GRACE & MERCY HEALTHCARE LIMITED
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Safeguarding Policy
APRIL 2024
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Introduction
The policy describes GMHCL’s approach to the safeguarding of Adults and Children, to
whom the service is delivering services or has some responsibility for their welfare
through its care provision. It should, where applicable, be linked to the agency’s
safeguarding of adults policies concerning definitions of abuse and its overall approach to
safeguarding, which are all based on common principles, ie:
a. empowerment — supporting people to make decisions and have a say in their care
b. protection — support and representation for those in greatest need
c. prevention — it is better to take action before harm occurs
d. proportionality — safeguarding must be built on proportionality and a consideration
of people’s human rights
e. partnership — local solutions through services working with their communities
f. accountability — safeguarding practice and arrangements should be accountable and
transparent.
Policy Statement
As a CQC-registered service, we recognise that our safeguarding responsibilities are
defined by:
• Regulation 13: Safeguarding Service Users from Abuse and Improper Treatment of the
Health and Social Care Act 2008 (Regulated Activities) Regulations 2014
• The Care Act 2014, Chapter 14: Safeguarding of the Care Act statutory guidance
describes the duties and responsibilities of local authorities and its partner
organisations to protect adults with care and support needs from abuse, neglect and
other sources of harm.
And, as our statutory responsibilities extend to children, we also recognise that we could
need to operate under the Children Act 1989 and the Children Act 2004, and follow the
government best practice guidance in Working Together to Safeguard Children (updated
2018). This guidance requires all children’s service providers to adopt a child-centred
approach to safeguarding by:
• keeping the child in focus when making decisions about their lives and working in
partnership with them and their families
• making the welfare of children paramount
• recognising that children are vulnerable to neglect and abuse or exploitation from
within their family and from individuals they come across in their day-to-day lives
• listening to and gaining from children their views and ideas about how they want to be
kept safe, which require us to:
– be vigilant and notice when things are troubling them
– understand and act when they are troubled
– develop trusting relationships with them
– treat them with respect
– inform and involve them in decisions and procedures
– explain to them what is happening and what is intended to happen
– support them as individuals
– help them to have someone who can advocate on their behalf when necessary
– prevent and protect them from all forms of abuse and exploitation.
The children and young people’s safeguarding policy is based on the understanding the
following.
1. Risks of Abuse.
The children and young people we encounter in the course of providing services may be at
risk of abuse or harm in various forms. The service understands that in general the risks
are higher under the following circumstances.
The child:
• is disabled with specific additional needs and challenges to their carers
• has special educational needs
• has caring responsibilities, which increases household pressures and stresses
• is showing signs of being drawn into anti-social or criminal behaviour, including gang
involvement and association with organised crime groups
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• is frequently missing/goes missing from home or from their accommodation
• is at risk of modern slavery, trafficking or exploitation
• is at risk of being radicalised or exploited
• is in a challenging household such as where there is drug and alcohol misuse, adult
mental health issues and domestic abuse
• is misusing drugs or alcohol themselves
• has returned home to their family from care
• is a privately fostered child
• has a parent/carer in custody.
2. Abuse may be committed by the staff providing care or by others who could be in a
trusting relationship with a child, including other household members, relatives, friends
and peers.
3. Our service has a duty to do everything possible to prevent abuse, but also to report and
address it wherever we meet it. With children we understand that abuse or risk of abuse is
most likely to take one or more forms as described next.
Defining Abuse
GMHCL will work to common and shared definitions of abuse that have been developed
nationally and are included in Working Together to Safeguard Children and the Care Act
2014 statutory guidance and which will have been adopted locally.
Types of Abuse
It recognises that abuse/harm of people using services in the care home may take many
forms including:
• physical abuse, hitting, slapping, pushing, etc
• social abuse, including bullying, cyberbullying, harassment and personal exploitation
• social isolation/scapegoating/ostracism/stigmatisation
• financial or material bullying and exploitation
• psychological or emotional abuse
• sexual abuse/exploitation
• neglect and acts of omission
• discriminatory abuse
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• self-harm, including self-neglect
• inhuman or degrading treatment
• inappropriate or excessive restraint and restrictions on movement and activities and
different forms of coercive and controlling behaviour
• organisational abuse, including when as a member of a community group or
enterprise.
Situations in which abuse occurs
We also recognises that children and young people might be put at risk when exposed to
situations of:
• domestic abuse and violence
• modern slavery
• exploitation by criminal gangs including those running “county lines” and in other
cases for the purposes of child sexual exploitation
• radicalisation and extremism that encourages and induces violence and possibly acts
of terrorism
• homelessness particularly when after leaving or running away from home or care.
