential risks and that steps are taken to mitigate this risk of occurring. Specifically:

Content – e.g. exposure to age appropriate material, inaccurate or misleading information, socially unacceptable material (e.g. inciting violence, hate or intolerance), and illegal material. Acumen Community Buildings will seek to uses technology to mitigate and prevent this risk.
Contact – e.g. grooming using communication technologies leading to inappropriate behaviour or abuse.
Commerce – e.g. exposure to inappropriate advertising, on-line gambling, identity theft and financial scams. Acumen Community Buildings will seek to uses technology to mitigate and prevent this risk.

Culture – e.g. bullying via websites, mobile phones or other communication technologies, or inappropriate downloading of copyright materials (i.e. music, films, images), exposure to inappropriate advertising, online gambling and financial scams.

Training for employees and volunteers will raise awareness of these issues.

11 WHAT TO DO IF YOU WITNESS AN EVENT/INCIDENT RELATING TO SAFEGUARDING

11.1 If you witness an incident you must do all you can to stop the abuse immediately without putting yourself or the victim at any further risk.

Note: A client, volunteer or employee may decide to remain in a situation of high risk event if a lower risk option may be available. If the person is judged as having the capacity to make this decision and is over the age of 18, employees should ensure that the person is supported and everything possible id done to reduce the likelihood of harm occurring. Regular reviews will need to be carried out to respond to a change in the situation and this process should be clearly recorded throughout.

Contacting the police

Direct calls to the police should be reserved for incident of assault and violence where an element of urgency applies. If you require immediate response and assistance from the police – that is if you cannot stop the incident that is currently happening or you think that it will reoccur in shortly – you should made an emergency 999 call.

11.1.1 Is it safeguarding? For a situation to be considered as safeguarding in relation to Acumen Community Buildings’ policy, the person suspected of being harmed or abused must be a child or vulnerable adult as specified in Section 5 of this policy document (Definitions). If a person is not classed as vulnerable Acumen Community Buildings still has a duty of care to protect them from harm.

Violence – with any form of violence, and without putting yourself at risk of harm, you must inform the perpetrator of your concerns and advise them to stop the action immediately. Ask them to move themselves to an area where there is no contact with other people. Advise them that you are calling the police. If the perpetrator does stop and leaves the scene as request it is essential that you, or another employee, stays with the victim until they can be handed over to the care of another responsible adult.

Note: One-off acts of violence are a code of conduct issue and not a formal safeguarding issues and must be managed accordingly. Judgement needs to be made to establish if it is a one off occurrence.

11.1.2 Is it abuse? There are many permutations of ‘suspected incidents’ so you will have to make a judgement of the situation. You need to make sure you have a clear understanding of what may be happening. This is not investigating, it is just gaining an understanding of the situation.

Therefore, the first thing to do is establish the facts. For example:

If you see two clients touching each other inappropriately, are they in a relationship which you are unaware of?

If you see one client taking money off another, had it been borrowed previously and is now being returned?

You may need to speak to a colleague. If you are not sure and cannot establish the facts, it is acceptable to raise your concerns and discuss the situation with your manager. This will put others on the alert and everyone can keep their eyes and ears open.

Do not speak to other staff or your line manager if it involves and employee. In this instance you should contact the Designated Person for Safeguarding.

If, while you are establishing the facts the suspected victim discloses something, you should follow the disclosure process outlined in these procedures. If you are unsure you should discuss it with the Designated Person for Safeguarding.

Once you suspect or know of any abuse of a child or vulnerable adult you must immediately follow the procedures for disclosures.

12. WHAT TO DO IN THE EVENT OF A DISCLOSURE

12.1 Acumen Community Buildings employees may be made aware of safeguarding concerns from clients, parents/carers, volunteers or members of the public. The concerns may be about the behaviour of employees, volunteers, contracts or sub-contractors, relatives or friends, or another person.

12.2 It is the responsibility of the person to whom the disclosure is made or was witnessed by disclosure to report it in the first instance to Acumen Community Buildings’ designated Safeguarding Lead. The Safeguarding lead is Kate Welch, Chair of Trustees. Contact details for the Chair are: 0191 386 9785 or 07809 330 102. All correspondence should be addressed to The Old Rectory, The Broadway, Houghton-le-Spring DH4 4BB.

12.3 If the Chair is not available, or, if at any point, there is a risk of immediate serious harm to a person call 999. If there is no immediate risk call 101. To report a safeguarding concern to Sunderland’s Safeguarding Team take the following action:

If you are worried about an adult, then please report your concern online here or call Sunderland City Council’s Contact Centre number for Health & Wellbeing on 0191 520 5552.

If you are a member of the public or a professional concerned about the safety and welfare of a child or young person, further information can be found here. Or, you can contact Together for Children – Sunderland on 0191 5205560  (available 8.30am to 5.00pm Monday – Thursday, 8.30am to 4.30pm Friday); or the Out of Hours Team on 0191 520 5552 (also available 24 hours Saturday and Sunday)

12.4 Concerns should always lead to help for the Young Person or Adult at Risk. 

12.5 Receiving a Disclosure or Complaint

12.5.1 Handling of a disclosure is the same, regardless of where it comes from. If a child or vulnerable adult reports a case of apparent abuse you should listen carefully and made verbatim notes. You should:

Stay calm and focus on what you are being told.
Explain that you have a duty of care to refer the disclosure if it is a safeguarding issue.
Try and make the complainant feel safe and secure.
Allow them to speak freely, without interruption unless you need to clarify facts.
Reassure them that you are taking their complaint seriously and provide support and reassurance that they have a right to speak out.

Record the name, address, and date of birth of the complainant.
Explain how the matter will be dealt with.

