Safeguarding Policy and Procedures

Estimated reading time: 108 minutes

Forest Skills Ltd t/a Chris Garland Training (hereafter known as “the Company), makes a positive contribution to a strong and safe community and recognises the right of every individual to stay safe.

The Company comes into contact with children and/or vulnerable adults through the provision of training courses. The types of contact with children and/or vulnerable adults will be infrequent, unregulated or controlled contact.

This policy seeks to ensure that the Company undertakes its responsibilities with regard to protection of children and/or vulnerable adults and will respond to concerns appropriately. The policy establishes a framework to support paid and unpaid staff in their practices and clarifies the organisation’s expectations.

Legislation

The principal pieces of legislation governing this policy are:

• Working together to safeguard Children 2010
• The Children Act 1989
• The Adoption and Children Act 2002
• The Children act 2004
• Safeguarding Vulnerable Groups Act 2006
• Care Standards Act 2000
• Public Interest Disclosure Act 1998
• The Police Act 1997
• Mental Health Act 1983
• NHS and Community Care Act 1990
• Rehabilitation of Offenders Act 1974

Definitions

Safeguarding is about embedding practices throughout the organisation to ensure the protection of children and / or vulnerable adults wherever possible. In contrast, child and adult protection is about responding to circumstances that arise.

Abuse is a selfish act of oppression and injustice, exploitation and manipulation of power by those in a position of authority. This can be caused by those inflicting harm or those who fail to act to prevent harm. Abuse is not restricted to any socio-economic group, gender or culture.

It can take a number of forms, including the following:

• Physical abuse
• Sexual abuse
• Emotional abuse
• Bullying
• Neglect
• Financial (or material) abuse

Definition of a child

A child is under the age of 18 (as defined in the United Nations convention on the Rights of a Child).

Definition of Vulnerable Adults

A vulnerable adult is a person aged 18 years or over who may be unable to take care of themselves or protect themselves from harm or from being exploited. This may include a person who:

• Is elderly and frail
• Has a mental illness including dementia
• Has a physical or sensory disability
• Has a learning disability
• Has a severe physical illness
• Is a substance mis-user
• Is homeless

Responsibilities

All staff have responsibility to follow the guidance provided in this policy and related policies, and to pass on any welfare concerns using the required procedures. The Company expects all staff to promote good practice by being an excellent role model, contribute to discussions about safeguarding and to positively involve people in developing safe practices.

The Director has responsibility to ensure:

• The policy is in place and appropriate.
• The policy is accessible.
• The policy is implemented.
• The policy is monitored and reviewed.
• Liaison with and monitoring staff at work.
• Sufficient resources (time and money) are allocated to ensure that the policy can be effectively implemented.
• Promoting the welfare of children and vulnerable adults.
• Ensure staff (paid and unpaid) have access to appropriate training/information.
• Receive staff concerns about safeguarding and respond to all seriously, swiftly and appropriately.
• Keep up to date with local arrangements for safeguarding and DBS.
• Develop and maintain effective links with relevant agencies.
• Take forward concerns about responses.

Implementation stages

The scope of this Safeguarding Policy is broad ranging and in practice, it will be implemented via a range of policies and procedures within the organisation. These include:

• Whistleblowing – ability to inform on other staff/ practices within the organisation
• Grievance and disciplinary procedures – to address breaches of procedures/ policies
• Health and Safety policy, including lone working procedures,  mitigating risk to staff and clients
• Equal Opportunities policy– ensuring safeguarding procedures are in line with this policy, in particular around discriminatory abuse and ensuring that the safeguarding policy and procedures are not discriminatory
• Data protection (how records are stored, processed and access to those records)
• Confidentiality (or limited confidentiality policy) ensuring that service users are aware of your duty to disclose
• Staff induction
• Staff training

Safe recruitment

The Company ensures safe recruitment through the following processes:

• Providing the following safeguarding statement in recruitment adverts or application details: ‘recruitment is done in line with safe recruitment practices.’
• Job or role descriptions for all roles involving contact with children and/or vulnerable adults will contain reference to safeguarding responsibilities.
• There are person specifications for roles which contain a statement on core competency with regard to child/ vulnerable adult protection/ safeguarding.
• Interviews are conducted according to equal opportunity principles with any interview questions being based on the relevant job description and person specification.
• DBS checks will be conducted for specific roles for all staff (paid or unpaid) working with children and vulnerable adults. It is a criminal offence for individuals barred by the ISA to work or apply to work with children or vulnerable adults in a wide range of posts.
• No formal job offers are made until after checks for suitability are completed (including DBS and 2 references).

