- 1.1 The Children Act 1989 and 2004 and the associated statutory guidance, ‘Working Together to Safeguard Children’ (HM Government, 2018) and ‘Promoting the Health and Well-being of Looked After Children’ (DH, 2015) set out the principles for safeguarding and promoting the welfare of children and young people. This policy outlines how we will fulfil their legal duties and statutory responsibilities effectively in accordance with safeguarding children procedures of safeguarding partnerships of the relevant local authority to a child in need or at risk.
- 1.2 Whereas our online video consultation service provides urgent primary healthcare to adults aged between 18 and 65 years, we recognises that in the cause of providing care, our service and GPs may encounter adults with children who may be vulnerable. Our safeguarding policy for children has been adapted from a policy sample of the Royal College of General Practitioners (RCGP), for our service to be aware of and to enable our service and our GPs to identify and respond to the needs of vulnerable children and their families; and supporting victims of abuse and neglect, providing on-going care and assessment while contributing to case conferences and multi-agency plans as might be necessary to do so. We understand that our role in providing primary care uniquely gives us access to relevant the historical information on our adult patients, parental, familial and/or environment factors which may flag up early warnings and indications of child safeguarding issues.
2.0 Impact Analyses
- 2.1.1 In line with our Equality and Diversity Policies, this policy aims to safeguard all children and young people 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. Approaches to safeguarding children must be child centred, upholding the welfare of the child as paramount (Children Acts 1989 and 2004).
- 2.1.2 All our employees must respect the alleged victim’s (and their family’s/ carers) culture, religious beliefs, gender and sexuality. However, this must not prevent action to safeguard children and young people who are at risk of, or experiencing, abuse.
- 2.1.3 All reasonable endeavours should be used to establish the child, young person and families/carer’s preferred method of communication, and to communicate in a way they can understand. This will include ensuring access to an interpretation service where people use languages (including signing) other than English. Every effort must be made to respect the person’s preferences regarding gender and background of the interpreter.
Due consideration has been given to the Bribery Act 2010 in the development of this policy and no specific risks were identified.
3.1. This policy applies to all our employees, clinical and non-clinical including locums and contractors working with us.
3.2. All our employees have an individual responsibility for the protection and welfare of children and must know what to do if they are concerned that a child is being abused or neglected.
4.0 Policy Aim
4.1. We adopt a zero-tolerance approach to child abuse and neglect.
4.2 This policy outlines how our service will fulfil its statutory responsibilities and ensure that there are in place robust structures, systems and quality standards for safeguarding children, and for promoting the health and welfare of Looked After Children which are in line with the multi-agency safeguarding children partnerships of the relevant local authority to the child in need or at risk.
5.0 Our Commitment
We are committed to ensuring that we will take measures that are necessary to equip our employees (clinical and non-clinical) with the information, training, tools, materials and resources that they need to place the safeguarding of children in every encounter with a service user.
- Definitions in relation to the following terms used within this document are taken from statutory guidance (HM Government, 2018):
- “Child” or “young person”, as in the Children Act 1989 and 2004, is anyone who has not yet reached their 18th birthday. The fact that a child has reached 16 years of age, is living independently or is in further education, is a member of the armed forces, is in hospital or in custody in the secure estate, does not change his/her status or entitlements to services or protection. Where ‘child’or ‘children’ is used in this document, this refers to children and young people.
- “Safeguarding” and “promoting the welfare of children” is defined as:
- protecting children from maltreatment
- preventing impairment of children’s health or development
- ensuring that children are growing up in circumstances consistent with the provision of safe and effective care
- taking action to enable all children to have the best outcomes
6.1.3 “Child In Need” is defined under the Children Act 1989 as a child who is unlikely to achieve or maintain a satisfactory level of health or development, or their health and development will be significantly impaired, without the provision of services; or a child who is disabled. In such circumstances assessments by a social worker are carried out under Section 17 of the Children Act 1989 with parental consent. A ‘child at risk’ is a child who is experiencing or is at risk of abuse, neglect or other kinds of harm; and who has needs for care and support (whether or not the authority is meeting any of those needs).
- “Child Protection” is one element of safeguarding and promoting children’s welfare. Child protection refers to the activity that is undertaken to protect specific children who are suffering, or are likely to suffer, significant harm.
- “Significant Harm” is the concept introduced by the Children Act 1989 as the threshold that justifies compulsory intervention in family life in the best interests of children. It gives Local Authorities a duty to make enquiries to decide whether they should take action to safeguard or promote the welfare of a child who is suffering, or likely to suffer, significant harm.
