ACE Safeguarding Children, Young People and Vulnerable Adults.
Introduction and Purpose
- Policy Statement
- Telephone and online appointments
- Corresponding Policies
Introduction and Purpose
ACE is committed to the wellbeing and safety of all children, young people and vulnerable adults who are under the organisation’s care. It is the duty of all adults at the organisation (staff and volunteers) to safeguard the welfare of children and vulnerable adults by creating an environment that protects them from harm, ensuring policy and best practice guidelines are followed, including compliance with statutory requirements.
This policy is informed by local authority safeguarding procedures for Cumbria and Lancashire.
The aims of the ACE Safeguarding Children, Young People and Vulnerable Adults Policy are:
- To safeguard all children, young people and vulnerable adults who encounter the organisation.
- To demonstrate best practice in the area of safeguarding children, young people and vulnerable adults, underpinned by the principles and values of best practice in working to support the development and empowerment of young people, in line with the strategic aims of the Children’s Safeguarding Assurance Partnership, Lancashire Safeguarding Adults Board and Cumbria’s Safeguarding Children’s Board.
- To develop a positive and proactive engagement programme to enable all children, young people and vulnerable adults to participate in an enjoyable and safe programme of activities and therapy.
- To promote high ethical standards within the organisation and ensure these are embedded within philosophy and practice.
- To ensure that ace is fully compliant with relevant national and local safeguarding legislation including The Care Act 2014 regarding vulnerable adults.
- To ensure that all children and adults at risk are kept safe during online and telephone work during covid 19 and beyond.
The key principles underpinning the policy are:
- The child’s and/or vulnerable adult’s welfare is, and should always be, the paramount consideration.
- All children, young people and vulnerable adults have the right to be protected from abuse regardless of their age, gender, disability, culture, language, racial origin, religious beliefs or sexual identity.
- All allegations of abuse will be taken seriously and responded to promptly and appropriately.
- ACE staff and volunteers have a duty of care to prevent abuse and to report any abuse discovered or suspected.
- ACE will work with local agencies to ensure that any concerns are reported and acted upon appropriately.
- Parents and other members of the family will be actively encouraged and supported to engage with ACE and clear communication channels will be developed to facilitate this.
- Staff and volunteers will provide good role models of behaviour, in line with the principles of best practice when working with children, young people and adults.
- Partnerships Local solutions through services working with their communities. Safeguarding adults will be most effective where citizens, services and communities work collaboratively to prevent, identify and respond to harm and abuse. The skills of the multiagency team should be utilised when safeguarding adults with care and support needs.
A “Child” is defined as anyone under the age of 18.
Adult at Risk’ – a person aged 18 or over who needs care and support regardless of whether they are receiving them and because of those needs are unable to protect themselves against abuse or neglect.
Where applicable all of these forms of abuse apply to staff and volunteers within the workplace at Ace in addition to the young people and adults at risk whom we work with.
Bullying can take many forms, including physical, such as hitting, kicking, hair pulling; verbal, such as name calling and taunting; and emotional, such as withdrawal of affection/friendship, exclusion, threatening, intimidation, and provocation; damage to property. Increasingly bullying can take the form of text messaging and e-mail messaging. Bullying can be carried out by peers, family members (parents, siblings) teachers or staff within institutions or colleagues/managers (within a workplace setting). As with other forms of abuse, it is important to recognise when a child, young person or vulnerable adult is being bullied and to be prepared to act on this immediately.
Child Sexual Exploitation
Child sexual exploitation is a form of child sexual abuse. It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants, and/ or (b) for the financial advantage or increased status of the perpetrator or facilitator. The victim may have been sexually exploited even if the sexual activity appears consensual. Child sexual exploitations does not always involve physical contact; it can also occur through the use of technology.
Is defined in the UK as any incident or pattern of incidents of controlling, coercive, threatening behaviour, violence or abuse between those aged 16 or over who are, or have been, intimate partners or family members regardless of gender or sexuality. The abuse can encompass, but is not limited to psychological, physical, sexual, financial, emotional.
