OPS001
Safeguarding Adults at
Risk of Harm
June 2013
Named and post of person responsible for policy:
Contact:
Jonathan Senker, Chief Executive
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Contents
Policy Statement
Scope
1. Responsibilities
2. Definitions
3. Recognition
4. Action to be taken in cases of Alleged/Suspected Abuse
5. Additional Actions and Guidance for All Safeguarding Alerts
6. Recording Procedures for Cases of Alleged/Suspected Abuse
7. Investigations
8. Follow Up
9. Confidentiality
10. Further Safeguarding Adults at Risk of Harm
11. Internal Reporting
Appendix A1 – Summary flowchart of actions where alleged perpetrator is not a
member of VoiceAbility staff
Appendix A2 – Summary flowchart of actions where alleged perpetrator is a
member of VoiceAbility staff
Appendix B – Indicators of Abuse
Appendix C – Preserving Evidence
Appendix D – Guidance when making a Safeguarding Adults at risk of harm alert
Appendix E – Guidance for when to contact other agencies
Appendix F – Recording Guidance
Appendix G – VoiceAbility Safeguarding Report Form
Appendix H – VoiceAbility Follow Up recording form
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Policy Statement
VoiceAbility is committed to promoting the rights of all people to be safe and secure and
to be free from any form of abuse. All VoiceAbility staff and volunteers have a duty to be
alert to the possibility of abuse and to work to safeguard adults at risk of harm from abuse.
All VoiceAbility employees and volunteers will be appropriately trained and supported to
adhere to the ‘Safeguarding Adults at Risk’ Policy and Procedures.
Appropriate recruitment checks will be made for new staff and volunteers in line with our
Recruitment and Selection policy (Policy HR017) and for relevant roles Disclosure and
Barring Service update checks will be made in line with any statutory guidance in force.
VoiceAbility will take all suspicions of abuse seriously and respond to them following the
procedures outlined in this document.
SCOPE
This policy applies to all people working on behalf of VoiceAbility including employees,
agency workers, consultants, contractor, volunteers and trustees. There is a separate
policy covering suspicions of abuse of Children & Young People.
This policy covers:


Suspicions of abuse perpetrated by a member of VoiceAbility workforce (paid
and voluntary).
Suspicions of abuse perpetrated by someone or an institution outside of
VoiceAbility.
1. Responsibilities
Staff & Volunteers in local services have a responsibility to:





Read, understand and work in line with their local Multi Agency Procedure.
Recognise the signs of potential abuse and raise concerns in line with this
policy.
Where appropriate and in line with this policy, decide if they need to take
immediate action and raise safeguarding alert.
Keep records in line with this policy.
Follow up on concerns with the aim to ensure individuals are safeguarded
and get positive outcomes.
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Staff & Volunteers not working in client facing services have the responsibility to:



Read, understand and work in line with their local Multi Agency Procedure.
Recognise the signs of potential abuse and raise concerns in line with this
policy.
Where appropriate and in line with this policy, decide if they need to take
immediate action and raise safeguarding alert.
Service Managers and other managers within our client facing services (e.g.
Managing Advocate or Project Leaders) have a responsibility to:






Ensure that members of staff and all volunteers in services that they have
a responsibility for, understand and are compliant with this procedure and
policies in operation locally.
Ensure that staff in their teams are adequately trained in safeguarding
(Normally trained to equivalent of level 1-3 via an external agency and
attend VoiceAbility Safeguarding Training).
Make decisions where appropriate as to whether concerns that are
brought to their attention meet the threshold for making safeguarding
alerts (always erring on the side of caution where there is uncertainty) and
ensure that alerts are raised appropriately.
Analyse safeguarding data in their areas of responsibility to:
o Make links where there are a number of concerns about potential
abuse and take appropriate action in relation to them
o Identify and report as appropriate on gaps in safeguarding practice
and/or compliance with our policy
o Provide Regional Directors and others with reports on safeguarding
as required.
Liaise with the statutory agencies regarding concerns of potential abuse
by a member of their team as required by VoiceAbility.
Ensure that alerts are followed up and that clear outcomes are achieved
Regional Directors have a responsibility to:




Check compliance with this policy at a regional level.
Ensuring their management teams are compliant with this policy and
procedure.
Ensure that their managers are adequately trained in safeguarding (to the
equivalent of level 3 – 4 and attend VoiceAbility Safeguarding Training).).
Provide guidance to service managers on complex safeguarding issues.
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


Liaise with the statutory agencies regarding concerns of potential abuse
by a member of VoiceAbility staff or volunteer where it is more appropriate
that the Regional Director takes this responsibility.
Undertake investigations, where this is deemed appropriate, in
consultation with the relevant statutory authorities.
Analyse data on safeguarding at a Regional level, decide on appropriate
action and report as required to executive team.
Regional HR Business Partners have a responsibility to:




Provide advice and guidance to managers when a suspected perpetrator
of alleged abuse is a member of VoiceAbility workforce.
Maintain record of and collate data on concerns raised about suspected
abuse allegedly conducted by a member of VoiceAbility workforce.
Provide Regional Directors and the HR Director with reports on
safeguarding allegations against VoiceAbility staff and volunteers as
required.
To maintain a Regional Safeguarding File with details of all safeguarding
allegations made against members of staff and volunteers within that
region.
HR Director has a responsibility to:

Ensure appropriate referrals are made to the Disclosure and Barring
Service in the event of a reportable allegation against a member of
VoiceAbility staff or VoiceAbility volunteer.
Heads of Service (e.g. Heads of Finance/IT) have a responsibility to:


