1.1 At Street Connect we:
- give paramount importance to the welfare of participants and recognise that at times this principle may take precedence over other principles such as confidentiality;
- recognise that many participants are vulnerable adults and that there is a duty to protect them, as far as is possible;
- understand our obligations to co-operate with local authorities in the enactment of our statutory duties under the Adult Support and Protection (Scotland) Act 2007;
- recognise the lead being provided by the local Adult Protection Committee and will follow inter-agency guidelines insofar as they apply to our services.
1.2 We will ensure that all staff and volunteers are aware of and understand:
- the different types of harm that can be caused by the conduct of others;
- their duty to escalate and/or report to the local authority when they know or believe that harm has been caused to a vulnerable adult;
- their duty to co-operate with the local authority including assisting with enquiries and providing information.
1.3 We understand our legal obligations as an employer of persons undertaking regulated work with vulnerable adults under The Protection of Vulnerable Groups (Scotland) Act 2007 and undertake to recruit and retain staff using procedures that safeguard vulnerable adults.
1.4 The current Scottish Government legislation covering the protection of vulnerable adults is the Adult Support and Protection (Scotland) Act 2007. The Act includes:
- principles governing intervention in an adult’s affairs;
- definitions of ‘harm’ and ‘adults at risk’
- duties on local authorities to inquire and investigate, and new powers including protection orders;
- duties of co-operation that apply to other organisations, and offences by organisations or individuals that do not co-operate or obstruct;
- a requirement to establish local Adult Protection Committees that will organise training and issue inter-agency procedures.
1.5 Related to this Act is the Protection of Vulnerable Groups Act (Scotland) 2007 which introduced the PVG registration system, under which all who work with vulnerable adults (or with children) have to be checked and approved before they may start such work.
2.1 Board of Directors
- To ensure there is in place a Safeguarding Policy which complies with current legislation, guidance and good practice.
- To approve a Safeguarding Statement for issue to all relevant staff and volunteers.
- To ensure Street Connect assesses the risks relating to safeguarding and has in place the required controls to eliminate or minimise identified risks.
- To deal with any safeguarding matters which require Board consideration.
- Chief Executive:
- Overall responsibility for ensuring all staff and volunteers have been advised of the policy and are clear about their role and responsibilities with regard to safeguarding.
- To ensure every new staff member or volunteer working with vulnerable people receives, has explained to them and then signs the Safeguarding Statement.
- To ensure that all relevant staff and volunteers have been registered and approved under the PVG scheme and that no-one starts work with vulnerable people until their registration is confirmed.
- To identify any general awareness or specific training required, and ensure the required training etc. is provided to staff and volunteers who come into contact with vulnerable adults as part of their duties.
- To ensure there are procedures in place to investigate and deal with any suspected or actual cases of abuse, that all Managers, staff and volunteers are aware of these and they are implemented when required.
- Head of Business Development:
- Where required, to ensure that any UK charities or organisations Street Connect partners with in delivering services have a Safeguarding policy which complies with current legislation and standards.
- To administer the PVG scheme ensuring all relevant staff and volunteers have a current PVG registration.
- To ensure that where any staff and volunteers they are responsible for come into contact with vulnerable adults, they are clear about their responsibilities regarding safeguarding, have received all the training and information required, and comply with the requirements of this policy.
- To ensure adequate and accurate records of all contact etc. with vulnerable people are maintained.
- To co-operate fully in any investigation regarding a breach of this policy or the law.
2.3 Staff & Volunteers
To ensure they:
- read and understand this policy, sign the Safeguarding Statement (all staff), and comply with all relevant safeguarding requirements;
- report promptly any suspected or actual incidents of abuse, and co-operate in any subsequent investigation.
3.1 A vulnerable adult is a person over 16 years of age who, because they are affected by disability, mental disorder, illness or physical or mental infirmity, is more vulnerable to being harmed than others who are not so affected.
Adults at Risk
3.2 Many of Street Connect’s participants are vulnerable adults, but that does not mean they are ‘adults at risk’. It is only when the local authority has established that a vulnerable adult is both at risk of harm and unable to safeguard themselves that the person can be regarded as an adult at risk and the local authority is able to exercise its full powers.
3.3 ‘Harm’ may take a number of forms, such as physical harm, psychological and emotional harm, financial harm, sexual abuse, neglect, spiritual harm or discriminating against a person in some way. It may include ‘domestic abuse’. It may be deliberate or unintended.
This means hurting a person’s body – actual physical injury – or stopping a person moving about. It can include:
- hitting a person, for example causing bruising or fractures;
- shaking a person;
- other types of injury such as burns, scalds or poisoning;
- locking a person up;
- inappropriate feeding or poor personal care.