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Other forms of abuse
Female Genital Mutilation
We remain aware of other circumstances where abuse might occur such as where
underage young women are being prepared for a forced marriage or to undergo female
genital mutation, which is illegal in the UK. Wherever there is evidence that this is being
practised the service will treat it as potential or actual abuse that must be reported
promptly to the children’s safeguarding authority for the appropriate action to be taken in
line with the guidance found in:
• Multi-Agency Statutory Guidance on Female Genital Mutilation, Department for
Education, Department of Health and Social Care and Home Office.
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The Safeguarding Framework
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The person responsible for children’s safeguarding in this care service, and who will acts as
a safeguarding champion is:
(JESSICA MOTTRAM)
Jessica Mottram will act as the point of contact for all safeguarding issues that will be raised
in or with the service.
Our service recognises that safeguarding involves a range of responses to different forms of
abuse and potential sources of harm and the different contexts in which abuse occurs.
Accordingly, this policy should be read and used in association with other policies all
designed to make sure that users are safe from abuse and the risks of their coming to harm
are kept to the minimum and well-managed.
GRACE & MERCY HEALTHCARE LIMITED develops its policies and procedures in line with
local Safeguarding Children’s Boards (SABs) or Multi-Agency Safeguarding Hub (MASH)
recommendations and guidance, as found on its website together with relevant
documentation for, eg raising alerts and staff training.
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Management responsibilities in relation to abuse
GRACE & MERCY HEALTHCARE LIMITED requires its managers to take responsibility for:
• developing the systems and structures within which it is possible to deliver the best
possible care
• encouraging a culture and ethos that is hostile to any sort of abuse/harm
• producing and regularly revising the policies and procedures to prevent and deal with
abuse/harm
• operating staffing policies which identify, appropriately deal with and, if necessary,
exclude from practice potential or actual abusers
• providing training for staff in all aspects of safeguarding, abuse/harm and protection
• investigating any evidence of abuse/harm speedily and sympathetically
• implementing improvements to procedures if an investigation into abuse/harm
reveals deficiencies in the way in which the service operates
• collaborating with all other relevant agencies in combating abuse/harm and
improving the safeguarding and protection of people using services
• liaising with the relevant safeguarding children’s authority teams and following their
guidance and instructions where applicable, including the issues arising from multi-
agency involvement
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• notifying the Care Quality Commission of all instances of abuse, alleged or suspected
abuse, using CQC’s online reporting procedures.
Staff responsibilities
GRACE & MERCY HEALTHCARE LIMIED insists that all its staff have a responsibility to:
• provide people with the best possible care
• never engage in abusive/harmful action in relation to people who use the services
• report anything they witness which is or might be abusive/harmful
• co-operate in every possible way in any investigation into alleged abuse
• participate in training activities relating to abuse/harm and protection from harm.
Preventing abuse from occurring
We are committed to taking all possible steps to prevent abuse or harm of children and
young people receiving care from occurring, including:
• setting out and making widely known to the children and young people and using
appropriate formats for responding to suspicions or evidence of abuse/harm
• operating staffing policies which ensure that all potential staff in regulated activity are
rigorously checked, by the taking up of references and clearance through DBS criminal
records and barred list checks, with equivalent checks for staff employed from
overseas
• encouraging among staff, people using care services and all other stakeholders a
climate of openness and awareness that makes it possible to pass on concerns about
behaviour that might be abusive or that might lead to abuse/harm
• incorporating material relevant to abuse/harm into staff training at all levels
• maintaining vigilance concerning the possibility of abuse/harm of people using
services from whatever source
• maintaining robust procedures for providing safe care practice
• discussing concerns with the local children’s safeguarding team
• helping people as far as possible to avoid or control situations or relationships that
would make them vulnerable to abuse/harm.
Recognising abuse
GRACE & MERCY HEALTHCARE LIMITED expects all staff to be vigilant regarding the
welfare of children with whom we have contact in the course of providing services.
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Staff working with and in regular contact with children and their families will be trained to
recognise the signs of abuse or risks and when abuse might occur and to respond in line
with national and local child protection policies and procedures.
We will identify any instances of actual or possible abuse/harm involving people by all
possible means including:
• fostering an open and trusting communication structure so that staff, people receiving
care and others feel able to discuss their concerns with someone authorised to take
action
• the safeguarding lead being responsible for informing staff and people receiving care
about who they could turn to for advice and action if they become aware or suspect
that abuse/harm is occurring
• encouraging staff to recognise that a commitment to the highest possible standards of
care must, when necessary, overrule loyalty to colleagues individually or corporately,
if necessary through whistleblowing
• making it clear to staff that failing to report incidents or suspicions of abuse is itself
abusive and may lead to disciplinary or criminal proceedings
• operating systems of management, supervision, internal inspection and quality control
that have the potential to reveal abuse/harm where it exists.