Ensure that staff and volunteers in their teams are adequately trained on
safeguarding (equivalent to level 1 or 2 and attend VoiceAbility
Safeguarding Training).) and about this policy.
Liaise with statutory authorities if the suspected perpetrator is in the
service team and undertake investigations, where this is deemed to be
appropriate in consultation with the relevant statutory authorities.
Executive Management Team has a responsibility to:
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




Check organisational compliance with this policy.
Ensure that Regional Directors and Heads of Services are compliant with
this policy.
Ensure that Regional Directors and Head of Quality are adequately trained
in safeguarding (normally equivalent to level 4 attend VoiceAbility
Safeguarding Training).)).
Report on safeguarding to the board of Trustees.
Liaise with statutory authorities if the suspected perpetrator is at regional
director or Head of Service level.
Chief Executive has responsibility to:
Ensure there is a named and suitably trained organisational lead for safeguarding
adults at risk of harm. The lead may be the Chief Executive or another member
of the Executive Management Team.
The Organisational Lead has responsibility to:
 Ensure the organisation holds and implements a fit for purpose policy
 Ensure that Executive team members are adequately trained on
safeguarding.
 Ensure appropriate liaison with statutory authorities if the suspected
perpetrator is a manager in VoiceAbility at executive level.
 Undertake investigations, where this is deemed to be appropriate, in
consultation with the relevant statutory authorities,
 Ensure there are internal reporting, management and governance
systems in place to ensure the robustness of VoiceAbility’s practice and to
learn from safeguarding experience.
 To report to the Executive Management Team and Board of Trustees on
any safeguarding matters, including any safeguarding allegations made
against a member of VoiceAbility staff or volunteer.
Trustees have responsibility to:



Hold the Chief Executive to account in relation to safeguarding
performance of the organisation.
Ensure the Chief Executive is adequately trained in safeguarding
(Equivalent to Level 4 and attend VoiceAbility Safeguarding Training).
Ensure effective liaison with statutory authorities and ensure investigations
are undertaken, where appropriate, if the suspected perpetrator is at Chief
Executive level.
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2.
DEFINITIONS
2.1
For the purpose of this policy an adult at risk of harm is defined as anyone 18
years of age and over, who is, or maybe, in need of community care services for
example:

People with mental needs or mental illness

People with a physical disability

People with drug and alcohol related problems

People with sensory impairments

People with a learning difficulty/ disability

People who are elderly and frail

People with acquired brain injury

People with ASD
2.2
People who abuse include:

People who are well known to their victims

A relative, spouse or partner, friend or neighbour, as paid or voluntary
worker or a health or social care worker

People that are strangers to their victims

Another person who uses services
In some cases, people who abuse may not realize they are abusing. For
example, carers who act out of character and abuse because of the stress of
caring.
2.3
Abuse can take place anywhere, including:

The persons own home

A carers home

Day centre

A care home

A hospital

The workplace

Educational institutions

Community and public places
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RECOGNITION
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3.1
The ‘No Secrets’ (DH 2000) Guidance on developing and implementing multiagency policies and procedures to protect adults at risk from abuse defines
abuse as “the violation of an individual’s human and civil rights by any other
person or persons”.
3.2
The abuse of adults at risk can take many forms (see Appendix B for Indicators
or Abuse), such as:
3.3
Physical Abuse
Physical abuse may include physical assault ranging from rough, inappropriate or
careless handling, to direct violence – hitting, slapping, pushing or kicking. It can
include medical mistreatments such as the misuse of medication, withholding or
inappropriately alerting medication or treatment regimes. It is also the misuse of
restraint.
3.4
Psychological/Emotional Abuse
Psychological or emotional abuse may include verbal abuse, threats, bullying,
racial abuse, deprivation of contact, humiliation, blaming, controlling, intimidation,
coercion, harassment, isolation or withdrawal from services or supportive
networks.
3.5
Sexual Abuse
Sexual abuse may include rape and sexual assault, or sexual acts and
inappropriate touching to which the adult has not consented, or could not
consent, or was pressured into consenting or acts of a sexual nature where one
of the participants is in a position of trust, power or authority (Sexual Offences
Act 2003).
3.6
Financial or Material Abuse
Financial abuse may include improper use of, or withholding , a person’s money
or property; theft, fraud, exploitation or pressure in connection with wills, property
or inheritance.
3.7
Neglect or Acts of Omission
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Neglect could include ignoring medical, physical or social care needs, failure to
provide access to appropriate health, social care or educational service, the
withholding of daily living needs, such as medication, food and drink, and
heating.
3.8
Discriminatory Abuse
Discriminatory abuse may include racist or sexist remarks or comments based
upon a person’s impairment, origin, colour, disability, age, illness, sexual
orientation or gender, and other forms of harassment, slurs or similar treatment.
3.9
Institutional Abuse
Institutional abuse includes the collective failures of an organsiation to provide an
appropriate and professional service to vulnerable people. It can be seen or
detected in processes, attitudes and behaviour that amount to discrimination
through prejudice, ignorance, thoughtlessness, stereotyping, or, malicious intent.
It includes failure to ensure necessary safeguards are in place to protect
vulnerable adults and maintain good standards of care in accordance with
individual needs, including training of staff, supervision and management, record
keeping and liaising with other care providers.
3.10
Self Harm and Suicidal Behaviours
In their own right, self-harming and/or suicidal behaviours do not fall under the
safeguarding procedures. However, these behaviours may be an indicator that
an individual has been, or is being, abused.
In the event of self harm or suicidal behaviours you must consult VoiceAbility’s
Confidentiality Policy OPS005.
In the event of life threatening action having taken place, ring 999.
VoiceAbility has also produced guidance on responding to callers who are
suicidal, which should be consulted where appropriate.
3.11
In addition to this Policy and No Secrets there are additional sources of
information and guidance. These include, but are not limited to Local Authority
Multi Agency Policies, Procedures and Guidance, including guidance produced
by local authority on reporting procedures, thresholds of abuse and significant
harm, conduct of investigation and other related matters.
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3.12
Where any Policy and Guidance produced by a Local Authority places a higher
burden of action or a lower threshold of abuse than is considered within this
policy, VoiceAbility expects all staff and volunteers within that Local Authority
area to follow the burdens and thresholds imposed by the Local Authority policy
and guidance.
If you have any concerns about an adult at risk’s safety or treatment by others
that may be possible abuse, you must take the action described in section 4 at
the earliest opportunity, and no later than the same day.
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ACTION TO BE TAKEN IN CASES OF ALLEGED/SUSPECTED ABUSE
4.1
A summary of these actions can be found in Appendix A1 where the alleged
perpetrator is not a member of the VoiceAbility workforce, and Appendix A2
where the alleged perpetrator is a member of the VoiceAbility workforce.
4.2
It is not the responsibility of VoiceAbility staff and volunteers to investigate
suspected abuse. It is the responsibility of VoiceAbility staff and volunteers to
report suspected abuse and to work with the person at risk of abuse to ensure
that they can be free from abuse in the future.
4.3
This is because undertaking our own investigations may compromise future
investigations by the police or local authority and will run counter to the clear
statutory guidance in place.
4.4
Emergency Services
4.4.1 If any person is in danger, first ensure they are safe and, if immediate help is
needed, call the emergency services on 999.
4.4.2 If the person is seriously injured seek immediate medical treatment and inform
your line manager at the earliest opportunity after doing so.
4.4.3 Immediately alert the emergency services if delay may increase the prospect of
evidence being contaminated and/ or increases the prospect of successful
prosecution. Notify your line manager that 999 have been contacted immediately,
on the same day.
4.5
Preserve Evidence
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4.5.1 Ensure that evidence is preserved. See appendix C for further information and
guidance.
4.6
Making an Alert
4.6.1 If you discover or suspect potential abuse, and believe that it would constitute
abuse (under the categories listed in Section 3) you must report this to the local
authority following their local authority multi agency procedure.
4.6.2 Further guidance in reporting potential abuse can be found in Appendix D. This
must be done at the earliest opportunity and no later than the same day as the
abuse is discovered or suspected.
4.6.3 You must give consideration as to whether the person at risk of harm can be
supported to raise the alert themselves.
4.6.4 Where you are in any doubt whether abuse has happened, or might happen, a
VoiceAbility manager will work with you to decide if a safeguarding alert should
be raised or if a different course of action is required. For example, if it is
suspected poor practice rather than suspected abuse.
4.6.5 When deciding if it is poor practice or abuse you will need to consider the level
and frequency of any previous concerns recorded about poor practice.
4.6.6 Concerns about poor practice which are not considered to constitute abuse
under safeguarding procedures must be reported to the individual’s line manager
or other suitable management representative.
4.6.7 You must contact your manager as soon as possible and certainly quickly
enough to ensure that the matter is reported to the Local Authority on the same
day if such a report is required.
4.6.8 If your line manager is not available then you should contact any Service
Manager, Regional Director, Quality Assurance Manager or Head of Quality and
Development to discuss and agree what action to take.
4.7
Written Record
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4.7.1 It is vital that a written record of any incident or allegation causing concern about
crime or abuse is made as soon as possible after the information is obtained, and
kept by the person raising the concern. See Section 6 for guidance.
4.8
Reporting
4.8.1 As soon as possible, complete the Local Authority reporting form (if the Local
Authority stipulates they require this) or VoiceAbility form in appendix G.
4.8.2 This should be no later than the day that the abuse is suspected or identified.
4.8.3 Ensure it is recorded when and to whom within the local authority the suspected
abuse was reported.
4.8.4 Copies of the forms should be uploaded to MAAVIS; see appendix F for
guidance on recording.
4.8.5 Documentation may be required for criminal proceedings.
4.9
Follow up In Writing
4.9.1 The alert is to be followed up in writing to the Local Authority on the same day.