Do not:

Promise confidentiality. Stress you have a duty to report the complaint if it is a safeguarding issue.
Be emotional. Showing anger, disgust or disbelief may stop the complainant talking.

Interrogate, ask leading questions or repeated. You questions should be open and aimed at gathering the facts.
Express an opinion.
Make suggestions or try to lead the discussions.

You should never:

Discuss anything with the person subject to the allegation.

Investigate the matter yourself.
Discuss the disclosure with anyone other than the Designated Person for Safeguarding or person to whom you should report the matter to in the Local Safeguarding Board.

12.5.2 If the alleged perpetrator is on-site and could come into direct contact with the alleged victim you should consider what action needs to be taken to minimise further risk and ensure the safety of both parties.

12.5.3 If the disclosure relates to something from the past, the perpetrator is dead or the victim tells does not want to pursue the issues you can give them links to local or national support groups as long as you identify the discloser is no longer at risk. If the alleged perpetrator is still living, however, you must report it to the ISA.

12.5.4 You may find that the disclosure is not a safeguarding issue but should be dealt with following other specific procedures.

12.5.5 The person to whom the disclosure is made, or who witnessed an incident, must record the information within two hours or he disclosure being made.

13. HOW TO REPORT ALLEGATIONS OR DISCLOSURES

13.1 Allegations in relation to an Acumen Community Buildings employee, contractor, sub-contractor or volunteer.

13.1.1 You should contact the Designated Person for Safeguarding who will take responsibility for any further action.

13.1.2 Where an allegation exists the employee or volunteer must be immediately suspended whilst the allegation is being investigated. No contact must be made between the alleged perpetrator and any employee or volunteer of Acumen Community Buildings. The employee will normally be suspended on full pay.

13.1.3 The allegation will be investigated by the Designated Person for Safeguarding. If the allegation is upheld the appropriate authorities will be informed.

13.2 Disclosures involving a child

These must be passed directly to the local authority child/adult protection teak without investigation.

13.3 Designated Person for Safeguarding Information Recording

The appropriate disclosure reporting or should be completed within two hours of the disclosure. Storage and access to information recorded will be managed by the Safeguarding Officer.

HOW TO MAKE A REFERRAL

Only the Designated Person for Safeguarding or the Safeguarding Officer will process referrals.

If the allegation involves a Acumen Community Buildings employee the Safeguarding Officer must be informed about the disclosure. The Designated Person will investigate and where appropriate refer the issue to the ISA.

ACUMEN COMMUNITY BUILDINGS SAFEGUARDING POLICY AND PROCEDURES

DISCLOSURE/INCIDENT FORM A – ALLEGATION AGAINST ACUMEN COMMUNITY BUILDINGS EMPLOYEE OR VOLUNTEER

Use this form to record allegations, disclosures or suspicions of abuse or harm in relation to Acumen Community Buildings employee or volunteer.

Following completion of investigations you should send the form, signed and dated, to Designated Person for Safeguarding in an envelope marked ‘Confidential – for Addressee Only’

Details about the person receiving the disclosure
Name:	Phone Nos
Email address:
Work location and special project (if relevant)
Have you informed Acumen Community Buildings’ Designated Person for Safeguarding? (delete as appropriate)	Yes		No
Name of Designated Person for Safeguarding
Date and Time Designated Person was Informed	Date: …../…./….		Time:…………….
Signature
Acumen Community Buildings Employee Accused Details
Name of Acumen Community Buildings employee accused
Job title of employee accused
Disclosure Details
Name of person making disclosure or witness statement
Location address where disclosure incident occurred
Location telephone No.
Name and contact details of any additional witnesses

Description of incident/statement of allegation/disclosure including time and date(s)

Child or Vulnerable Adult Details
Surname:
Forename:
Known as:
Gender (delete as appropriate)	Male	Female
Home Address:
Phone Nos:
Email:
Are there any health/disability/disadvantages? (delete as appropriate	Yes	No
If you have said ‘Yes’ please enter details below

Please describe any visible injury or signs e.g. bruising, behavioural changes below

ACUMEN COMMUNITY BUILDINGS SAFEGUARDING POLICY AND PROCEDURES

DISCLOSURE/INCIDENT FORM B – ALLEGATION AGAINST NON-ACUMEN COMMUNITY BUILDINGS EMPLOYEE

Use this form to record allegations, disclosures or suspicions of abuse or harm in relation to someone who is not a Acumen Community Buildings employee or volunteer.

Following completion of investigations you should send the form, signed and dated, to Local Safeguarding Board person you have contacted in an envelope marked ‘Confidential – for Addressee Only’

Details about the person receiving the disclosure
Name:	Phone Nos
Email address:
Work location and special project (if relevant)
Have you informed Acumen Community Buildings’ Designated Person for Safeguarding? (delete as appropriate)	Yes		No
Name of Designated Person for Safeguarding
Date and Time Designated Person was Informed	Date: …../…./….		Time:…………….
Signature
Person Who is Accused Details
Name of person accused
Relationship to accuser
Disclosure Details
Name of person making disclosure or witness statement
Location address where disclosure incident occurred
Location telephone No.
Name and contact details of any additional witnesses

Description of incident/statement of allegation/disclosure including time and date(s)

Child or Vulnerable Adult Details
Surname:
Forename:
Known as:
Gender (delete as appropriate)	Male	Female
Home Address:
Phone Nos:
Email:
Are there any health/disability/disadvantages? (delete as appropriate	Yes	No
If you have said ‘Yes’ please enter details below

Please describe any visible injury or signs e.g. bruising, behavioural changes below

Review and Revision:

This policy will be reviewed as it is deemed appropriate, but no less frequently than every 12 months.

Policy review will be undertaken by the Directors

Policy Commencement Date	October 2017
Policy Version	Version 6
Date of Review	October 2022
Date of next review	October 2023
Signature

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