Group adult safeguarding policy

1. What the policy covers

This policy applies to any adult who:

• has care/support needs.
• is experiencing, or is at risk of, abuse or neglect.
• is unable to protect him/herself because of their care/support needs.

The above applies regardless of whether the person’s care and support needs are being met via the local authority, via an informal arrangement or not at all. It is also irrelevant whether the local authority or the person funds any care and support services that are in place.

Housing Plus Group (HPG) recognises that people can be at risk of abuse or neglect regardless of where they live.

The statutory guidance also recognises people who are victims of sexual exploitation, domestic abuse, and modern slavery. It also recognises that unpaid carers e.g. a family member will sometimes have care and support needs of their own and may be experiencing intentional or unintentional harm from the adult they are trying to support.

People with care and support needs are not inherently vulnerable but may come to be at risk of abuse or neglect at any point due to ill health, disability, getting older, cognitive impairment, having limited support networks or being socially isolated.

Our policy also applies to safeguarding situations, where there are concerns or evidence that a member of HPG staff may be at risk of abuse, suffering harm or perpetrating abuse or neglect upon another person.

The Care Act 2014 explicitly acknowledges the role of housing and the valuable contribution that housing providers can make in helping to keep people safe. The Care Act’s statutory guidance sets out the responsibilities of housing providers to ensure that they play their part effectively in safeguarding referrals, including when it is determined a safeguarding referral has met the threshold for a section 42 enquiry.

2. We will:

• Engage with those who we believe need safeguarding while treating them with respect and
  discuss any referrals or signposting with them when it is safe to do so.
• Make sure that our responsibilities are understood including how Directors and senior members of
  staff lead our organisation by:
  • 1. Making sure that clear policies and procedures are in place and that we actively share information and work with partner agencies.
  • 2. Taking care to link this policy to other key policies and procedures.
  • 3. Training all HPG staff (and those who work with us) to identify signs of abuse and know how to respond to concerns appropriately.
  • 4. Providing staff and managers, who are responsible for making decisions about dealing with concerns, with support, guidance, and supervision.
  • 5. Putting in place effective mechanisms to capture, analyse, monitor, and review all concerns, and share learning. The Safeguarding and Wellbeing Committee will manage all cases including when to close them.

When we are made aware of a safeguarding issue and the threshold is not met or the local authority do not accept the referral, we will look to support the customers in terms of raising and managing a wellbeing concern. There is a different procedure for managing these concerns in Care Plus and general needs accommodation.

3. Guidance

Our policy and procedures are underpinned by the six principles of safeguarding, as enshrined in the Care Act 2014 and its statutory guidance – Appendix 1.

We will not discriminate on the grounds of any protected characteristic and due regard will be given to individual differences including age, disability, gender, gender reassignment, race and ethnicity, religion or belief, sexual orientation, caring responsibilities, culture, language, marital or civil partnership status.

• All colleagues have a responsibility to comply with our safeguarding policy, undertake training in line with company expectations and act when they become aware of, or suspect a safeguarding situation may exist.
• All colleagues must report suspected or actual abuse as soon as possible after they become aware
  of it. In all instances line managers should be made aware, unless there is a belief they engaged in the abuse, in which case a more senior manager should be approached. Any member of the Safeguarding and Wellbeing Committee can give advice and support to staff or managers who have concerns about a possible safeguarding incident.
• We understand colleagues may not be sure whether a matter is a safeguarding issue or not and we encourage everyone to raise incidents so that we can ensure people are protected.
• HPG’s Safeguarding steering group review performance on a quarterly basis including case studies detailing important lessons learned.

4. Making sure we do what we say

Safeguarding is embedded in our corporate framework through the Safeguarding and Wellbeing Committee, safeguarding steering group, reports written and presented to our Audit and Risk Committee, links with other policies, our values, our competency framework and training programmes.

Our approach emphasises the need for a balance between risk avoidance and risk appraisal, considering a person’s preferences, circumstances, and tolerance of acceptable risks. HPG’s risk register references safeguarding from a governance perspective and is considered by our Audit and Risk Committee.

The procedures which support this policy aim to ensure that our staff, managers, and People team know what to do when any concerns become known, including where a member of staff may be implicated. Our procedures have been formulated in accordance with local authority multi-agency procedures and include requirements for recording of information, information sharing, assessing risk and assessments.

Our Executive team and senior managers have a responsibility for ensuring this policy and its associated procedures are effectively implemented and to support managers and staff in dealing with all concerns.