- Intimidation and threats. This could be things like shouting, acting aggressing or just generally making you feel scared. This is often done as a way of making a person feel small and stopping them from standing up for themselves.
- This includes name calling or making lots of unpleasant or sarcastic comments.
- This is dismissing someone’s opinion. It can also involve causing someone to doubt their own opinion by acting as if they are being oversensitive if they complain. It is also disrupting a version of events or by suddenly being really after being cruel.
- Being made to feel guilty. This can range from emotional blackmail (threats to kill oneself or lots of emotional outbursts) to sulking all the time or giving the silent treatment as a way of manipulation.
- Economic abuse. This is withholding money, not sharing financial decisions, or even preventing someone from getting a job.
- Telling you what you can and can’t do. This can be explicit, for example only allowing someone out at certain times or controlling who they see, or implicit implying upset or anger if something is done or said in a certain way. See Appendix 2 for domestic abuse support agencies.
Emotional abuse is the persistent emotional ill treatment of a child or young person, resulting in severe and persistent adverse effects on their emotional development. This may involve making a child feel or believe they are worthless or unloved, inadequate or unable to display emotion or affection themselves.
Empowerment – Presumption of person-led decisions and consent.
Adults should be in control of their care and their consent is needed for decisions and actions designed to protect them. Clear justification must be made and documented where action is taken without consent such as lack of capacity or other legal or public interest justification. Where a person is not able to control the decision, they should still be included in decisions to the extent that they are able. Decisions made must respect the person’s age, culture, beliefs and lifestyle.
This may be limiting access to money or other resources, or by forcing all financial responsibility onto their victim while limiting their ability to provide this.
Financial abuse may include:
- Taking money
- Not allowing access to shared money
- Making them account for everything spent
- Making them beg for money
- Preventing them from gaining employment
- Causing them to lose, or forcing them to give up, employment
- Taking out loans, credit cards or running up debts in the victim’s name
- Forcing them to commit crimes for money
- Not allowing them to buy necessities, for themselves or their children, including sufficient food
- Financial abuse can also be when the perpetrator is spending money needed to maintain the home on themselves.
When one or more parties do not consent to the marriage or consent is obtained using duress.
Protection Orders. – The aim of the order is to protect both adults and children who have been or are being forced into marriage against their wishes.
Honour based violence is a crime or incident which has or may have been committed to protect or defend the honour of the family and/or community.” … Such violence can occur when perpetrators perceive that a relative has shamed the family and/or community by breaking their honour code.
Note: Staff receive online training in these areas at induction and should be aware of signs and symptoms emphasised in training and the relevant mandatory reporting duties particularly with regard to the serious Crime act 2015. See appendix 5 for act and procedure for reporting and appendix 6 for helpline contacts and guidance.
Mental Capacity Act 2005
All staff will complete Mca Training online at induction and complete vulnerable adults training online within which there is an in-depth section on mental capacity.
The purpose of the MCA is to protect a person’s right to make their own decision. The five key principles of the act must be applied:
- Capacity must be presumed unless it can be proven otherwise
- People should be given full support to make their own decision
- If a person decides that you consider unwise this does not necessarily mean the person lacks the capacity to make the decision in question
- Anything done for, or on behalf of a person who lacks capacity must be done in their best interest
- Before doing something to someone or making a decision on their behalf, consider whether the outcome could be achieved in a less restrictive way.
- Within the Mental Capacity Act’s Code of Practice, ‘children’ refers to people aged below 16. ‘Young people’ refers to people aged 16-17. This differs from the Children Act 1989 and the law more generally; where the term ‘child’ is used to refer to people aged under 18. Therefore, the majority of the MCA applies to 16- and 17-year olds.
The Act does not generally apply to people under the age of 16 but there are two exceptions: –
- The Court of Protection can make decisions about a child’s property or finances (or appoint a deputy to make these decisions
- Offences of ill treatment or wilful neglect of a person who lacks capacity within Section 2(1) can also apply to victims younger than 16 (Section 44);
The United Nations defines Modern Slavery as the recruitment, transportation, transfer, harbouring, or receipt of persons by improper means (such as force, abduction, fraud, or coercion) for an improper purpose including forced labour or sexual exploitation. It takes on many forms today. See Appendix 6 for helplines.