- “Abuse” – this is a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm, or by failing to act to prevent harm. Children may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others. Abuse can take place wholly online, or technology may be used to facilitate offline abuse. Children may be abused by an adult or adults, or another child or children.
- Statutory guidance defines abuse as (HM Government, 2018):
Physical abuse: “A form of abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child.”
NB:Femalegenitalmutilation is considered to be a form of physical abuse.
Emotional abuse: The persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development. It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children. These may include interactions that are beyond a child’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction. It may involve seeing or hearing the ill- treatment of another. It may involve serious bullying (including cyber bullying), causing children frequently to feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, though it may occur alone.
Sexual abuse involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level or violence, whether or not the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example, rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. They may also include non-contact activites, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse. Sexual abuse can take place online, and technology can be used to facilitate offline abuse. Sexual abuse is not solely perpetrated by adult males. Women can also commit acts of sexual abuse, as can other children.
Child Sexual Exploitation: This is a form of child sexual abuse. It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator. The victim may have been sexually exploited even if the sexual activity appears consensual. Child sexual exploitation does not always involve physical contact; it can also occur through the use of technology.
Neglect: This is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to;
- provide adequate food, clothing and shelter (including exclusion from home or abandonment);
- protect a child from physical and emotional harm or danger;
- ensure adequate supervision (including the use of inadequate care-givers);
- ensure access to appropriate medical care or treatment;
- Neglect may also include neglect of, or unresponsiveness to, a child’s basic emotional needs.
7.0 CONTEST and PREVENT (Radicalisation of vulnerable people)
7.1. Contest is the Government's Counter Terrorism Strategy, which aims to reduce the risk from international terrorism, so that people can go about their lives freely and with confidence.
- Contest has four strands which encompass;
- PREVENT; to stop people becoming terrorists or supporting violent extremism.
- PURSUE; to stop terrorist attacks through disruption, investigation and detection.
- PREPARE; where an attack cannot be stopped, to mitigate its impact.
- PROTECT; to strengthen against terrorist attack, including borders, utilities, transport infrastructure and crowded places.
- 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.
- Healthcare professionals may meet and treat children and young people who are vulnerable to radicalisation because they may have a heightened susceptibility to being influenced by others.
- 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.
7.6 Any of our employees who have concerns that someone may be becoming radicalised should seek advice and support from the Safeguarding Lead and dedicated Prevent Lead.
- The Designated Professional for Adult Safeguarding currently the Register Manager acts as the Prevent lead and advises on concerns following the referral pathway in line with the policy and procedure. Where there is any suspicion of radicalization, our Prevent Lead will identify and contact the Prevent Lead for General Practice in the area in which the individual resides.
- It is important to note that Prevent operates within the pre-criminal space and is aligned to the multi-agency safeguarding agenda.
- Notice: if you have a cause for concern about someone, perhaps their altered attitude or change in behaviour
- Check: discuss concern with appropriate other (Safeguarding Lead)
- Share: appropriate, proportionate information (Safeguarding Lead/ Prevent Lead)
8.0 Roles and Responsibilities
8.1. The safeguarding partnerships of the relevant local authority to the child in need or at risk are responsible for developing local procedures and ensuring multi-agency training is available. The safeguarding partnerships have a role in scrutinising the safeguarding arrangements of statutory agencies and promoting effective joint working.
- It is the responsibility of Children’s Social Care (CSC) to investigate allegations of child abuse in conjunction, and with the participation of, other agencies. They also lead the Child in Need process.
- CSC work with all health services, including Primary Care, education, police, prison and probation services, district councils and other organisations such as the National Society for the Prevention of Cruelty to Children (NSPCC), domestic violence forums, youth services and armed forces, all of whom contribute and work together to share responsibility for safeguarding children and promoting their welfare.
- Clinical Commissioning Groups are required to employ a Named GP to advise and support the Safeguarding Leads of GPs and primary care providers. We have a lead for safeguarding lead (the Registered Manager) and a deputy lead who is currently the Nominated Person. Both will work closely with the Named GP based in the different clinical commissioning groups that they will be interfacing with on a needs basis as we encounter a child in need or child at risk in providing primary care services to adults. (HM Government 2018)
- Whereas we are aware that our services is not responsible for investigating child abuse and neglect, we recognise that we have a responsibility for sharing information, acting on concerns and contributing to the 'child in need', ‘child at risk’, 'child protection', and ‘looked after children’ processes.