See section 8 for guidance about follow up actions.
4.10
Recording
4.10.1 Record all suspicions of abuse regardless of whether an alert was made on
MAAVIS (VoiceAbility Database) the same day following the recording procedure
& guidance in Appendix F.
4.10.2 Do not record the notes, allegation or suspicions of abuse on MAAVIS when it
relates to a member of VoiceAbility workforce.
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Where the alert is about a member of the VoiceAbility workforce
4.11 If a member of VoiceAbility staff is thought to have abused, the procedure
outlined in sections 4.1 to 4.5 must be followed. You must also:
a) Contact your manager as soon as possible and certainly quickly
enough to ensure that the matter is reported to the Local Authority
on the same day if such a report is required.
b) If your line manager is not available then you should contact any
Service Manager, Regional Director, Quality Assurance Manager or
Head of Quality and Development to discuss and agree what action
to take.
c) If a delay caused by trying to contact an appropriate manager
might jeopardise the safety of any person, or jeopardise any
subsequent investigation, then immediately contact the Local
Authority to report the potential abuse using the Local Authority
Multi Agency reporting procedure. Then contact your line manager
or appropriate VoiceAbility manager.
d) It is vital that a written record of any incident or allegation causing
concern about crime or abuse is made as soon as possible after
the information is obtained, and kept by the person raising the
concern. See Section 6 for guidance.
e) Where abuse is suspected, managers will need to consider what
immediate actions need to be taken to ensure that any person at
risk of harm remains safe and that evidence is maintained.
Managers should seek urgent advice from a Regional HR Business
Partner.
f) The role of the Regional HR Business Partner is to offer advice to
the appropriate manager about how any employment issues should
be dealt with, that have arisen as a result of the allegation. This will
include ensuring that any relevant organisational policies are
followed. The Regional HR Business Partner’s role is not to offer
advice about whether any thresholds of abuse are likely to be met
and the local authority informed.
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g) When deciding if it is poor practice or abuse you will need to
consider the level and frequency of any previous concerns
recorded about poor practice.
h) Where there is doubt as to whether the matter is a safeguarding
one, the line manager or Regional Director will decide if a
safeguarding alert should be raised or if a different course of action
is required.
For example, if it is suspected poor practice falling short of
suspected abuse.
Concerns about poor practice which are not considered to
constitute abuse under safeguarding procedures must be reported
to the individual’s line manager and will be addressed through the
appropriate process. For employees this could mean action under
the Capability Procedure HR027 or Disciplinary Procedure HR026
i) The manager must alert the local authority to the safeguarding
issue as soon as possible and always on the same day.
j) If the alert has already been raised with the local authority, the
manager will make contact with the local authority on the same day
as the manager becomes aware of the potential abuse.
k) The alert is to be followed up in writing to the Local Authority on the
same day. See Section 8 about follow up actions.
l) Managers must inform their Regional Director of the allegations or
suspected abuse on the same day as they become aware of the
potential abuse.
.
m) Record any allegations and subsequent actions taken following the
guidance in paragraph 6.3.
n) Follow up actions should recorded on Appendix H
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5.
ADDITIONAL GUIDANCE AND ACTIONS FOR ALL SAFEGUARDING
ALERTS
5.1
If the allegation of abuse comes from a third party this needs to be reported as
described in section 4; you need to be clear with the local authority where the
allegation has come from. This should be recorded on MAAVIS and on the
reporting form in Appendix G or on the Local Authority safeguarding report form if
that is completed instead. Refer to Appendix D for further guidance on making
the alert.
5.2
If a third party informs you that they have already reported the potential abuse to
the appropriate local authority, you must still report the allegation to the local
authority independently.
5.3
Where necessary or appropriate you might need to contact the Police in addition
to the local authority. In some situations this will need to be done straight away;
see sections 4.4 and 4.11 for more guidance.
5.4
Where necessary or appropriate, VoiceAbility managers need to consider
contacting the Care Quality Commissioner in addition to the local authority.
Guidance on the sort of situation this may arise in can be found in Appendix E.
5.5
If the adult at risk of harm is funded by another local authority then you need to
alert to the authority where the person resides, as well as the authority with
responsibility for funding. The authority where the person lives will usually have
responsibility for any investigation.
6.
RECORDING PROCEDURES FOR CASES OF ALLEGED/SUSPECTED
ABUSE
6.1
It is vital that a written record of any incident or allegation causing concern about
a crime or abuse is made as soon as possible after the information is obtained,
and kept by the person raising the concern. Written records must reflect as
accurately as possible what was said and done by the people initially involved in
the incident either as a victim, suspect or potential witness. The notes must be
kept safe as it may be necessary to make records available as evidence and to
disclose them to a court.
You must make an accurate record at the time (certainly on the same day),
including:
I.
Date and time of the incident/disclosure
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II.
Exactly what the person (the adult at risk, other person raising the concern)
said, using their own words (their account) about the incident and how it
occurred or exactly what has been reported to you.
III.
Appearance and behaviour of the adult at risk, or the other person raising
the concern
IV.
Any injuries observed
V.
Name and signature of the person making the record
VI.
If you witnessed the incident, write down exactly what you saw
VII.
The date and time of your record, including any notes made at the time of
the incident or disclosure - which you must retain.
VIII.
The record should be factual. However, if the record does contain your
opinion or an assessment, it should be clearly stated as such and be
backed up by factual evidence. Information from another person should be
clearly attributed to them.’
(Based on SCIE 2011, SCIE Report 39, Protecting Adults at Risk, 2.3.1.3, P57)
Only ask the person sufficient questions to establish what has happened i.e. was
it an accident or possible abuse. All questions asked must be open questions.
6.2
See Appendix F for further information about recording any safeguarding adults
at risk of harm issues on MAAVIS and the alleged perpetrator is not a member
of the VoiceAbility workforce.
6.3
Where the alleged perpetrator is member of the VoiceAbility workforce, you
must:
a. keep original copies of your notes in a private locked cabinet and
send copies to the manager you contact. Do not record the notes,
allegation or suspicions of abuse on MAAVIS when it relates to a
member of VoiceAbility Workforce.
b. Managers are to keep copies of written records, reports,
correspondence and actions log are to be kept in a locked cabinet.
and copies sent to Regional HR Business Partners.
c. Send copies of all documents and logs to Regional HR Business
Partner
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INVESTIGATIONS
7.1
VoiceAbility will always co-operate fully with any investigations by the statutory
authorities.
7.2
In all usual circumstances VoiceAbility will seek the consent of the relevant
statutory authority before undertaking its own investigations in order to avoid any
risk of compromising those investigations.
7.3
Investigations into allegations about a member of VoiceAbility staff will follow the
procedures in the Disciplinary Policy HR026.
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FOLLOW UP
8.1
Safeguarding children and adults at risk of harm is a key strategic aim of
VoiceAbility. All staff will treat serious concerns about risk of harm from both
disclosures and observations as an advocacy issue. All staff have a duty to
ensure that:




the person’s voice is heard;
their interests are respected;
concerns and allegations about significant risk of harm are investigated;
and
their right to live a life free from abuse is upheld.
8.2
Following any alert being made, the member of VoiceAbility staff that made the
alert must have contact with the local authority to ensure that action has been
taken to safeguard the person from abuse.
8.3
If you have concerns that no, or insufficient, action has been taken when you
follow up, or during the progression of the case, then contact your line manager.
8.4
Taking care to not compromise any investigation, as far as possible, try to ensure
that the person who is the subject of the alleged abuse is kept appropriately
involved in any safeguarding investigation and informed about any protective
measures being discussed or actions taken. Further guidance on how to involve
the person without compromising any investigation can be gained from your line
manager or the investigating authority.
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8.5
Record all follow up on MAAVIS or, in the case of allegations against a member
of VoiceAbility workforce, a written log is to be kept and securely stored in the
Regional Safeguarding File held by the VoiceAbility Regional HR Business
Partner.
8.6
Ensure the adult at risk of abuse has access to VoiceAbility’s support throughout
the Safeguarding Issue. This might include, but is not limited to:
I.
supporting them to prepare and raise their voice at any meetings
II. support them to access services that might reduce the risks of them being
abused or to help them achieve their desired outcomes and goals
III. asking questions of any professionals investigating the potential abuse or
involved in any plan to ensure their safety
IV. ensure the their rights are supported, especially their right to be free from
abuse.
8.7
Where you have raised a Safeguarding Alert, but the Local Authority does not
believe this reaches the threshold of abuse you should support the person at risk
of abuse to access advocacy support to resolve the issue e.g. by conducting a
piece of professional advocacy with them to raise the issue with any appropriate
manager of the service and escalating as appropriate to obtain a positive
outcome.
8.8
Record the outcomes of the safeguarding concern/issue.
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Confidentiality
9.1
People have a right to expect that all staff and volunteers will deal sensitively and
sympathetically with their situation. It is important that information remains
confidential and that only those with a ‘need to know’ should be privy to it.
9.2
In line with VoiceAbility’s Confidentiality Policy OPS 005, other people in the
individual life (e.g. parents or carers) should not be automatically informed. They
may be informed, following discussion with the relevant statutory authorities
where the person consents to this, or, if the person lacks capacity to decide this
and it is decided that disclosure is in the best interests of the person.
9.3
In cases where the suspected perpetrator is a member of VoiceAbility workforce
records relating to the safeguarding will not be kept on MAAVIS.
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9.4
Access to client records held on MAAVIS should always be accessed on a ‘need
to know’ basis and in line with VoiceAbility’s Data Protection policy COR 005.
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Further Safeguarding adults at Risk of Harm
10.1
Safer recruitment
VoiceAbility aims to ensure that employees and volunteers in relevant posts are
suitable to work with children or adults in vulnerable circumstances. VoiceAbility
undertakes a range of safer recruitment checks on prospective employees and
volunteers, including Disclosure and Barring Service checks at the appropriate
level and barred list checks for relevant posts. Further details are in the
Recruitment and Selection policy and procedure (HR017).
10.2
Referrals to Disclosure & Barring Service (DBS)
VoiceAbility is committed to its duty to make referrals to the DBS in line with the
Safeguarding Vulnerable Groups Act 2006. It is the responsibility of the Director
of Human Resources to ensure appropriate referrals are made to the DBS when
an employee or volunteer has been dismissed or removed from working with
children or vulnerable adults (or would or may have if the person had not left or
resigned etc.). Referrals will be made in line with DBS guidance when an
employee or volunteer has:
1. Been cautioned or convicted for a relevant offences; or
2. Engaged in relevant conduct in relation to children and/or vulnerable
adults (i.e. an action or inaction (neglect) that has harmed a children or
vulnerable adult or put them at risk of harm); or
3. Satisfied the Harm Test in relation to children and/or vulnerable adults.
(i.e. there has been no relevant conduct (i.e. no action or inaction) but a
risk of harm to a child or vulnerable adult still exists).
(DBS Factsheet 1)
10.3
If an employee has sufficient concerns that suspected abuse perpetrated by a
member of VoiceAbility staff have not been properly reported to the relevant
statutory authority or are not being taken seriously, they can contact the Chief
Executive of VoiceAbility about this and/ or contact the local authority. There will
not be any sanctions taken by VoiceAbility for members of staff contacting the
local authority in these instances if done in good faith and without malice.
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Furthermore, for concerns of public interest, whistle blowing is protected in law
as outlined in VoiceAbility’s Whistle Blowing Policy HR004.
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Internal Reporting - Effective Governance, Management and Learning
11.1 VoiceAbility will ensure it has a robust process in place to collate and review data
regarding safeguarding concerns.
11.2 VoiceAbility will continually review best practice in recognising and reporting
safeguarding concerns across the organisation.
11.3 This data together with feedback from staff and volunteers, managers, people we
work with, commissioners and safeguarding professionals will be reviewed with
the Safeguarding Lead on a quarterly basis to support the development of an
organisation-wide Action Plan.
20
Appendix A1
Where alleged perpetrator is not a member of VoiceAbility workforce
Summary of Actions and reporting procedures
Allegation or suspicion of abuse by someone external to VoiceAbility
Is the person in immediate danger, requiring urgent medical attention
or
is immediate response needed by the emergency services to preserve evidence
/increase chances of successful investigation?
If yes: call 999
If no (or after calling 999):
Notify your manager immediately
that 999 have been contacted
Preserve evidence
Line manager to advise regarding
alert and agree course of action with
team member
Need to take into account any
previous concerns
If no alert, notes of the
discussion and reason for
decision should be held on the
person’s MAAVIS file.
If unsure, contact your line
manager for advice and support
Make written record
On Same Day
If sure it is possible abuse either
support the person to alert, or use
Local Authority reporting procedure
Alert to be made according to the local
multi-agency safeguarding procedures.
Refer to local policies on this.
Fill out VoiceAbility or Local Authority safeguarding reporting form
Follow up alert in writing.
Record on MAAVIS and attach the reporting form and copies of original notes to
person’s MAAVIS record
Follow up on alert and record action taken by local authority as appropriate.
If no action is taken by Local Authority report to line manager and agree actions to be taken.
21
Appendix A2 - Where member of VoiceAbility workforce is the alleged perpetrator
of abuse
Summary of Actions and reporting procedures
Is the person in immediate danger, requiring urgent medical attention
or
is immediate response needed by the emergency services to preserve evidence
/increase chances of successful investigation?
If yes: call 999
If no (or after calling 999):
Notify your manager immediately that 999 have
been contacted
Preserve evidence
Line Manager:
2. If there is a significant concerns about
practice take into account any previous
concerns when deciding if concerns
constitute abuse.
3. If unsure, contact your line manager for
advice and support
If delay in contacting line
manager would
jeopardise the safety of
any person or future
investigation contact the
local authority, then contact
your line manager
Make written record
Is abuse suspected?
YES
NO
Record concern raised on
VoiceAbility reporting form, record
rationale for not alerting send
information to HR business
partner
Address any practice concerns
through Capability or Disciplinary
Procedures
Make alerts following local procedures at
the earliest opportunity and always on the
same day
Follow up alert in writing
Inform Regional Director on the same day.
Send copies of all paperwork to HR
business partner.
Cooperate fully with any investigations by the 22
statutory authorities. In all usual
circumstances VoiceAbility will seek the consent of the relevant statutory authority before
undertaking its own investigations.
On Same Day
1. Make sure person is immediately safe and
gain advice from HR Business Partner.
Ensure you have all the relevant
information
Contact your Line Manager
at the earliest opportunity,
this must allow for an alert
to be made on the same
day
Appendix B – Indicators of abuse
This is not a comprehensive list of indicators. Be alert to indicators and record
such things you observe in your notes on MAAVIS. You will then be able to
review your records to see a bigger picture if needed.
Physical Abuse:






Unexplained bruising; some types of bruising are particularly characteristic of
physical abuse. Bruising may be faint or severe. There may be a pattern to the
bruising e.g. when and where it occurs
Non-accidental injury;
Hand slap marks
Marks made by an implement
Pinch or grab marks, or grip marks – this could indicate that the person has been
shaken, inappropriately restrained, or forcibly removed
Black eyes
Psychological /Emotional Abuse:







Appears scared, anxious or withdrawn
Unexplained sleep disturbances
A reluctance to accept medical attention
Humiliated in front of others
Not being able to do things they used to
Not being able to concentrate or focus
Too eager to do everything they are asked
Financial Abuse:






Sudden inability to pay bills
Apparent lack of knowledge of income
Disparity between income and satisfactory living conditions
Extraordinary interest from other in person’s finances
Unauthorised disposal of property, possessions
Under pressure to make or alter a will
Sexual Abuse:
 Disclosure by means of hints and veiled comments
 Torn, stained or bloody underclothes
 Fear of pregnancy that may be exaggerated
 Difficulty in walking/sitting with no apparent explanation
23


Bleeding, bruising, torn tissue or injury to the rectal and vaginal area
Self-mutilation
Institutional Abuse:






Is unacceptable practice encouraged, tolerated or left unchallenged?
Are service users respected and treated with dignity?
Are the staff well treated and do they enjoy their work?
Are the staff given appropriate training?
Is there a high staff turnover?
Does the organization have a safeguarding adults’ policy?
Neglect














Unusual weight loss, malnutrition, dehydration, deprivation of meals may
constitute “wilful neglect”
Absence of appropriate privacy and dignity
Untreated physical problems, such as bed sores or failure to give prescribed
medication
Unsanitary or unsafe living conditions: dirt, bugs, having no running water, soiled
bedding and clothes
Sensory deprivation - lack of access to glasses, hearing aids etc.
Absence of method of calling for assistance or ignoring calls for help
Unsuitable clothing or covering for the weather
Desertion at a public place or the adult at risk of harm being left alone all day
A carers refusal to arrange access for visitors
Carers who are unable to meet properly the needs for daily care of the cared for
person or refuse to accept help and support to meet these needs properly
Poor relations and/or communication between the cared-for and carers, including
lack of respect or courtesy
The carers have little insight or understanding of the vulnerable person’s
condition or needs
The carer/cared for person have frequently requested help but problems have not
been solved
The carer has their own needs that are unmet e.g. physical or mental health
problems, the cared for person being aggressive and violent towards the carer,
the carer is over burdened.
24
Discriminatory Abuse









Discrimination demonstrated on any grounds including sex, race, colour,
language, culture, religion, politics, sexual orientation, disability or age
Harassment and slurs which are degrading
Hate crime
Being refused access to services or being excluded inappropriately
Adult at risk of harm’s loss of self-esteem
Resistance or refusal to access services that are required to meet need
Expressions of anger or frustration
Tendency to withdraw and isolation
Fearfulness and anxiety
25
Appendix C - Preserving Evidence
In most circumstances you may not need to do anything except record the events that
have given cause for concern. The best way to preserve evidence is to report the matter
as quickly as possible.
However, there may be occasions when it is important to follow certain rules

Make a written record of messages (e.g. answer-phone) to ensure they
are not lost. Include the date and time and sign them

Ensure written records (notes, letters, bank statements, medication
records etc.) are kept in a safe place

Don’t tidy up, wash clothes, bedding or other items.

