Safeguarding Vulnerable People Policy & Procedure

Policy Statement

Safeguarding is a term used in the United Kingdom and Ireland to denote measures to protect the health, well-being and human rights of individuals, which allow people — especially children, young people and vulnerable adults — to live free from abuse, harm and neglect. At Petit Miracles, safeguarding the people we support is vital to our service delivery. As we work with vulnerable adults from varying backgrounds, we have a duty and commitment to ensure we safeguard the welfare of the people we support. An adult at risk is defined as a person who has care and support needs and is, or is at risk of, being abused, exploited or neglected and unable to protect themselves against the abuse, exploitation or neglect or risk of it because of those needs. There are many different types of abuse that vulnerable adults may face: 

• Physical abuse
• Domestic violence or abuse
• Sexual abuse
• Psychological or emotional abuse
• Financial or material abuse
• Modern slavery
• Discriminatory abuse
• Organisational or institutional abuse
• Neglect or acts of omission
• Historical Abuse
• Radicalisation
• Human trafficking
• Cyber bullying
• Gang/criminal Abuse
• Female mutilation
• Self-neglect

This policy has been created to prevent abuse, and to identify and deal with abuse where it is occurring. Safeguarding Vulnerable Groups Act 2006 sets out the type of activity covered by the act in relation to children and vulnerable adults. 

1. Who is a vulnerable adult? 

• A vulnerable adult is defined as a person 18+ years of age ‘who is or may be in need of community care services by reason of mental or other disability, age or illness; and who is or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation’ (Department of Health, 2000) 
• This may mean that they have a reduced ability to protect themselves from assault, abuse or neglect 
• This can be as a result of a learning or physical disability (not normally to include dyslexia); a physical or mental illness, chronic or otherwise (including an addiction to alcohol or drugs); or a reduction in physical or mental capacity 

2. Objectives of Policy 

To achieve the objective of this policy we will provide the following:

• Provide vetted staff (and where appropriate, volunteers) with relevant safeguarding training and support
• Provide a safe environment for all beneficiaries 
• Provide a structure and processes that ensure allegations or suspicions are dealt with appropriately and in-line with our procedures

3. Guiding Principles 

To provide vetted staff (and where appropriate, volunteers) with relevant safeguarding training and support, we will:

• Recruit, vet (enhanced Disclosure and Barring Service checks) and train trustees, staff and volunteers ensuring they are suitable to work with vulnerable adults. Trustees, staff and volunteers will be recruited in-line with our Safer Recruitment policy:
• All staff members’ suitability will be assessed during the interview process and a minimum of 2 references are requested to assess their suitability
• Ensure everyone knows their responsibility and role in safeguarding 
• Enable effective delivery of safeguarding by ensuring staff receive induction training, which will give an overview of the organisation and ensure they know its purpose, values, services and structure
• Provide further and ongoing safeguarding training ensuring at least one staff member has received Safeguarding Officer training -Refresher courses usually occur once a year or every two years
• Support staff and volunteers to carry out their job with appropriate supervision

To provide a safe environment for all beneficiaries, we will: 

• Listen to our beneficiaries and use the information to make recommendations, ensuring they are safe. Ensuring that our students, with different communication styles can communicate any concerns they have.
• Be sensitive to noticing changes in behaviour that may be caused by abuse.
• Empower them by encouraging them to make their own decisions and provide informed consent
• Respect their individual thoughts, feelings and goals and make an effort to create relationships where they feel comfortable to disclose any abuse
• Regularly check our risk assessments, policies and processes are up to date, topical and meet the needs of our beneficiaries. 

To provide a structure and processes that ensure allegations or suspicions are dealt with appropriately and in-line with our procedures, we will:

• Provide clear and accessible information regarding safeguarding for staff, trustees, volunteers and beneficiaries 
• Share the safeguarding policy with beneficiaries to ensure they understand their role in safeguarding
• Highlight safeguarding as a permanent agenda item for team meetings and trustee meetings
• Provide clear records of any incidents or beneficiary feedback on safeguarding issues, general feedback or best practice suggestions 
• Provide ongoing safeguarding training for any relevant staff members, trustees and where necessary, volunteers, ensuring at least one staff member has received Safeguarding Officer training 

4. Trustees and responsible person: Overall leadership of safeguarding 

• Safeguarding is the duty of all staff, trustees and volunteers, this policy has been created to help staff/volunteers to recognize and respond to cases of abuse 
• The Programme Director is the Safeguarding Officer as of January 2021, after completing ‘ Level 4 Designated Safeguarding Officer Training for Schools, Colleges, and Training Providers’ in November 2020. At the time of writing this policy, the most recent Designated Safeguarding Officer (Adults) certificate was received by Safeguarding officer in March 2023 and next training will take place in March 2025.