Neglect /Acts of Omission.
Neglect /Acts of Omission is the persistent failure to meet a child or vulnerable adults basic physical and/or psychological needs. It may involve a parent or carer failing to provide adequate food, shelter and clothing; failing to protect a child or young person from physical harm or danger; or the failure to ensure access to appropriate medical care or treatment. It may also include neglect of the child or vulnerable person’s basic emotional needs, such as
love, warmth and security.
Online abuse / online grooming
Online abuse is any type of abuse that happens on the internet . It can happen across any device that’s connected to the web, like computers, tablets and mobile phones and it can happen anywhere online including social media, text messages and messaging apps.
Organisational or institutional abuse is the mistreatment of people brought about by poor or inadequate care or support, or systematic poor practice that affects the whole care setting. It occurs when the individual’s wishes and needs are sacrificed for the smooth running of a group, service or organisation.
Physical abuse may involve hitting, shaking, throwing, burning or scalding, drowning, suffocating or otherwise causing physical injury to a child or young adult. Physical abuse may also occur when a parent or carer deliberately causes ill health to the child or young adult. Physical abuse can be caused through omission or the failure to act to protect.
Position of Trust
People can be considered to be in a ‘position of trust’ where they are likely to have contact with adults at risk as part of their employment or voluntary work.
Prevention of harm or abuse is a primary goal. Prevention involves helping the person to reduce risks of harm and abuse that are unacceptable to them. Prevention also involves reducing risks of neglect and abuse occurring within health services.
Proportionality – Proportionality and least intrusive response appropriate to the risk presented.
Responses to harm and abuse should reflect the nature and seriousness of the concern. Responses must be the least restrictive of the person’s rights and take account of the person’s age, culture, wishes, lifestyle and beliefs. Proportionality also relates to managing concerns in the most effective and efficient way.
Protection – Support and representation for those in greatest need.
All staff have a duty to support all patients to protect themselves. Staff have a positive obligation to take additional measures for patients who may be less able to protect themselves.
Self-neglect is any failure of an adult to take care of himself or herself that causes or is reasonably likely to cause within a short period of time, serious physical, mental or emotional harm or substantial damage to or loss of assets.
Self-neglect can happen because of an individual’s choice of lifestyle, or the person may:
- be depressed,
- have poor health,
- have cognitive (memory or decision making) problems, or
- be physically unable to care for self.
Sexual abuse involves forcing or enticing a child, young person or adult to take part in sexual activities, where they are not aware of, or unable to give consent to, what is happening. The activities may involve physical contact, including penetrative acts, such as rape, buggery or oral sex or non-penetrative acts such as fondling. Sexual abuse may also include non-contact activities, such as involving children in looking at, or in the production of, sexually explicit or pornographic materials or activities, or encouraging children and young adults to behave in sexually inappropriate ways. This covers activities such as internet “grooming”. Boys and girls can be abused by males and females, by adults and other young people.
Ace will ensure that staff and volunteers are aware of and comply with the 4 strategic objectives of the CSAP online safeguarding strategy.
Ace will also comply with its social media policy regarding children and people at risk interaction with its social media accounts
The Care Act 2014 defines safeguarding duties which apply to an adult who:
- Has needs for care and (whether or not the local authority is meeting any of those needs)
- Is experiencing, or at risk of neglect or abuse
- As a result of those care and support needs is unable to protect themselves from either the risk of, or the experience of abuse or neglect.
This could include people with learning disabilities, mental health problems, older people and people with physical disabilities or impairments. This can include people who are vulnerable themselves as a consequence of their role as a carer for such a person. They may need additional support to protect themselves, for example, in situations such as domestic abuse, physical frailty or chronic illness, sensory impairment, challenging behaviour, drug or alcohol problems.
The risks that increase a person’s vulnerability should be appropriately assessed and identified by the health care professional at the first contact and continue throughout the care pathway (DH 2010).
