-
SHOP
A. Introduction
The Safeguarding Adults at Risk Policy and Procedure represent Luminary’s commitment to safeguard adults at risk of harm.
The policy and procedure apply to ALL Luminary staff and volunteers. They represent Luminary’s commitment to:
- working together with other agencies to prevent and protect adults at risk of abuse
- empower and support people to make their own choices
- investigate actual or suspected abuse or neglect
- support adults and provide a service to adults at risk who are experiencing exploitation, abuse or neglect
B. Context
Unlike Child Protection, there is no statutory protection for, or definition of adults at risk of abuse.
There is a presumption that adults have the mental capacity to make informed decisions about their lives. If someone has been assessed as not having mental capacity, then decisions should be made in their best interests as set out in the Mental Capacity Act 2005.
Adults at risk should be given information, advice and support in a form they can understand and have their views included when decisions are being taken about their lives. All decisions taken about another person’s life should be timely, reasonable, justified, proportionate and ethical.
- All staff have a duty to report any concerns or suspicions that an adult at risk is being, or is at risk of being, abused.
- Actions to protect the adult from abuse should always be given a high priority by all organisations involved. Concerns or allegations should be reported without delay and given high priority.
- Luminary will work to safeguard adults at risk, making their dignity, safety and well-being a high priority.
- All staff have a duty to understand their role and responsibilities in regard to this policy and procedure.
- Every effort should be made to ensure that adults at risk are afforded appropriate protection under the law.
- As far as possible Luminary staff and volunteers must respect the rights of the person causing harm. If that person is also an adult at risk, they must receive support and their needs should be addressed.
- Luminary staff will work effectively with interagency working in order to provide the most effective means of safeguarding adults.
C. Definitions
'Adult At Risk'
‘Adult at risk’ means adults who need community care services because of mental or other disability, age or illness and who is, or may be, unable to take care of themselves against significant harm or exploitation.
- An adult at risk may therefore be a person who:
- is unable to look after their own wellbeing, property, rights or other interests
- misuses substances or alcohol
- has a learning disability
- has a physical disability and/or a sensory impairment
- has mental health needs including dementia or a personality disorder
- has been groomed, trafficked or exploited
- has a long term illness or condition
- is in need of care and support but is unable to demonstrate the capacity to make an informed decision about themselves
- is elderly and frail due to ill health, physical disability, or cognitive impairment
- Actions to protect the adult from abuse should always be given high priority. The dignity, safety and wellbeing of an individual should be a priority within any action taken.
- In the context of safeguarding adults, the extent to which the adult is at risk is related to how able they are to make and exercise their own informed choices free from duress, pressure or undue influence of any sort, and to protect themselves from abuse, neglect and exploitation. It is important to note that people with capacity can also still be ‘at risk’.
- It is always essential in safeguarding to consider whether the adult at risk is capable of giving informed consent. If they are, their consent to any course of action should be obtained. This may be in relation to whether they give their consent to:
- An activity that may be abusive – if consent to abuse or neglect was given under duress, for example, as a result of exploitation, pressure, fear, intimidation – this apparent consent should be. disregarded.
- A Safeguarding Adults investigation going ahead in response to a concern that has been raised. Where an adult at risk with capacity has made a decision that they do not want action to be taken and there are no public interest considerations, their wishes must be respected. The person should be given information and have the opportunity to consider all the risks and fully understand the likely consequences of their decision over the short and long term.
- If after discussion with the adult at risk who has mental capacity, they refuse any intervention, their wishes must be respected unless:
- there is a public interest – eg not acting will put other adults or children at risk
- there is a duty of care to intervene eg a crime has been, or will be, committed
- We recognise that there are often complex issues and factors that many of the individuals may have experienced throughout some point in their lives. Such factors should be taken into consideration when looking at who an adult at risk may be. Many of the women that we will encounter will have various experiences of being homeless, fleeing exploitation and/or trafficking, prostitution, suffering from low self esteem, self harm, substance misuse, learning difficulties, emotional wellbeing needs or mental health issues such as Borderline Personality Disorder.
- At all times Luminary will consider the welfare of the Adult at Risk to be of high importance. We are committed to achieving this by:
- Actively striving to promote the empowerment and wellbeing of adults at risk through respectful and responsive high quality service provision.
- Helping to prevent the physical, sexual, emotional or psychological, financial and discriminatory abuse and neglect of adults at risk and to report any such abuse that is discovered or suspected.
- Believing and promoting that all individuals have the right to be able to live their lives free from exploitation, fear, abuse, harm or degrading treatment. All individuals have the right to protection from any such mistreatment and harm.
- Believing and promoting that all individuals have the right to make choices and that their right to independence is actively encouraged. We acknowledge that such choices may at times involve an element of risk. We are committed to ensuring that any such risks are formally acknowledged and understood by all concerned, taking all reasonable measures to ensure risks are minimized wherever possible.
- Being committed to respecting equal opportunities, anti -discriminatory practise and diversity issues.
- All staff and volunteers are required not to share any private information or photos about the service users in any context.
- Ensuring that the law and statutory requirements which relate to adults at risk are known and put into practice.
- Safe recruitment, supervision and training for all those working with adults at risk within Luminary.
'Abuse'
‘Abuse’ is an emotive term and can be subject to interpretation, Luminary recognises that abuse can be “a violation of an individual’s human and civil rights by any other person or persons” (“No Secrets”, Department of Health 2000).
Abuse may be:
- A single or repeated act
- An act of neglect; lack of appropriate action taking place
- Multiple acts; an adult at risk may be neglected and also financially abused
'The Abuser'
It is important to recognise that the ‘abuser’ could be anyone, including friends, relatives, family members, other Service Users, professional paid staff, volunteers and persons unknown to the adult at risk. They may also themselves be an adult at risk.
'Exploitation'
Exploitation is exerting undue influence or forcing an adult at risk to perform services for the benefit of others.
'SIGNIFICANT HARM’
The Law Commissioner’s Green Paper ‘Who Decides’ 1997 builds on the concept introduced in the Children Act, 1989 and suggests:
"Harm should be taken to include not only ill treatment (including sexual abuse and forms of ill treatment that are not physical); but also the impairment of, or an unavoidable deterioration in physical or mental health, and the impairment of physical, intellectual, emotional social or behavioural development.”
'No Secrets' also uses the concept of significant harm. This refers to:
- Ill treatment
- Impairment of physical or mental health
- Impairment of physical, intellectual, emotional social or behavioural development
'No Secrets' puts forward the following factors to be taken into account when making an assessment of the seriousness of the risk to the person:
- Vulnerability of the person
- Nature and extent of the abuse or neglect
- Length of time the abuse or neglect has been occurring
- Impact of the alleged abuse
- Impact of the alleged abuse
- Risk of repeated or increasingly serious acts of abuse or neglect
- Risk that serious harm could result if no action is taken
- Illegality of the act
D. Categories of abuse: signs and possible indicators
Physical Abuse
Is the physical mistreatment or non-accidental injury of an adult. Some possible signs of abuse are detailed as follows:
- Slapping
- Kicking
- Punching
- Shaking
- Bruising
- Burns
- Cutting
Indicators of possible physical abuse may include, but are not limited to:
- An injury not fitting the explanation given
- Unexplained or unusual fractures in various stages of healing
- Bruises or burns in the shape of objects e.g. cigarette burns, belt buckles or water
- Bruising in well protected areas e.g. behind the ears, on face, inside of the upper arms or thighs, buttocks, breasts, genital or rectal area
- Lacerations
- Unlawful or inappropriate use of restraint and/or deprivation of liberty is physical abuse
Neglect or Acts of Omission
This includes deliberate refusal to meet basic needs. Signs of neglect can include individuals experiencing the following:
- Lack of choice, denied diversity
- Poor judgemental attitudes
- Derogatory terms used about the adult or their situation
- Failure to ensure appropriate privacy and dignity
- Poor surroundings e.g. neglect of repairs, inadequate heating
- Over or under protective practices
Behaviour that can lead to neglect includes:
- Ignoring medical or physical needs
- failing to allow access to appropriate health, social and educational services
Indicators of possible neglect or omission may include, but are not limited to:
- Loss of weight
- Clothing in a poor condition
- Failure to access appropriate health, educational services or social care
Unintentional neglect could result from a professional failing to meet the needs of the adult at risk because they do not understand the needs or may not know about the services available. It may also occur if the individuals are unaware of or do not understand the possible effect of the lack of action on the adult at risk.
Psychological or Emotional Abuse
This includes threats of harm, abandonment, isolation or humiliation which may result in the adult feeling in low mood, undervalued and perhaps unnecessarily dependant.
Some ways in which psychological/emotional abuse can take the form of are detailed below:
- Failure to respond adequately to emotional needs
- Failure to protect from the emotional abuse of others
- Harassment or humiliation (bullying)
- Intimidation
- Failure to meet cultural requirements
- Unreasonable demands
- Denial of choice
- Controlling or creating over dependence
- Verbal abuse
- Cyber bullying
- Mental distress
- Negating the right of the adult at risk to make choices and undermining their self esteem
- Isolation and over dependence
Indicators of possible psychological or emotional abuse may include, but are not limited to:
- Low self esteem
- Tearfulness
- Alteration in psychological state e.g. may appear to be withdrawn, agitated or anxious in general
- Aggressive or challenging behaviour
- Attention seeking behaviour
- Self harm
- Depression
- Insomnia
- Unexplained paranoia
Sexual Abuse
This is the involvement of any individual in any sexual activity to which they either cannot or have not given their consent or does not truly comprehend and so cannot give consent. Or where the other party is in a position of trust, power or authority and uses this to override or overcome lack of consent. Sexual abuse includes:
- Rape or sexual assault
- Inappropriate touching
- Fondling
- Sexual intercourse/buggery or attempted sexual intercourse/buggery
- Inflicting pornography on an individual
- Offensive or inappropriate language including sexual innuendos and sexual teasing
Indicators of possible sexual abuse may include, but are not limited to:
- Change in usual behaviour
- Overt sexual behaviour/language
- Bleeding or pain in the genital/rectal area
- Disturbed sleep pattern
- Torn, stained or bloody underwear
- Self‐harming
Financial or Material Abuse
This can be considered as unauthorised extraction of the adult at risk’s resources or their resources being withheld or misused by someone else and including:
- Misuse, embezzlement or theft of a person’s money, property or possessions
- Failing to account satisfactorily for the use of a person’s money, property or possessions, fraudulent use of money
- Extortion of money, property, possessions through theft
Indicators of possible financial or material abuse may include, but are not limited to:
- Lifestyle does not reflect known income
- Unexplained withdrawals from account
- Unexplained/sudden inability to pay service charge/bills etc.
Financial abuse is a crime.
Discriminatory Abuse
The inappropriate treatment of an adult at risk because of their age, gender, race, religion, cultural background, sexuality, disability, etc.
Discriminatory abuse exists when values, belief or culture result in a misuse of power that denies opportunity to some groups or individuals.
Discriminatory abuse links to all other forms of abuse and can include:
- Unequal treatment
- Inappropriate use of language:
- Racist remarks
- Sexist remarks
- Derogatory remarks or verbal abuse
- Comments about disability
- Bullying or other forms of harassment
- Deliberate exclusion
Indicators of possible discriminatory abuse may include, but are not limited to:
- Inappropriate remarks or comments
- Lack of respect shown to people
- Staff member/volunteer may avoid being with certain groups of people
Institutional Abuse
Institutional abuse is the mistreatment or abuse or neglect of an adult at risk by individuals within an organisational setting where routines, systems and practices result in denying, restricting or curtailing the dignity, privacy, choice, independence or fulfilment of an adult at risk.
A number of inquiries into institutional abuse have shown that abuse is most likely to occur when staff:
- Receive little support from management
- Are inadequately trained
- Are poorly supervised
- Receive inadequate guidance
E. Key Principles
The most important priority is to ensure that the most urgent medical and welfare requirements of the adult at risk are met.
Preserve any potential forensic opportunities, record verbatim the disclosure made by the adult at risk.
Any sexual activity that is not freely consented to is criminal and should be reported to the police immediately, before any internal investigation.
Sexual relationships, or inappropriate sexual behaviour between a member of staff (or volunteer) and a service user are always abusive and will lead to disciplinary hearings. This will be in addition to any criminal actions taken.
A sexual relationship between the service user and a care worker is a criminal offence under Sections 38-42 of the Sexual Offences Act 2003.
There may be Safeguarding Adults referrals that involve sexual innuendo or remarks that will not result in a criminal investigation; however, all Safeguarding Adults referrals that indicate any form of sexual abuse require a risk assessment, intelligence gathering and appropriate information sharing with relevant partners.
F. Responsibilities
Duty Of Care
All staff & volunteers of Luminary have a ‘duty of care’ towards those who use our services.
This means taking action whenever there is a concern of possible mistreatment or abuse to an adult at risk. The procedural guidelines supporting this Policy are intended to provide a good practice framework and to support staff; staff are therefore expected to comply with them.
Failure to report any concerns may be viewed as being negligent or agreeing with the abuse, which in some cases could lead to disciplinary action.
All staff should:
- Be aware that they must call the police/ambulance where appropriate
- Share their concerns with appropriate colleagues and seek advice and support unless they are implicated in the abuse
- Know they must inform the appropriate safeguarding officer as per escalation chart
- Know that they must make a clear, factual record of their concern and the action taken using the Safeguarding Incident Reporting Form
In addition, Support Workers & Safeguarding Staff should:
- Know what services are available and how to access help and advice
- Know how and where to make a referral via Adult Social Care
Responsibility of Managers:
- To ensure that the alleged victim is safe
- To ensure that any staff or volunteer who may have caused the harm is not in contact with service users and others who may be at risk
- To ensure that information is provided in a timely manner
- Operate safe recruitment practices and ensure reference checks are made
- Support staff who raise concerns
Monitoring
Safer Recruitment
All staff who work in a support-work capacity with our service users are subject to an enhanced disclosure check from the Disclosure and Barring Service.
For any team recruitment, an interview should be conducted, and two satisfactory references received, to assess an applicant’s suitability prior to an offer of employment or volunteering being made. On appointment staff and volunteers serve a probationary period for performance monitoring.
Volunteers within projects are recruited within the same processes as those for paid members of staff.
The named Safeguarding Adults Co-ordinator (SAC)- Alice Williams (Luminary CEO) will monitor any concerns and keep a record of safeguarding prompt logs compiled by staff. The SAC will report to the Charity Board on a quarterly basis.
G. Training
This policy and associated procedures are to be rolled out across Luminary through in- house training and in addition staff may access local authority Safeguarding Adult training.
16.1 Safeguarding Adults at Risk Policy & Procedure
Page Navigation
A. Introduction
The Safeguarding Adults at Risk Policy and Procedure represent Luminary’s commitment to safeguard adults at risk of harm.
The policy and procedure apply to ALL Luminary staff and volunteers. They represent Luminary’s commitment to:
- working together with other agencies to prevent and protect adults at risk of abuse
- empower and support people to make their own choices
- investigate actual or suspected abuse or neglect
- support adults and provide a service to adults at risk who are experiencing exploitation, abuse or neglect
B. Context
Unlike Child Protection, there is no statutory protection for, or definition of adults at risk of abuse.
There is a presumption that adults have the mental capacity to make informed decisions about their lives. If someone has been assessed as not having mental capacity, then decisions should be made in their best interests as set out in the Mental Capacity Act 2005.
