2.1 We recognise that GPs are the first point of contact for most people with health problems, this sometimes includes individuals who are not registered with a GP practice but seek medical attention. Safeguarding adults is a complex area of practice. The client group is extremely wide, ranging from adults who are incapable of looking after any aspect of their lives, to individuals experiencing a short period of illness or disability. Individuals may have a wide range of services and service providers involved in their lives, making it difficult to identify those with responsibility.
3.1.1. In line with our Equality and Diversity Policies, this policy aims to safeguard all adults who may be at risk of abuse, irrespective of disability, race, religion/belief, colour, language, birth, nationality, ethnic or national origin, gender or sexual orientation.
3.1.2. All our staff must respect the adult at risk’s (and their family’s/ carers) culture, religious beliefs, gender and sexuality. However, this must not prevent action to safeguard adults who are at risk of, or experiencing, abuse.
3.1.3. All reasonable endeavours should be used to establish the adult at risk and their family/carer’s preferred method of communication, and to communicate in a way they can understand.
3.2. Bribery Act 2010
Due consideration has been given to the Bribery Act 2010 in the development of this policy and no specific risks were identified.
4.1. This policy applies to GP Partners, Locums and all our employees.
4.2. All our employees have an individual responsibility to safeguard and promote the welfare of individuals and must know what to do if concerned that an adult is at risk of being abused or neglected.
5.1. We adopt a zero-tolerance approach to abuse and neglect and in doing so ensures that safeguarding the rights of adults at risk of abuse is integral to all we do.
5.2 This policy outlines how we will fulfil its statutory responsibilities and ensure that there are in place robust structures, systems and quality standards for safeguarding adults, which will be in line with the Safeguarding Adult Boards procedures the local authorities that service users will be resident.
6.1. All adults (those over 18 years of age) have the right to live a life free from abuse and neglect. Abuse is a violation of an individual’s human and civil rights by any other person or persons.
6.2 Where someone is 18 or over but is still receiving children’s services and a safeguarding issue is raised, the matter should be dealt with through adult safeguarding arrangements. For example, this could occur when a young person with substantial and complex needs continues to be supported in a residential educational setting until the age of 25. Where appropriate, adult safeguarding services should involve the local authority’s children’s safeguarding colleagues as well as any relevant partners.
6.3. The safeguarding duties apply to an adult who:
6.4. Consideration needs to be given to a number of factors; abuse may consist of a single act or repeated acts. It may be physical, verbal 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 or she has not consented to, or cannot consent. Abuse can occur in any relationship and may result in significant harm to, or exploitation of, the person subjected to it.
7.1. We acknowledge the six principles of adult safeguarding and ensures these principles underpin the safeguarding work of all our employees
• Empowerment; People being supported and encouraged to make their own decisions and informed consent.
“I am asked what I want as the outcomes from the safeguarding process and these directly inform what happens.”
• Prevention; It is better to take action before harm occurs.
“I receive clear and simple information about what abuse is, how to recognise the signs and what I can do to seek help.”
• Proportionality; The least intrusive response appropriate to the risk presented.
“I am sure that the professionals will work in my interest, as I see them and they will only get involved as much as needed.”
• Protection; Support and representation for those in greatest need.
“I get help and support to report abuse and neglect. I get help so that I am able to take part in the safeguarding process to the extent to which I want.”
• Partnership; Local solutions through services working with their communities. Communities have a part to play in preventing, detecting and reporting neglect and abuse.
“I know that staff treat any personal and sensitive information in confidence, only sharing what is helpful and necessary. I am confident that professionals will work together and with me to get the best result for me.”
• Accountability; Accountability and transparency in delivering
“I understand the role of everyone involved in my life”
7.2 Making Safeguarding Personal
The adult should always be involved from the beginning of the enquiry unless there are exceptional circumstances that would increase the risk of abuse. If the adult has substantial difficulty in being involved, and there is no one appropriate to support them for the purpose of facilitating their involvement, then the practice must arrange for an independent advocate to represent them for the purpose of facilitating their involvement.
‘Making Safeguarding Personal’ involves
9.1 A person’s ability to make a particular decision may at a particular time be affected by:
9.2. There may be a fine distinction between a person who lacks the mental capacity to make a particular decision and a person whose ability to make a decision is impaired, e.g. by duress or undue influence or the perceived lack of any alternative choice. Nonetheless, it is an important distinction to make.