Support provided should be appropriate to the person’s physical and mental abilities, culture, religion, gender and sexual orientation and tailored to enable people to live lives that are free from violence, harassment, humiliation and degradation.
Also referred to as psychological violence, emotional abuse, or mental abuse, is a form of abuse, characterized by a person subjecting, or exposing, another person to behaviour that may result in psychological trauma, including anxiety, chronic depression, or post-traumatic stress disorder. It is often associated with situations of power imbalance in abusive relationships including bullying, gaslighting and abuse in the workplace.
ACE has a Designated Safeguarding Officer, who has overall responsibility for the safeguarding of children, young people and vulnerable adults who engage in activities provided by the organisation. The Designated Safeguarding Officer is Sally Temple, see Appendix 7 for contact details. A key part of this role involves providing training, support and information to staff and volunteers in relation to safeguarding procedures and ensuring compliance. The officer will also ensure that all workers and directors complete relevant safeguarding training for children and vulnerable adults including Prevent, CSE, MCA, data protection, level 1 and 2 safeguarding children and safeguarding vulnerable adults and comply with the principles learnt therein. See Appendix 2, 5 and 6.
The safeguarding adults and children lead are trained to Level 5 safeguarding with the Childrens Safeguarding Assurance Partnership.
The Safeguarding Officer will also ensure that links are established and maintained with Local Authority (Lancashire County Council/Cumbria County Council) Safeguarding Boards, The childrens safeguarding assurance partnership and Social Services.
PIPOT information (Person in a Position of Trust)
All Pan Lancashire & Cumbria Safeguarding Adults Board relevant partners are to identify a person who will hold responsibility for information management oversight within their respective organisations of individuals within their agencies where concerns have been raised about a person in a position of trust (PiPoT). This person for ACE is the safeguarding lead Sally Temple
The Ace PIPOT lead has clear recording and information sharing guidance, can set explicit timescales for action and is aware of the need to preserve evidence. The ACE PiPoT lead will share safeguarding concerns about people who hold a ‘position of trust’ using multiagency safeguarding procedures and key partners will contribute to initial enquiries and any subsequent strategy discussion / meeting
Human Resources and Disclosure
As part of the recruitment and selection process, offers of employment, voluntary work opportunities or placements to positions which involve working with children, young people or vulnerable adults, are subject to satisfactory enhanced DBS disclosure and appropriate references. Staff will not be allowed to work unsupervised with children, young people and vulnerable adults until their Disclosure certificate has been received.
All staff, volunteers and students on placement will be required to complete initial training on Safeguarding as part of their induction and further training to the level required for their job responsibilities. The officer will also ensure that all workers and Directors complete relevant safeguarding training for children and vulnerable adults including Prevent, CSE, MCA, data protection, level 1 and 2 safeguarding children and safeguarding vulnerable adults and comply with the principles learnt therein. See Appendix 2, 5 and 6.
Ace is linked with the Lancashire and Cumbria Safeguarding Boards. We have a managed programme of safeguarding training to ensure that all trustees, staff and volunteers receive the right level of training for their roles and responsibilities. As part of ACE’s commitment to safeguarding throughout all its services, we have a dedicated vulnerable adults and children lead.
Health and Safety
ACE’s Health and Safety Policy gives guidance to those whose role involves working with children, young people and vulnerable adults. Risk assessments must consider situations where there is the potential for safeguarding to be compromised in any way – for example, during residential or external visits.
When children, young people or vulnerable adults are being transported on behalf of the organisation, they will be accompanied by a member of staff or volunteer who has a satisfactory DBS disclosure, and with the specific prior consent of their parent or guardian.
If invited to stay overnight, on a residential, young people will be accompanied by nominated staff members or volunteers who have been enhanced DBS checked and have undertaken Safeguarding training. Written parental/guardian consent will be sought before a child or young person is invited to go on a residential. Emergency contact numbers will be sought from parents/carers prior to any external visit or residential.
Code of Behaviour
All ACE staff and volunteers will be required to adhere to a Code of Behaviour. See Appendix 1.