Procedures for when Abuse Has Occurred or is Alleged to Have
Occurred
If a child or young person is evidently being abused/harmed or they or others allege that
someone has been abused, the care provider will act promptly to limit the harm and deal
with the situation, as follows. The care provider will follow all local guidance and
procedures on the actions it will take.
1.0. Initial procedures
Emergencies
1. A staff member who witnesses a situation in which a child or young person is in actual or
imminent danger must use their judgment as to the best way to stop what is happening
without further damage to anyone involved including themselves, either by immediately
intervening personally or by summoning help.
2. If the situation is an emergency, with a child in immediate danger, staff should take
urgent action to intervene and call for assistance as soon as possible from the appropriate
authority, eg police/paramedics. They should give any necessary first aid and contact
appropriate emergency services if necessary. If the abuser remains present, staff should
seek to calm the situation.
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3. The duty manager, senior staff member or safeguarding lead to whom actual or
suspected abuse/harm is reported must immediately take action to provide protection,
support or additional care to the child or young person who has been harmed and refer the
matter to the safeguarding authority/police in line with local procedures.
Concerns, suspicions, reports and allegations of abuse
4. Where staff or others, who could be a child or young person, raise a safeguarding
concern or allege abuse, the matter should be reported immediately to the service manager
or safeguarding lead (depending on the circumstances).
5. The designated person could discuss with the child’s parents or guardians and the child
or young person, where practical, in order to gather further information and to consider
the appropriate action to take.
6. If the concern, allegation or report is of a serious nature, the manager/lead will refer the
matter immediately to the local safeguarding children’s team.
7. The safeguarding lead will consider whether, on the basis of the information they have
gathered, make a referral to the children’s safeguarding team/(MASH). Alternatively the
safeguarding lead might seek the advice of the safeguarding team on an anonymous basis
to decide if a referral should be made.
8. Once the referral has been made we will allow the safeguarding team to conduct its
enquiries and will base its own responses on the outcomes. This could involve reporting
further and taking part in a safeguarding strategy meeting and helping to implement any
child protection plan that is decided.
9. There could be serious instances where a safeguarding matter might need to be reported
directly to the police, and the care provider will then take guidance from the police on
further action.
10. We will take steps to ensure that there is no further risk of the child/young person
being abused/harmed by the alleged or suspected perpetrator if such actions fall within its
area of responsibility.
11. We will ensure that it addresses the needs of the child/young person for any special or
additional care, support or protection or for checks on health or wellbeing as required.
12. If the alleged abuser is a staff member and there is sufficient evidence that abuse/harm
has or might have occurred, the manager will suspend the person from duty pending the
outcome of a disciplinary investigation. The manager will receive guidance on the steps to
be taken from the professionals leading the enquiries.
13. If the evidence is insufficiently strong to warrant suspension, the staff member against
whom the allegation has been made will be instructed not to have further unsupervised
contact with anyone until the matter is resolved.
14. However, it should be noted that in the event of a referral being made to the police
because a criminal offence might have been committed the police investigation will take
precedence and no action should be taken that might jeopardise its enquiries, which might
contaminate the evidence it is seeking and collecting.
15. All details associated with allegations of abuse will be recorded clearly and accurately.
The record will be securely kept and the agency’s rules on confidentiality carefully
followed. Reports will be made available as required to the Care Quality Commission
(CQC)/investigating local authority safeguarding team/police.
2.0 Abuse Enquiries
Safeguarding enquiries should be based on a child-centred approach in which the
wellbeing of the victim or alleged victim is the central focus of all the activities involved.
In some cases, the alleged abuse might have been reported directly to the local
safeguarding team and the care provider will then follow the lines of enquiry that are being
made and co-operate fully in the enquiries by providing information and taking part in
discussions.
In many cases, an investigation will be carried out or led by a member of an external
agency in line with the action plan determined by the initial strategy meeting convened by
the local safeguarding team.
In some circumstances, GMHCL would be asked to carry out its own enquiries. In these
instances, the following guidance would be followed.
1. An appointed person such as the safeguarding lead will usually discuss with the various
parties involved including the child/young person and their parents/guardians/other
appropriate people.
2. The lead person is expected to take into account in his or her conducting of the
investigation:
• the fears and sensitivity of the child/young person harmed
• any risks of intimidation or reprisals
• the need to protect and support witnesses
• any confidentiality or data protection issues
• the possible involvement of other agencies, including the police, local safeguarding
team and the CQC
• the obligation to keep the abused/harmed person and in specific instances the alleged
perpetrator informed on the progress of the investigation.