Adults at risk should be given information, advice and support in a form they can understand and have their views included when decisions are being taken about their lives. All decisions taken about another person’s life should be timely, reasonable, justified, proportionate and ethical.
- All staff have a duty to report any concerns or suspicions that an adult at risk is being, or is at risk of being, abused.
- Actions to protect the adult from abuse should always be given a high priority by all organisations involved. Concerns or allegations should be reported without delay and given high priority.
- Luminary will work to safeguard adults at risk, making their dignity, safety and well-being a high priority.
- All staff have a duty to understand their role and responsibilities in regard to this policy and procedure.
- Every effort should be made to ensure that adults at risk are afforded appropriate protection under the law.
- As far as possible Luminary staff and volunteers must respect the rights of the person causing harm. If that person is also an adult at risk, they must receive support and their needs should be addressed.
- Luminary staff will work effectively with interagency working in order to provide the most effective means of safeguarding adults.
C. Definitions
'Adult At Risk'
‘Adult at risk’ means adults who need community care services because of mental or other disability, age or illness and who is, or may be, unable to take care of themselves against significant harm or exploitation.
- An adult at risk may therefore be a person who:
- is unable to look after their own wellbeing, property, rights or other interests
- misuses substances or alcohol
- has a learning disability
- has a physical disability and/or a sensory impairment
- has mental health needs including dementia or a personality disorder
- has been groomed, trafficked or exploited
- has a long term illness or condition
- is in need of care and support but is unable to demonstrate the capacity to make an informed decision about themselves
- is elderly and frail due to ill health, physical disability, or cognitive impairment
- Actions to protect the adult from abuse should always be given high priority. The dignity, safety and wellbeing of an individual should be a priority within any action taken.
- In the context of safeguarding adults, the extent to which the adult is at risk is related to how able they are to make and exercise their own informed choices free from duress, pressure or undue influence of any sort, and to protect themselves from abuse, neglect and exploitation. It is important to note that people with capacity can also still be ‘at risk’.
- It is always essential in safeguarding to consider whether the adult at risk is capable of giving informed consent. If they are, their consent to any course of action should be obtained. This may be in relation to whether they give their consent to:
- An activity that may be abusive – if consent to abuse or neglect was given under duress, for example, as a result of exploitation, pressure, fear, intimidation – this apparent consent should be. disregarded.
- A Safeguarding Adults investigation going ahead in response to a concern that has been raised. Where an adult at risk with capacity has made a decision that they do not want action to be taken and there are no public interest considerations, their wishes must be respected. The person should be given information and have the opportunity to consider all the risks and fully understand the likely consequences of their decision over the short and long term.
- If after discussion with the adult at risk who has mental capacity, they refuse any intervention, their wishes must be respected unless:
- there is a public interest – eg not acting will put other adults or children at risk
- there is a duty of care to intervene eg a crime has been, or will be, committed
- We recognise that there are often complex issues and factors that many of the individuals may have experienced throughout some point in their lives. Such factors should be taken into consideration when looking at who an adult at risk may be. Many of the women that we will encounter will have various experiences of being homeless, fleeing exploitation and/or trafficking, prostitution, suffering from low self esteem, self harm, substance misuse, learning difficulties, emotional wellbeing needs or mental health issues such as Borderline Personality Disorder.
- At all times Luminary will consider the welfare of the Adult at Risk to be of high importance. We are committed to achieving this by:
- Actively striving to promote the empowerment and wellbeing of adults at risk through respectful and responsive high quality service provision.
- Helping to prevent the physical, sexual, emotional or psychological, financial and discriminatory abuse and neglect of adults at risk and to report any such abuse that is discovered or suspected.
- Believing and promoting that all individuals have the right to be able to live their lives free from exploitation, fear, abuse, harm or degrading treatment. All individuals have the right to protection from any such mistreatment and harm.
- Believing and promoting that all individuals have the right to make choices and that their right to independence is actively encouraged. We acknowledge that such choices may at times involve an element of risk. We are committed to ensuring that any such risks are formally acknowledged and understood by all concerned, taking all reasonable measures to ensure risks are minimized wherever possible.
- Being committed to respecting equal opportunities, anti -discriminatory practise and diversity issues.
- All staff and volunteers are required not to share any private information or photos about the service users in any context.
- Ensuring that the law and statutory requirements which relate to adults at risk are known and put into practice.
- Safe recruitment, supervision and training for all those working with adults at risk within Luminary.
'Abuse'
‘Abuse’ is an emotive term and can be subject to interpretation, Luminary recognises that abuse can be “a violation of an individual’s human and civil rights by any other person or persons” (“No Secrets”, Department of Health 2000).
Abuse may be:
- A single or repeated act
- An act of neglect; lack of appropriate action taking place
- Multiple acts; an adult at risk may be neglected and also financially abused
'The Abuser'
It is important to recognise that the ‘abuser’ could be anyone, including friends, relatives, family members, other Service Users, professional paid staff, volunteers and persons unknown to the adult at risk. They may also themselves be an adult at risk.
'Exploitation'
Exploitation is exerting undue influence or forcing an adult at risk to perform services for the benefit of others.
'SIGNIFICANT HARM’
The Law Commissioner’s Green Paper ‘Who Decides’ 1997 builds on the concept introduced in the Children Act, 1989 and suggests:
"Harm should be taken to include not only ill treatment (including sexual abuse and forms of ill treatment that are not physical); but also the impairment of, or an unavoidable deterioration in physical or mental health, and the impairment of physical, intellectual, emotional social or behavioural development.”
'No Secrets' also uses the concept of significant harm. This refers to:
- Ill treatment
- Impairment of physical or mental health
- Impairment of physical, intellectual, emotional social or behavioural development
'No Secrets' puts forward the following factors to be taken into account when making an assessment of the seriousness of the risk to the person:
- Vulnerability of the person
- Nature and extent of the abuse or neglect
- Length of time the abuse or neglect has been occurring
- Impact of the alleged abuse
- Impact of the alleged abuse
- Risk of repeated or increasingly serious acts of abuse or neglect
- Risk that serious harm could result if no action is taken
- Illegality of the act
D. Categories of abuse: signs and possible indicators
Physical Abuse
Is the physical mistreatment or non-accidental injury of an adult. Some possible signs of abuse are detailed as follows:
- Slapping
- Kicking
- Punching
- Shaking
- Bruising
- Burns
- Cutting
Indicators of possible physical abuse may include, but are not limited to:
- An injury not fitting the explanation given
- Unexplained or unusual fractures in various stages of healing
- Bruises or burns in the shape of objects e.g. cigarette burns, belt buckles or water
- Bruising in well protected areas e.g. behind the ears, on face, inside of the upper arms or thighs, buttocks, breasts, genital or rectal area
- Lacerations
- Unlawful or inappropriate use of restraint and/or deprivation of liberty is physical abuse
Neglect or Acts of Omission
This includes deliberate refusal to meet basic needs. Signs of neglect can include individuals experiencing the following:
- Lack of choice, denied diversity
- Poor judgemental attitudes
- Derogatory terms used about the adult or their situation
- Failure to ensure appropriate privacy and dignity
- Poor surroundings e.g. neglect of repairs, inadequate heating
- Over or under protective practices
Behaviour that can lead to neglect includes:
- Ignoring medical or physical needs
- failing to allow access to appropriate health, social and educational services
Indicators of possible neglect or omission may include, but are not limited to:
- Loss of weight
- Clothing in a poor condition
- Failure to access appropriate health, educational services or social care
Unintentional neglect could result from a professional failing to meet the needs of the adult at risk because they do not understand the needs or may not know about the services available. It may also occur if the individuals are unaware of or do not understand the possible effect of the lack of action on the adult at risk.
Psychological or Emotional Abuse
This includes threats of harm, abandonment, isolation or humiliation which may result in the adult feeling in low mood, undervalued and perhaps unnecessarily dependant.
Some ways in which psychological/emotional abuse can take the form of are detailed below:
- Failure to respond adequately to emotional needs
- Failure to protect from the emotional abuse of others
- Harassment or humiliation (bullying)
- Intimidation
- Failure to meet cultural requirements
- Unreasonable demands
- Denial of choice
- Controlling or creating over dependence
- Verbal abuse
- Cyber bullying
- Mental distress
- Negating the right of the adult at risk to make choices and undermining their self esteem
- Isolation and over dependence
Indicators of possible psychological or emotional abuse may include, but are not limited to:
- Low self esteem
- Tearfulness
- Alteration in psychological state e.g. may appear to be withdrawn, agitated or anxious in general
- Aggressive or challenging behaviour
- Attention seeking behaviour
- Self harm
- Depression
- Insomnia
- Unexplained paranoia
Sexual Abuse
This is the involvement of any individual in any sexual activity to which they either cannot or have not given their consent or does not truly comprehend and so cannot give consent. Or where the other party is in a position of trust, power or authority and uses this to override or overcome lack of consent. Sexual abuse includes:
- Rape or sexual assault
- Inappropriate touching
- Fondling
- Sexual intercourse/buggery or attempted sexual intercourse/buggery
- Inflicting pornography on an individual
- Offensive or inappropriate language including sexual innuendos and sexual teasing
Indicators of possible sexual abuse may include, but are not limited to:
- Change in usual behaviour
- Overt sexual behaviour/language
- Bleeding or pain in the genital/rectal area
- Disturbed sleep pattern
- Torn, stained or bloody underwear
- Self‐harming
Financial or Material Abuse
This can be considered as unauthorised extraction of the adult at risk’s resources or their resources being withheld or misused by someone else and including:
- Misuse, embezzlement or theft of a person’s money, property or possessions
- Failing to account satisfactorily for the use of a person’s money, property or possessions, fraudulent use of money
- Extortion of money, property, possessions through theft
Indicators of possible financial or material abuse may include, but are not limited to:
- Lifestyle does not reflect known income
- Unexplained withdrawals from account
- Unexplained/sudden inability to pay service charge/bills etc.
Financial abuse is a crime.
Discriminatory Abuse
The inappropriate treatment of an adult at risk because of their age, gender, race, religion, cultural background, sexuality, disability, etc.
Discriminatory abuse exists when values, belief or culture result in a misuse of power that denies opportunity to some groups or individuals.
Discriminatory abuse links to all other forms of abuse and can include:
- Unequal treatment
- Inappropriate use of language:
- Racist remarks
- Sexist remarks
- Derogatory remarks or verbal abuse
- Comments about disability
- Bullying or other forms of harassment
- Deliberate exclusion
Indicators of possible discriminatory abuse may include, but are not limited to:
- Inappropriate remarks or comments
- Lack of respect shown to people
- Staff member/volunteer may avoid being with certain groups of people
Institutional Abuse
Institutional abuse is the mistreatment or abuse or neglect of an adult at risk by individuals within an organisational setting where routines, systems and practices result in denying, restricting or curtailing the dignity, privacy, choice, independence or fulfilment of an adult at risk.
A number of inquiries into institutional abuse have shown that abuse is most likely to occur when staff:
- Receive little support from management
- Are inadequately trained
- Are poorly supervised
- Receive inadequate guidance
E. Key Principles
The most important priority is to ensure that the most urgent medical and welfare requirements of the adult at risk are met.
Preserve any potential forensic opportunities, record verbatim the disclosure made by the adult at risk.
Any sexual activity that is not freely consented to is criminal and should be reported to the police immediately, before any internal investigation.
Sexual relationships, or inappropriate sexual behaviour between a member of staff (or volunteer) and a service user are always abusive and will lead to disciplinary hearings. This will be in addition to any criminal actions taken.
A sexual relationship between the service user and a care worker is a criminal offence under Sections 38-42 of the Sexual Offences Act 2003.
There may be Safeguarding Adults referrals that involve sexual innuendo or remarks that will not result in a criminal investigation; however, all Safeguarding Adults referrals that indicate any form of sexual abuse require a risk assessment, intelligence gathering and appropriate information sharing with relevant partners.
F. Responsibilities
Duty Of Care
All staff & volunteers of Luminary have a ‘duty of care’ towards those who use our services.
This means taking action whenever there is a concern of possible mistreatment or abuse to an adult at risk. The procedural guidelines supporting this Policy are intended to provide a good practice framework and to support staff; staff are therefore expected to comply with them.
Failure to report any concerns may be viewed as being negligent or agreeing with the abuse, which in some cases could lead to disciplinary action.
All staff should:
- Be aware that they must call the police/ambulance where appropriate
- Share their concerns with appropriate colleagues and seek advice and support unless they are implicated in the abuse
- Know they must inform the appropriate safeguarding officer as per escalation chart
- Know that they must make a clear, factual record of their concern and the action taken using the Safeguarding Incident Reporting Form
In addition, Support Workers & Safeguarding Staff should:
- Know what services are available and how to access help and advice
- Know how and where to make a referral via Adult Social Care
Responsibility of Managers:
- To ensure that the alleged victim is safe
- To ensure that any staff or volunteer who may have caused the harm is not in contact with service users and others who may be at risk
- To ensure that information is provided in a timely manner
- Operate safe recruitment practices and ensure reference checks are made
- Support staff who raise concerns
Monitoring
Safer Recruitment
All staff who work in a support-work capacity with our service users are subject to an enhanced disclosure check from the Disclosure and Barring Service.
For any team recruitment, an interview should be conducted, and two satisfactory references received, to assess an applicant’s suitability prior to an offer of employment or volunteering being made. On appointment staff and volunteers serve a probationary period for performance monitoring.
Volunteers within projects are recruited within the same processes as those for paid members of staff.
The named Safeguarding Adults Co-ordinator (SAC)- Alice Williams (Luminary CEO) will monitor any concerns and keep a record of safeguarding prompt logs compiled by staff. The SAC will report to the Charity Board on a quarterly basis.
G. Training
This policy and associated procedures are to be rolled out across Luminary through in- house training and in addition staff may access local authority Safeguarding Adult training.
16.1 Safeguarding Adults at Risk Policy & Procedure
Page Navigation
A. Introduction
The Safeguarding Adults at Risk Policy and Procedure represent Luminary’s commitment to safeguard adults at risk of harm.
The policy and procedure apply to ALL Luminary staff and volunteers. They represent Luminary’s commitment to:
- working together with other agencies to prevent and protect adults at risk of abuse
- empower and support people to make their own choices
- investigate actual or suspected abuse or neglect
- support adults and provide a service to adults at risk who are experiencing exploitation, abuse or neglect
B. Context
Unlike Child Protection, there is no statutory protection for, or definition of adults at risk of abuse.
There is a presumption that adults have the mental capacity to make informed decisions about their lives. If someone has been assessed as not having mental capacity, then decisions should be made in their best interests as set out in the Mental Capacity Act 2005.
Adults at risk should be given information, advice and support in a form they can understand and have their views included when decisions are being taken about their lives. All decisions taken about another person’s life should be timely, reasonable, justified, proportionate and ethical.
- All staff have a duty to report any concerns or suspicions that an adult at risk is being, or is at risk of being, abused.
- Actions to protect the adult from abuse should always be given a high priority by all organisations involved. Concerns or allegations should be reported without delay and given high priority.
- Luminary will work to safeguard adults at risk, making their dignity, safety and well-being a high priority.
- All staff have a duty to understand their role and responsibilities in regard to this policy and procedure.
- Every effort should be made to ensure that adults at risk are afforded appropriate protection under the law.
- As far as possible Luminary staff and volunteers must respect the rights of the person causing harm. If that person is also an adult at risk, they must receive support and their needs should be addressed.