5. What is abuse? 

• Abuse is a violation of an individual’s human and civil rights
• Abuse can be physical, emotional or psychological, it may be an act of neglect or an omission to act, or it may occur when a vulnerable person is persuaded to enter into a financial or sexual transaction to which he is she has not consented, or cannot consent
• Abuse can occur in any relationship and may result in significant harm to, or exploitation of, the person subjected to it
• Abuse can take place in any setting, and to any vulnerable adult, whether living alone or with a relative, in a nursing, residential or day care setting, hospital, custodial situations or when support services are coming into people’s own homes, etc
• There are several forms of abuse, some of which are more likely to happen to young people but any form of abuse can happen to anyone. For the purpose of ensuring trustees, staff and volunteers are aware of the types of abuse prone to children and adults, we have created two tables. As already mentioned any type of abuse can happen to anyone at any time:

Young People- Types of Abuse

Psychological or emotional abuse is….
– Blaming, shaming
– Threatening, shouting, humiliating, constant criticism
– Exposing child to abuse or addiction
– Being absent
– Not providing care or positive attention/constantly ignoring the child
– Not promoting their physical or social development

Bullying/Cyber bullying is….
– Abusive text messages
– Trolling- sending messages via chat rooms, social media, on-line games
– Shaming on-line
– Encouraging damaging behaviour such as self-harming or sexting
– Stealing on-line identities to shame or cause trouble using their name
– Excluding someone from joining a game, chat room so as to alienate them
– Sharing embarrassing videos or messages

Child trafficking is…
– When a young person is forced to leave their home and are then transported elsewhere and exploited. They can be sexually exploited, or for
benefit fraud, into a forced marriage, modern day slavery or committing crimes such as moving drugs.

Gang and criminal exploitation is…
–  When a young person is forced into criminal behaviour by a street gang or organised crime gang for the purpose of violence, financial gain.

Domestic abuse is…
– Physical abuse, hitting, punching, cutting
– Threatening language and behaviour
– Controlling behaviour, i.e. telling them what they can’t wear
– Withholding money
– Non-consensual sexual intercourse
– Emotional abuse
– Psychological abuse

Female genital mutilation is….
– When a female’s genitalia is purposely altered or removed for non-medical reasons, specifically to control female sexuality. It is a criminal offence in the U.K.

Grooming is…
– When a person slowly aims to build a relationship with a young person with the aim to manipulate, abuse and/or exploit.
– Grooming can be a mentor, an authority figure, parent, an romantic partner.

Physical Abuse is….
Is when someone harms a young person through:

– Hitting, punching, cutting, slapping, kicking, throwing, shaking
– Scalding/burning
– Poisoning
– Drowning
– Biting and scratching
– Rough handling
– Restraint
– Involuntary confinement
– Forcible feeding or with holding food

Neglect is….
– A persistent failure to provide basic needs, i.e. food, shelter, care, clothing, health care, education, social development, put in harm’s way.

Historical abuse is….
When a person was the victim of abuse when they were younger (under 18) years of age

Sexual abuse is….
When a young person is forced into sexual activities. This can happen both on-line and in person.
In person sexual abuse is…

– Touching a young person’s body
– Forcing a child to partake in sexual activity
– Making a young person to touch someone else
– Making a young person undress
– Sexual abuse can be intercourse or touching, or kissing.
– On-line abuse is exposing themselves or making the young person expose themselves
– Making them masturbate or perform sexual acts.

Radicalisation is…
– The grooming of a young person who becomes a supporter of terrorism or extremist ideologies associated with terrorist groups.