Psychological and emotional harm
This means hurting someone mentally. It can be caused by exposure to behaviour that is threatening, bullying, or verbally abusive. It may also be caused by neglect or denial of companionship, or disregard for religious, cultural or moral codes. Such harm may be difficult to identify but may be reflected in changes in mood or self-care. It can include:
- upsetting a person’s feelings;
- making a person feel scared;
- leaving a person alone for too long.
This includes stealing from a vulnerable person, stopping a person from being able to use their money or belongings, or loss/damage to their belongings or property.
This means getting a person to do sexual things they do not want to do or do not understand. Sexual abuse is exposure to sexual activity without the person’s consent or from which they are unable to withdraw. Social and moral standards are likely to be contravened. Some activities may be illegal. Signs of sexual abuse may include changes to mood and behaviour as well as physical evidence. Sexual harm can include:
- making a person engage in sexual activities;
- taking photos of the person at private times;
- making a person look at DVDs, online materials or photos of a sexual nature;
- getting a person to do sexual things for money or presents.
Neglect is the failure of others to attend to a person’s essential needs which affects their physical or mental health. Needs include food, clothing, cleanliness, shelter, warmth and health. Neglect means stopping a person from getting the things they need to be well, including seeing their doctor, obtaining medicines or having food. Signs of neglect include untreated pressure sores, unnecessary sedation, unexplained falls, and medication denial or wrong administration.
This occurs when leaders to whom people look to for guidance and spiritual nurture abuse their positions of authority to manipulate, control or dominate.
This means hurting someone by being hateful or bigoted towards them. It can include:
- mistreating or behaving differently towards someone due to their gender, sexual orientation, race, disability, age, colour, language, religion or belief, or politics [This list is not exclusive].
4.0 SAFEGUARDING MEASURES
4.1 Where the post involves or could involve contact with vulnerable adults our recruitment process will include relevant questions and checks. We will take up references for all such posts and volunteer roles before confirming the appointment.
4.2 For staff posts and volunteer roles which are in the category of ‘regulated work’ currently covered by the Protecting Vulnerable Groups (PVG) Scheme we will ensure PVG checks are completed as part of the recruitment process (see the PVG policy).
4.3 We will regularly review and update our recruitment procedures, particularly with regard to changes in safeguarding legislation or in the PVG Scheme.
Induction & training
4.4 We will provide a comprehensive induction programme for all new staff and volunteers, tailored to the requirements of their post or role, including general awareness about safeguarding and how to raise any concerns. If required, we will provide more specific training to minimise any identified risks and/or assist the staff/volunteer to recognise possible or actual signs of harm or abuse.
4.5 As part of our ongoing learning and development programme, we will ensure staff and volunteers who require it receive updates and training regarding any changes to safeguarding principles or practice.
4.6 Street Connect’s Safeguarding Officer with lead responsibility for safeguarding is the Operations Manager, who is supported by the Partnership Co-ordinator as depute.
4.7 The Safeguarding Officer and depute will liaise with relevant local and national agencies when required, will monitor the provision of relevant induction and ongoing training, will determine how any concerns or complaints not resolved by other levels of management should be dealt with, will oversee any investigations, implement the agreed outcome and ensure the required records on employment, concerns and investigations are maintained.
Raising and investigating concerns (see also Appendix 1)
4.8 If any staff or volunteers have any concerns or complaints regarding safeguarding within Street Connect they should contact their line manager in the first instance (or, in their absence, or if the concern is about their line manager, they should contact the Chief Executive). Contact should be made without delay, preferably immediately they become aware of the details. A participant or member of the public may contact any staff member who must pass the concern on to their line manager.
Staff or volunteers may also use our Whistleblowing policy to raise a concern or complaint. This includes raising a concern directly with another agency, such as Social Services, or the Police.
4.9 The line manager will decide if the concern can be dealt with locally, or if it should be ‘escalated’ and passed to the Safeguarding Officer. If the participant is already known or is found to be an ‘adult at risk’ then the Safeguarding Officer will pass the allegation as soon as possible to the relevant local authority Social Services staff to investigate. We will co-operate fully in any such investigation, to the extent that we may be involved.
4.10 If there is no requirement to pass the allegation immediately to Social Services, and where the allegation involves a staff member or volunteer, the Safeguarding Officer will carry out a more detailed investigation. At any stage in the investigation the Safeguarding Officer may decide the allegation should be passed to Social Services for further investigation.
4.11 It may be decided to suspend any staff or volunteer(s) subject to the allegation(s). For staff, any such suspension will be on full pay and will be for as short a period as possible.
4.12 Should staff be found guilty of a safeguarding offence they will be dealt with under our disciplinary procedures (separately from any action taken by the Police or any other agency). Offences classed as ‘gross misconduct’ will normally result in dismissal without notice. Any volunteer found guilty of an offence will normally be removed from their role. Records, Confidentiality & Data Protection
4.13 Relevant Managers will ensure that adequate and accurate records are kept of all incidents or observations arising from contact with vulnerable adults (and where appropriate, with their families or carers), always being aware that such records may be accessed in the course of investigations.