3. The safeguarding lead will assure the child/young person who could have been
abused/harmed that they will be taken seriously, that the comments will as far as possible
be treated confidentially, that they will be protected from reprisals and intimidation, and
that they will be kept informed of actions taken and of the outcome.
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4. The safeguarding lead will consider if the child/young person needs independent help or
representation, including the services of an independent advocate, in presenting their
evidence and will arrange for the appropriate help or support to be made available.
5. If the evidence is insufficiently strong to warrant suspension, a staff member against
whom the allegation has been made will be instructed not to have further unsupervised
contact with anyone until the matter is resolved.
3.0. Following the enquiry completion
1. If it is concluded from the enquiries that on the balance of probabilities a staff member
has abused/harmed a child/young person (but where no criminal charges are being laid),
the registered manager will initiate and carry through disciplinary proceedings.
2. If abuse/harm is proved, the manager will initiate appropriate action, which most likely
will be dismissal and referral to the DBS to prevent them from being employed further in
regulated activity.
3. Other employment sanctions could apply depending on whether there might have been
mitigating or extenuating circumstances. In some such cases, retraining could be
appropriate.
4. The child/young person/parents/guardian as appropriate will be informed of the
outcome of the investigation and any further action and will be consulted about whether
any redress or apology would be appropriate and helpful to them in line with the service’s
duty of candour.
5. The registered manager will take appropriate steps to inform the DBS for possible
inclusion of the person on its barring lists as someone who is unsuitable to work again in
regulated activity with vulnerable children.
6. At all stages of the process, a careful record will be kept of all actions taken, paying
particular attention to the sensitivity of the abused/harmed child/young person and the
views of their parents/guardians.
7. Where relevant to the resolution of the situation, a plan will be drawn up to address the
issues with the alleged or known perpetrator(s), particularly if they will be continuing to
form part of the victim’s life, directly or indirectly.
See, for example, the following policies:
• Safeguarding from Bullying, Harassment, Exploitation and Other Forms of Social Abuse
• Safeguarding People Using a Care Service from the Harmful Actions and Behaviour of
Peers and Social Contacts.
4.0 Planning further action
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At the end of an incident involving possible or actual abuse/harm, the care provider will
review with partner agencies what has happened and identify how it could improve its
safeguarding practice.
If necessary, policies, procedures and training arrangements will be modified or developed
in response to the review’s findings.
Alternatively, it might need to co-operate in an external review or serious case review.
Recruitment
The service takes great care in the recruitment of staff, carries out all possible checks on
recruits to ensure that they are of a high standard and will co-operate in all government
initiatives regarding the sharing of information on staff who are found to be unsuitable to
be involved in work which brings them into contact with children.
Referrals to DBS barred lists
We will always comply with its legal requirement to refer a care worker to the DBS barred
lists following the procedures issued by the DBS, where it has evidence that the staff
member in question has been guilty of misconduct by harming or putting a child/young
person at risk of harm during the course of their work.
Government guidance
We are committed to working within current government guidance on multi-agency
policies and procedures to protect children from abuse and its CQC registration
requirements.
Contacts and sources of assistance
Birmingham Safeguarding Children Partnership
PO Box 17340
BIRMINGHAM
B2 2DR
Email: BSCP.ContactUs@birminghamchildrenstrust.co.uk
Tel: 0121 464 2612
Training
All staff will receive training in recognising abuse or harm and carrying out their
responsibilities under this policy as part of their induction programme and further training
in line with their training needs as identified from their supervision, appraisals and policy
developments and changes. The training is updated on a regular scheduled basis at least
annually.
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All training, including induction training, is in line with the guidance and standards
produced by the relevant social and healthcare workforce development organisations and
the local safeguarding authority training policies and guidance.
Staff new to care work who are employed to work with children/young people must
achieve Standard 11: Safeguarding Children as part of their Care Certificate training (and
Standard 10 if they work with adults also).
Other new staff will have a baseline training level, which is at least the equivalent of the
Care Certificate Standards 9 and 10 from previous or current induction training.
All staff will receive training to ensure that they are familiar with local Safeguarding
Children’s Boards policies and procedures.
All staff following induction will be expected to proceed to at least a Foundation Level 2
award and a Multi-Agency (Level 3) training in child safeguarding.
Managers and staff responsible for safeguarding will receive Specialist Safeguarding
Training (Level 4) and, where appropriate to their roles and responsibilities, achieve the
Multi-Agency Safeguarding Leaders Development Programme (Level 5).
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Signed: _____________________________
Date: _____________________________
Policy review date: _____________________________