9.3. Safeguarding interventions must ensure that when an adult with mental capacity takes a decision to remain in an abusive situation, they do so without duress or undue influence, with an understanding of the risks involved, and with access to appropriate services should they change their mind. The exception to this principle would occur in situations where the decision may have been influenced by threat or coercion and consequently lack validity and need to be over-ridden.
10.2 The 5 principles of the MCA must be followed and are directly applicable to safeguarding:
1. A person must be assumed to have capacity unless it is established that they lacks capacity. Assumptions should not be made that a person lacks capacity merely because they appear to be vulnerable;
2. A person is not to be treated as unable to make a decision unless all practicable steps to help them do so have been taken without success. Empower individuals to make decisions about managing risks e.g. use communication aides to assist someone to make decisions; for example, choose the optimum time of day where a person with dementia may best be able to evaluate risks;
3. A person is not to be treated as unable to make a decision because they make an unwise decision. Individuals may wish to balance their safety with other qualities of life such as independence and family life. This may lead them to make choices about their safety that others may deem to be unwise but they have the right to make those choices;
4. An act or decision made under this Act for or on behalf of a person who lacks capacity must be done, or made, in their best interests. Best interest decisions in safeguarding take account of all relevant factors including the views of the individual, their values, lifestyle and beliefs and the views of others involved in their care;
5. Before the act is done, or the decision is made, regard must be had to whether the purpose for which it is needed can be as effectively achieved in a way that is less restrictive of the person’s right and freedom of action. Any use of restriction and restraint must be necessary and proportionate to prevent harm to that individual. Safeguarding interventions need to balance the wish to protect the individual from harm with protecting other rights such as right to family life.
10.3 Deprivation of Liberty Safeguards
We will also consider whether a person is deprived or their liberty as defined by the MCA in its Deprivation of Liberty Safeguards. If this deprivation is thought to be unlawful, this will be reported to the Local Authority within a reasonable time frame of usually no longer than 48 hours. The Local Authority holds the legal power to process an application and make a Deprivation of Liberty Safeguard (DOLS) order where it is decided that a person’s freedom needs to be restricted in their best interests.
10.4 Independent Mental Capacity Advocate (IMCA)
An independent Mental Capacity Advocate (IMCA) will be sought by our Service if the person lacking capacity has no one to represent them. We will follow the process for sourcing an advocate from approaching the local authority that the service user is resident to follow their procedure. An IMCA must be engaged if major treatment decisions are being made or if a change of residence is being considered. If a patient has no one to represent them during the course of a safeguarding investigation an IMCA should be used.
11.1. Contest is the Government's Counter Terrorism Strategy, which aims to reduce the risk from terrorism, so that people can go about their lives freely and with confidence.
11.2 Contest has four strands which encompass;
11.3 Prevent focuses on preventing people becoming involved in terrorism, supporting extreme violence or becoming susceptible to radicalisation. Alongside other agencies, such as education services, local authorities and the police, healthcare services have been identified as a key strategic partner in supporting this strategy.
11.4 Channel is a programme which focuses on providing support at an early stage to people who are identified as being vulnerable to being drawn into terrorism. The programme uses a multi-agency approach to protect vulnerable people by:
11.5. Healthcare professionals may meet and treat people who are vulnerable to radicalisation, such as people with mental health issues or learning disabilities, who may have a heightened susceptibility to being influenced by others.
11.6. The key challenge for the health sector is to be vigilant for signs that someone has been or is being drawn into terrorism. GPs and their staff are the first point of contact for most people and are in a prime position to safeguard those people they feel may be at risk of radicalisation.
11.7 Our employees who have concerns about that someone may be becoming radicalised must seek advice and support from the Safeguarding Lead and dedicated PREVENT Lead.
11.8. The Designated Professional for Adult Safeguarding acts as the PREVENT lead for General Practice and will advise on concerns following the referral pathway in line with the policy and procedure.
Our PREVENT Lead is:
Dr. Sylvia Kama-Kieghe (Registered Manager)
11.9. It is important to note that PREVENT operates within the pre-criminal space and is aligned to the multi-agency safeguarding agenda.
12.1. The Safeguarding Adults Boards (SAB) are responsible for ensuring that;
• publish a safeguarding plan and report to the public annually on its progress, so that different organisations can make sure they are working together in the best way.
