Safeguarding Adults at Risk: Policy and Procedures
The Directors of the School of Contemplative Life (SoCL) adopted this ‘Safeguarding Adults: Policy and Procedures’ on 19th May 2022. Any amendment dates are detailed at the bottom of this document.
The Safeguarding Adults: Policy and Procedures (“Policy”) applies to all Trustees, Staff and Volunteers (“People Involved in Service Delivery”) who have been formally engaged in writing by the SoCL whether paid or unpaid. All People Involved in Service Delivery are required to accept and personally abide by this Policy.
The purpose of this Policy is to provide:
- Those People Involved in Service Delivery with guidelines for the safeguarding of everyone who comes into contact with the SoCL, particularly adults at risk, those with care and support needs, or from vulnerable groups (‘Adults at Risk”);
- Those people who engage in the services delivered by SoCL reassurance that we have a Policy in place to protect Adults at Risk.
This Policy relates to the services delivered by the SoCL. It sets out policy, good practice and procedures to contribute to the prevention of abuse of Adults at Risk and a course of action to be followed if abuse is suspected.
This Policy has been developed based on the provision of services to adults and in full consideration of the following:
- The Department for Health’s Statement on Adult Safeguarding
- The Charity Commission for England and Wales’ Policy Paper: Strategy for dealing with safeguarding issues in charities
- The Care Act 2014
- The Department for Health’s statement: Regulated activity (adults) – The definition of ‘regulated activity’ (adults) as defined by the Safeguarding Vulnerable Groups Act 2006
4. About SoCL
The SoCL is a registered charity no. 1195159 whose object is to promote and protect emotional, mental and spiritual health for the benefit of the public by provision of meditation and in such other ways as the charity trustees may decide.
The aims of the SoCL are to:
- Teach meditation as a simple and universal practice for people of all ages, backgrounds and beliefs which opens us to the gift of contemplation.
- Contribute to the restoration of contemplative practice at the heart of Christian living as an experiential way of prayer and response to the call of Christ, which purifies our motives and reveals the true nature of our being – from and in God.
- Promote the inseparable relationship between interior transformation and social transformation.
- Nurture the common ground in contemplative practice across faith traditions.
- Be a source of peace and an antidote to the fundamentalism which gives rise to so much conflict and violence in the world.
The SoCL does not engage in any ‘regulated activity’ for adults as defined in the Safeguarding Vulnerable Groups Act 2006, as updated by the Protection of Freedoms Act 2012.
The SoCL does not run any activity that is primarily for any of the vulnerable groups, which may include Adults at Risk, as detailed below, and we have no plans to change this. However, from time to time, adults who may be considered vulnerable or at risk may engage with us. Additionally, people who engage in the services delivered by SoCL, including those who might be considered Adults at Risk, may seek spiritual advice from People Involved in Service Delivery.
It is possible that in these circumstances statements may be made by an Adult at Risk, or questions asked by them, which take the form of a disclosure of abuse. Like all organisations, the SoCL has a duty to safeguard any Adults at Risk with whom the SoCL including People Involved in Service Delivery have contact. We take our responsibility very seriously and are committed to safeguarding of all who engage with the SoCL.
5. Responsibility for Safeguarding
All Adults at Risk have a right to equal protection from all types of harm or abuse, regardless of age, disability, gender, racial heritage, religious belief, sexual orientation or identity. Some Adults at Risk are at higher risk because of the impact of past experiences, their level of dependency or their communication needs, or because of other issues.
The trustees, who take responsibility for the implementation of this policy, recognise that the vast majority of the activities of the SoCL occur online. In the event our business model changes, this Policy will require further development, for example, if we develop a programme for children; volunteers are formally engaged to deliver activities on behalf of or in association with the SoCL we deliver services abroad or we start to operate from a permanent, physical location.
6. What does this policy cover?
DSO: the SoCL’s Designated Safeguarding Officer is Rachel Sharpe. She can be contacted at Rachel@schoolofcontemplativelife.com.
Child: means any person under the age of 18.
Adults at risk: we use the latest definition from The Care Act of 2014 which makes provision for adults with care and support needs. This policy applies to those aged 18 or over who have need for care and support (regardless of whether the local authority is meeting any of those needs, by reason of mental health issues, learning or physical disability, sensory impairment, age or illness) and is experiencing, or at risk of, abuse or neglect and, as a result of those needs, is unable to protect themselves from either the risk of, or the experience of, abuse or neglect.
The Care Act of 2014 now identifies ‘Adults at risk or with care needs’ rather than labelling individual adults as permanently vulnerable. At any point in time, any adult may by considered at risk and be unable to protect themselves.