Adults – Types of Abuse

Physical Abuse is….
Is when someone harms a young person through:

– Hitting, punching, cutting, kicking, throwing, shaking
– Scalding/burning
– Poisoning
– Drowning
– Biting and scratching.
–  Rough handling
– Restraint
– Involuntary confinement
– Forcible feeding or withholding food

Domestic abuse is….
– Physical abuse, hitting, punching, cutting.
– Threatening language and behaviour
– Controlling behaviour, i.e. telling them what they can’t wear
– Withholding money
– Non-consensual sexual intercourse
– Emotional abuse
– Psychological abuse

Sexual abuse is…
When a person is forced into sexual activities. This can happen both on-line and in person.

In person sexual abuse is…
– Touching a person’s body
– Forcing a child to partake in sexual activity
– Making a person to touch someone else
– Making a person undress
– Sexual abuse can be intercourse or touching, or kissing.
– On-line abuse is exposing themselves or making the person expose themselves
– Making them masturbate or perform sexual acts.

Psychological or emotional abuse is…
– Patronising or infantilising manner/language
– Socially isolating someone by not allowing them to see friends or family or social opportunities
– Removing communication, mobile phone
– Closing down the expression of choice and opinion
– Harassment, threats, humiliation, intimidation, coercion, bullying, swearing or verbal abuse
– Threats of harm or abandonment
– Cyber bullying

Financial abuse is…
–  Stealing money or possessions
– Not allowing a person to access their own money or assets
– Coerced/pressured into taking on a loan, property, etc.
– Pressure to remove from a will, steal inheritance
– Theft or misuse of personal finance in a care home
– Falsifying documents or using another person’s bank account, cards or documents
– Misuse of a power of attorney, deputy or other legal authority

Modern Slavery is….
– Forced labour
– Human trafficking
– Sexual exploitation such as prostitution, pornography.

Discriminatory abuse is…
-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)
– Discriminatory abuse is any form of abuse which if carried out because of a person’s differences. It can include verbal abuse, harassment or deliberate exclusion, denying access to services or providing substandard services.
– The abuse might be directed at a person because of their race, gender, age, disability, religion, sexuality, appearance or cultural background.

Institutional abuse is….
– Inappropriate use of power or control
– Lack of personal clothing or possessions
– Financial abuse
– Physical or verbal abuse
– Patriarchal and/or authoritarian management
– Unsafe, dirty or overcrowded environment.
– A strict routine
– Lack Isolating people from community or family contacts
– Lack of choice offered with food, dress, care or activities
– No provisions for religion, belief, or cultural backgrounds

Neglect is….

A constant failure to provide basic needs, i.e. food, shelter, care, clothing, health care, education, social development, put in harm’s way.

     6. Prevention The organisation will actively seek to prevent vulnerable adults becoming the victims of abuse or neglect. It will do this in a number of ways: 

• Creating a culture which respects all individuals’ rights and discourages discrimination of any kind 
• By identifying the responsible person, who has overall responsibility for vulnerable adult matters, will receive training in this field and act as a source of advice and support. 
• By informing vulnerable adults of their rights to be free from harm and encouraging them to talk to the responsible person or trustees if they have any concerns 
• Through the ongoing programme of support, at an appropriate level, to promote self-esteem and social inclusion and address the issue of the protection of vulnerable adults in the wider context 

7. Overall guidance & procedure for staff 

• The organisation recognises its legal duty to work with other agencies in safeguarding vulnerable adults and in responding to abuse. Staff involved with vulnerable adults (teaching and non-teaching) have a responsibility to be mindful of issues related to vulnerable adult safety and welfare and a duty to report and refer any concerns however “minor” they appear to be 
• The organisation will be proactive and take positive steps to ensure the beneficiaries understand their rights to safety and protection and the options available to express their fears or concerns. 
• There is signage, using pec signs and staff photos, in the workshop to provide information to students around who they can talk to if they feel worried, anxious, or concerned. We also make sure to communicate verbally to students and beneficiaries who they can talk to and what will happen if they do. 
• We provide a ‘worries bird box’ that students can use to express any concerns they have, if they don’t want to speak directly to staff. We check the box at the end of every day. 
• We embed the knowledge of their options to report concerns by making sure they are aware of their options when they first come to us and throughout their time
• If they would not like to disclose to our staff, they also are provided with information around how to self advocate with contact details of The Community Response and reablement team
• When beneficiaries make allegations about abuse or neglect, they should always be listened to, have their comments taken seriously and, where appropriate, the allegations should be investigated thoroughly 
• If you suspect that a beneficiary is going to discuss abuse, either towards themselves or another person, establish ground rules concerning confidentiality 
• If the beneficiary is fully aware of what could happen, they can: 