- Luminary staff will work effectively with interagency working in order to provide the most effective means of safeguarding adults.
C. Definitions
'Adult At Risk'
‘Adult at risk’ means adults who need community care services because of mental or other disability, age or illness and who is, or may be, unable to take care of themselves against significant harm or exploitation.
- An adult at risk may therefore be a person who:
- is unable to look after their own wellbeing, property, rights or other interests
- misuses substances or alcohol
- has a learning disability
- has a physical disability and/or a sensory impairment
- has mental health needs including dementia or a personality disorder
- has been groomed, trafficked or exploited
- has a long term illness or condition
- is in need of care and support but is unable to demonstrate the capacity to make an informed decision about themselves
- is elderly and frail due to ill health, physical disability, or cognitive impairment
- Actions to protect the adult from abuse should always be given high priority. The dignity, safety and wellbeing of an individual should be a priority within any action taken.
- In the context of safeguarding adults, the extent to which the adult is at risk is related to how able they are to make and exercise their own informed choices free from duress, pressure or undue influence of any sort, and to protect themselves from abuse, neglect and exploitation. It is important to note that people with capacity can also still be ‘at risk’.
- It is always essential in safeguarding to consider whether the adult at risk is capable of giving informed consent. If they are, their consent to any course of action should be obtained. This may be in relation to whether they give their consent to:
- An activity that may be abusive – if consent to abuse or neglect was given under duress, for example, as a result of exploitation, pressure, fear, intimidation – this apparent consent should be. disregarded.
- A Safeguarding Adults investigation going ahead in response to a concern that has been raised. Where an adult at risk with capacity has made a decision that they do not want action to be taken and there are no public interest considerations, their wishes must be respected. The person should be given information and have the opportunity to consider all the risks and fully understand the likely consequences of their decision over the short and long term.
- If after discussion with the adult at risk who has mental capacity, they refuse any intervention, their wishes must be respected unless:
- there is a public interest – eg not acting will put other adults or children at risk
- there is a duty of care to intervene eg a crime has been, or will be, committed
- We recognise that there are often complex issues and factors that many of the individuals may have experienced throughout some point in their lives. Such factors should be taken into consideration when looking at who an adult at risk may be. Many of the women that we will encounter will have various experiences of being homeless, fleeing exploitation and/or trafficking, prostitution, suffering from low self esteem, self harm, substance misuse, learning difficulties, emotional wellbeing needs or mental health issues such as Borderline Personality Disorder.
- At all times Luminary will consider the welfare of the Adult at Risk to be of high importance. We are committed to achieving this by:
- Actively striving to promote the empowerment and wellbeing of adults at risk through respectful and responsive high quality service provision.
- Helping to prevent the physical, sexual, emotional or psychological, financial and discriminatory abuse and neglect of adults at risk and to report any such abuse that is discovered or suspected.
- Believing and promoting that all individuals have the right to be able to live their lives free from exploitation, fear, abuse, harm or degrading treatment. All individuals have the right to protection from any such mistreatment and harm.
- Believing and promoting that all individuals have the right to make choices and that their right to independence is actively encouraged. We acknowledge that such choices may at times involve an element of risk. We are committed to ensuring that any such risks are formally acknowledged and understood by all concerned, taking all reasonable measures to ensure risks are minimized wherever possible.
- Being committed to respecting equal opportunities, anti -discriminatory practise and diversity issues.
- All staff and volunteers are required not to share any private information or photos about the service users in any context.
- Ensuring that the law and statutory requirements which relate to adults at risk are known and put into practice.
- Safe recruitment, supervision and training for all those working with adults at risk within Luminary.
'Abuse'
‘Abuse’ is an emotive term and can be subject to interpretation, Luminary recognises that abuse can be “a violation of an individual’s human and civil rights by any other person or persons” (“No Secrets”, Department of Health 2000).
Abuse may be:
- A single or repeated act
- An act of neglect; lack of appropriate action taking place
- Multiple acts; an adult at risk may be neglected and also financially abused
'The Abuser'
It is important to recognise that the ‘abuser’ could be anyone, including friends, relatives, family members, other Service Users, professional paid staff, volunteers and persons unknown to the adult at risk. They may also themselves be an adult at risk.
'Exploitation'
Exploitation is exerting undue influence or forcing an adult at risk to perform services for the benefit of others.
'SIGNIFICANT HARM’
The Law Commissioner’s Green Paper ‘Who Decides’ 1997 builds on the concept introduced in the Children Act, 1989 and suggests:
"Harm should be taken to include not only ill treatment (including sexual abuse and forms of ill treatment that are not physical); but also the impairment of, or an unavoidable deterioration in physical or mental health, and the impairment of physical, intellectual, emotional social or behavioural development.”
'No Secrets' also uses the concept of significant harm. This refers to:
- Ill treatment
- Impairment of physical or mental health
- Impairment of physical, intellectual, emotional social or behavioural development
'No Secrets' puts forward the following factors to be taken into account when making an assessment of the seriousness of the risk to the person:
- Vulnerability of the person
- Nature and extent of the abuse or neglect
- Length of time the abuse or neglect has been occurring
- Impact of the alleged abuse
- Impact of the alleged abuse
- Risk of repeated or increasingly serious acts of abuse or neglect
- Risk that serious harm could result if no action is taken
- Illegality of the act
D. Categories of abuse: signs and possible indicators
Physical Abuse
Is the physical mistreatment or non-accidental injury of an adult. Some possible signs of abuse are detailed as follows:
- Slapping
- Kicking
- Punching
- Shaking
- Bruising
- Burns
- Cutting
Indicators of possible physical abuse may include, but are not limited to:
- An injury not fitting the explanation given
- Unexplained or unusual fractures in various stages of healing
- Bruises or burns in the shape of objects e.g. cigarette burns, belt buckles or water
- Bruising in well protected areas e.g. behind the ears, on face, inside of the upper arms or thighs, buttocks, breasts, genital or rectal area
- Lacerations
- Unlawful or inappropriate use of restraint and/or deprivation of liberty is physical abuse
Neglect or Acts of Omission
This includes deliberate refusal to meet basic needs. Signs of neglect can include individuals experiencing the following:
- Lack of choice, denied diversity
- Poor judgemental attitudes
- Derogatory terms used about the adult or their situation
- Failure to ensure appropriate privacy and dignity
- Poor surroundings e.g. neglect of repairs, inadequate heating
- Over or under protective practices
Behaviour that can lead to neglect includes:
- Ignoring medical or physical needs
- failing to allow access to appropriate health, social and educational services
Indicators of possible neglect or omission may include, but are not limited to:
- Loss of weight
- Clothing in a poor condition
- Failure to access appropriate health, educational services or social care
Unintentional neglect could result from a professional failing to meet the needs of the adult at risk because they do not understand the needs or may not know about the services available. It may also occur if the individuals are unaware of or do not understand the possible effect of the lack of action on the adult at risk.
Psychological or Emotional Abuse
This includes threats of harm, abandonment, isolation or humiliation which may result in the adult feeling in low mood, undervalued and perhaps unnecessarily dependant.
Some ways in which psychological/emotional abuse can take the form of are detailed below:
- Failure to respond adequately to emotional needs
- Failure to protect from the emotional abuse of others
- Harassment or humiliation (bullying)
- Intimidation
- Failure to meet cultural requirements
- Unreasonable demands
- Denial of choice
- Controlling or creating over dependence
- Verbal abuse
- Cyber bullying
- Mental distress
- Negating the right of the adult at risk to make choices and undermining their self esteem
- Isolation and over dependence
Indicators of possible psychological or emotional abuse may include, but are not limited to:
- Low self esteem
- Tearfulness
- Alteration in psychological state e.g. may appear to be withdrawn, agitated or anxious in general
- Aggressive or challenging behaviour
- Attention seeking behaviour
- Self harm
- Depression
- Insomnia
- Unexplained paranoia
Sexual Abuse
This is the involvement of any individual in any sexual activity to which they either cannot or have not given their consent or does not truly comprehend and so cannot give consent. Or where the other party is in a position of trust, power or authority and uses this to override or overcome lack of consent. Sexual abuse includes:
- Rape or sexual assault
- Inappropriate touching
- Fondling
- Sexual intercourse/buggery or attempted sexual intercourse/buggery
- Inflicting pornography on an individual
- Offensive or inappropriate language including sexual innuendos and sexual teasing
Indicators of possible sexual abuse may include, but are not limited to:
- Change in usual behaviour
- Overt sexual behaviour/language
- Bleeding or pain in the genital/rectal area
- Disturbed sleep pattern
- Torn, stained or bloody underwear
- Self‐harming
Financial or Material Abuse
This can be considered as unauthorised extraction of the adult at risk’s resources or their resources being withheld or misused by someone else and including:
- Misuse, embezzlement or theft of a person’s money, property or possessions
- Failing to account satisfactorily for the use of a person’s money, property or possessions, fraudulent use of money
- Extortion of money, property, possessions through theft
Indicators of possible financial or material abuse may include, but are not limited to:
- Lifestyle does not reflect known income
- Unexplained withdrawals from account
- Unexplained/sudden inability to pay service charge/bills etc.
Financial abuse is a crime.
Discriminatory Abuse
The inappropriate treatment of an adult at risk because of their age, gender, race, religion, cultural background, sexuality, disability, etc.
Discriminatory abuse exists when values, belief or culture result in a misuse of power that denies opportunity to some groups or individuals.
Discriminatory abuse links to all other forms of abuse and can include:
- Unequal treatment
- Inappropriate use of language:
- Racist remarks
- Sexist remarks
- Derogatory remarks or verbal abuse
- Comments about disability
- Bullying or other forms of harassment
- Deliberate exclusion
Indicators of possible discriminatory abuse may include, but are not limited to:
- Inappropriate remarks or comments
- Lack of respect shown to people
- Staff member/volunteer may avoid being with certain groups of people
Institutional Abuse
Institutional abuse is the mistreatment or abuse or neglect of an adult at risk by individuals within an organisational setting where routines, systems and practices result in denying, restricting or curtailing the dignity, privacy, choice, independence or fulfilment of an adult at risk.
A number of inquiries into institutional abuse have shown that abuse is most likely to occur when staff:
- Receive little support from management
- Are inadequately trained
- Are poorly supervised
- Receive inadequate guidance
E. Key Principles
The most important priority is to ensure that the most urgent medical and welfare requirements of the adult at risk are met.
Preserve any potential forensic opportunities, record verbatim the disclosure made by the adult at risk.
Any sexual activity that is not freely consented to is criminal and should be reported to the police immediately, before any internal investigation.
Sexual relationships, or inappropriate sexual behaviour between a member of staff (or volunteer) and a service user are always abusive and will lead to disciplinary hearings. This will be in addition to any criminal actions taken.
A sexual relationship between the service user and a care worker is a criminal offence under Sections 38-42 of the Sexual Offences Act 2003.
There may be Safeguarding Adults referrals that involve sexual innuendo or remarks that will not result in a criminal investigation; however, all Safeguarding Adults referrals that indicate any form of sexual abuse require a risk assessment, intelligence gathering and appropriate information sharing with relevant partners.
F. Responsibilities
Duty Of Care
All staff & volunteers of Luminary have a ‘duty of care’ towards those who use our services.
This means taking action whenever there is a concern of possible mistreatment or abuse to an adult at risk. The procedural guidelines supporting this Policy are intended to provide a good practice framework and to support staff; staff are therefore expected to comply with them.
Failure to report any concerns may be viewed as being negligent or agreeing with the abuse, which in some cases could lead to disciplinary action.
All staff should:
- Be aware that they must call the police/ambulance where appropriate
- Share their concerns with appropriate colleagues and seek advice and support unless they are implicated in the abuse
- Know they must inform the appropriate safeguarding officer as per escalation chart
- Know that they must make a clear, factual record of their concern and the action taken using the Safeguarding Incident Reporting Form
In addition, Support Workers & Safeguarding Staff should:
- Know what services are available and how to access help and advice
- Know how and where to make a referral via Adult Social Care
Responsibility of Managers:
- To ensure that the alleged victim is safe
- To ensure that any staff or volunteer who may have caused the harm is not in contact with service users and others who may be at risk
- To ensure that information is provided in a timely manner
- Operate safe recruitment practices and ensure reference checks are made
- Support staff who raise concerns
Monitoring
Safer Recruitment
All staff who work in a support-work capacity with our service users are subject to an enhanced disclosure check from the Disclosure and Barring Service.
For any team recruitment, an interview should be conducted, and two satisfactory references received, to assess an applicant’s suitability prior to an offer of employment or volunteering being made. On appointment staff and volunteers serve a probationary period for performance monitoring.
Volunteers within projects are recruited within the same processes as those for paid members of staff.
The named Safeguarding Adults Co-ordinator (SAC)- Alice Williams (Luminary CEO) will monitor any concerns and keep a record of safeguarding prompt logs compiled by staff. The SAC will report to the Charity Board on a quarterly basis.
G. Training
This policy and associated procedures are to be rolled out across Luminary through in- house training and in addition staff may access local authority Safeguarding Adult training.
-
CAKES
16.1 Safeguarding Adults at Risk Policy & Procedure
Page Navigation
A. Introduction
The Safeguarding Adults at Risk Policy and Procedure represent Luminary’s commitment to safeguard adults at risk of harm.
The policy and procedure apply to ALL Luminary staff and volunteers. They represent Luminary’s commitment to:
- working together with other agencies to prevent and protect adults at risk of abuse
- empower and support people to make their own choices
- investigate actual or suspected abuse or neglect
- support adults and provide a service to adults at risk who are experiencing exploitation, abuse or neglect
B. Context
Unlike Child Protection, there is no statutory protection for, or definition of adults at risk of abuse.
There is a presumption that adults have the mental capacity to make informed decisions about their lives. If someone has been assessed as not having mental capacity, then decisions should be made in their best interests as set out in the Mental Capacity Act 2005.
Adults at risk should be given information, advice and support in a form they can understand and have their views included when decisions are being taken about their lives. All decisions taken about another person’s life should be timely, reasonable, justified, proportionate and ethical.
- All staff have a duty to report any concerns or suspicions that an adult at risk is being, or is at risk of being, abused.
- Actions to protect the adult from abuse should always be given a high priority by all organisations involved. Concerns or allegations should be reported without delay and given high priority.
- Luminary will work to safeguard adults at risk, making their dignity, safety and well-being a high priority.
- All staff have a duty to understand their role and responsibilities in regard to this policy and procedure.
- Every effort should be made to ensure that adults at risk are afforded appropriate protection under the law.
- As far as possible Luminary staff and volunteers must respect the rights of the person causing harm. If that person is also an adult at risk, they must receive support and their needs should be addressed.
- Luminary staff will work effectively with interagency working in order to provide the most effective means of safeguarding adults.
C. Definitions
'Adult At Risk'
‘Adult at risk’ means adults who need community care services because of mental or other disability, age or illness and who is, or may be, unable to take care of themselves against significant harm or exploitation.
- An adult at risk may therefore be a person who:
- is unable to look after their own wellbeing, property, rights or other interests
- misuses substances or alcohol
- has a learning disability
- has a physical disability and/or a sensory impairment
- has mental health needs including dementia or a personality disorder
- has been groomed, trafficked or exploited
- has a long term illness or condition
- is in need of care and support but is unable to demonstrate the capacity to make an informed decision about themselves
- is elderly and frail due to ill health, physical disability, or cognitive impairment
- Actions to protect the adult from abuse should always be given high priority. The dignity, safety and wellbeing of an individual should be a priority within any action taken.