Regulated activity for adults: in addition, the Safeguarding Vulnerable Groups Act of 2006, and the Protection of Freedoms Act 2012, are also relevant as they specify on which occasions helping an adult with care needs becomes a regulated activity. “The definition of regulated activity for adults from 10th September 2012 will identify the activities provided to any adult which, if any adult requires them, will mean that the adult will be considered vulnerable at that particular time.” Those involved in a regulated activity may need vetting by the Disclosure and Barring Service set up by the Safeguarding Vulnerable Groups Act. These ‘activities’ include personal care and making certain kinds of decision for example related to finances. Further details are available here: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/ 216900/Regulated-Activity-Adults-Dec-2012.pdf
As such, people aged 18 or over who engage with SoCL may need safeguarding even if they are not in need of community care services. Any adult may temporarily be an Adult at Risk if, whilst engaging in an in-person activity, they need personal care, such as help with going to the toilet and eating. We also recognise that many people who are generally emotionally and psychologically stable in most aspects of their lives may on occasion find themselves as an Adult at Risk. This may be because of illness, bereavement, relationship breakdown or because their practice of meditation has made them more sensitive and self-aware, particularly if they are new to the practice of meditation. The SoCL will take great care to avoid exploiting such vulnerability.
Mental capacity: the Mental Capacity Act of 2015, defines ‘capacity’ as the ability to make a decision at a particular time, for example when under considerable stress. The starting assumption must always be that a person has the capacity to make a decision unless it can be established that they lack capacity. This affects our policy on safeguarding Adults at Risk, especially regarding decisions on passing on reports of abuse to other agencies such as the police and social services.
Abuse: abuse is the harming of a person usually by someone who is in a position of power, trust or authority over them, or who may be perceived by that person to be in a position of power, trust or authority over them. The harm may be physical, psychological or emotional, or it may exploit the victim in more subtle ways.
6.2 Types of abuse
- Bodily assaults resulting in injuries (e.g. hitting, slapping, pushing, kicking, misuse of medication, restraint or inappropriate sanctions)
- Bodily impairment (e.g. malnutrition, dehydration, failure to thrive) and medical/health maltreatment
- Rape, incest, acts of indecency, sexual assault
- Sexual harassment or sexual acts to which the vulnerable adult has not consented, or could not consent or was pressured into consenting. Sexual abuse might also include exposure to pornographic materials, being made to witness sexual acts; also sexual harassment, with or without physical contact
- Threats of harm, controlling, intimidation, coercion, harassment, humiliation, verbal abuse, enforced isolation or withdrawal from services or supportive networks
- Bullying, shouting or swearing
Abuse through neglect
- Ignoring medical or physical care needs
- Failure to provide access to appropriate health, social care or educational services
- The withholding of the necessities of life, such as medication, adequate nutrition and heating
Financial or material
- Theft, fraud or exploitation, pressure in connection with wills, property or inheritance or financial transactions
- The misuse or misappropriation of property, possessions or benefits
Language which is racist, sexist, or based on a person’s disability, gender or sexual orientation, etc.
6.3 Signs of abuse
- A history of unexplained falls or minor injuries
- Bruising in well-protected areas, or clustered from repeated striking
- Finger marks
- Burns of unusual location or type
- Injuries found at different states of healing
- Injury shape similar to an object
- Injuries to head/face/scalp
- History of moving from doctor to doctor, or between social care agencies; reluctance to seek help
- Accounts which vary with time or are inconsistent with physical evidence
- Weight loss due to malnutrition; or rapid weight gain
- Ulcers, bed sores and being left in wet clothing
- Drowsiness due to too much medication; or lack of medication causing recurring crises/hospital admissions
- Disclosure or partial disclosure (use of phrases such as ‘it’s a secret’)
- Medical problems, (e.g. genital infections, pregnancy, difficulty walking or sitting)
- Disturbed behaviour (e.g. depression, sudden withdrawal from activities, loss of previous skills, sleeplessness or nightmares, self-injury, showing fear or aggression to one particular person, inappropriately seductive behaviour, loss of appetite or difficulty in keeping food down)
- Unusual circumstances, such as, for example, two service-users found in a toilet/bathroom area, one of them distressed
Signs of psychological or emotional vulnerability
- Unkempt, unwashed appearance and smell/poor personal hygiene
- Over meticulousness; inappropriate dress
- Withdrawnness, agitation, anxiety and/or not wanting to be touched
- Change in appetite
- Insomnia or need for excessive sleep
- Fearfulness, low self-esteem or confusion
- Unexplained paranoia; excessive fears
Signs of neglect
- Poor physical condition and/or clothing in poor condition
- Inadequate diet
- Untreated injuries or medical problems
- Failure to be given prescribed medication
Signs of financial or material vulnerability
- Unexplained or sudden inability to pay bills
- Unexplained or sudden withdrawal of money from accounts
- Disparity between assets and satisfactory living conditions
- Unusual level of interest by family members and other people in the vulnerable person’s financial assets
Signs of discrimination
- Lack of respect shown to an individual
- Substandard service offered to an individual
- Exclusion from rights afforded to others (such as health, education, criminal justice)
Other signs of abuse
- Controlling relationships
- Inappropriate use of restraint
- Sensory deprivation (e.g. glasses or hearing aid)
- Denial of visitors or phone calls
- Failure to ensure privacy or personal dignity
- Lack of personal clothing or possessions
7. People who may abuse
Abuse may happen anywhere and may be carried out by anyone including:
- People Involved in Service Delivery
- Other participants in SoCL activities
- Those engaged with partner organisations
- Informal carers, family, friends and neighbours
8. Keeping Adults at Risk safe
The SoCL has taken the following measures to help ensure the safety of Adults at Risk:
- The appointment of a Designated Safeguarding Officer (DSO) by the SoCL
- Adopting best practice, as set out within this Policy when designing services and activities
- Recruiting People Involved in Service Delivery safely, ensuring that all necessary checks are made
- Recording and storing personal information professionally and securely; and sharing information about safeguarding and good practice with People Involved in Service Delivery
- Using safeguarding procedures as contained within this Policy to share concerns and relevant information with agencies who need to be informed
- Using procedures within this Policy to manage any allegations against People Involved in Service Delivery appropriately
- Creating and maintaining an anti-bullying environment
- Ensuring that there are effective complaints procedures in place and that complainants are treated fairly and without discrimination
- Ensuring that a safe physical environment for all who engage in the services and activities of SoCL is provided by applying health and safety measures in accordance with the law and regulatory guidance
9. Procedure for raising concerns
- Safeguarding concerns regarding an Adult at Risk should be raised with the DSO.