Disclosure and Barring Service Gap Management

The Company commits resources to providing Disclosure and barring service checks on staff (paid or unpaid) whose roles involve contact with children and/or vulnerable adults. To avoid DBS gaps, the Company will maintain and review a list of roles across the organisation which involves contact with children/vulnerable adults.

In addition to checks on recruitment for roles involving contact with children/vulnerable adults, for established staff the following processes are in place:

• A 3 year rolling programme of re-checking DBS’s is in place for holders of all identified posts.
• Existing staff (paid or unpaid) who transfer from a role which does not require a DBS check to one which involves contact with children/vulnerable adults will be subject to a DBS check.

Service delivery contracting and sub-contracting

There will be systematic checking of safeguarding arrangements of partner organisations. Contracts and memorandums of agreement for partnership delivery work will include clear minimum requirements, arrangements for safeguarding and non-compliance procedures.

Communications training and support for staff

The Company commits resources for induction, training of staff (paid and unpaid), effective communications and support mechanisms in relation to safeguarding. Induction will include:

• Discussion of the Safeguarding Policy (and confirmation of understanding).
• Discussion of other relevant policies.
• Ensure familiarity with reporting processes.
• Initial training on safeguarding including:
  • Sexual Harassment in the Workplace
  • Safeguarding Children and Young People
  • Safeguarding Adults
  • Safe working practices,
  • Safe recruitment,
  • Understanding child protection
  • Procedure for safeguarding referrals.

All staff who, through their role, are in contact with children and/or vulnerable adults will have access to safeguarding training at an appropriate level. Training will include e-learning courses and face to face courses.

Commitment to the following communication methods will ensure effective communication of safeguarding issues and practice:

• Provision of a clear and effective reporting procedure which encourages reporting of concerns. (See “Reporting” below).
• Encouraging open discussion to identify and barriers to reporting so that they can be addressed.
• Annual staff reminders about policies and procedures.

We recognise that involvement in situations where there is risk or actual harm can be stressful for staff concerned. The mechanisms in place to support staff include:

• Debriefing support for paid and unpaid staff so that they can reflect on the issues they have dealt with.
• Seeking further support as appropriate.
• Staff who have initiated protection concerns will be contacted by the Director within one week.

Professional boundaries

Professional boundaries are what define the limits of a relationship between an employee and a client. They are a set of standards we agree to uphold that ensures that the correct detachment is kept in place between the employee and client.

The Company expects staff to protect the professional integrity of themselves and the organisation.

The following professional boundaries must be adhered to:

• Giving and receiving gifts from clients: The Company does not allow paid or unpaid staff to give gifts to or receive gifts from clients. However, gifts may be provided by the organisation as part of a planned activity.
• Staff contact with user groups. Personal relationships between a member of staff (paid or unpaid) and a current client is prohibited. This includes relationships through social networking site such as Facebook. It is also prohibited to enter into a personal relationship with a person who has been a client within the past 12 months.

The following policies also contain guidance on staff (paid or unpaid) conduct:

• Allegations Against Staff or Volunteers Policy
• Anti-bullying Policy
• Appeals Policy and Procedure Policy
• Conflict of Interests Policy
• Complaints Policy
• Confidentiality and whistleblowing Policy
• Data Protection Policy
• Data Protection – Staff Training Policy
• Disciplinary and Grievance Policy
• Equal Opportunities & Pay Policy
• Equality, Diversity and Inclusion Policy
• Health & Safety Policy
• Maladministration & Malpractice Policy
• Modern Slavery Statement
• Privacy and Cookie Policy
• Reasonable Adjustments and Special Considerations Policy
• Reflective Practice Policy
• Near Miss, Accident & Incident Reporting Policy
• First Aid and Medicine Policy

If the professional boundaries and/or policies are breached this could result in disciplinary procedures or enactment of the allegation management procedures.

