Safeguarding Adults Policy and Procedure

1. Purpose

This policy sets out the arrangements Kashfam Ltd has in place for safeguarding and promoting the welfare of adults at risk (adults are those aged 18 and over), and for complying with local policies and procedures. It safeguards Service Users from abuse and improper treatment (CQC Regulation 13) through robust procedures for prevention, identification and response.

The Registered Manager, Miss Benhilda Gwaze, has overall management responsibility for this policy and is accountable for managing safeguarding concerns. Kashfam Ltd follows the Surrey Safeguarding Adults Board multi-agency safeguarding procedures, which take precedence over our own. A separate Safeguarding Children and Child Protection Policy covers children.

• Managed and governed appropriately, with systems to assess, monitor and improve the service
• Records completed accurately and stored safely and securely
• UK GDPR and the Data Protection Act 2018 are met
• Care and support delivered is consistent, safe and of high quality

2. Who this applies to

This policy applies to all staff. It protects Service Users and affects their families, advocates, representatives, commissioners, external health professionals, the local authority, the NHS and housing provider partners.

3. What is safeguarding?

Safeguarding means the actions taken to keep Service Users safe from harm and neglect. Under the Care Act 2014, adult safeguarding duties apply to any adult who has care and support needs, is experiencing or at risk of abuse or neglect, and is unable to protect themselves because of those needs.

We follow the six principles of the Care Act and the approach of Making Safeguarding Personal, so that safeguarding is person-led and focused on the outcomes the Service User wants.

• Empowerment – people are supported to make their own decisions and give informed consent
• Prevention – it is better to act before harm occurs
• Proportionality – the least intrusive response appropriate to the risk
• Protection – support and representation for those in greatest need
• Partnership – local solutions through services working with their communities
• Accountability – accountability and transparency in delivering safeguarding

4. Forms of abuse and neglect

The signs of abuse are not always obvious, and a person may not tell anyone what is happening. Staff are trained to recognise the main forms of abuse set out in the Care Act 2014 statutory guidance:

• Physical abuse – being hit, restrained, denied food or water, or misuse of medication
• Domestic violence or abuse – controlling, coercive or threatening behaviour, including so-called honour-based violence, FGM and forced marriage
• Sexual abuse – any sexual act or behaviour without consent or understanding
• Psychological or emotional abuse – threats, humiliation, intimidation, isolation, cyberbullying
• Financial or material abuse – theft, fraud, scams, coercion about money, wills or property
• Modern slavery – slavery, human trafficking, forced labour and domestic servitude
• Discriminatory abuse – harassment or unfair treatment because of a protected characteristic
• Organisational abuse – neglect and poor care practice within a care setting or a person's own home
• Neglect and acts of omission – ignoring medical, emotional or physical care needs
• Self-neglect – neglecting personal hygiene, health or surroundings, including hoarding

5. Preventing abuse

We build a positive culture where abuse is not tolerated. Some people face a higher risk of abuse, including people with communication difficulties, cognitive impairment or fluctuating capacity, people who self-neglect, and people affected by drugs or alcohol.

• Safe recruitment, induction, supervision and training for all staff
• Detailed assessments, Care Plans and up-to-date risk assessments
• Extra monitoring and support for Service Users at higher risk
• Trained, familiar staff and a risk assessment when escorting a Service User to another setting
• Accessible information for Service Users, including a Service User Guide and a safeguarding leaflet

6. What staff must do if they have a concern

Safeguarding is everybody's business. Staff who suspect abuse or neglect must act and must not assume someone else will. A concern may come from something you observe, an allegation, or a disclosure. Staff must Recognise, Respond, Record and Report.

• Stay calm and non-judgemental, and do not show shock or disbelief
• Make sure the Service User is safe and call 999 if there is a medical emergency, danger to life, or a crime in progress
• Let the person speak freely; use simple, open questions and never ask leading questions or investigate
• Do not promise to keep secrets; explain that you must share the concern with your manager
• Write down what was said in their own words as soon as possible, then sign and date it; use a body map for any marks or bruising
• Preserve evidence, for example by asking the person not to wash
• Report to the Registered Manager or Safeguarding Lead, Benhilda Gwaze, straight away
• If the concern is about the manager, or they have not acted, use the whistleblowing procedure or contact the local authority, CQC or police directly

7. Referral and enquiry

The Registered Manager or Safeguarding Lead leads on decision-making and records their reasoning. They consider the three duties in Section 42 of the Care Act 2014 and decide whether to refer a safeguarding concern to Surrey County Council Adult Social Care. If a Service User does not want action taken but abuse or neglect is suspected, a referral must still be made.

The local authority is the lead agency for adult safeguarding and decides whether an enquiry is needed and who will conduct it. The Service User is involved throughout, with an advocate if they wish, and their desired outcomes guide what happens. Where the local authority decides not to investigate, we review risk assessments and Care Plans and consider other routes such as complaints or a best-interest meeting.

8. Consent and mental capacity

Consent is not required to report information that directly concerns the safety of an adult at risk, though informing the Service User is good practice unless it would put them or others at further risk. All decisions follow the Mental Capacity Act 2005 and its five principles:

• The presumption of capacity
• Service Users are supported to make their own decisions
• Service Users can make unwise decisions
• Best interest decisions
• Least restrictive option

9. Informing regulators and other bodies

By law, we notify the Care Quality Commission without delay of incidents and allegations of abuse, and of any incident reported to or investigated by the police. We also alert the local safeguarding authority when we notify CQC. Kashfam Healthcare is working towards CQC registration.

Where a worker is guilty of misconduct that harmed or placed an adult at risk, we refer them to the Disclosure and Barring Service (DBS). Allegations against people in positions of trust are reported immediately to the Registered Manager and referred to the local authority.

10. Specific situations

• Pressure ulcers – follow the DHSC guidance 'Pressure Ulcers: How to Safeguard Adults'; the decision guide is completed within 48 hours and a score of 15 or above usually triggers a concern
• Medication errors – reported through local safeguarding procedures and to CQC, with an open approach and duty of candour
• Radicalisation – staff follow our Protecting Adults at Risk from Radicalisation policy
• Self-neglect and refusal of care – refusal is always documented and repeated refusal is escalated as a safeguarding concern
• Restrictive practices – restraint is only used when absolutely necessary, proportionate and lawful; any misuse is treated as potential abuse
• Deprivation of liberty – in community settings this must be authorised by the Court of Protection
• Criminal offences – where a crime is suspected, the police are involved early
• County lines and cuckooing – staff are trained to spot signs such as unknown visitors at unusual times and changes in behaviour
• FGM – there is a mandatory duty to report known cases in under 18-year-olds to the police on 101

11. Confidentiality and sharing information

Information is shared in line with UK GDPR, the Data Protection Act 2018 and the Caldicott principles. Adults at risk are told what is recorded about them and are normally asked before information is shared, although this can be overridden where they or others are at risk. Confidentiality must never be allowed to conflict with the interests of the adult at risk.

12. Staff support, training and audit

Staff, including volunteers, are trained to recognise and respond to abuse, benchmarked against the Royal College of Nursing intercollegiate guidance. Our Safeguarding Lead holds at least a Level 3 safeguarding qualification, refreshed at least every two years. Staff subject to an allegation are supported fairly. We audit recruitment and DBS checks, incident reporting and training, and review safeguarding incidents for learning.