Do not try to clear or tidy anything up

Try not to touch anything unless you have to for the immediate wellbeing
of the victim – if you have to try to make a record of what you have done

If any sexual offence is suspected try, to discourage the victim from
washing, drinking, cleaning their teeth or going to the toilet until the police
are present

Preserve anything used to warm or comfort the victim e.g. a blanket

Try to ensure that no one else enters the premises or alleged scene of
crime until the police arrive

If you can, try and ensure that the alleged perpetrator does not have any
contact with the victim

Record any physical signs or injuries using a body map or hand drawing.
Write a description of any physical signs or injuries including size, shape,
colour etc.

Always remember to sign and date your notes and any other records you
have made

If the alleged perpetrator is a member of staff, it may be necessary in
some circumstances, to retain equipment (i.e. mobile phone, laptops
etc), gain passwords and/or ensure the alleged perpetrator can’t
access VoiceAbility systems to preserve evidence.
26
Appendix D
Making a Safeguarding Alert for Adults at Risk of Harm
1. Follow your Local Authority Multi Agency procedure for making a Safeguarding
referral.
2. Give information about the suspected abuse:
I.
II.
III.
IV.
V.
VI.
VII.
VIII.
IX.
X.
Date and time of the incident/disclosure
Where the event or disclosed event took place
Exactly what the person (the adult at risk, other person raising the
concern) said, using their own words (their account) about the incident
and how it occurred or exactly what has been reported to you
Appearance and behaviour of the adult at risk, or the other person raising
the concern
Any injuries observed or that you are aware of
If you witnessed the incident, exactly what you saw
Any details of previous concerns raised or incidents of abuse
Is there any evidence, or do we have any information, that indicates that
there is a decline in the individual’s health or condition
Were there any other witnesses. Pass on any names and contact details.
Your account should be factual. However, if the record does contain your
opinion or an assessment, it should be clearly stated as such and be
backed up by factual evidence. Information from another person should be
clearly attributed to them.
3. Give any necessary information that might help any work with the adult, such as:
I.
The adult at risk of harm’s support needs, condition or disability
II. Their communication needs
III. Any information that we have been given about any risks that we have to
be aware of when working with the adult, whether these are risks to any
workers or to the person themselves
IV. Any other information that will support any third parties work with the adult
4. When making the alert, ensure you obtain and record the following details:
I.
Who are you speaking to, what is their role and what are their contact
details
II. What time and date did you speak to them
III. What action will they now take
IV. When will someone contact you to give feedback about any action taken
V. Who will contact you to give you this feedback
27
Appendix E – Contacting Regulators, Police and Other Agencies
In some situations it may be necessary or appropriate for VoiceAbility managers to
contact the Police, Care Quality Commission or other regulatory body. Examples of
such situations are:







Contacting the police if a suspected criminal offence has occurred. The police
should be urgently contacted where evidence needs to be preserved.
Where the person at risk of harm is concerned about their safety, is it possible to
support them to build a relationship with local Police Community Support so that
they feel reassured about contacting them should they feel concerned about their
own safety in the future.
Supporting an Adult with Learning Disabilities to access and use their local “Keep
Safe” initiative.
Contacting the Care Quality Commission if there is evidence suggesting
widespread poor practice in a residential, supported living service or nursing
home.
Contact your local Healthwatch where you are concerned about poor practice for
anyone, or a group of people, receiving any health and social care.
Contacting the Commissioner or a provider service where you are concerned
about the quality of service being received by someone or a group of people.
In some circumstances relating to services for children and young people, it may
be appropriate to contact Ofsted.
28
Appendix F
Recording Guidance for safeguarding concerns where the alleged perpetrator is
not part of VoiceAbility workforce.
Recording for instances where the alleged perpetrator is a member of
VoiceAbility workforce is outlined in sections 5.7.
This guidance relates to the keeping records only. The full reporting procedure
must be followed at all times.
1.
Written record of incident or allegation
1.1.
Please note, and follow the guidance below:
29
It is vital that a written record of any incident or allegation causing concern about
crime or abuse is made as soon as possible after the information is obtained, and
kept by the person raising the concern. Written records must reflect as accurately as
possible what was said and done by the people initially involved in the incident either
as a victim, suspect or potential witness. The notes must be kept safe as it may be
necessary to make records available as evidence and to disclose them to a court.
You must make an accurate record at the time (and certainly on the same day),
including:
I.
Date and time of the incident/disclosure
II.
Exactly what the person (the adult or child at risk, other person raising the
concern) said, using their own words (their account) about the incident and
how it occurred or exactly what has been reported to you.
III.
Appearance and behaviour of the adult or child at risk, or the other person
raising the concern
IV.
Any injuries observed
V.
Name and signature of the person making the record
VI.
If you witnessed the incident, write down exactly what you saw
VII.
Put date and time of your record, including
contemporaneously- which you must retain.
VIII.
The record should be factual. However, if the record does contain your
opinion or an assessment, it should be clearly stated as such and be backed
up by factual evidence. Information from another person should be clearly
attributed to them.’
any
notes
made
(Based on SCIE 2011, SCIE Report 39, Protecting Adults at Risk, 2.3.1.3, P57)
2.
2.1.
Recording a concern
Recording a concern about a person we are currently working with (Existing
Partner)
2.1.1. Record your concern as a new issue under the referral on MAAVIS, coded as
‘Safeguarding adult - alert’ or 'Safeguarding children and young people - alert', as
appropriate.
2.2.
Recording a concern about a person we are NOT currently working with.
30
Please note: Where you have any concerns about potential abuse it does
not matter whether we are working with the person who is subject of your
concerns, nor whether that person fits the criteria for the particular service
for which you work.
2.2.1. You may be concerned about potential abuse of someone who we are not
currently working with. In this case, try to find out the person's name and add
them to MAAVIS as a new referral and then record your concern as in 1.1 above.
Following our Data Protection Policy COR005, tell the person that we will keep a
record.
2.2.2. If you are unable to establish their name, add them to MAAVIS as a new Referral
called “SG.[servicelocation].[number]". For the first such alert in Newham it would
therefore be “SG.Newham.1” You should then try to ascertain the person’s name
at the earliest opportunity and update MAAVIS when you have this.
2.3.
You must record your concern even if, after discussion with your line manager, no
external alert is raised.
3.
Keeping your record safe.
3.1.
You must ensure that you have signed and dated any handwritten notes that you
made at the time. Once signed and dated, your notes must be scanned and
attached under the Referral record in MAAVIS using the Notes and Attachments
function. Keep originals in a locked filling cabinet so that they can be made
available if required.
3.2.
If after discussion with your manager (although you should not delay reporting a
safeguarding concern based on a managers availability ), a formal alert is to be
made, you must use the reporting form, VoiceAbility Safeguarding Vulnerable
Adults Policy Appendix G, or the appropriate local authority safeguarding reporting
form to record the alert. You must attach the completed form to the Referral record
on MAAVIS, by using the Notes and Attachments function as above.
4.
Recording Actions Taken
4.1.
Record all follow up or further actions taken on MAAVIS on the same calendar
day. These actions may include making an external safeguarding alert, and then
following up on the alert until the case’s conclusion. In some circumstances
another course of action may be decided upon by your line manager. The recording
should be done by the person taking the action.
4.2.
When selecting the “Record Type” on the Issue page, select the type of advocacy
that the Referral is for i.e. if it is an IMCA referral, select IMCA.
31
4.3.
Where an external safeguarding alert is to be made, this must be recorded on
MAAVIS within the Issue. This is done by selecting the appropriate option of the
“Response to the Potential Abuse” pick list (Where you chose not to make an
external alert, make brief notes in the “Reason no alert made or accepted” field
and refer to any detailed notes in a Task record if appropriate.
4.4.
Where the Local Authority Safeguarding Team did not accept the Alert, make brief
notes in the “Reason no alert made or accepted” field and refer to any detailed
notes in a Task record is appropriate.
4.5.
Select the appropriate type of abuse from the “Type of Abuse” multi-picklist on the
Issue page.
5.
Record the outcomes
5.1.
It is the responsibility of the person raising the alert to the Local Authority to record
the outcomes for the safeguarding issue on MAAVIS. All issues should have a
recorded outcome on MAAVIS before the issue is closed.
6.
Risk Assessment
6.1.
Where appropriate you should conduct a Risk Assessment, or review any current
Risk Assessment. Any records of this should be saved as a Note & Attachment
under the Partner record and the risk section of the Partner Record should be
updated.
7.
Closing a Safeguarding Alert Issue
7.1.
A safeguarding alert issue may only be closed with the approval of your line
manager. You must record your discussion with your line manager and the
decision taken on MAAVIS under ‘Tasks’.
Appendix G - Reporting Form
Safeguarding Vulnerable Adults
CONFIDENTIAL
Please return the completed form immediately to your line manager
32
Details of Service User:
Name:
Telephone:
Address:
Age/DoB:
Gender:
Information necessary needed to work with service user:
Does the service user have any support needs (disability, impairment or condition)?
How does the service user communicate (including any steps to make the service
accessible, such as translators)?
Has service user given consent for referral?
Any information we have been given about any risks that we have to be aware of
when working with the adult, whether these are risks to any workers or to the person
themselves
Any other information that will support any third parties work with the adult
Details of Carer (if relevant):
Name:
Telephone:
Address (if different from above):
33
Relationship to vulnerable person:
Are you reporting your own concerns or passing on those of somebody else? Please
give details:
Date and time of incident(s)/disclosure:
Where the event or disclosed event took place
Exactly what the person (the adult at risk, other person raising the concern) said,
using their own words about the incident and how it occurred or exactly what has
been reported to you
Appearance and behaviour of the adult at risk, or the other person raising the concern
Any injures observed or that you are aware of
If you witnessed the incident, exactly what you saw
Any details of previous concerns raised or incidents of abuse
If there any evidence, or do we have any information, that indicates there is a decline
in the individual’s health or condition
Were there any other witnesses. Provide names and contact details.
Details of alleged perpetrators (if known):
Name:
Telephone:
34
Address:
Relationship to vulnerable person:
Signed:
Date:
Print Name:
Time:
Internal Use Only:
Was this concern reported to the Local Authority Safeguarding team? Yes/No
If no, please outline the reasons why not reported and who agreed this course of
action.
If yes:
Name of person reported
to
Job Role
Contact Details
Date & Time Reported
What action they will
take
Who will contact you to
give you feedback
When will they contact
you to feedback
Which address the follow
up in writing sent to
35
Signed:
Date:
Print Name:
Time:
For completion by your line manager
Date/Time received:
Reference no./Case no.
36
Appendix H – Follow Up Action for Concerns regarding about a VoiceAbility staff
or volunteer
Details of further action taken (person(s) contacted and when) :
Details of follow up:
Date
Person(s)
contacted
Details
Action Taken
Signed:
Print Name:
Date:
Time:
Copies of this form should be held with the person’s file and by the Line Manager.
37