- We are aware that there is an expectation that our service and team should contribute to the ‘early help’ agenda. Children and their families who receive coordinated early help are less likely to develop difficulties that require intervention through a statutory assessment under the Children Act 1989. An Early Intervention assessment can be completed with the agreement of parents so that local agencies can work with the family to identify what help the child and family might need to reduce an escalation of needs that could require statutory intervention.
9.0 Service/Primary Care Provider Arrangements
9.1 Our Service has clearly identified lines of accountability to promote the work of safeguarding children. Safeguarding responsibilities will be clearly defined in all job descriptions and there are nominated leads for safeguarding children.
- The Practice Lead for Safeguarding Children is:
Dr. Sylvia Kama-Kieghe (The Registered Manager)
The Deputy Practice Lead for Safeguarding Children is:
Dr. David Kieghe (The Nominated Person)
The Administration Lead for managing Safeguarding data is:
Dr. David Kieghe (The Nominated Person)
- The responsibilities of our Leads for Safeguarding Children are to:
- Act as a focus for external contacts on child protection matters, particularly with other health colleagues to ensure concerns regarding a child are identified and shared in a timely manner to reduce further risk to the child.
- Establish links and seek appropriate advice and support from the Named GP (appointed by the Clinical Commissioning Group for the local area of a child in need or at risk) for Safeguarding Children, the Nurse Consultant Safeguarding Children and Vulnerable Adults in Primary Care and the Designated Doctors and Nurses.
- Ensure partners and staff have access to our Safeguarding Children Policy and Safeguarding Partnership Procedures.
- Ensure that the Practice meets contractual and clinical governance guidance concerning safeguarding children.
- Promote appropriate recording of child protection issues.
- Support arrangements to ensure continued accuracy of information where children’s records are flagged to identify they are subject to a child protection plan or are a Looked after Child.
- Promote relevant child protection training for partners and staff.
- Promote the provision of GP information to child protection conferences through either attendance or completion of child protection reports within a timely manner.
- Encourage regular discussion of child protection issues, including any relevant learning from serious case reviews at staff meetings.
- Act as a point of contact for employees and our children safeguarding partners to bring any concerns that they have and record this along with any subsequent action taken as a result.
- Ensures that all employees receive adequate support when dealing with safeguarding children concerns. Understanding it is not the role of our service to decide whether or not a child has been abused or neglected and signposts colleagues to sources of advice and understand the referral process to Children’s Social Care.
- Ensures safe recruitment procedures.
- Ensures and supports robust reporting and complaints procedures.
- Leads on analysis of relevant significant events/root cause.
- Makes recommendations for change or improvements in practice.
- Our service will ensure that safeguarding responsibilities are clearly defined in all job descriptions. For employees of the practice, failure to adhere to this policy and procedures could lead to dismissal and/or constitute gross misconduct.
- All GPs have a critical role to play in safeguarding and promoting the welfare of children. Identification of child 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. GPs should aim to contribute to the Child Protection process including child protection conferences and strategy meetings, and meetings such as Multi Agency Risk Assessment Conferences (MARAC) and other such multi-agency assessments, so that decisions about children can be made with as much relevant information as possible.
- MARACs are risk management meetings where professionals share information on high risk cases of domestic violence and abuse and put in place a risk management plan for victims and their families. Information from online primary care services such as ours may provide vital information to the risk assessment process in such cases and assist GPs in contributing to this process and promoting the welfare of their patients.
- Our GPs may have relevant information to share with conferences and multi-agency meetings, even if they do not directly consult children. It could be information about adults with children that our GPs consult on our portal.
- It will not always be possible for our GP to attend all case conferences, MARACs or other such meetings when indicated and if this is the case our GP will do the following:
- contact the Independent Conference Chair or chair of the conference or meeting and give apologies for attendance
- complete and send a case conference report (within procedural timeframes) or other relevant document enabling the sharing of appropriate information as required
- We are aware that our Nurses (if we have employed or contracted) have a responsibility to ensure that a child’s welfare is promoted and treated as paramount. 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:
- take all reasonable steps to protect people who are vulnerable or at risk from harm, neglect or abuse
- share information if you believe someone may be at risk of harm, in line with the laws relating to the disclosure of information, and
- have knowledge of and keep to the relevant laws and policies about protecting and caring for vulnerable people
When we do employ a nurse or nurses, we will expect and ensure that they comply with their responsibilities regarding the safeguarding of children.
- We will ensure that all our employees keep up to date with national developments relating to preventing harm, exploitation, coercion, abuse and the welfare of children and young people. All our employees must uphold the general rules of our service on safeguarding including;
- Challenging any unacceptable behaviour by any other employee.