- In the context of safeguarding adults, the extent to which the adult is at risk is related to how able they are to make and exercise their own informed choices free from duress, pressure or undue influence of any sort, and to protect themselves from abuse, neglect and exploitation. It is important to note that people with capacity can also still be ‘at risk’.
- It is always essential in safeguarding to consider whether the adult at risk is capable of giving informed consent. If they are, their consent to any course of action should be obtained. This may be in relation to whether they give their consent to:
- An activity that may be abusive – if consent to abuse or neglect was given under duress, for example, as a result of exploitation, pressure, fear, intimidation – this apparent consent should be. disregarded.
- A Safeguarding Adults investigation going ahead in response to a concern that has been raised. Where an adult at risk with capacity has made a decision that they do not want action to be taken and there are no public interest considerations, their wishes must be respected. The person should be given information and have the opportunity to consider all the risks and fully understand the likely consequences of their decision over the short and long term.
- If after discussion with the adult at risk who has mental capacity, they refuse any intervention, their wishes must be respected unless:
- there is a public interest – eg not acting will put other adults or children at risk
- there is a duty of care to intervene eg a crime has been, or will be, committed
- We recognise that there are often complex issues and factors that many of the individuals may have experienced throughout some point in their lives. Such factors should be taken into consideration when looking at who an adult at risk may be. Many of the women that we will encounter will have various experiences of being homeless, fleeing exploitation and/or trafficking, prostitution, suffering from low self esteem, self harm, substance misuse, learning difficulties, emotional wellbeing needs or mental health issues such as Borderline Personality Disorder.
- At all times Luminary will consider the welfare of the Adult at Risk to be of high importance. We are committed to achieving this by:
- Actively striving to promote the empowerment and wellbeing of adults at risk through respectful and responsive high quality service provision.
- Helping to prevent the physical, sexual, emotional or psychological, financial and discriminatory abuse and neglect of adults at risk and to report any such abuse that is discovered or suspected.
- Believing and promoting that all individuals have the right to be able to live their lives free from exploitation, fear, abuse, harm or degrading treatment. All individuals have the right to protection from any such mistreatment and harm.
- Believing and promoting that all individuals have the right to make choices and that their right to independence is actively encouraged. We acknowledge that such choices may at times involve an element of risk. We are committed to ensuring that any such risks are formally acknowledged and understood by all concerned, taking all reasonable measures to ensure risks are minimized wherever possible.
- Being committed to respecting equal opportunities, anti -discriminatory practise and diversity issues.
- All staff and volunteers are required not to share any private information or photos about the service users in any context.
- Ensuring that the law and statutory requirements which relate to adults at risk are known and put into practice.
- Safe recruitment, supervision and training for all those working with adults at risk within Luminary.
'Abuse'
‘Abuse’ is an emotive term and can be subject to interpretation, Luminary recognises that abuse can be “a violation of an individual’s human and civil rights by any other person or persons” (“No Secrets”, Department of Health 2000).
Abuse may be:
- A single or repeated act
- An act of neglect; lack of appropriate action taking place
- Multiple acts; an adult at risk may be neglected and also financially abused
'The Abuser'
It is important to recognise that the ‘abuser’ could be anyone, including friends, relatives, family members, other Service Users, professional paid staff, volunteers and persons unknown to the adult at risk. They may also themselves be an adult at risk.
'Exploitation'
Exploitation is exerting undue influence or forcing an adult at risk to perform services for the benefit of others.
'SIGNIFICANT HARM’
The Law Commissioner’s Green Paper ‘Who Decides’ 1997 builds on the concept introduced in the Children Act, 1989 and suggests:
"Harm should be taken to include not only ill treatment (including sexual abuse and forms of ill treatment that are not physical); but also the impairment of, or an unavoidable deterioration in physical or mental health, and the impairment of physical, intellectual, emotional social or behavioural development.”
'No Secrets' also uses the concept of significant harm. This refers to:
- Ill treatment
- Impairment of physical or mental health
- Impairment of physical, intellectual, emotional social or behavioural development
'No Secrets' puts forward the following factors to be taken into account when making an assessment of the seriousness of the risk to the person:
- Vulnerability of the person
- Nature and extent of the abuse or neglect
- Length of time the abuse or neglect has been occurring
- Impact of the alleged abuse
- Impact of the alleged abuse
- Risk of repeated or increasingly serious acts of abuse or neglect
- Risk that serious harm could result if no action is taken
- Illegality of the act
D. Categories of abuse: signs and possible indicators
Physical Abuse
Is the physical mistreatment or non-accidental injury of an adult. Some possible signs of abuse are detailed as follows:
- Slapping
- Kicking
- Punching
- Shaking
- Bruising
- Burns
- Cutting
Indicators of possible physical abuse may include, but are not limited to:
- An injury not fitting the explanation given
- Unexplained or unusual fractures in various stages of healing
- Bruises or burns in the shape of objects e.g. cigarette burns, belt buckles or water
- Bruising in well protected areas e.g. behind the ears, on face, inside of the upper arms or thighs, buttocks, breasts, genital or rectal area
- Lacerations
- Unlawful or inappropriate use of restraint and/or deprivation of liberty is physical abuse
Neglect or Acts of Omission
This includes deliberate refusal to meet basic needs. Signs of neglect can include individuals experiencing the following:
- Lack of choice, denied diversity
- Poor judgemental attitudes
- Derogatory terms used about the adult or their situation
- Failure to ensure appropriate privacy and dignity
- Poor surroundings e.g. neglect of repairs, inadequate heating
- Over or under protective practices
Behaviour that can lead to neglect includes:
- Ignoring medical or physical needs
- failing to allow access to appropriate health, social and educational services
Indicators of possible neglect or omission may include, but are not limited to:
- Loss of weight
- Clothing in a poor condition
- Failure to access appropriate health, educational services or social care
Unintentional neglect could result from a professional failing to meet the needs of the adult at risk because they do not understand the needs or may not know about the services available. It may also occur if the individuals are unaware of or do not understand the possible effect of the lack of action on the adult at risk.
Psychological or Emotional Abuse
This includes threats of harm, abandonment, isolation or humiliation which may result in the adult feeling in low mood, undervalued and perhaps unnecessarily dependant.
Some ways in which psychological/emotional abuse can take the form of are detailed below:
- Failure to respond adequately to emotional needs
- Failure to protect from the emotional abuse of others
- Harassment or humiliation (bullying)
- Intimidation
- Failure to meet cultural requirements
- Unreasonable demands
- Denial of choice
- Controlling or creating over dependence
- Verbal abuse
- Cyber bullying
- Mental distress
- Negating the right of the adult at risk to make choices and undermining their self esteem
- Isolation and over dependence
Indicators of possible psychological or emotional abuse may include, but are not limited to:
- Low self esteem
- Tearfulness
- Alteration in psychological state e.g. may appear to be withdrawn, agitated or anxious in general
- Aggressive or challenging behaviour
- Attention seeking behaviour
- Self harm
- Depression
- Insomnia
- Unexplained paranoia
Sexual Abuse
This is the involvement of any individual in any sexual activity to which they either cannot or have not given their consent or does not truly comprehend and so cannot give consent. Or where the other party is in a position of trust, power or authority and uses this to override or overcome lack of consent. Sexual abuse includes:
- Rape or sexual assault
- Inappropriate touching
- Fondling
- Sexual intercourse/buggery or attempted sexual intercourse/buggery
- Inflicting pornography on an individual
- Offensive or inappropriate language including sexual innuendos and sexual teasing
Indicators of possible sexual abuse may include, but are not limited to:
- Change in usual behaviour
- Overt sexual behaviour/language
- Bleeding or pain in the genital/rectal area
- Disturbed sleep pattern
- Torn, stained or bloody underwear
- Self‐harming
Financial or Material Abuse
This can be considered as unauthorised extraction of the adult at risk’s resources or their resources being withheld or misused by someone else and including:
- Misuse, embezzlement or theft of a person’s money, property or possessions
- Failing to account satisfactorily for the use of a person’s money, property or possessions, fraudulent use of money
- Extortion of money, property, possessions through theft
Indicators of possible financial or material abuse may include, but are not limited to:
- Lifestyle does not reflect known income
- Unexplained withdrawals from account
- Unexplained/sudden inability to pay service charge/bills etc.
Financial abuse is a crime.
Discriminatory Abuse
The inappropriate treatment of an adult at risk because of their age, gender, race, religion, cultural background, sexuality, disability, etc.
Discriminatory abuse exists when values, belief or culture result in a misuse of power that denies opportunity to some groups or individuals.
Discriminatory abuse links to all other forms of abuse and can include:
- Unequal treatment
- Inappropriate use of language:
- Racist remarks
- Sexist remarks
- Derogatory remarks or verbal abuse
- Comments about disability
- Bullying or other forms of harassment
- Deliberate exclusion
Indicators of possible discriminatory abuse may include, but are not limited to:
- Inappropriate remarks or comments
- Lack of respect shown to people
- Staff member/volunteer may avoid being with certain groups of people
Institutional Abuse
Institutional abuse is the mistreatment or abuse or neglect of an adult at risk by individuals within an organisational setting where routines, systems and practices result in denying, restricting or curtailing the dignity, privacy, choice, independence or fulfilment of an adult at risk.
A number of inquiries into institutional abuse have shown that abuse is most likely to occur when staff:
- Receive little support from management
- Are inadequately trained
- Are poorly supervised
- Receive inadequate guidance
E. Key Principles
The most important priority is to ensure that the most urgent medical and welfare requirements of the adult at risk are met.
Preserve any potential forensic opportunities, record verbatim the disclosure made by the adult at risk.
Any sexual activity that is not freely consented to is criminal and should be reported to the police immediately, before any internal investigation.
Sexual relationships, or inappropriate sexual behaviour between a member of staff (or volunteer) and a service user are always abusive and will lead to disciplinary hearings. This will be in addition to any criminal actions taken.
A sexual relationship between the service user and a care worker is a criminal offence under Sections 38-42 of the Sexual Offences Act 2003.
There may be Safeguarding Adults referrals that involve sexual innuendo or remarks that will not result in a criminal investigation; however, all Safeguarding Adults referrals that indicate any form of sexual abuse require a risk assessment, intelligence gathering and appropriate information sharing with relevant partners.
F. Responsibilities
Duty Of Care
All staff & volunteers of Luminary have a ‘duty of care’ towards those who use our services.
This means taking action whenever there is a concern of possible mistreatment or abuse to an adult at risk. The procedural guidelines supporting this Policy are intended to provide a good practice framework and to support staff; staff are therefore expected to comply with them.
Failure to report any concerns may be viewed as being negligent or agreeing with the abuse, which in some cases could lead to disciplinary action.
All staff should:
- Be aware that they must call the police/ambulance where appropriate
- Share their concerns with appropriate colleagues and seek advice and support unless they are implicated in the abuse
- Know they must inform the appropriate safeguarding officer as per escalation chart
- Know that they must make a clear, factual record of their concern and the action taken using the Safeguarding Incident Reporting Form
In addition, Support Workers & Safeguarding Staff should:
- Know what services are available and how to access help and advice
- Know how and where to make a referral via Adult Social Care
Responsibility of Managers:
- To ensure that the alleged victim is safe
- To ensure that any staff or volunteer who may have caused the harm is not in contact with service users and others who may be at risk
- To ensure that information is provided in a timely manner
- Operate safe recruitment practices and ensure reference checks are made
- Support staff who raise concerns
Monitoring
Safer Recruitment
All staff who work in a support-work capacity with our service users are subject to an enhanced disclosure check from the Disclosure and Barring Service.
For any team recruitment, an interview should be conducted, and two satisfactory references received, to assess an applicant’s suitability prior to an offer of employment or volunteering being made. On appointment staff and volunteers serve a probationary period for performance monitoring.
Volunteers within projects are recruited within the same processes as those for paid members of staff.
The named Safeguarding Adults Co-ordinator (SAC)- Alice Williams (Luminary CEO) will monitor any concerns and keep a record of safeguarding prompt logs compiled by staff. The SAC will report to the Charity Board on a quarterly basis.
G. Training
This policy and associated procedures are to be rolled out across Luminary through in- house training and in addition staff may access local authority Safeguarding Adult training.
16.1 Safeguarding Adults at Risk Policy & Procedure
Page Navigation
A. Introduction
The Safeguarding Adults at Risk Policy and Procedure represent Luminary’s commitment to safeguard adults at risk of harm.
The policy and procedure apply to ALL Luminary staff and volunteers. They represent Luminary’s commitment to:
- working together with other agencies to prevent and protect adults at risk of abuse
- empower and support people to make their own choices
- investigate actual or suspected abuse or neglect
- support adults and provide a service to adults at risk who are experiencing exploitation, abuse or neglect
B. Context
Unlike Child Protection, there is no statutory protection for, or definition of adults at risk of abuse.
There is a presumption that adults have the mental capacity to make informed decisions about their lives. If someone has been assessed as not having mental capacity, then decisions should be made in their best interests as set out in the Mental Capacity Act 2005.
Adults at risk should be given information, advice and support in a form they can understand and have their views included when decisions are being taken about their lives. All decisions taken about another person’s life should be timely, reasonable, justified, proportionate and ethical.
- All staff have a duty to report any concerns or suspicions that an adult at risk is being, or is at risk of being, abused.
- Actions to protect the adult from abuse should always be given a high priority by all organisations involved. Concerns or allegations should be reported without delay and given high priority.
- Luminary will work to safeguard adults at risk, making their dignity, safety and well-being a high priority.
- All staff have a duty to understand their role and responsibilities in regard to this policy and procedure.
- Every effort should be made to ensure that adults at risk are afforded appropriate protection under the law.
- As far as possible Luminary staff and volunteers must respect the rights of the person causing harm. If that person is also an adult at risk, they must receive support and their needs should be addressed.
- Luminary staff will work effectively with interagency working in order to provide the most effective means of safeguarding adults.
C. Definitions
'Adult At Risk'
‘Adult at risk’ means adults who need community care services because of mental or other disability, age or illness and who is, or may be, unable to take care of themselves against significant harm or exploitation.
- An adult at risk may therefore be a person who:
- is unable to look after their own wellbeing, property, rights or other interests
- misuses substances or alcohol
- has a learning disability
- has a physical disability and/or a sensory impairment
- has mental health needs including dementia or a personality disorder
- has been groomed, trafficked or exploited
- has a long term illness or condition
- is in need of care and support but is unable to demonstrate the capacity to make an informed decision about themselves
- is elderly and frail due to ill health, physical disability, or cognitive impairment
- Actions to protect the adult from abuse should always be given high priority. The dignity, safety and wellbeing of an individual should be a priority within any action taken.
- In the context of safeguarding adults, the extent to which the adult is at risk is related to how able they are to make and exercise their own informed choices free from duress, pressure or undue influence of any sort, and to protect themselves from abuse, neglect and exploitation. It is important to note that people with capacity can also still be ‘at risk’.
- It is always essential in safeguarding to consider whether the adult at risk is capable of giving informed consent. If they are, their consent to any course of action should be obtained. This may be in relation to whether they give their consent to:
- An activity that may be abusive – if consent to abuse or neglect was given under duress, for example, as a result of exploitation, pressure, fear, intimidation – this apparent consent should be. disregarded.
- A Safeguarding Adults investigation going ahead in response to a concern that has been raised. Where an adult at risk with capacity has made a decision that they do not want action to be taken and there are no public interest considerations, their wishes must be respected. The person should be given information and have the opportunity to consider all the risks and fully understand the likely consequences of their decision over the short and long term.