Reporting

The process outlined below details the stages involved in raising and reporting safeguarding concerns at the Company.

1. Communicate your concerns with your immediate manager. In the case of the Director, communicate your concerns with your Internal Quality Assessor.
2. Seek medical attention for the vulnerable person if needed.
3. Discuss with parents of child or with vulnerable person.
4. Obtain permission to make referral if safe and appropriate.
5. If needed, seek advice from Cheshire East Council Safeguarding team.
   1. Adults: https://www.cheshireeast.gov.uk/livewell/staying-safe/community-safety/safeguarding-adults-at-risk.aspx
   1. Children: https://www.cheshireeast.gov.uk/livewell/care-and-support-for-children/services-from-childrens-social-care/child-protection/child-protection.aspx
6. Complete the Local Authority Safeguarding Vulnerable Groups Incident Report Form if required and submit to the local authority within 24 hours of making a contact.
7. Ensure that feedback from the Local Authority is received and their response recorded. The local authority has a process for reporting and this must be adopted. Organisations will be expected to complete the local authorities initial contact form when informing them of a concern about a child. The use of this form and compliance with the policy will be mandatory.

Allegations Management

The Company recognises its duty to report concerns or allegations against its staff (paid or unpaid) within the organisation or by a professional from another organisation.

The process for raising and dealing with allegations is as follows:

1. Any member of staff (paid or unpaid) from the Company is required to report any concerns in the first instance to the Director. A written record of the concern will be completed by the Director.
2. Contact local authority for advice:
   1. Adults: https://www.cheshireeast.gov.uk/livewell/staying-safe/community-safety/safeguarding-adults-at-risk.aspx
   1. Children: https://www.cheshireeast.gov.uk/livewell/care-and-support-for-children/services-from-childrens-social-care/child-protection/child-protection.aspx
3. Follow the advice provided.

The Company recognises its legal duty to report any concerns about unsafe practice by any of its paid or unpaid staff to the Disclosure and Barring Service (DBS), according to the DBS referral guidance document. (https://www.submit-a-barring-referral.service.gov.uk/start)

Monitoring

The Company will monitor the following Safeguarding aspects:

• Safe recruitment practices.
• DBS checks undertaken.
• References applied for new staff.
• Records made and kept of supervision sessions.
• Training – register/ record of staff training on child/ vulnerable adult protection.
• Monitoring whether concerns are being reported and actioned.
• Checking that policies are up to date and relevant.
• Reviewing the current reporting procedure in place.
• Presence and action of Designated senior manager responsible for Safeguarding is in post.

Managing information

Information will be gathered, recorded and stored in accordance with the following policies:

• Allegations Against Staff or Volunteers
• Anti-bullying
• Appeals Policy and Procedure
• Assessment centre management
• Complaints
• Complaints Summary Record
• Confidentiality and whistleblowing
• Data Protection
• Disciplinary and Grievance
• Equal Opportunities & Pay
• Equality, Diversity and Inclusion
• Equality, Diversity and Inclusion – Staff Training Policy
• Maladministration & Malpractice
• Privacy and Cookie
• Near Miss, Accident & Incident Reporting

All staff must be aware that they have a professional duty to share information with other agencies to safeguard children and vulnerable adults. The public interest in safeguarding children and vulnerable adults may override confidentiality interests. However, information will be shared on a need-to-know basis only, as judged by the Director. All staff must be aware that they cannot promise clients or their families/carers that they will keep secrets.

Conflict resolution and complaints

The Company is aware of the Cheshire East Safeguarding Children’s Partnership Escalation policy on resolution of professional disagreements in work relating to the safety of children and if necessary, this will be taken forward by Director.

(https://pancheshire-cheshireeast.trixonline.co.uk/contents/contents)

Conflicts in respect of safety of vulnerable adults will be taken forward by the Director.

Communicating and reviewing the policy

The Company will make clients aware of the Safeguarding Policy through the following means:

• A statement to customers about safeguarding arrangements is displayed on the Company website.
• The Complaints Policy outlines how clients can make complaint about the service.

Review

This policy will be reviewed annually by the Director and when there are changes in legislation.