- Never promise to keep a secret about any sensitive information disclosed to you but follow the guidance of our service on confidentiality and sharing information, while remembering that the welfare of the child is paramount.
- Respect a young person’s right to personal privacy and encourage children, young people and adults to feel comfortable to point out attitudes or behaviours they do not like.
- It is not the role of any person within the service to begin any form of investigation relating to an allegation, report or disclosure of harm, exploitation, coercion and/or abuse. All allegations, reports or disclosures/concerns about a child suffering or likely to suffer significant harm should be reported to our safeguarding lead who will refer to Children’s Local Social Care Services.
- Our employees will be advised of the policy at staff meetings. The Safeguarding Children Policy will be available via our website and web portal
- Breaches of this policy may be investigated and may result in the matter being treated as a disciplinary offence under our disciplinary procedure.
11.0 Training and Awareness
11.1. The induction for employees will include a briefing on the Safeguarding Children Policy by the Registered Manager who is our Lead for Safeguarding. Employees will be given information about who to inform if they have concerns about a child’s safety or welfare.
11.2 All our employees must be competent to be alert to potential indicators of abuse and neglect in children, know how to act on their concerns and fulfil their responsibilities in line with the ‘Safeguarding Children and Young People Competencies for Health Care Staff Intercollegiate Document’ (RCN, 2019).
The RCGP has produced a supplementary guide to primary care safeguarding training requirements for both child and adult safeguarding.
- All our employees will complete the level of training commensurate with their role and responsibilities.
- We will keep a training database detailing the uptake of all staff training so that the Safeguarding Leads can be alerted to unmet training needs.
11.5 All our GPs and employees should keep a learning log for their appraisals and or personal development plans (a template can be found in the Intercollegiate Document: Safeguarding Children and Young People: Competencies for Health Care Staff, RCN, 2019).
12.0 Recognising child maltreatment or abuse
13.0 Responding to concerns about a child
- To seek further information/ share concerns contact our Registered Manager
- To seek further advice, contact our Safeguarding Lead and Deputy.
- Making a child protection referral
- Clearly document concerns and collate any family information known to you.
- If you are unsure how to proceed, seek advice from one our Safeguarding Lead, or duty Paediatrician at local hospital.
- If child protection referral is required, contact the Local Children’s Social Care. Give all details/information regarding your concerns and confirm that you are making a child protection referral.
- Follow up verbal referral in writing within 24 hours. Retain a copy of your referral for your reference.
- If you believe that a child is at risk of immediate harm, call the Police/ Local Children’s Social Care as an emergency.
- We will build a list of contacts of Local Children’s Social Care in England as we encounter children’s safeguarding issues and include their phone numbers on our Admin and GP dashboards
- We will build a list of Safeguarding Partnership websites as we encounter children’s safeguarding issues and include links to websites on our portal
14.0 Recording Information
- We will ensure that our software systems can identify and flag patients with risk factors or concerns as per the RCGP guidance:
Processing and Storing of Safeguarding Information in Primary Care, and
Guidance on Recording of Domestic Violence and Abuse Information in Service Medical Records available from the RCGP Child Safeguarding Toolkit.
- It is recognised that it is as important to be alert to the siblings and other members of the household as the child there are direct concerns about.
- Key information about children and their family and carers includes;
- Details of any disability for the child
- Details of mental health issues for the child
- Information supplied by all members of the Primary Care Team, including the Health Visitor and School Nurse
- Conversations with and referrals to outside agencies
- Historical details of the parents experience as a child if concerns known
- Details of any housing problems
- Details of significant illness or problems in the family
- Details of any parental substance misuse
- Details of any parental mental health issues
- Details of any parental learning disabilities
- History of domestic abuse in the household.
- Information will be sought and entered from:
- The summarising of new patient health checks on all children, including enquiry about family, social and household circumstances.
- Any contact with a potential carer – ‘seeing the child behind the adult’ – so that a patient with a substance misuse problem is asked about any responsibility they may have for a child, and that child’s record amended accordingly.
- Opportunistic consultations: Antenatal, Postnatal bookings, 6-week check
- Correspondence from OOH reports and other primary and secondary care providers.
14.5. We will appoint a dedicated Administration Team who will be responsible for managing alerts and Child Protection information/ correspondence, all held together within one health record.
15.0 Information Sharing
- Keeping children and young people safe from harm requires professionals and others to share information about their health and development and exposure to possible harm. Often, it is only when information from a number of sources has been shared and pulled together that it becomes clear that there are concerns a child is in need of protection or services.