- If after discussion with the adult at risk who has mental capacity, they refuse any intervention, their wishes must be respected unless:
- there is a public interest – eg not acting will put other adults or children at risk
- there is a duty of care to intervene eg a crime has been, or will be, committed
- We recognise that there are often complex issues and factors that many of the individuals may have experienced throughout some point in their lives. Such factors should be taken into consideration when looking at who an adult at risk may be. Many of the women that we will encounter will have various experiences of being homeless, fleeing exploitation and/or trafficking, prostitution, suffering from low self esteem, self harm, substance misuse, learning difficulties, emotional wellbeing needs or mental health issues such as Borderline Personality Disorder.
- At all times Luminary will consider the welfare of the Adult at Risk to be of high importance. We are committed to achieving this by:
- Actively striving to promote the empowerment and wellbeing of adults at risk through respectful and responsive high quality service provision.
- Helping to prevent the physical, sexual, emotional or psychological, financial and discriminatory abuse and neglect of adults at risk and to report any such abuse that is discovered or suspected.
- Believing and promoting that all individuals have the right to be able to live their lives free from exploitation, fear, abuse, harm or degrading treatment. All individuals have the right to protection from any such mistreatment and harm.
- Believing and promoting that all individuals have the right to make choices and that their right to independence is actively encouraged. We acknowledge that such choices may at times involve an element of risk. We are committed to ensuring that any such risks are formally acknowledged and understood by all concerned, taking all reasonable measures to ensure risks are minimized wherever possible.
- Being committed to respecting equal opportunities, anti -discriminatory practise and diversity issues.
- All staff and volunteers are required not to share any private information or photos about the service users in any context.
- Ensuring that the law and statutory requirements which relate to adults at risk are known and put into practice.
- Safe recruitment, supervision and training for all those working with adults at risk within Luminary.
'Abuse'
‘Abuse’ is an emotive term and can be subject to interpretation, Luminary recognises that abuse can be “a violation of an individual’s human and civil rights by any other person or persons” (“No Secrets”, Department of Health 2000).
Abuse may be:
- A single or repeated act
- An act of neglect; lack of appropriate action taking place
- Multiple acts; an adult at risk may be neglected and also financially abused
'The Abuser'
It is important to recognise that the ‘abuser’ could be anyone, including friends, relatives, family members, other Service Users, professional paid staff, volunteers and persons unknown to the adult at risk. They may also themselves be an adult at risk.
'Exploitation'
Exploitation is exerting undue influence or forcing an adult at risk to perform services for the benefit of others.
'SIGNIFICANT HARM’
The Law Commissioner’s Green Paper ‘Who Decides’ 1997 builds on the concept introduced in the Children Act, 1989 and suggests:
"Harm should be taken to include not only ill treatment (including sexual abuse and forms of ill treatment that are not physical); but also the impairment of, or an unavoidable deterioration in physical or mental health, and the impairment of physical, intellectual, emotional social or behavioural development.”
'No Secrets' also uses the concept of significant harm. This refers to:
- Ill treatment
- Impairment of physical or mental health
- Impairment of physical, intellectual, emotional social or behavioural development
'No Secrets' puts forward the following factors to be taken into account when making an assessment of the seriousness of the risk to the person:
- Vulnerability of the person
- Nature and extent of the abuse or neglect
- Length of time the abuse or neglect has been occurring
- Impact of the alleged abuse
- Impact of the alleged abuse
- Risk of repeated or increasingly serious acts of abuse or neglect
- Risk that serious harm could result if no action is taken
- Illegality of the act
D. Categories of abuse: signs and possible indicators
Physical Abuse
Is the physical mistreatment or non-accidental injury of an adult. Some possible signs of abuse are detailed as follows:
- Slapping
- Kicking
- Punching
- Shaking
- Bruising
- Burns
- Cutting
Indicators of possible physical abuse may include, but are not limited to:
- An injury not fitting the explanation given
- Unexplained or unusual fractures in various stages of healing
- Bruises or burns in the shape of objects e.g. cigarette burns, belt buckles or water
- Bruising in well protected areas e.g. behind the ears, on face, inside of the upper arms or thighs, buttocks, breasts, genital or rectal area
- Lacerations
- Unlawful or inappropriate use of restraint and/or deprivation of liberty is physical abuse
Neglect or Acts of Omission
This includes deliberate refusal to meet basic needs. Signs of neglect can include individuals experiencing the following:
- Lack of choice, denied diversity
- Poor judgemental attitudes
- Derogatory terms used about the adult or their situation
- Failure to ensure appropriate privacy and dignity
- Poor surroundings e.g. neglect of repairs, inadequate heating
- Over or under protective practices
Behaviour that can lead to neglect includes:
- Ignoring medical or physical needs
- failing to allow access to appropriate health, social and educational services
Indicators of possible neglect or omission may include, but are not limited to:
- Loss of weight
- Clothing in a poor condition
- Failure to access appropriate health, educational services or social care
Unintentional neglect could result from a professional failing to meet the needs of the adult at risk because they do not understand the needs or may not know about the services available. It may also occur if the individuals are unaware of or do not understand the possible effect of the lack of action on the adult at risk.
Psychological or Emotional Abuse
This includes threats of harm, abandonment, isolation or humiliation which may result in the adult feeling in low mood, undervalued and perhaps unnecessarily dependant.
Some ways in which psychological/emotional abuse can take the form of are detailed below:
- Failure to respond adequately to emotional needs
- Failure to protect from the emotional abuse of others
- Harassment or humiliation (bullying)
- Intimidation
- Failure to meet cultural requirements
- Unreasonable demands
- Denial of choice
- Controlling or creating over dependence
- Verbal abuse
- Cyber bullying
- Mental distress
- Negating the right of the adult at risk to make choices and undermining their self esteem
- Isolation and over dependence
Indicators of possible psychological or emotional abuse may include, but are not limited to:
- Low self esteem
- Tearfulness
- Alteration in psychological state e.g. may appear to be withdrawn, agitated or anxious in general
- Aggressive or challenging behaviour
- Attention seeking behaviour
- Self harm
- Depression
- Insomnia
- Unexplained paranoia
Sexual Abuse
This is the involvement of any individual in any sexual activity to which they either cannot or have not given their consent or does not truly comprehend and so cannot give consent. Or where the other party is in a position of trust, power or authority and uses this to override or overcome lack of consent. Sexual abuse includes:
- Rape or sexual assault
- Inappropriate touching
- Fondling
- Sexual intercourse/buggery or attempted sexual intercourse/buggery
- Inflicting pornography on an individual
- Offensive or inappropriate language including sexual innuendos and sexual teasing
Indicators of possible sexual abuse may include, but are not limited to:
- Change in usual behaviour
- Overt sexual behaviour/language
- Bleeding or pain in the genital/rectal area
- Disturbed sleep pattern
- Torn, stained or bloody underwear
- Self‐harming
Financial or Material Abuse
This can be considered as unauthorised extraction of the adult at risk’s resources or their resources being withheld or misused by someone else and including:
- Misuse, embezzlement or theft of a person’s money, property or possessions
- Failing to account satisfactorily for the use of a person’s money, property or possessions, fraudulent use of money
- Extortion of money, property, possessions through theft
Indicators of possible financial or material abuse may include, but are not limited to:
- Lifestyle does not reflect known income
- Unexplained withdrawals from account
- Unexplained/sudden inability to pay service charge/bills etc.
Financial abuse is a crime.
Discriminatory Abuse
The inappropriate treatment of an adult at risk because of their age, gender, race, religion, cultural background, sexuality, disability, etc.
Discriminatory abuse exists when values, belief or culture result in a misuse of power that denies opportunity to some groups or individuals.
Discriminatory abuse links to all other forms of abuse and can include:
- Unequal treatment
- Inappropriate use of language:
- Racist remarks
- Sexist remarks
- Derogatory remarks or verbal abuse
- Comments about disability
- Bullying or other forms of harassment
- Deliberate exclusion
Indicators of possible discriminatory abuse may include, but are not limited to:
- Inappropriate remarks or comments
- Lack of respect shown to people
- Staff member/volunteer may avoid being with certain groups of people
Institutional Abuse
Institutional abuse is the mistreatment or abuse or neglect of an adult at risk by individuals within an organisational setting where routines, systems and practices result in denying, restricting or curtailing the dignity, privacy, choice, independence or fulfilment of an adult at risk.
A number of inquiries into institutional abuse have shown that abuse is most likely to occur when staff:
- Receive little support from management
- Are inadequately trained
- Are poorly supervised
- Receive inadequate guidance
E. Key Principles
The most important priority is to ensure that the most urgent medical and welfare requirements of the adult at risk are met.
Preserve any potential forensic opportunities, record verbatim the disclosure made by the adult at risk.
Any sexual activity that is not freely consented to is criminal and should be reported to the police immediately, before any internal investigation.
Sexual relationships, or inappropriate sexual behaviour between a member of staff (or volunteer) and a service user are always abusive and will lead to disciplinary hearings. This will be in addition to any criminal actions taken.
A sexual relationship between the service user and a care worker is a criminal offence under Sections 38-42 of the Sexual Offences Act 2003.
There may be Safeguarding Adults referrals that involve sexual innuendo or remarks that will not result in a criminal investigation; however, all Safeguarding Adults referrals that indicate any form of sexual abuse require a risk assessment, intelligence gathering and appropriate information sharing with relevant partners.
F. Responsibilities
Duty Of Care
All staff & volunteers of Luminary have a ‘duty of care’ towards those who use our services.
This means taking action whenever there is a concern of possible mistreatment or abuse to an adult at risk. The procedural guidelines supporting this Policy are intended to provide a good practice framework and to support staff; staff are therefore expected to comply with them.
Failure to report any concerns may be viewed as being negligent or agreeing with the abuse, which in some cases could lead to disciplinary action.
All staff should:
- Be aware that they must call the police/ambulance where appropriate
- Share their concerns with appropriate colleagues and seek advice and support unless they are implicated in the abuse
- Know they must inform the appropriate safeguarding officer as per escalation chart
- Know that they must make a clear, factual record of their concern and the action taken using the Safeguarding Incident Reporting Form
In addition, Support Workers & Safeguarding Staff should:
- Know what services are available and how to access help and advice
- Know how and where to make a referral via Adult Social Care
Responsibility of Managers:
- To ensure that the alleged victim is safe
- To ensure that any staff or volunteer who may have caused the harm is not in contact with service users and others who may be at risk
- To ensure that information is provided in a timely manner
- Operate safe recruitment practices and ensure reference checks are made
- Support staff who raise concerns
Monitoring
Safer Recruitment
All staff who work in a support-work capacity with our service users are subject to an enhanced disclosure check from the Disclosure and Barring Service.
For any team recruitment, an interview should be conducted, and two satisfactory references received, to assess an applicant’s suitability prior to an offer of employment or volunteering being made. On appointment staff and volunteers serve a probationary period for performance monitoring.
Volunteers within projects are recruited within the same processes as those for paid members of staff.
The named Safeguarding Adults Co-ordinator (SAC)- Alice Williams (Luminary CEO) will monitor any concerns and keep a record of safeguarding prompt logs compiled by staff. The SAC will report to the Charity Board on a quarterly basis.
G. Training
This policy and associated procedures are to be rolled out across Luminary through in- house training and in addition staff may access local authority Safeguarding Adult training.
16.1 Safeguarding Adults at Risk Policy & Procedure
Page Navigation
A. Introduction
The Safeguarding Adults at Risk Policy and Procedure represent Luminary’s commitment to safeguard adults at risk of harm.
The policy and procedure apply to ALL Luminary staff and volunteers. They represent Luminary’s commitment to:
- working together with other agencies to prevent and protect adults at risk of abuse
- empower and support people to make their own choices
- investigate actual or suspected abuse or neglect
- support adults and provide a service to adults at risk who are experiencing exploitation, abuse or neglect
B. Context
Unlike Child Protection, there is no statutory protection for, or definition of adults at risk of abuse.
There is a presumption that adults have the mental capacity to make informed decisions about their lives. If someone has been assessed as not having mental capacity, then decisions should be made in their best interests as set out in the Mental Capacity Act 2005.
Adults at risk should be given information, advice and support in a form they can understand and have their views included when decisions are being taken about their lives. All decisions taken about another person’s life should be timely, reasonable, justified, proportionate and ethical.
- All staff have a duty to report any concerns or suspicions that an adult at risk is being, or is at risk of being, abused.
- Actions to protect the adult from abuse should always be given a high priority by all organisations involved. Concerns or allegations should be reported without delay and given high priority.
- Luminary will work to safeguard adults at risk, making their dignity, safety and well-being a high priority.
- All staff have a duty to understand their role and responsibilities in regard to this policy and procedure.
- Every effort should be made to ensure that adults at risk are afforded appropriate protection under the law.
- As far as possible Luminary staff and volunteers must respect the rights of the person causing harm. If that person is also an adult at risk, they must receive support and their needs should be addressed.
- Luminary staff will work effectively with interagency working in order to provide the most effective means of safeguarding adults.
C. Definitions
'Adult At Risk'
‘Adult at risk’ means adults who need community care services because of mental or other disability, age or illness and who is, or may be, unable to take care of themselves against significant harm or exploitation.
- An adult at risk may therefore be a person who:
- is unable to look after their own wellbeing, property, rights or other interests
- misuses substances or alcohol
- has a learning disability
- has a physical disability and/or a sensory impairment
- has mental health needs including dementia or a personality disorder
- has been groomed, trafficked or exploited
- has a long term illness or condition
- is in need of care and support but is unable to demonstrate the capacity to make an informed decision about themselves
- is elderly and frail due to ill health, physical disability, or cognitive impairment
- Actions to protect the adult from abuse should always be given high priority. The dignity, safety and wellbeing of an individual should be a priority within any action taken.
- In the context of safeguarding adults, the extent to which the adult is at risk is related to how able they are to make and exercise their own informed choices free from duress, pressure or undue influence of any sort, and to protect themselves from abuse, neglect and exploitation. It is important to note that people with capacity can also still be ‘at risk’.
- It is always essential in safeguarding to consider whether the adult at risk is capable of giving informed consent. If they are, their consent to any course of action should be obtained. This may be in relation to whether they give their consent to:
- An activity that may be abusive – if consent to abuse or neglect was given under duress, for example, as a result of exploitation, pressure, fear, intimidation – this apparent consent should be. disregarded.
- A Safeguarding Adults investigation going ahead in response to a concern that has been raised. Where an adult at risk with capacity has made a decision that they do not want action to be taken and there are no public interest considerations, their wishes must be respected. The person should be given information and have the opportunity to consider all the risks and fully understand the likely consequences of their decision over the short and long term.
- If after discussion with the adult at risk who has mental capacity, they refuse any intervention, their wishes must be respected unless:
- there is a public interest – eg not acting will put other adults or children at risk
- there is a duty of care to intervene eg a crime has been, or will be, committed
- We recognise that there are often complex issues and factors that many of the individuals may have experienced throughout some point in their lives. Such factors should be taken into consideration when looking at who an adult at risk may be. Many of the women that we will encounter will have various experiences of being homeless, fleeing exploitation and/or trafficking, prostitution, suffering from low self esteem, self harm, substance misuse, learning difficulties, emotional wellbeing needs or mental health issues such as Borderline Personality Disorder.