12.2. The Local Authority is responsible for making enquires, or asking others to make enquiries, when they think an adult with care and support needs may be at risk of abuse or neglect and to find out what, if any, action may be needed. This applies whether or not the authority is actually providing any care and support services to that adult.
12.3 The Service team have a responsibility for recognising the potential signs and indicators of abuse, sharing information appropriately, and acting on concerns in a timely manner. Our Service recognises that safeguarding adults is a shared responsibility with the need for effective joint working between professionals and agencies. In order to achieve effective joint working there must be constructive relationships at all levels, promoted and supported by:
12.4 When an Adult Safeguarding Referral is not accepted by the Local Authority
We recognise that there may be times when the Local Authority may not accept a safeguarding referral for a variety of reasons, so other measures may need to be taken to protect adults at risk of harm. These may include:
13.1 We have clearly identified lines of accountability within the practice to promote the work of safeguarding vulnerable adults within the practice. Safeguarding responsibilities will be clearly defined in all job descriptions and there are nominated leads for safeguarding adults.
13.2. Our Lead for Safeguarding Adults is:
Dr. Sylvia Kama-Kieghe (Registered Manager)
The Deputy Lead for Safeguarding Adults is:
Dr. David Kieghe (Nominated Person)
The Administration Lead for managing Safeguarding data is:
Dr. David Kieghe (Nominated Person)
13.3. Our Lead for Safeguarding Adults is responsible for;
13.4. The Nominated Person and Registered Manager are responsible for ensuring that safeguarding responsibilities are clearly defined in all job descriptions. Failure to adhere to this policy and procedures could lead to dismissal and/or constitute gross misconduct. The Registered Manager and Nominated Person have a responsibility to ensure that we have a clear safer recruitment policy and that this is adhered to.
13.5 Partners in our Service are responsible for ensuring that;
13.6. GPs have an important role to play in safeguarding and promoting the welfare of adults. Identification of abuse has been likened to putting together a complex multi-dimensional jigsaw. GPs hold knowledge of family circumstances and can interpret multiple observations accurately recorded over time and may be the only professionals holding vital pieces necessary to complete the picture.
The GMCs ‘Good medical practice code’ (2013) stresses the need for doctors to
GPs contribution to multi-agency safeguarding adults’ meetings and other such meetings including Multi Agency Risk Assessment Conferences (MARAC) for cases of high-risk domestic violence is important and supports guidance from the Royal College of General Practitioners.
13.7 Our nurses (when we employ) must ensure that Safeguarding is part of everyday nursing practice. The Nursing and Midwifery Council’s Code of Conduct states that Nurses should raise concerns immediately if they believe a person is vulnerable or at risk and needs extra support and protection’
The Code states that Nurses must:
13.8 All Individual staff members, including partners, employees and Locums have an individual responsibility to;
14.1.1. When an adult makes a disclosure it is important to reassure the adult at risk and that the information will be taken seriously. It is good practice to ensure that the adult is given information about what steps will be taken, including any emergency action to address their immediate safety or well-being.
14.1.2 When suspecting or having abuse reported to them by a patient or member of the public, our employees will initially:
14.1.2. The human rights and views of the adult at risk should be considered as a priority, with opportunities for their involvement in the safeguarding process to be sought in ensuring that the safeguarding process is person centred.
14.1.3 If an adult in need of protection or any other person makes an allegation to you asking that you keep it confidential, you should inform the person that you will respect their right to confidentiality as far as you are able to, but that you are not able to keep the matter secret and that you must inform our manager/safeguarding lead and the Local Authority safeguarding team.
14.1.4. If it is suspected that a crime could have been committed, it is important that you do not contact the person alleged to have caused harm or anyone that might be in touch with them. Contact the police 999 in an emergency or 101 for non-emergencies.
14.1.5. The disclosed information must be recorded in the health records in the way that the adult at risk describes the events.
14.1.6. Ability to consent to the safeguarding process should be determined by the person’s mental capacity at that specific time and their understanding of risk and consequences of their situation. In determining validity of consent to making a safeguarding adult alert, the possibility of threat or coercion from others should also be explored and considered.
14.1.7. There may be instances where a safeguarding alert can be made without an adult at risk’s consent, this could include circumstances where others could be at risk if the alert is not made or instances where a crime may have been committed. This is known as a public interest disclosure to share information. In circumstances where information is shared using public interest disclosure the ‘alerter’ must be able to justify their decision to raise an alert in that information is accurate, shared in a timely manner and necessary and proportionate to the identified risk.