All issues of confidentiality should adhere to the following 7 principles of information sharing.
- Remember that GDPR is not a barrier to sharing information
- Be open and honest
- Seek advice
- Share with consent where appropriate
- Consider safety and well-being
- Information sought and utilised must be necessary, proportionate, relevant, accurate, timely and secure
- Keep a record.
Recognising and Responding to Abuse
Recognising the signs of abuse
It is important to recognise that abuse can take many forms. Children, young people and vulnerable adults may be abused or suffer neglect through the infliction of harm or through failure to act to prevent harm from occurring. Abuse can occur in family, educational, institutional or community settings, and the perpetrator may be known or unknown to the child or vulnerable adults. There are 10 forms of abuse and staff/ volunteers should contact the ACE Designated Safeguarding Officer immediately if they have any concerns in relation to any of the following. Appendix 3 and 4 give further information on how to proceed if you suspect abuse of a child or vulnerable adult.
Responding to a report or suspicion
Where possible, the ACE Designated Safeguarding Officer should be contacted as early as possible. In the cases of suspected/reported child abuse, staff and volunteers must adhere to the following guidelines.
- Always treat any allegations extremely seriously and act as if you believe what the child, young person or vulnerable adult is saying.
- Tell the child, young person or vulnerable adult that they are right to disclose.
- Reassure them that they are not to blame.
- Be honest about your own position – and about who you must tell and why you must report disclosures.
- Tell the child or vulnerable adult what you are doing and when and keep them informed of what is happening.
- Write down everything said and what was done. Keep a record of this and subsequent conversations, making sure any recorded information is factual and accurate. Good record keeping is a vital component of professional practice. Where there are concerns about a child or vulnerable adult’s welfare, all concerns, discussions and decisions made and the reasons for those decisions must be recorded in writing in the medical records. Any bruises, marks and/or unexplained injuries observed should be clearly documented on a body map within the records
- Seek medical attention if necessary.
- Inform parents or carers, unless there are grounds to believe they are involved in the abuse.
- Remain calm and remember this is likely to be a stressful situation for the child, young person or vulnerable adult.
- Make promises that you cannot keep.
- Interrogate the child or vulnerable adult. It is not your job to carry out an investigation. This will be up to the police or social services.
- Cast doubt on what the person has told you. Don’t interrupt or change the subject.
- Say anything that makes the child, young person or vulnerable adult feel responsible for the abuse.
- Include your own opinion or interpretation in any written reports. It is important to make sure that what is written is an accurate reflection of what the child or young person has been telling you. or
- Avoid showing emotions, such as distrust, anger or disbelief, as this may stop an individual from talking or make them feel your negative feelings at being directed at them
All serious untoward incidents (SUIs) compromising the safety and welfare of children and vulnerable adults are to be reported to the Head of Safeguarding for the CCG, or where needed to relevant funders, by the Designated Safeguarding Officer Sally Temple.
All complaints that refer to the safety of children and vulnerable adults are investigated thoroughly by ACE.
ACE will regularly review cases where there are safeguarding concerns (for both children and vulnerable adults). Reviews will be monitored and recorded.
Children Missing Education Officer
When it is known that a child is not accessing education a referral will be made to the Local Authority in which the child lives. Where it is discovered a child is not receiving any form of education the Children Missing Education Officer is to be notified.
Online and Telephone Appointments
During Covid 19 Ace has become a hybrid service with a combination of face to face, online and telephone appointments. At all times Ace will comply with local and national Covid 19 restrictions as indicated in its dynamic risk assessment.
The following procedures will be followed for online and telephone appointments
- Staff will use Ace mobiles where they have them and otherwise will dial 141 to block their numbers
- Consent for phone work will be sought at first call from the young person (if 16 plus) and from the parent if under 16. This can be done verbally on first appointment and recorded on standard consent form.
- The Ace staff member will explain the service, seek consent, discuss confidentiality, risk assess and set boundaries at first call as they would in a face to face appointment.
- Other methods of remote work such as whatsapp calls and zoom calls are only to be used if consent is sought as for phone calls. These methods are only to be used with line manager’s agreement and using Ace computers and phones.