- At all times Luminary will consider the welfare of the Adult at Risk to be of high importance. We are committed to achieving this by:
- Actively striving to promote the empowerment and wellbeing of adults at risk through respectful and responsive high quality service provision.
- Helping to prevent the physical, sexual, emotional or psychological, financial and discriminatory abuse and neglect of adults at risk and to report any such abuse that is discovered or suspected.
- Believing and promoting that all individuals have the right to be able to live their lives free from exploitation, fear, abuse, harm or degrading treatment. All individuals have the right to protection from any such mistreatment and harm.
- Believing and promoting that all individuals have the right to make choices and that their right to independence is actively encouraged. We acknowledge that such choices may at times involve an element of risk. We are committed to ensuring that any such risks are formally acknowledged and understood by all concerned, taking all reasonable measures to ensure risks are minimized wherever possible.
- Being committed to respecting equal opportunities, anti -discriminatory practise and diversity issues.
- All staff and volunteers are required not to share any private information or photos about the service users in any context.
- Ensuring that the law and statutory requirements which relate to adults at risk are known and put into practice.
- Safe recruitment, supervision and training for all those working with adults at risk within Luminary.
'Abuse'
‘Abuse’ is an emotive term and can be subject to interpretation, Luminary recognises that abuse can be “a violation of an individual’s human and civil rights by any other person or persons” (“No Secrets”, Department of Health 2000).
Abuse may be:
- A single or repeated act
- An act of neglect; lack of appropriate action taking place
- Multiple acts; an adult at risk may be neglected and also financially abused
'The Abuser'
It is important to recognise that the ‘abuser’ could be anyone, including friends, relatives, family members, other Service Users, professional paid staff, volunteers and persons unknown to the adult at risk. They may also themselves be an adult at risk.
'Exploitation'
Exploitation is exerting undue influence or forcing an adult at risk to perform services for the benefit of others.
'SIGNIFICANT HARM’
The Law Commissioner’s Green Paper ‘Who Decides’ 1997 builds on the concept introduced in the Children Act, 1989 and suggests:
"Harm should be taken to include not only ill treatment (including sexual abuse and forms of ill treatment that are not physical); but also the impairment of, or an unavoidable deterioration in physical or mental health, and the impairment of physical, intellectual, emotional social or behavioural development.”
'No Secrets' also uses the concept of significant harm. This refers to:
- Ill treatment
- Impairment of physical or mental health
- Impairment of physical, intellectual, emotional social or behavioural development
'No Secrets' puts forward the following factors to be taken into account when making an assessment of the seriousness of the risk to the person:
- Vulnerability of the person
- Nature and extent of the abuse or neglect
- Length of time the abuse or neglect has been occurring
- Impact of the alleged abuse
- Impact of the alleged abuse
- Risk of repeated or increasingly serious acts of abuse or neglect
- Risk that serious harm could result if no action is taken
- Illegality of the act
D. Categories of abuse: signs and possible indicators
Physical Abuse
Is the physical mistreatment or non-accidental injury of an adult. Some possible signs of abuse are detailed as follows:
- Slapping
- Kicking
- Punching
- Shaking
- Bruising
- Burns
- Cutting
Indicators of possible physical abuse may include, but are not limited to:
- An injury not fitting the explanation given
- Unexplained or unusual fractures in various stages of healing
- Bruises or burns in the shape of objects e.g. cigarette burns, belt buckles or water
- Bruising in well protected areas e.g. behind the ears, on face, inside of the upper arms or thighs, buttocks, breasts, genital or rectal area
- Lacerations
- Unlawful or inappropriate use of restraint and/or deprivation of liberty is physical abuse
Neglect or Acts of Omission
This includes deliberate refusal to meet basic needs. Signs of neglect can include individuals experiencing the following:
- Lack of choice, denied diversity
- Poor judgemental attitudes
- Derogatory terms used about the adult or their situation
- Failure to ensure appropriate privacy and dignity
- Poor surroundings e.g. neglect of repairs, inadequate heating
- Over or under protective practices
Behaviour that can lead to neglect includes:
- Ignoring medical or physical needs
- failing to allow access to appropriate health, social and educational services
Indicators of possible neglect or omission may include, but are not limited to:
- Loss of weight
- Clothing in a poor condition
- Failure to access appropriate health, educational services or social care
Unintentional neglect could result from a professional failing to meet the needs of the adult at risk because they do not understand the needs or may not know about the services available. It may also occur if the individuals are unaware of or do not understand the possible effect of the lack of action on the adult at risk.
Psychological or Emotional Abuse
This includes threats of harm, abandonment, isolation or humiliation which may result in the adult feeling in low mood, undervalued and perhaps unnecessarily dependant.
Some ways in which psychological/emotional abuse can take the form of are detailed below:
- Failure to respond adequately to emotional needs
- Failure to protect from the emotional abuse of others
- Harassment or humiliation (bullying)
- Intimidation
- Failure to meet cultural requirements
- Unreasonable demands
- Denial of choice
- Controlling or creating over dependence
- Verbal abuse
- Cyber bullying
- Mental distress
- Negating the right of the adult at risk to make choices and undermining their self esteem
- Isolation and over dependence
Indicators of possible psychological or emotional abuse may include, but are not limited to:
- Low self esteem
- Tearfulness
- Alteration in psychological state e.g. may appear to be withdrawn, agitated or anxious in general
- Aggressive or challenging behaviour
- Attention seeking behaviour
- Self harm
- Depression
- Insomnia
- Unexplained paranoia
Sexual Abuse
This is the involvement of any individual in any sexual activity to which they either cannot or have not given their consent or does not truly comprehend and so cannot give consent. Or where the other party is in a position of trust, power or authority and uses this to override or overcome lack of consent. Sexual abuse includes:
- Rape or sexual assault
- Inappropriate touching
- Fondling
- Sexual intercourse/buggery or attempted sexual intercourse/buggery
- Inflicting pornography on an individual
- Offensive or inappropriate language including sexual innuendos and sexual teasing
Indicators of possible sexual abuse may include, but are not limited to:
- Change in usual behaviour
- Overt sexual behaviour/language
- Bleeding or pain in the genital/rectal area
- Disturbed sleep pattern
- Torn, stained or bloody underwear
- Self‐harming
Financial or Material Abuse
This can be considered as unauthorised extraction of the adult at risk’s resources or their resources being withheld or misused by someone else and including:
- Misuse, embezzlement or theft of a person’s money, property or possessions
- Failing to account satisfactorily for the use of a person’s money, property or possessions, fraudulent use of money
- Extortion of money, property, possessions through theft
Indicators of possible financial or material abuse may include, but are not limited to:
- Lifestyle does not reflect known income
- Unexplained withdrawals from account
- Unexplained/sudden inability to pay service charge/bills etc.
Financial abuse is a crime.
Discriminatory Abuse
The inappropriate treatment of an adult at risk because of their age, gender, race, religion, cultural background, sexuality, disability, etc.
Discriminatory abuse exists when values, belief or culture result in a misuse of power that denies opportunity to some groups or individuals.
Discriminatory abuse links to all other forms of abuse and can include:
- Unequal treatment
- Inappropriate use of language:
- Racist remarks
- Sexist remarks
- Derogatory remarks or verbal abuse
- Comments about disability
- Bullying or other forms of harassment
- Deliberate exclusion
Indicators of possible discriminatory abuse may include, but are not limited to:
- Inappropriate remarks or comments
- Lack of respect shown to people
- Staff member/volunteer may avoid being with certain groups of people
Institutional Abuse
Institutional abuse is the mistreatment or abuse or neglect of an adult at risk by individuals within an organisational setting where routines, systems and practices result in denying, restricting or curtailing the dignity, privacy, choice, independence or fulfilment of an adult at risk.
A number of inquiries into institutional abuse have shown that abuse is most likely to occur when staff:
- Receive little support from management
- Are inadequately trained
- Are poorly supervised
- Receive inadequate guidance
E. Key Principles
The most important priority is to ensure that the most urgent medical and welfare requirements of the adult at risk are met.
Preserve any potential forensic opportunities, record verbatim the disclosure made by the adult at risk.
Any sexual activity that is not freely consented to is criminal and should be reported to the police immediately, before any internal investigation.
Sexual relationships, or inappropriate sexual behaviour between a member of staff (or volunteer) and a service user are always abusive and will lead to disciplinary hearings. This will be in addition to any criminal actions taken.
A sexual relationship between the service user and a care worker is a criminal offence under Sections 38-42 of the Sexual Offences Act 2003.
There may be Safeguarding Adults referrals that involve sexual innuendo or remarks that will not result in a criminal investigation; however, all Safeguarding Adults referrals that indicate any form of sexual abuse require a risk assessment, intelligence gathering and appropriate information sharing with relevant partners.
F. Responsibilities
Duty Of Care
All staff & volunteers of Luminary have a ‘duty of care’ towards those who use our services.
This means taking action whenever there is a concern of possible mistreatment or abuse to an adult at risk. The procedural guidelines supporting this Policy are intended to provide a good practice framework and to support staff; staff are therefore expected to comply with them.
Failure to report any concerns may be viewed as being negligent or agreeing with the abuse, which in some cases could lead to disciplinary action.
All staff should:
- Be aware that they must call the police/ambulance where appropriate
- Share their concerns with appropriate colleagues and seek advice and support unless they are implicated in the abuse
- Know they must inform the appropriate safeguarding officer as per escalation chart
- Know that they must make a clear, factual record of their concern and the action taken using the Safeguarding Incident Reporting Form
In addition, Support Workers & Safeguarding Staff should:
- Know what services are available and how to access help and advice
- Know how and where to make a referral via Adult Social Care
Responsibility of Managers:
- To ensure that the alleged victim is safe
- To ensure that any staff or volunteer who may have caused the harm is not in contact with service users and others who may be at risk
- To ensure that information is provided in a timely manner
- Operate safe recruitment practices and ensure reference checks are made
- Support staff who raise concerns
Monitoring
Safer Recruitment
All staff who work in a support-work capacity with our service users are subject to an enhanced disclosure check from the Disclosure and Barring Service.
For any team recruitment, an interview should be conducted, and two satisfactory references received, to assess an applicant’s suitability prior to an offer of employment or volunteering being made. On appointment staff and volunteers serve a probationary period for performance monitoring.
Volunteers within projects are recruited within the same processes as those for paid members of staff.
The named Safeguarding Adults Co-ordinator (SAC)- Alice Williams (Luminary CEO) will monitor any concerns and keep a record of safeguarding prompt logs compiled by staff. The SAC will report to the Charity Board on a quarterly basis.
G. Training
This policy and associated procedures are to be rolled out across Luminary through in- house training and in addition staff may access local authority Safeguarding Adult training.
-
ABOUT US
16.1 Safeguarding Adults at Risk Policy & Procedure
Page Navigation
A. Introduction
The Safeguarding Adults at Risk Policy and Procedure represent Luminary’s commitment to safeguard adults at risk of harm.
The policy and procedure apply to ALL Luminary staff and volunteers. They represent Luminary’s commitment to:
- working together with other agencies to prevent and protect adults at risk of abuse
- empower and support people to make their own choices
- investigate actual or suspected abuse or neglect
- support adults and provide a service to adults at risk who are experiencing exploitation, abuse or neglect
B. Context
Unlike Child Protection, there is no statutory protection for, or definition of adults at risk of abuse.
There is a presumption that adults have the mental capacity to make informed decisions about their lives. If someone has been assessed as not having mental capacity, then decisions should be made in their best interests as set out in the Mental Capacity Act 2005.
Adults at risk should be given information, advice and support in a form they can understand and have their views included when decisions are being taken about their lives. All decisions taken about another person’s life should be timely, reasonable, justified, proportionate and ethical.
- All staff have a duty to report any concerns or suspicions that an adult at risk is being, or is at risk of being, abused.
- Actions to protect the adult from abuse should always be given a high priority by all organisations involved. Concerns or allegations should be reported without delay and given high priority.
- Luminary will work to safeguard adults at risk, making their dignity, safety and well-being a high priority.
- All staff have a duty to understand their role and responsibilities in regard to this policy and procedure.
- Every effort should be made to ensure that adults at risk are afforded appropriate protection under the law.
- As far as possible Luminary staff and volunteers must respect the rights of the person causing harm. If that person is also an adult at risk, they must receive support and their needs should be addressed.
- Luminary staff will work effectively with interagency working in order to provide the most effective means of safeguarding adults.
C. Definitions
'Adult At Risk'
‘Adult at risk’ means adults who need community care services because of mental or other disability, age or illness and who is, or may be, unable to take care of themselves against significant harm or exploitation.
- An adult at risk may therefore be a person who:
- is unable to look after their own wellbeing, property, rights or other interests
- misuses substances or alcohol
- has a learning disability
- has a physical disability and/or a sensory impairment
- has mental health needs including dementia or a personality disorder
- has been groomed, trafficked or exploited
- has a long term illness or condition
- is in need of care and support but is unable to demonstrate the capacity to make an informed decision about themselves
- is elderly and frail due to ill health, physical disability, or cognitive impairment
- Actions to protect the adult from abuse should always be given high priority. The dignity, safety and wellbeing of an individual should be a priority within any action taken.
- In the context of safeguarding adults, the extent to which the adult is at risk is related to how able they are to make and exercise their own informed choices free from duress, pressure or undue influence of any sort, and to protect themselves from abuse, neglect and exploitation. It is important to note that people with capacity can also still be ‘at risk’.
- It is always essential in safeguarding to consider whether the adult at risk is capable of giving informed consent. If they are, their consent to any course of action should be obtained. This may be in relation to whether they give their consent to:
- An activity that may be abusive – if consent to abuse or neglect was given under duress, for example, as a result of exploitation, pressure, fear, intimidation – this apparent consent should be. disregarded.
- A Safeguarding Adults investigation going ahead in response to a concern that has been raised. Where an adult at risk with capacity has made a decision that they do not want action to be taken and there are no public interest considerations, their wishes must be respected. The person should be given information and have the opportunity to consider all the risks and fully understand the likely consequences of their decision over the short and long term.
- If after discussion with the adult at risk who has mental capacity, they refuse any intervention, their wishes must be respected unless:
- there is a public interest – eg not acting will put other adults or children at risk
- there is a duty of care to intervene eg a crime has been, or will be, committed
- We recognise that there are often complex issues and factors that many of the individuals may have experienced throughout some point in their lives. Such factors should be taken into consideration when looking at who an adult at risk may be. Many of the women that we will encounter will have various experiences of being homeless, fleeing exploitation and/or trafficking, prostitution, suffering from low self esteem, self harm, substance misuse, learning difficulties, emotional wellbeing needs or mental health issues such as Borderline Personality Disorder.
- At all times Luminary will consider the welfare of the Adult at Risk to be of high importance. We are committed to achieving this by:
- Actively striving to promote the empowerment and wellbeing of adults at risk through respectful and responsive high quality service provision.
- Helping to prevent the physical, sexual, emotional or psychological, financial and discriminatory abuse and neglect of adults at risk and to report any such abuse that is discovered or suspected.
- Believing and promoting that all individuals have the right to be able to live their lives free from exploitation, fear, abuse, harm or degrading treatment. All individuals have the right to protection from any such mistreatment and harm.
- Believing and promoting that all individuals have the right to make choices and that their right to independence is actively encouraged. We acknowledge that such choices may at times involve an element of risk. We are committed to ensuring that any such risks are formally acknowledged and understood by all concerned, taking all reasonable measures to ensure risks are minimized wherever possible.