14.1.8 If any member of the Practice team is unsure how to proceed or is in doubt about making an alert, the case can be discussed with our Safeguarding lead or the Nominated Person (Deputy Safeguarding lead)
14.2. Risk Assessment
14.2.1. It is best practice to raise an alert at the earliest opportunity of the allegation from when the abuse or neglect was witnessed or suspected. A preliminary risk assessment should be undertaken with the main objective to act in the adult at risks best interest and to prevent the further risk of potential harm. It is important to consider the following:
14.2.2. Once the alert has been raised and if appropriate to be managed by the safeguarding process, the safeguarding plan sets out an individual risk assessment plan to ascertain what steps can be taken to safeguard the adult at risk, review their health or social care needs to ensure appropriate accessibility to relevant services and how best to support them through any action to seek justice or reduce the risk of further harm.
14.2.3 An adult who has capacity may choose to stay in an abusive situation or choose to not take part in the safeguarding process. In such a case the plan may therefore be centred around managing the risk of the situation with the person ensuring that they are aware of options to support their safety. Such cases will require careful monitoring and recording so it is recommended to seek advice if this occurs.
14.2.4 To seek further advice contact:
Please contact the Named GP or Nurse Consultant for Safeguarding in Primary Care in the clinical commissioning group or the local authority where the service user is resident
14.2.5. Local Safeguarding Adult Board:
The relevant local safeguarding adult board in the local authority of the service user
15. Information Sharing
15.1. Sharing of information is vital for early intervention and is essential to protect adults at risk from suffering harm from abuse or neglect. It is important that all practitioners understand when, why and how they should share information.
15.2. Always consider the safety and welfare of the adult at risk when making decisions on whether to share information about them. Where there is concern that the adult may be suffering or is at risk of suffering significant harm then their safety and welfare must be the overriding consideration.
15.3. Information may also be shared where an adult is at risk of serious harm, or if it would undermine the prevention, detection, or prosecution of a serious crime including where consent might lead to interference with any potential investigation.
15.4. Sharing the right information, at the right time, with the right people, is fundamental to good practice in safeguarding adults but has been highlighted as a difficult area of practice. It is important to keep a balance between the need to maintain confidentiality and the need to share information to protect others. Decisions to share information must always be based on professional judgement about the safety and wellbeing of the individual and in accordance with legal, ethical and professional obligations.
16. Recording Information16.1 Where there are concerns about an adult’s welfare, all concerns, discussions and decisions made and the reasons for those decisions must be recorded in writing in the person’s medical records.
16.2 We will ensure that computer systems and software are used to identify those patients and families with risk factors or concerns using relevant agreed Codes.
16.3 It is recognised that it is as important to be alert to the children and other members of the household as the adult there are direct concerns about.
16.4. We will appoint a dedicated Administration Team who will be responsible for managing alerts and Safeguarding Adult information/ correspondence which is all held together within one health record.
17. Implementation17.1. All our employees will be advised of this policy through staff meetings. The Safeguarding Adult Policy will be available via our website and portal
17.2. Breaches of this policy may be investigated and may result in the matter being treated as a disciplinary offence under our disciplinary procedure.
18. Training and Awareness18.1. Our induction for partners and employees will include a briefing on the Safeguarding Adult Policy by the Registered Manager or Nominated Person (Lead and Deputy for Safeguarding). At induction new employees will be given information about who to inform if they have concerns about an Adult’s safety or welfare and how to access the Local Safeguarding Adult procedures.
18.2 All our employees must be trained and competent to be alert to potential indicators of abuse and neglect in Adults, know how to act on their concerns and fulfil their responsibilities in line with LSAB policy and procedures.
18.3. We will enable our employees to participate in training on adult safeguarding and promoting their welfare provided on both a single and interagency basis. The training will be proportionate and relevant to the roles and responsibilities of each staff member.
18.4. Will will keep a training database detailing the uptake of all staff training so that our Nominated Person and Safeguarding Leads can be alerted to unmet training needs.
18.5 All GPs and other employees should keep a learning log for their appraisals and or personal development plans
19. Safer Employment19.1. The Criminal Records Bureau (CRB) and Independent Safeguarding Authority (ISA) functions have now merged to create the Disclosure and Barring Service (DBS).