• choose whether they want to speak now or have time to think about it
• be as informed as possible regarding the implications of passing on this information 

• The responsible person must notify the Trustees and Safeguarding Lead as soon as practicable and in any event within 2 hours of the initial concern arising 

• The responsible person will then, if they believe the person is in immediate danger, call 999. If not in immediate danger to contact the trustees and the Hammersmith and Fulham Community Response and reablement team in order to discuss appropriate action on 0800 145 6095, (8am to 6pm, Monday to Friday) or 020 8748 8588 (out of hours)- in the case of a call, the person reporting should take written notes to ensure there is a written record of what was discussed and any actions that were agreed upon
• Ensure any information recorded regarding the concern is kept in the correct file and only available to authorised persons
• If the concern involves a criminal act, it is appropriate to inform the police
• You can also email the adult multi-agency safeguarding hub at safeguardingadults@lbhf.gov.uk
• The Hammersmith and Fulham Community Response and reablement team coordinates action in vulnerable adult cases, including liaison with police
• Note: It is important to convey that the Hammersmith and Fulham Community Response and reablement team will need to assess the situation and would want to work with the vulnerable adult in determining what could/should happen next. They would wish to respect the vulnerable adults’ wishes and feelings provided no one is at immediate risk of harm. 
• Questions should be kept to the minimum necessary to understand what is being alleged. Leading questions must be avoided as the use of leading questions can cause problems for the subsequent investigation and any court proceedings 

• If it is agreed to be a Vulnerable Adult matter, a written record of the date and time of the report shall be made and the report must include the name and position of the person to whom the matter is reported. 
• The telephone report should be confirmed/acknowledged in writing from the Response and reablement team Unit within one working day. If not, it is appropriate to chase this after 3 days
• If the consent has not been gained from the vulnerable adult, the responsible person should discuss with the Community Response and reablement team what action will be taken to inform the parents / carers of the vulnerable adult and a note of that conversation should be made. 

8. Responding to an allegation 

• It is usually the designated person(s) that have responsibility for recording all instances of alleged or reported abuse. Staff should approach the designated person with any concerns of abuse
• A full record shall be made as soon as possible outlining the nature of the allegation and any other relevant information including: 
• The date 
• The time 
• The place where the disclosure of information took place 
• The place where the alleged abuse happened 
• Your name and the names of others present 
• The name of the complainant and, where different, the name of the vulnerable adult who has allegedly been abused 
• The nature of the alleged abuse 
• A description of any injuries observed 
• The account which has been given of the allegation 

Safeguarding reporting template used for recording safeguarding allegations. When recording this information, ensure that it is: factual and not opinion based, legible, and accurate.

• The report should be clear and free of jargon specific to our industry. Information will need to include concerns that are supported by evidence where possible.  
• Where appropriate, include any actions or past accusations that have been taken or made up to this point and identify relevant issues such as mental health or substance issues
• Details of urgent action that may need to be taken
• Details of discussion with family or carers. If no discussion took place, explain why

9. Procedure 

This procedure must be followed whenever there is any allegation from a vulnerable adult that abuse has, or may have, occurred or where there is a significant concern that a child may be abused: 

RECEIVE: 

• What is said and accept what you are told – you do not need to decide whether or not it is true 
• Listen without displaying shock or disbelief 

REASSURE: 

• The beneficiary 
• Acknowledge their courage in telling 
• Do not promise confidentiality 

Remind them they are not to blame – avoid criticising the alleged perpetrator

REACT: 

• Respond to the beneficiary but do not interrogate 
• Avoid leading questions but ask open ended ones 
• Clarify anything you do not understand 
• Explain what you will do next, i.e. inform the trustees, Local Authority Community Response and reablement team, and any care providers for the alleged abuse, or in emergency 999 

RECORD:

• Make notes as soon as possible – during the interview if you can, include: time, date, place, the beneficiary’s own words. 
• Describe observable behaviour and appearance 
• Cross out mistakes – do not use Tippex 
• Do not destroy your original notes – they may be needed later on and must be given to the Designated Person. 