• Our approach includes regular basic awareness training for staff to advanced level training for senior managers and key front-line staff.
• Training includes the links to local authority multiagency procedures as well as to other key
  procedures. E-learning is available for all staff and locally based training via local authorities is also
  utilised.

Awareness-raising with customers is undertaken through a variety of communication channels, including information leaflets, articles in customer newsletters and e-bulletins, websites and discussions with customers in supported housing as part of support planning and tenancy reviews.

HPG also recognises that it could be expected to make enquiries for a local authority in line with their duties under Section 42 of the Care Act.
(Guidance at SSASPB- Section 4 Safeguarding Enquiries section 42 care act 2014 (ssaspb.org.uk))

HPG is also committed to cooperating and participating fully in any safeguarding reviews.

We are committed to safe recruitment and ensuring no vulnerable adult is placed at risk where our recruitment practice could have foreseen and prevented the risk occurring. Our Recruitment and selection policy covers our approach to recruiting: ensuring that we take all reasonable steps to protect vulnerable individuals from harm such as the use of Disclosure and Barring Service (DBS) and enhanced checks.

If we receive an allegation that a colleague has abused or neglected a customer, we will report this to our People team, the local police, our safeguarding team and to the DBS as appropriate. We will work with the police and local authority safeguarding team to investigate. (If we are referring to our safeguarding team then list this before the police).

5. We will look at this again

In three year’s time unless anything changes. (Nov 2027)

Appendix 1- Priciples of Safeguarding

• Empowerment – People should be supported to retain control of their own lives, and their wishes,
  feelings, values, and beliefs should be fully considered. The role of HPG staff is to support the
  person to make informed decisions throughout the process.
• Protection – the safeguarding framework should support people to safeguard themselves from
  abuse or be protected if they are unable to make their own decisions about their safety.
• Prevention – is the primary goal and includes increasing awareness and understanding and
  supporting people to safeguard themselves. Arrangements should be in place to minimise the risk of abuse.
• Proportionality – responses to concerns must be proportional to the assessed risk and the nature
  of the concern. Where a person lacks mental capacity, any decisions made on their behalf must be made in their “best interest” and be least restrictive to their rights and freedoms in Accordance with the Mental Capacity Act.
• Partnerships – working collaboratively to prevent and respond effectively to concerns of abuse.
  This includes with the person, other partners, statutory agencies, relatives, friends, informal carers, and advocates to achieve good outcomes.
• Accountability – decisions made should be transparent, recorded, and defensible. There should be good governance of safeguarding including review and learning. The Boards and staff need to understand what is expected of them, fulfil their responsibilities, and work collaboratively with others.

Acting without consent should only be done if there is a clear justification to act contrary to the person’s wishes.

Our safeguarding arrangements will be compliant with the Care Act 2014 with the Mental Capacity Act 2005 (MCA), its principles and associated Code of Practice to ensure that any decisions made on behalf of those who lack capacity are always made in the person’s best interests and as least restrictive as possible. The policy will be adopted to take account of any changes in relevant legislation, which always takes precedence over HPG policy if there is any incompatibility or conflict. We also recognise that there could be overlaps with deprivation of liberty issues and safeguarding.

HPG intends that safeguarding is embedded in all our activities. Raising awareness with our customers and communities and working together with them and other agencies, we will provide effective support ensuring staff have the confidence to deal with concerns and where necessary, “blow the whistle.”

Safeguarding is fundamentally about prevention, wherever possible. By ensuring that our staff are
observant means that we can make a real difference through early and positive interventions.

This policy also ensures that our own housing support services comply with safeguarding standards as set out in Local Authority contracts. Compliance with local authority procedures is a common requirement of service contracts with local authority commissioners. The policy provides for precedence of local authority procedures where contracts include this requirement. HPG will assess local authority requirements to ensure they are acceptable before submitting binding tenders or an application to join service frameworks.

Appendix 2 – Examples of the types of safeguarding

Types of physical abuse

• Assault, hitting, slapping, punching, kicking, hair-pulling, biting, pushing
• Rough handling
• Scalding and burning
• Physical punishments
• Inappropriate or unlawful use of restraint
• Involuntary isolation or confinement
• Misuse of medication (e.g. over-sedation)
• Unauthorised restraint, restricting movement (e.g. tying someone to a chair)

Types of domestic violence or abuse

Domestic violence or abuse can be characterised by any of the indicators of abuse outlined in this briefing relating to:

• psychological
• physical
• sexual
• financial
• emotional.