19.2. Our recruitment process recognises that it has a responsibility to ensure that it undertakes appropriate criminal record checks on applicants for any position within our organisation that qualifies for either an enhanced or standard level check. Any requirement for a check and eligibility for the level of check is dependent on the roles and responsibilities of the job.
19.3. We recognise that it has a legal duty to refer information to the DBS if an employee has harmed, or poses a risk of harm, to vulnerable groups and where they have dismissed them or are considering dismissal. This includes situations where an employee has resigned before a decision to dismiss them has been made.
19.4. For further information see
19.5. We are aware that safer employment extends beyond criminal record checks to other aspects of the recruitment process including:
20. Managing Allegations against Staff who have contact with Vulnerable Adults20.1. Vulnerable adults can be subjected to abuse by those who work with them in any and every setting. All allegations of abuse or maltreatment of vulnerable adults by an employee, agency worker, independent contractor or volunteer will be taken seriously and treated in accordance with Safeguarding Adult Board policy and procedures (SAB).
20.2. Our safeguarding lead should, following consultation with the Designated Adult Safeguarding Manager, Local Authority Safeguarding Adults Enquiry Team and where appropriate the Police, inform the subject that allegations have been made against them without disclosing the nature of those allegations until further enquiry has taken place. If it is deemed appropriate to conduct an investigation prior to informing those who are implicated, clear record needs to be made of who took the decision and why.
20.3. Suspension of the employee concerned from their employment should not be automatic. Depending on the person’s role within our organisation and the nature of the allegation it may be possible to step the person aside from their regular duties to allow them to remain at work whilst ensuring that they are supervised or have no patient/public contact. This is known as suspension without prejudice Suspension offers protection for them as well as the alleged victim and other service users and enables a full and fair investigation/safeguarding risk assessment to take place. Our Registered Manager and Nominated Person will need to balance supporting the alleged victim, the wider staff team, the investigation and being fair to the person alleged to have caused harm.
20.4. We will follow up all allegations regardless of whether the person involved resigns from their post, responsibilities or a position of trust, even if the person refuses to co-operate with the process. Compromise agreements, where a person agrees to resign without any disciplinary action and agreed future reference must not be used in these cases.
20.5. If it is concluded that there is insufficient evidence to determine whether the allegation is substantiated, the chair of the safeguarding strategy meeting will ensure that relevant information is passed to the Safeguarding lead. The management of our organisation will consider what further action, if any, should be taken in consultation with the Local Authority safeguarding lead for Managing Allegations.
20.6. When an allegation of abuse or neglect has been substantiated, our Safeguarding lead should consult with the Local Authority safeguarding team for advice and whether it is appropriate to make a referral to the professional or regulatory body and to the Disclosure and Barring Service (DBS), because the person concerned is considered unsuitable to work with Adults at Risk.
21. Whistle blowing21.1. We recognises that it is important to build a culture that allows our employees to feel comfortable about sharing information, in confidence and with a lead person, regarding concerns about quality of care or a colleague’s behaviour as spelt out in our whistleblowing policy.
22. Professional Challenge22.1. We will enable and encourage any employee that disagrees with an action taken and still has concerns regarding an adult at risk of abuse to either contact the relevant local authority Safeguarding Practice Lead, Nurse Consultant Safeguarding Primary Care, or the Designated Professional for Safeguarding Adults for independent reflection and support.
23 Monitoring and Audit
23.1. Audit of awareness of this safeguarding adult policy and processes will be undertaken by the Registered Manager (our Safeguarding Lead) and Nominated Person (Deputy Safeguarding lead).
This Policy is based on the following statutory and non-statutory guidance:
Health and Social Care Act 2008 ( Regulated Activities ) regulations 2014 http://www.legislation.gov.uk/uksi/2014/2936/pdfs/uksi_20142936_en.pdf
HM Government (2015) Information Sharing Advice for practitioners providing safeguarding services to children, young people, parents and carers https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/419628/Information_sharing_advice_safeguarding_practitioners.pdf
HM Government (2015) Revised PREVENT Duty Guidance for England and Wales
HM Government (2014) The Care Act http://www.legislation.gov.uk/ukpga/2014/23/contents/enacted
Local Government Association 2014 Making Safeguarding Personal: Guide.
NHS England (2016) Safeguarding Adults: Roles and competences for health care staff Intercollegiate Document
Mental Capacity Act 2005 http://www.legislation.gov.uk/ukpga/2005/9/contents