- If such a concern implicates the DSO, then it should be raised with the trustee responsible for safeguarding (Neil Gillespie, firstname.lastname@example.org).
- The person raising the concern must record information about the concern on the same day. This record must be a clear, precise and factual account of their observations.
- The DSO or designated trustee will check to determine the accuracy/truth of the concern and decide whether the matter should be referred to the relevant local Adult’s Social Care office.
10. Guidelines for dealing with a disclosure
If someone discloses that he or she has been abused, the person to whom it is disclosed should:
- Listen to what is being said without displaying shock or disbelief
- Accept what is being said
- Allow the person to talk freely
- Reassure the person, but without making promises which might not be possible to keep
- Not promise confidentiality, because it might be necessary to refer the case to the relevant Social Care Department
- Reassure the person that what happened was not their fault
- Stress that they were right to disclose the abuse
- Listen, rather than ask direct questions
- Ask open questions rather than leading questions
- Not criticise the alleged perpetrator
- Explain what has to be done next, and who has to be told
- Use the following Guidelines for Recording a Disclosure
11. Guidelines for recording a disclosure
- Make some brief notes as soon as possible after the conversation
- Do not destroy these original notes, in case they are needed later by a court
- Record the date, time and place of the disclosure, the words used by the person making the disclosure, and any unusual non-verbal behaviour that they displayed
- Draw a diagram to indicate the position of any bruising or other injury
- Be careful to record statements and observations, rather than interpretations or assumptions
- Pass the record of the disclosure immediately and directly to the DSO
The charity is required, under the Data Protection Act 2018, to maintain confidentiality of all participants.
- Any disclosure of abuse should immediately be passed to the DSO
- Any access to personal information by People Involved in Service Delivery is strictly role-specific
- People Involved in Service Delivery are expected to treat information that they receive about an Adult at Risk in a discreet and confidential manner, regarding the safety and privacy of the Adult at Risk to be of the upmost importance
- All People Involved in Service Delivery should be cautious when passing information to others about an Adult at Risk and should check the appropriateness with the DSO.
When safeguarding Adults at Risk, there may be a need to disclose confidential information to someone from another organisation, such as the police, adult social services or mental health team. SoCL will only do this when the law allows, and when disclosure will help an Adult at Risk, or prevent a crime. If confidential information is to be shared, this will be done where possible with the agreement of the Adult at Risk. If this is not given, assessment of their best interests may still justify disclosure, and issues involving a wider or public interest may justify overriding their views.
Where the Adult at Risk lacks mental capacity, the SoCL may undertake consultation with another on their behalf (in accordance with the guidelines in the Mental Capacity Act 2015). Any information shared will be on a “need to know” basis i.e. only information that is directly relevant to safeguarding an Adult at Risk and only the minimum necessary to achieve the objective of protection of vulnerable groups. Where an Adult at Risk expresses a wish for concerns not to be pursued, this should be respected wherever possible. However, decisions about whether to respect their wishes must have regard to the level of risk to the individual and others, and their capacity to understand the decision in
question. In some circumstances the wishes of the Adult at Risk may be overridden in favour of considerations of safety.
The consent of the Adult at Risk must be obtained except where:
- The Adult at Risk lacks the mental capacity to make a decision (in accordance with the guidelines in the Mental Capacity Act 2015), and a risk assessment indicates that referral would be in their best interests
- Others may be at risk
- A crime has been committed
13. Periodic review
This policy is reviewed annually, unless an interim update is required due to, including but not limited to, a change in the law or a change to our service provision.
Adopted on: 19.02.22
Amended on: N/A
Last reviewed: N/A
14. For any queries
Please don’t hesitate to contact: email@example.com