SUPPORT:

• Consider what support is needed for the beneficiary – you may need to give them a lot of your time or they may need to be referred 

10. Additional information and Further Definitions of Abuse 

• Physical abuse is the physical ill treatment of an adult, which may or may not cause physical injury and causes harm to the individual’s person. It may involve pushing, slapping, pinching, punching, hitting, shaking, throwing, poisoning, burning, scalding, drowning or suffocating, force feeding, improper administration of medicines or denial of prescribed medicines, forced isolation and confinement, including a person being locked in a room or inappropriate sanctions or restraint, or inappropriate manual handling. It may be the result of a deliberate failure to prevent injury occurring 
• Psychological and Emotional Abuse. Psychological abuse may involve the use of harassment, bullying, intimidation, indifference, hostility, rejection, threats, humiliation, name-calling, other degrading behaviours, shouting, swearing, discrimination or the use of oppressive language, mobile phone texting abuse, email, emotional abuse and all forms of cyber abuse. It can result in feelings of low self-worth. Some level of psychological or emotional abuse is present in all forms of abuse 
• Sexual abuse involves a vulnerable adult participating in, or watching, sexual activity to which they have not consented or were pressured into consenting, or to which they cannot give informed consent. It is not necessary for the individual to be aware that the activity is sexual. The activities may include: physical contact, including penetrative or non-penetrative acts, e.g. rape, buggery, indecent assault or inappropriate touch, incest, and situations where the perpetrator touches the abused person’s body (e.g. breasts, buttocks, genital area); Non-contact activities, e.g. exposing genitals to the abused person, or coercing the abused person into participating in or watching pornographic videos or photographs 
• Neglect is the deliberate withholding or unintentional failure to provide help or support, which is necessary for the adult to carry out activities of daily living. It also includes a failure to intervene in situations that are dangerous to the person concerned or to others, particularly when the person lacks the mental capacity to assess risk. Neglect may involve: failing to provide adequate food, shelter and clothing; failure to ensure access to appropriate medical care or treatment; neglect of basic emotional needs
• Financial/Material Abuse is the exploitation, inappropriate use or misappropriation of a person’s financial resources or property. It occurs when the individual is deprived of their own financial assets, for example, by holding money back from the individual, obtaining money by deception, or stealing money. It includes the withholding of money or the improper use of a person’s money or property, usually to the disadvantage of the person to whom it belongs 
• Institutional abuse can be defined as abuse or mistreatment by a regime as well as by individuals within any building where care is provided. Examples include lack of flexibility and choice, lack of consultation, public discussion of personal matters, inadequate or delayed responses, staff overly controlling service users’ relationships and activities 
• Discriminatory Abuse. Repeated, ongoing or widespread discrimination on the grounds of age, race, disability, religion, sexual preference or gender, slurs, harassment, name-calling, breaches in civil liberties, unequal access to health or social care 
• Significant Harm. Sometimes, a single traumatic event may constitute significant harm, eg violent assault, suffocation or poisoning. More often, significant harm is a compilation of significant events, both acute and long-standing, which interrupt, change or damage the adult’s physical and psychological development 
• Radicalisation, The government’s Prevent Duty Guidance defines radicalisation as “the process by which a person comes to support terrorism and extremist ideologies associated with terrorist groups”. Radicalisation groups and examples of extreme views are as ISIL (Islamic State), Al-Qaeda, Boko Harram, British Defence League, Animal Rights extremist groups such as SPEAK, Irish Republican Army (IRA), Anti-Abortion groups, to name a few.  We recognise that extremism and exposure to extremism can lead to dire circumstances and therefore has been considered a safeguarding concern. Extremism exists to divide people and communities and create destruction to one or both, it is the antithesis to what we at Petit Miracles stand for. Education and the teaching of British values is the key to challenging extremism. All staff must attend radicalisation and extremism training to ensure they can identify, support and report swiftly and with care and consideration.

11. Lifelong learning and commitment to improving

We are committed to continuously improving our understanding of the safeguarding concerns our beneficiaries face.  We will review this procedure and our practice regularly to ensure we are placing the right emphasis on the right safeguarding issues.  We promote a culture within our organisation that does not tolerate abuse and as practitioners are always striving to learn and improve our practices, ensuring to the best of our ability to keep our beneficiaries safe.

12. Safeguarding Officers Contact information:

Our offices can be reached on the company numbers: 07483303082 or 07557672911. In an emergency in out of office hours, staff can be contacted on their mobiles: Kate Moore: 07538712271