- Being committed to respecting equal opportunities, anti -discriminatory practise and diversity issues.
- All staff and volunteers are required not to share any private information or photos about the service users in any context.
- Ensuring that the law and statutory requirements which relate to adults at risk are known and put into practice.
- Safe recruitment, supervision and training for all those working with adults at risk within Luminary.
'Abuse'
‘Abuse’ is an emotive term and can be subject to interpretation, Luminary recognises that abuse can be “a violation of an individual’s human and civil rights by any other person or persons” (“No Secrets”, Department of Health 2000).
Abuse may be:
- A single or repeated act
- An act of neglect; lack of appropriate action taking place
- Multiple acts; an adult at risk may be neglected and also financially abused
'The Abuser'
It is important to recognise that the ‘abuser’ could be anyone, including friends, relatives, family members, other Service Users, professional paid staff, volunteers and persons unknown to the adult at risk. They may also themselves be an adult at risk.
'Exploitation'
Exploitation is exerting undue influence or forcing an adult at risk to perform services for the benefit of others.
'SIGNIFICANT HARM’
The Law Commissioner’s Green Paper ‘Who Decides’ 1997 builds on the concept introduced in the Children Act, 1989 and suggests:
"Harm should be taken to include not only ill treatment (including sexual abuse and forms of ill treatment that are not physical); but also the impairment of, or an unavoidable deterioration in physical or mental health, and the impairment of physical, intellectual, emotional social or behavioural development.”
'No Secrets' also uses the concept of significant harm. This refers to:
- Ill treatment
- Impairment of physical or mental health
- Impairment of physical, intellectual, emotional social or behavioural development
'No Secrets' puts forward the following factors to be taken into account when making an assessment of the seriousness of the risk to the person:
- Vulnerability of the person
- Nature and extent of the abuse or neglect
- Length of time the abuse or neglect has been occurring
- Impact of the alleged abuse
- Impact of the alleged abuse
- Risk of repeated or increasingly serious acts of abuse or neglect
- Risk that serious harm could result if no action is taken
- Illegality of the act
D. Categories of abuse: signs and possible indicators
Physical Abuse
Is the physical mistreatment or non-accidental injury of an adult. Some possible signs of abuse are detailed as follows:
- Slapping
- Kicking
- Punching
- Shaking
- Bruising
- Burns
- Cutting
Indicators of possible physical abuse may include, but are not limited to:
- An injury not fitting the explanation given
- Unexplained or unusual fractures in various stages of healing
- Bruises or burns in the shape of objects e.g. cigarette burns, belt buckles or water
- Bruising in well protected areas e.g. behind the ears, on face, inside of the upper arms or thighs, buttocks, breasts, genital or rectal area
- Lacerations
- Unlawful or inappropriate use of restraint and/or deprivation of liberty is physical abuse
Neglect or Acts of Omission
This includes deliberate refusal to meet basic needs. Signs of neglect can include individuals experiencing the following:
- Lack of choice, denied diversity
- Poor judgemental attitudes
- Derogatory terms used about the adult or their situation
- Failure to ensure appropriate privacy and dignity
- Poor surroundings e.g. neglect of repairs, inadequate heating
- Over or under protective practices
Behaviour that can lead to neglect includes:
- Ignoring medical or physical needs
- failing to allow access to appropriate health, social and educational services
Indicators of possible neglect or omission may include, but are not limited to:
- Loss of weight
- Clothing in a poor condition
- Failure to access appropriate health, educational services or social care
Unintentional neglect could result from a professional failing to meet the needs of the adult at risk because they do not understand the needs or may not know about the services available. It may also occur if the individuals are unaware of or do not understand the possible effect of the lack of action on the adult at risk.
Psychological or Emotional Abuse
This includes threats of harm, abandonment, isolation or humiliation which may result in the adult feeling in low mood, undervalued and perhaps unnecessarily dependant.
Some ways in which psychological/emotional abuse can take the form of are detailed below:
- Failure to respond adequately to emotional needs
- Failure to protect from the emotional abuse of others
- Harassment or humiliation (bullying)
- Intimidation
- Failure to meet cultural requirements
- Unreasonable demands
- Denial of choice
- Controlling or creating over dependence
- Verbal abuse
- Cyber bullying
- Mental distress
- Negating the right of the adult at risk to make choices and undermining their self esteem
- Isolation and over dependence
Indicators of possible psychological or emotional abuse may include, but are not limited to:
- Low self esteem
- Tearfulness
- Alteration in psychological state e.g. may appear to be withdrawn, agitated or anxious in general
- Aggressive or challenging behaviour
- Attention seeking behaviour
- Self harm
- Depression
- Insomnia
- Unexplained paranoia
Sexual Abuse
This is the involvement of any individual in any sexual activity to which they either cannot or have not given their consent or does not truly comprehend and so cannot give consent. Or where the other party is in a position of trust, power or authority and uses this to override or overcome lack of consent. Sexual abuse includes:
- Rape or sexual assault
- Inappropriate touching
- Fondling
- Sexual intercourse/buggery or attempted sexual intercourse/buggery
- Inflicting pornography on an individual
- Offensive or inappropriate language including sexual innuendos and sexual teasing
Indicators of possible sexual abuse may include, but are not limited to:
- Change in usual behaviour
- Overt sexual behaviour/language
- Bleeding or pain in the genital/rectal area
- Disturbed sleep pattern
- Torn, stained or bloody underwear
- Self‐harming
Financial or Material Abuse
This can be considered as unauthorised extraction of the adult at risk’s resources or their resources being withheld or misused by someone else and including:
- Misuse, embezzlement or theft of a person’s money, property or possessions
- Failing to account satisfactorily for the use of a person’s money, property or possessions, fraudulent use of money
- Extortion of money, property, possessions through theft
Indicators of possible financial or material abuse may include, but are not limited to:
- Lifestyle does not reflect known income
- Unexplained withdrawals from account
- Unexplained/sudden inability to pay service charge/bills etc.
Financial abuse is a crime.
Discriminatory Abuse
The inappropriate treatment of an adult at risk because of their age, gender, race, religion, cultural background, sexuality, disability, etc.
Discriminatory abuse exists when values, belief or culture result in a misuse of power that denies opportunity to some groups or individuals.
Discriminatory abuse links to all other forms of abuse and can include:
- Unequal treatment
- Inappropriate use of language:
- Racist remarks
- Sexist remarks
- Derogatory remarks or verbal abuse
- Comments about disability
- Bullying or other forms of harassment
- Deliberate exclusion
Indicators of possible discriminatory abuse may include, but are not limited to:
- Inappropriate remarks or comments
- Lack of respect shown to people
- Staff member/volunteer may avoid being with certain groups of people
Institutional Abuse
Institutional abuse is the mistreatment or abuse or neglect of an adult at risk by individuals within an organisational setting where routines, systems and practices result in denying, restricting or curtailing the dignity, privacy, choice, independence or fulfilment of an adult at risk.
A number of inquiries into institutional abuse have shown that abuse is most likely to occur when staff:
- Receive little support from management
- Are inadequately trained
- Are poorly supervised
- Receive inadequate guidance
E. Key Principles
The most important priority is to ensure that the most urgent medical and welfare requirements of the adult at risk are met.
Preserve any potential forensic opportunities, record verbatim the disclosure made by the adult at risk.
Any sexual activity that is not freely consented to is criminal and should be reported to the police immediately, before any internal investigation.
Sexual relationships, or inappropriate sexual behaviour between a member of staff (or volunteer) and a service user are always abusive and will lead to disciplinary hearings. This will be in addition to any criminal actions taken.
A sexual relationship between the service user and a care worker is a criminal offence under Sections 38-42 of the Sexual Offences Act 2003.
There may be Safeguarding Adults referrals that involve sexual innuendo or remarks that will not result in a criminal investigation; however, all Safeguarding Adults referrals that indicate any form of sexual abuse require a risk assessment, intelligence gathering and appropriate information sharing with relevant partners.
F. Responsibilities
Duty Of Care
All staff & volunteers of Luminary have a ‘duty of care’ towards those who use our services.
This means taking action whenever there is a concern of possible mistreatment or abuse to an adult at risk. The procedural guidelines supporting this Policy are intended to provide a good practice framework and to support staff; staff are therefore expected to comply with them.
Failure to report any concerns may be viewed as being negligent or agreeing with the abuse, which in some cases could lead to disciplinary action.
All staff should:
- Be aware that they must call the police/ambulance where appropriate
- Share their concerns with appropriate colleagues and seek advice and support unless they are implicated in the abuse
- Know they must inform the appropriate safeguarding officer as per escalation chart
- Know that they must make a clear, factual record of their concern and the action taken using the Safeguarding Incident Reporting Form
In addition, Support Workers & Safeguarding Staff should:
- Know what services are available and how to access help and advice
- Know how and where to make a referral via Adult Social Care
Responsibility of Managers:
- To ensure that the alleged victim is safe
- To ensure that any staff or volunteer who may have caused the harm is not in contact with service users and others who may be at risk
- To ensure that information is provided in a timely manner
- Operate safe recruitment practices and ensure reference checks are made
- Support staff who raise concerns
Monitoring
Safer Recruitment
All staff who work in a support-work capacity with our service users are subject to an enhanced disclosure check from the Disclosure and Barring Service.
For any team recruitment, an interview should be conducted, and two satisfactory references received, to assess an applicant’s suitability prior to an offer of employment or volunteering being made. On appointment staff and volunteers serve a probationary period for performance monitoring.
Volunteers within projects are recruited within the same processes as those for paid members of staff.
The named Safeguarding Adults Co-ordinator (SAC)- Alice Williams (Luminary CEO) will monitor any concerns and keep a record of safeguarding prompt logs compiled by staff. The SAC will report to the Charity Board on a quarterly basis.
G. Training
This policy and associated procedures are to be rolled out across Luminary through in- house training and in addition staff may access local authority Safeguarding Adult training.
16.1 Safeguarding Adults at Risk Policy & Procedure
Page Navigation
A. Introduction
The Safeguarding Adults at Risk Policy and Procedure represent Luminary’s commitment to safeguard adults at risk of harm.
The policy and procedure apply to ALL Luminary staff and volunteers. They represent Luminary’s commitment to:
- working together with other agencies to prevent and protect adults at risk of abuse
- empower and support people to make their own choices
- investigate actual or suspected abuse or neglect
- support adults and provide a service to adults at risk who are experiencing exploitation, abuse or neglect
B. Context
Unlike Child Protection, there is no statutory protection for, or definition of adults at risk of abuse.
There is a presumption that adults have the mental capacity to make informed decisions about their lives. If someone has been assessed as not having mental capacity, then decisions should be made in their best interests as set out in the Mental Capacity Act 2005.
Adults at risk should be given information, advice and support in a form they can understand and have their views included when decisions are being taken about their lives. All decisions taken about another person’s life should be timely, reasonable, justified, proportionate and ethical.
- All staff have a duty to report any concerns or suspicions that an adult at risk is being, or is at risk of being, abused.
- Actions to protect the adult from abuse should always be given a high priority by all organisations involved. Concerns or allegations should be reported without delay and given high priority.
- Luminary will work to safeguard adults at risk, making their dignity, safety and well-being a high priority.
- All staff have a duty to understand their role and responsibilities in regard to this policy and procedure.
- Every effort should be made to ensure that adults at risk are afforded appropriate protection under the law.
- As far as possible Luminary staff and volunteers must respect the rights of the person causing harm. If that person is also an adult at risk, they must receive support and their needs should be addressed.
- Luminary staff will work effectively with interagency working in order to provide the most effective means of safeguarding adults.
C. Definitions
'Adult At Risk'
‘Adult at risk’ means adults who need community care services because of mental or other disability, age or illness and who is, or may be, unable to take care of themselves against significant harm or exploitation.
- An adult at risk may therefore be a person who:
- is unable to look after their own wellbeing, property, rights or other interests
- misuses substances or alcohol
- has a learning disability
- has a physical disability and/or a sensory impairment
- has mental health needs including dementia or a personality disorder
- has been groomed, trafficked or exploited
- has a long term illness or condition
- is in need of care and support but is unable to demonstrate the capacity to make an informed decision about themselves
- is elderly and frail due to ill health, physical disability, or cognitive impairment
- Actions to protect the adult from abuse should always be given high priority. The dignity, safety and wellbeing of an individual should be a priority within any action taken.
- In the context of safeguarding adults, the extent to which the adult is at risk is related to how able they are to make and exercise their own informed choices free from duress, pressure or undue influence of any sort, and to protect themselves from abuse, neglect and exploitation. It is important to note that people with capacity can also still be ‘at risk’.
- It is always essential in safeguarding to consider whether the adult at risk is capable of giving informed consent. If they are, their consent to any course of action should be obtained. This may be in relation to whether they give their consent to:
- An activity that may be abusive – if consent to abuse or neglect was given under duress, for example, as a result of exploitation, pressure, fear, intimidation – this apparent consent should be. disregarded.
- A Safeguarding Adults investigation going ahead in response to a concern that has been raised. Where an adult at risk with capacity has made a decision that they do not want action to be taken and there are no public interest considerations, their wishes must be respected. The person should be given information and have the opportunity to consider all the risks and fully understand the likely consequences of their decision over the short and long term.
- If after discussion with the adult at risk who has mental capacity, they refuse any intervention, their wishes must be respected unless:
- there is a public interest – eg not acting will put other adults or children at risk
- there is a duty of care to intervene eg a crime has been, or will be, committed
- We recognise that there are often complex issues and factors that many of the individuals may have experienced throughout some point in their lives. Such factors should be taken into consideration when looking at who an adult at risk may be. Many of the women that we will encounter will have various experiences of being homeless, fleeing exploitation and/or trafficking, prostitution, suffering from low self esteem, self harm, substance misuse, learning difficulties, emotional wellbeing needs or mental health issues such as Borderline Personality Disorder.
- At all times Luminary will consider the welfare of the Adult at Risk to be of high importance. We are committed to achieving this by:
- Actively striving to promote the empowerment and wellbeing of adults at risk through respectful and responsive high quality service provision.
- Helping to prevent the physical, sexual, emotional or psychological, financial and discriminatory abuse and neglect of adults at risk and to report any such abuse that is discovered or suspected.
- Believing and promoting that all individuals have the right to be able to live their lives free from exploitation, fear, abuse, harm or degrading treatment. All individuals have the right to protection from any such mistreatment and harm.
- Believing and promoting that all individuals have the right to make choices and that their right to independence is actively encouraged. We acknowledge that such choices may at times involve an element of risk. We are committed to ensuring that any such risks are formally acknowledged and understood by all concerned, taking all reasonable measures to ensure risks are minimized wherever possible.
- Being committed to respecting equal opportunities, anti -discriminatory practise and diversity issues.
- All staff and volunteers are required not to share any private information or photos about the service users in any context.
- Ensuring that the law and statutory requirements which relate to adults at risk are known and put into practice.
- Safe recruitment, supervision and training for all those working with adults at risk within Luminary.
'Abuse'
‘Abuse’ is an emotive term and can be subject to interpretation, Luminary recognises that abuse can be “a violation of an individual’s human and civil rights by any other person or persons” (“No Secrets”, Department of Health 2000).
Abuse may be:
- A single or repeated act
- An act of neglect; lack of appropriate action taking place
- Multiple acts; an adult at risk may be neglected and also financially abused
'The Abuser'
It is important to recognise that the ‘abuser’ could be anyone, including friends, relatives, family members, other Service Users, professional paid staff, volunteers and persons unknown to the adult at risk. They may also themselves be an adult at risk.