Types of sexual abuse

• Rape, attempted rape or sexual assault
• Inappropriate touch anywhere
• Non – consensual masturbation of either or both persons
• Non – consensual sexual penetration or attempted penetration of the vagina, anus, or mouth
• Any sexual activity that the person lacks the capacity to consent to
• Inappropriate looking, sexual teasing or innuendo or sexual harassment
• Sexual photography or forced use of pornography or witnessing of sexual acts
• Indecent exposure

Types of psychological or emotional abuse

• Enforced social isolation – preventing someone accessing services, educational and social
  opportunities and seeing friends
• Removing mobility or communication aids or intentionally leaving someone unattended when
  they need assistance
• Failure to respect privacy
• Preventing stimulation, meaningful occupation or activities
• Intimidation, coercion, harassment, use of threats, humiliation, bullying, swearing or verbal abuse
• Addressing a person in a patronising or infantilising way
• Threats of harm or abandonment
• Cyber bullying

Types of financial or material abuse

• Theft of money or possessions
• Fraud, scamming
• Preventing a person from accessing their own money, benefits or assets
• Employees taking a loan from a person using the service
• Undue pressure, duress, threat or undue influence put on the person in connection with loans,
  wills, property, inheritance or financial transactions
• Denying assistance to manage/monitor financial affairs
• Denying assistance to access benefits
• Misuse of personal allowance in a care home
• Misuse of benefits or direct payments in a family home
• Someone moving into a person’s home and living rent free without agreement or under duress
• False representation, using another person’s bank account, cards or documents
• Misuse of a power of attorney, deputy, appointeeship or other legal authority

Types of modern slavery

• Human trafficking
• Forced labour
• Domestic servitude
• Sexual exploitation, such as escort work, prostitution and pornography
• Debt bondage – being forced to work to pay off debts that, realistically, they never will be able to
  pay off
  GOV.UK has more information on identifying and reporting modern slavery

Types of discriminatory abuse

• Unequal treatment based on age, disability, gender reassignment, marriage and civil partnership,
  pregnancy and maternity, race, religion and belief, sex or sexual orientation (known as ‘protected
  characteristics’ under the Equality Act 2010)
• Verbal abuse, derogatory remarks or inappropriate use of language related to a protected characteristic
• Denying access to communication aids, not allowing access to an interpreter, signer or lip-reader
• Harassment or deliberate exclusion on the grounds of a protected characteristic
• Denying basic rights to healthcare, education, employment and criminal justice relating to a
  protected characteristic
• Substandard service provision relating to a protected characteristic

Types of organisational or institutional abuse

• Discouraging visits or the involvement of relatives or friends
• Run-down or overcrowded establishment
• Authoritarian management or rigid regimes
• Lack of leadership and supervision
• Insufficient staff or high turnover resulting in poor quality care
• Abusive and disrespectful attitudes towards people using the service
• Inappropriate use of restraints
• Lack of respect for dignity and privacy
• Failure to manage residents with abusive behaviour
• Not providing adequate food and drink, or assistance with eating
• Not offering choice or promoting independence
• Misuse of medication
• Failure to provide care with dentures, spectacles or hearing aids
• Not taking account of individuals’ cultural, religious or ethnic needs
• Failure to respond to abuse appropriately
• Interference with personal correspondence or communication
• Failure to respond to complaints

Types of neglect and acts of omission

• Failure to provide or allow access to food, shelter, clothing, heating, stimulation and activity,
  personal or medical care
• Providing care in a way that the person dislikes
• Failure to administer medication as prescribed
• Refusal of access to visitors
• Not taking account of individuals’ cultural, religious or ethnic needs
• Not taking account of educational, social and recreational needs
• Ignoring or isolating the person
• Preventing the person from making their own decisions
• Preventing access to glasses, hearing aids, dentures, etc.
• Failure to ensure privacy and dignity

Types of self-neglect

• Lack of self-care to an extent that it threatens personal health and safety
• Neglecting to care for one’s personal hygiene, health or surroundings
• Inability to avoid self-harm
• Failure to seek help or access services to meet health and social care needs
• Inability or unwillingness to manage one’s personal affairs

Appendix 3- Process for managing cases

• Colleagues, contractors or customers call the Customer Services Contact Centre (CSC) or email the Community safety team.
• CSC transfer the call to the General need’s duty officer or, for retirement living properties, to the
  Safeguarding duty officer
• The duty officer triages the call using prescribed template and enters information onto the case
  management system.
• Triage form identifies risk by looking at threshold criteria.
• Duty officer makes call to local Safeguarding authority as appropriate and then passes to relevant Neighbourhood officer or Retirement living manager to complete action plan.
• Case referred to Safeguarding and Wellbeing Committee for monthly reviews.