- 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.
- Information sharing guidance: Information Sharing. Advice for practitioners providing safeguarding services to children, young people, parents and carers (July 2018).
- This guidance is applicable to all professionals charged with the responsibility of sharing information, including in safeguarding adult’s scenarios. The guidance outlines the seven golden rules to information sharing:
- The Data Protection Act 2018 associated General Data Protection Regulations and human rights law are not barriers to justified information sharing, but provide a framework to ensure that personal information about living individuals is shared.
- Be open and honest with the individual (and/or their family where appropriate) from the outset about why, what, how and with whom information will, or could be shared, and seek their agreement, unless it is unsafe or inappropriate to do so.
- Seek advice from other practitioners, or your information governance lead, if you are in any doubt about sharing the information concerned, without disclosing the identity of the individual where possible.
- Where possible, share information with consent, and where possible, respect the wishes of those who do not consent to having their information shared. Under the GDPR and Data Protection Act 2018 you may share information without consent if, in your judgement, there is a lawful basis to do so, such as where safety may be at risk. You will need to base your judgement on the facts of the case. When you are sharing or requesting personal information from someone, be clear of the basis upon which you are doing so. Where you do not have consent, be mindful that an individual might not expect information to be shared.
- Consider safety and wellbeing: base your information sharing decisions on considerations of the safety and wellbeing of the individual and others who may be affected by their actions.
- Necessary, proportionate, relevant, adequate, accurate, timely and secure: ensure that the information you share is necessary for the purpose for which you are sharing it, is shared only with those individuals who need to have it, is accurate and up-to-date, is shared in a timely fashion, and is shared securely (see principles).
- Keep a record of your decision and the reasons for it – whether it is to share information or not. If you decide to share, then record what you have shared, with
whom and for what purpose.
- Ideally consent should be provided along with the request for patient information. However, there are times when the concerns/risks to the child are such that it is not appropriate to seek consent, principally as this may lead to the child being further abused. A lack of consent should not prevent a GP or other practitioner within our team from sharing information if there is sufficient need in the public interest to override the lack of consent. The welfare of the child is paramount and where there are child protection concerns this outweighs confidentiality. However, where the practitioner is uncertain, advice about consent is available from our Safeguarding Lead.
16.0 Safer Employment
- The Disclosure and Barring Service (DBS) enables organisations in the public, private and voluntary sectors to make safer recruitment decisions by identifying candidates who may be unsuitable for certain work, especially that involving children or vulnerable adults, and provides wider access to criminal record information through its disclosure service for England and Wales.
- Our recruitment process ensures that it undertakes appropriate criminal record checks on applicants for any position within the practice 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.
- We recognise that we have 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.
- Safer employment extends beyond criminal record checks to other aspects of the recruitment process including:
- making clear statement in adverts and job descriptions regarding commitment to safeguarding
- seeking proof of identity and qualifications
- providing two references, one of which should be the most recent employer
- evidence of the person's right to work in the UK is obtained
Managing Allegations against Staff
- If an allegation is made against an employee and it relates to conduct towards a child, our Safeguarding Lead or Nominated Person must ensure that the Local Area Designated Officer (LADO) who is employed by the relevant Local Authority (contact details available on the relevant Safeguarding Partnership website as referenced above) to the residential address of the child, is informed. The LADO assumes oversight of any subsequent investigation process from beginning to end and will give advice. They will also liaise with the police and social care if necessary.
- After taking any immediate action in line with our policy, our Safeguarding Lead or Nominated Person should ensure that the LADO is informed if the employee has:
- behaved in a way that has harmed, or may have harmed, a child, or
- possibly committed a criminal offence against or related to a child, or
- behaved towards a child in a way that indicates unsuitability to work with children.
18.0 Whistle Blowing
18.1. We recognise 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 behavior, and we are doing so. Our employees are required to comply with our whistleblowing policy and procedure in this regard.
19.0 Professional Challenge
19.1. We will enable and encourage any employee that disagrees with an action taken and still has concerns regarding a child to contact LADO directly.
20.0 Monitoring and Audit
20.1. Audit of awareness of this safeguarding policy and processes for Children will be undertaken by our Safeguarding Leads i.e. the Registered Person or Nominated Person.
21.0 Policy Review
21.1. This policy will be reviewed two years from the date of issue. Earlier review may be required in response to exceptional circumstances, organisational change or relevant changes in legislation/guidance, as instructed by the Registered Manager responsible for this policy.
Updated: 16 March 2021
Next update: 16 March 2023