- All existing consent and confidentiality procedures apply to online and phone work.
ACE ensures adherence to this policy through mandatory training on Safeguarding. In addition, ACE ensures that this policy remains fit for purpose through annual reviews.
Policies, procedures and systems
All concerns, suspicions and allegations of abuse or harm will be recorded and reported to the Designated Safeguarding Officer in line with the CSAP LSAB, and CSCB
Regarding complaints and whistle blowing, staff and service users receive a guarantee that using procedures appropriately will not prejudice their own position or prospects. Whistleblowing is when a worker reports suspected wrongdoing at work. Officially this is called ‘making a disclosure in the public interest’.
All allegations of abuse or maltreatment of children by a staff member or volunteer will be taken seriously and treated in accordance with LSCB Lado procedure as follows.
As outlined in “Working Together to Safeguard Children” (2015), the LADO will be informed of all allegations against adults working with children and provides advice and guidance to Senior Managers on the progress of cases to ensure they are resolved as quickly as possible. Information relating to allegations is collated and presented to Safeguarding Children Boards to inform training, research, safer recruitment and awareness raising.
The LADO is located within Children’s Services and should be alerted to all cases in which it is alleged that a person who works with children has:
- Behaved in a way that has harmed, or may have harmed a child
- Possibly committed a criminal offence against, or related to, a child; or
- Behaved towards a child or children in a way that indicates they may pose a risk of harm to children.
The LADO role applies to the children’s workforce (paid, self-employed and volunteers). The LADO is involved from the initial phase of the allegation through to the conclusion of the case.
The LADO will provide advice and guidance and help determine that the allegation sits within the scope of the procedures. Within the role the LADO helps co-ordinate information sharing. The LADO will also monitor and track any investigation with the expectation that it is resolved as quickly as possible.
These procedures may also be used where concerns arise about:
- The person’s behaviour about his/her own children;
- The behaviour in the private or community life of a partner, member of the family or other household member;
- A person’s behaviour in their personal life, which may impact upon the safety of children to whom they owe a duty of care.
Remember: The LADO must be contacted when you have received any allegation or concern about any person who works with children who may have: –
- Behaved in a way that has harmed, or may have harmed a child
- Possibly committed a criminal offence against, or related to, a child; or
- Behaved towards a child or children in a way that indicates they may pose a risk of harm to children.
This policy is approved on a minimum annual basis.
The policy will be reviewed by a minimum of 2 Directors including the accountable Director. Approval of the policy will be minuted within the Directors meetings.
If the policy is revised within an annual review period, a new version is created, and the review date is moved to 12 months from the approval date.
The Safeguarding Policy should also be looked at in the context of ACE’s Confidentiality and Information Governance Policies. These policies set out the boundaries of confidentiality, as follows:
- Children, young people and vulnerable adults have the right to confidentiality. They should feel confident that anything they say to a member of staff or volunteer will remain confidential, except in specific circumstances.
- Where a child, young person or vulnerable adult discloses that they are at risk of harm, are experiencing harm (as identified in the categories of abuse highlighted below) or that they are at risk of harming themselves or other people confidentiality can’t be kept. This will be explained to the young person before work starts with them.
- These boundaries should make it clear that if a child, young person or vulnerable adult discloses that they are at risk of harm or risk harming others (as defined above), then ACE staff or volunteers will have to pass this information on. This will be accompanied by clear explanations of why it is important to refer the information on, who will be informed and why.
- All concerns should be discussed with the designated safeguarding officer (and the required procedures followed including sending in forms. If in any doubt, the ACE Designated Safeguarding Officer should always be consulted. If the safeguarding officer is unavailable the case can be discussed with the safeguarding board or social care without disclosing the identity of the individual
- In a clear safeguarding case, the prime concern is to keep the young person safe.
Procedures should be followed involving the relevant people: Designated safeguarding officer, parents, Accident and Emergency Department, school Safeguarding lead, social care or police. Completed forms must be sent to the designated safeguarding officer.