4.14 All personal information (data), employment and other records relating to safeguarding will normally be kept confidential to comply with current data protection legislation. However legislation does not prevent the sensible sharing of relevant information to prevent harm to an individual or to assist in the prevention or detection of a crime. Where required therefore we will share personal or other confidential information with statutory agencies, including the Police, normally with the consent of the victim unless it is clear a crime has been committed.
When the victim is a member of staff or volunteer
4.15 We will provide all necessary care and support, including pastoral support, to any staff member or volunteer who is a vulnerable adult and who suffers harm or abuse caused either by colleagues or persons outwith the organisation.
Working with partners
4.16 Where we work in co-operation with charities or other organisations within the UK, whose staff work with or come into contact with vulnerable adults as part of their role and activities, the Safeguarding Officer will ensure these charities/organisations have implemented a Safeguarding policy which complies with the current legislation and statutory guidance relevant to their location and type of work.
5.0 IMPLEMENTATION & REVIEW
5.1 The Chief Executive is responsible for ensuring that this policy is implemented by all relevant staff and volunteers.
5.2 The Chief Executive will ensure that this policy is reviewed by the Board at least every three years.
RAISING & INVESTIGATING CONCERNS
It is not for Street Connect staff to decide if a participant is an adult at risk. That is the responsibility of local authority officers. However, all Street Connect staff and especially Support Workers who regularly see vulnerable adults must be alert to evidence that they have been harmed or there may be a risk of harm. In all cases where this arises the procedures must be followed.
The line manager should ensure that when a Support Worker or volunteer reports a concern, a written report is prepared immediately. The report should be factual and comprehensive, be signed and dated, then passed to the Safeguarding Officer (Operations Manager) or in their absence the depute (Partnership Co-ordinator). Verbatim information should always be recorded in the written report. Such a report may become available to the local authority or others involved in inquiries and investigations.
It is not the role of Street Connect to investigate allegations of harm to participants by others. But it is our responsibility to investigate any breaches of this policy and safeguarding rules by staff members or volunteers. The Safeguarding Officer must, on the basis of reports received, communicate to the local authority any concerns they have. In order to decide whether to pass on concerns it is not necessary to know that the vulnerable adult is at risk of harm. It is sufficient that there is possible harm or risk of harm or a need for protection.
The Safeguarding Officer should keep brief written records in clear language of anything giving cause for concern, record all subsequent actions accurately and date and sign these records which must be typed or written in black pen within 24 hours of a visit or incident.
The Safeguarding Officer and any other staff or volunteers involved must co-operate with Social Work Services during investigations and in the ongoing care and protection of adults at risk.
Any Street Connect staff or volunteer who becomes aware that someone they are working with has been harmed or is in need of immediate medical assistance must immediately advise their line manager (failing whom the Chief Executive).
If the person concerned has been assaulted or injured, medical assistance or an ambulance should be immediately called or the general practitioner contacted.
If the person has been assaulted and is found alone, the line manager, if not present, must be contacted immediately.
In an emergency, any staff member may dial 999 for the Police and/or Ambulance and may withdraw from the immediate situation for reasons of safety or privacy to make the call.
If, whilst carrying out their duties a Support Worker identifies or suspects that a vulnerable participant has suffered harm in any form or is at risk of harm they must immediately inform their line manager and the Safeguarding Officer, or another senior colleague.
If no Street Connect staff can be contacted, then the staff member should contact the designated officer in the Social Work Department or the Police direct.
No permission from a participant or carer or relative or other person is required before reporting concerns.
If the matter reported is serious, the line manager will immediately prepare a written report. This will include anything said by the staff member or volunteer in the words they used. The staff member/volunteer may be asked to confirm that this is what you reported, by signing the statement.
If a participant discloses information concerning a possible assault or other form of harm, staff should listen carefully to what is said without any prompting, probing or comment. As soon as possible the staff member should make notes of what was said and anything else that is relevant and then contact their line manager and the Safeguarding Officer once immediate needs are met. The participant should be told that information that has been given will have to be passed on. The normal rules of confidentiality may be set aside in order that harm or suspected harm can be reported and investigated.
Apart from reporting to their line manager and Safeguarding Officer, all staff must observe carefully the rule of confidentiality on any report or action concerning harm or suspicion of harm.
The duty to report harm or concerns also applies where the concerns involve a colleague. If the concerns involve the staff member’s line manager, they should contact a more senior manager or the Chief Executive or, if necessary, report directly to Social Work Services. When a concern about a colleague or Manager is reported the person making the report is protected by the Whistleblowing Policy.
The Social Services for all area of the country can be found on local HSCP websites. https://hscscotland.scot/hscps/
Local Authority numbers can be found using https://www.gov.uk/find-local-council
Street Connect: 0141 237 5859