'Exploitation'
Exploitation is exerting undue influence or forcing an adult at risk to perform services for the benefit of others.
'SIGNIFICANT HARM’
The Law Commissioner’s Green Paper ‘Who Decides’ 1997 builds on the concept introduced in the Children Act, 1989 and suggests:
"Harm should be taken to include not only ill treatment (including sexual abuse and forms of ill treatment that are not physical); but also the impairment of, or an unavoidable deterioration in physical or mental health, and the impairment of physical, intellectual, emotional social or behavioural development.”
'No Secrets' also uses the concept of significant harm. This refers to:
- Ill treatment
- Impairment of physical or mental health
- Impairment of physical, intellectual, emotional social or behavioural development
'No Secrets' puts forward the following factors to be taken into account when making an assessment of the seriousness of the risk to the person:
- Vulnerability of the person
- Nature and extent of the abuse or neglect
- Length of time the abuse or neglect has been occurring
- Impact of the alleged abuse
- Impact of the alleged abuse
- Risk of repeated or increasingly serious acts of abuse or neglect
- Risk that serious harm could result if no action is taken
- Illegality of the act
D. Categories of abuse: signs and possible indicators
Physical Abuse
Is the physical mistreatment or non-accidental injury of an adult. Some possible signs of abuse are detailed as follows:
- Slapping
- Kicking
- Punching
- Shaking
- Bruising
- Burns
- Cutting
Indicators of possible physical abuse may include, but are not limited to:
- An injury not fitting the explanation given
- Unexplained or unusual fractures in various stages of healing
- Bruises or burns in the shape of objects e.g. cigarette burns, belt buckles or water
- Bruising in well protected areas e.g. behind the ears, on face, inside of the upper arms or thighs, buttocks, breasts, genital or rectal area
- Lacerations
- Unlawful or inappropriate use of restraint and/or deprivation of liberty is physical abuse
Neglect or Acts of Omission
This includes deliberate refusal to meet basic needs. Signs of neglect can include individuals experiencing the following:
- Lack of choice, denied diversity
- Poor judgemental attitudes
- Derogatory terms used about the adult or their situation
- Failure to ensure appropriate privacy and dignity
- Poor surroundings e.g. neglect of repairs, inadequate heating
- Over or under protective practices
Behaviour that can lead to neglect includes:
- Ignoring medical or physical needs
- failing to allow access to appropriate health, social and educational services
Indicators of possible neglect or omission may include, but are not limited to:
- Loss of weight
- Clothing in a poor condition
- Failure to access appropriate health, educational services or social care
Unintentional neglect could result from a professional failing to meet the needs of the adult at risk because they do not understand the needs or may not know about the services available. It may also occur if the individuals are unaware of or do not understand the possible effect of the lack of action on the adult at risk.
Psychological or Emotional Abuse
This includes threats of harm, abandonment, isolation or humiliation which may result in the adult feeling in low mood, undervalued and perhaps unnecessarily dependant.
Some ways in which psychological/emotional abuse can take the form of are detailed below:
- Failure to respond adequately to emotional needs
- Failure to protect from the emotional abuse of others
- Harassment or humiliation (bullying)
- Intimidation
- Failure to meet cultural requirements
- Unreasonable demands
- Denial of choice
- Controlling or creating over dependence
- Verbal abuse
- Cyber bullying
- Mental distress
- Negating the right of the adult at risk to make choices and undermining their self esteem
- Isolation and over dependence
Indicators of possible psychological or emotional abuse may include, but are not limited to:
- Low self esteem
- Tearfulness
- Alteration in psychological state e.g. may appear to be withdrawn, agitated or anxious in general
- Aggressive or challenging behaviour
- Attention seeking behaviour
- Self harm
- Depression
- Insomnia
- Unexplained paranoia
Sexual Abuse
This is the involvement of any individual in any sexual activity to which they either cannot or have not given their consent or does not truly comprehend and so cannot give consent. Or where the other party is in a position of trust, power or authority and uses this to override or overcome lack of consent. Sexual abuse includes:
- Rape or sexual assault
- Inappropriate touching
- Fondling
- Sexual intercourse/buggery or attempted sexual intercourse/buggery
- Inflicting pornography on an individual
- Offensive or inappropriate language including sexual innuendos and sexual teasing
Indicators of possible sexual abuse may include, but are not limited to:
- Change in usual behaviour
- Overt sexual behaviour/language
- Bleeding or pain in the genital/rectal area
- Disturbed sleep pattern
- Torn, stained or bloody underwear
- Self‐harming
Financial or Material Abuse
This can be considered as unauthorised extraction of the adult at risk’s resources or their resources being withheld or misused by someone else and including:
- Misuse, embezzlement or theft of a person’s money, property or possessions
- Failing to account satisfactorily for the use of a person’s money, property or possessions, fraudulent use of money
- Extortion of money, property, possessions through theft
Indicators of possible financial or material abuse may include, but are not limited to:
- Lifestyle does not reflect known income
- Unexplained withdrawals from account
- Unexplained/sudden inability to pay service charge/bills etc.
Financial abuse is a crime.
Discriminatory Abuse
The inappropriate treatment of an adult at risk because of their age, gender, race, religion, cultural background, sexuality, disability, etc.
Discriminatory abuse exists when values, belief or culture result in a misuse of power that denies opportunity to some groups or individuals.
Discriminatory abuse links to all other forms of abuse and can include:
- Unequal treatment
- Inappropriate use of language:
- Racist remarks
- Sexist remarks
- Derogatory remarks or verbal abuse
- Comments about disability
- Bullying or other forms of harassment
- Deliberate exclusion
Indicators of possible discriminatory abuse may include, but are not limited to:
- Inappropriate remarks or comments
- Lack of respect shown to people
- Staff member/volunteer may avoid being with certain groups of people
Institutional Abuse
Institutional abuse is the mistreatment or abuse or neglect of an adult at risk by individuals within an organisational setting where routines, systems and practices result in denying, restricting or curtailing the dignity, privacy, choice, independence or fulfilment of an adult at risk.
A number of inquiries into institutional abuse have shown that abuse is most likely to occur when staff:
- Receive little support from management
- Are inadequately trained
- Are poorly supervised
- Receive inadequate guidance
E. Key Principles
The most important priority is to ensure that the most urgent medical and welfare requirements of the adult at risk are met.
Preserve any potential forensic opportunities, record verbatim the disclosure made by the adult at risk.
Any sexual activity that is not freely consented to is criminal and should be reported to the police immediately, before any internal investigation.
Sexual relationships, or inappropriate sexual behaviour between a member of staff (or volunteer) and a service user are always abusive and will lead to disciplinary hearings. This will be in addition to any criminal actions taken.
A sexual relationship between the service user and a care worker is a criminal offence under Sections 38-42 of the Sexual Offences Act 2003.
There may be Safeguarding Adults referrals that involve sexual innuendo or remarks that will not result in a criminal investigation; however, all Safeguarding Adults referrals that indicate any form of sexual abuse require a risk assessment, intelligence gathering and appropriate information sharing with relevant partners.
F. Responsibilities
Duty Of Care
All staff & volunteers of Luminary have a ‘duty of care’ towards those who use our services.
This means taking action whenever there is a concern of possible mistreatment or abuse to an adult at risk. The procedural guidelines supporting this Policy are intended to provide a good practice framework and to support staff; staff are therefore expected to comply with them.
Failure to report any concerns may be viewed as being negligent or agreeing with the abuse, which in some cases could lead to disciplinary action.
All staff should:
- Be aware that they must call the police/ambulance where appropriate
- Share their concerns with appropriate colleagues and seek advice and support unless they are implicated in the abuse
- Know they must inform the appropriate safeguarding officer as per escalation chart
- Know that they must make a clear, factual record of their concern and the action taken using the Safeguarding Incident Reporting Form
In addition, Support Workers & Safeguarding Staff should:
- Know what services are available and how to access help and advice
- Know how and where to make a referral via Adult Social Care
Responsibility of Managers:
- To ensure that the alleged victim is safe
- To ensure that any staff or volunteer who may have caused the harm is not in contact with service users and others who may be at risk
- To ensure that information is provided in a timely manner
- Operate safe recruitment practices and ensure reference checks are made
- Support staff who raise concerns
Monitoring
Safer Recruitment
All staff who work in a support-work capacity with our service users are subject to an enhanced disclosure check from the Disclosure and Barring Service.
For any team recruitment, an interview should be conducted, and two satisfactory references received, to assess an applicant’s suitability prior to an offer of employment or volunteering being made. On appointment staff and volunteers serve a probationary period for performance monitoring.
Volunteers within projects are recruited within the same processes as those for paid members of staff.
The named Safeguarding Adults Co-ordinator (SAC)- Alice Williams (Luminary CEO) will monitor any concerns and keep a record of safeguarding prompt logs compiled by staff. The SAC will report to the Charity Board on a quarterly basis.
G. Training
This policy and associated procedures are to be rolled out across Luminary through in- house training and in addition staff may access local authority Safeguarding Adult training.
16.1 Safeguarding Adults at Risk Policy & Procedure
Page Navigation
A. Introduction
The Safeguarding Adults at Risk Policy and Procedure represent Luminary’s commitment to safeguard adults at risk of harm.
The policy and procedure apply to ALL Luminary staff and volunteers. They represent Luminary’s commitment to:
- working together with other agencies to prevent and protect adults at risk of abuse
- empower and support people to make their own choices
- investigate actual or suspected abuse or neglect
- support adults and provide a service to adults at risk who are experiencing exploitation, abuse or neglect
B. Context
Unlike Child Protection, there is no statutory protection for, or definition of adults at risk of abuse.
There is a presumption that adults have the mental capacity to make informed decisions about their lives. If someone has been assessed as not having mental capacity, then decisions should be made in their best interests as set out in the Mental Capacity Act 2005.
Adults at risk should be given information, advice and support in a form they can understand and have their views included when decisions are being taken about their lives. All decisions taken about another person’s life should be timely, reasonable, justified, proportionate and ethical.
- All staff have a duty to report any concerns or suspicions that an adult at risk is being, or is at risk of being, abused.
- Actions to protect the adult from abuse should always be given a high priority by all organisations involved. Concerns or allegations should be reported without delay and given high priority.
- Luminary will work to safeguard adults at risk, making their dignity, safety and well-being a high priority.
- All staff have a duty to understand their role and responsibilities in regard to this policy and procedure.
- Every effort should be made to ensure that adults at risk are afforded appropriate protection under the law.
- As far as possible Luminary staff and volunteers must respect the rights of the person causing harm. If that person is also an adult at risk, they must receive support and their needs should be addressed.
- Luminary staff will work effectively with interagency working in order to provide the most effective means of safeguarding adults.
C. Definitions
'Adult At Risk'
‘Adult at risk’ means adults who need community care services because of mental or other disability, age or illness and who is, or may be, unable to take care of themselves against significant harm or exploitation.
- An adult at risk may therefore be a person who:
- is unable to look after their own wellbeing, property, rights or other interests
- misuses substances or alcohol
- has a learning disability
- has a physical disability and/or a sensory impairment
- has mental health needs including dementia or a personality disorder
- has been groomed, trafficked or exploited
- has a long term illness or condition
- is in need of care and support but is unable to demonstrate the capacity to make an informed decision about themselves
- is elderly and frail due to ill health, physical disability, or cognitive impairment
- Actions to protect the adult from abuse should always be given high priority. The dignity, safety and wellbeing of an individual should be a priority within any action taken.
- In the context of safeguarding adults, the extent to which the adult is at risk is related to how able they are to make and exercise their own informed choices free from duress, pressure or undue influence of any sort, and to protect themselves from abuse, neglect and exploitation. It is important to note that people with capacity can also still be ‘at risk’.
- It is always essential in safeguarding to consider whether the adult at risk is capable of giving informed consent. If they are, their consent to any course of action should be obtained. This may be in relation to whether they give their consent to:
- An activity that may be abusive – if consent to abuse or neglect was given under duress, for example, as a result of exploitation, pressure, fear, intimidation – this apparent consent should be. disregarded.
- A Safeguarding Adults investigation going ahead in response to a concern that has been raised. Where an adult at risk with capacity has made a decision that they do not want action to be taken and there are no public interest considerations, their wishes must be respected. The person should be given information and have the opportunity to consider all the risks and fully understand the likely consequences of their decision over the short and long term.
- If after discussion with the adult at risk who has mental capacity, they refuse any intervention, their wishes must be respected unless:
- there is a public interest – eg not acting will put other adults or children at risk
- there is a duty of care to intervene eg a crime has been, or will be, committed
- We recognise that there are often complex issues and factors that many of the individuals may have experienced throughout some point in their lives. Such factors should be taken into consideration when looking at who an adult at risk may be. Many of the women that we will encounter will have various experiences of being homeless, fleeing exploitation and/or trafficking, prostitution, suffering from low self esteem, self harm, substance misuse, learning difficulties, emotional wellbeing needs or mental health issues such as Borderline Personality Disorder.
- At all times Luminary will consider the welfare of the Adult at Risk to be of high importance. We are committed to achieving this by:
- Actively striving to promote the empowerment and wellbeing of adults at risk through respectful and responsive high quality service provision.
- Helping to prevent the physical, sexual, emotional or psychological, financial and discriminatory abuse and neglect of adults at risk and to report any such abuse that is discovered or suspected.
- Believing and promoting that all individuals have the right to be able to live their lives free from exploitation, fear, abuse, harm or degrading treatment. All individuals have the right to protection from any such mistreatment and harm.
- Believing and promoting that all individuals have the right to make choices and that their right to independence is actively encouraged. We acknowledge that such choices may at times involve an element of risk. We are committed to ensuring that any such risks are formally acknowledged and understood by all concerned, taking all reasonable measures to ensure risks are minimized wherever possible.
- Being committed to respecting equal opportunities, anti -discriminatory practise and diversity issues.
- All staff and volunteers are required not to share any private information or photos about the service users in any context.
- Ensuring that the law and statutory requirements which relate to adults at risk are known and put into practice.
- Safe recruitment, supervision and training for all those working with adults at risk within Luminary.
'Abuse'
‘Abuse’ is an emotive term and can be subject to interpretation, Luminary recognises that abuse can be “a violation of an individual’s human and civil rights by any other person or persons” (“No Secrets”, Department of Health 2000).
Abuse may be:
- A single or repeated act
- An act of neglect; lack of appropriate action taking place
- Multiple acts; an adult at risk may be neglected and also financially abused
'The Abuser'
It is important to recognise that the ‘abuser’ could be anyone, including friends, relatives, family members, other Service Users, professional paid staff, volunteers and persons unknown to the adult at risk. They may also themselves be an adult at risk.
'Exploitation'
Exploitation is exerting undue influence or forcing an adult at risk to perform services for the benefit of others.
'SIGNIFICANT HARM’
The Law Commissioner’s Green Paper ‘Who Decides’ 1997 builds on the concept introduced in the Children Act, 1989 and suggests:
"Harm should be taken to include not only ill treatment (including sexual abuse and forms of ill treatment that are not physical); but also the impairment of, or an unavoidable deterioration in physical or mental health, and the impairment of physical, intellectual, emotional social or behavioural development.”
'No Secrets' also uses the concept of significant harm. This refers to:
- Ill treatment
- Impairment of physical or mental health
- Impairment of physical, intellectual, emotional social or behavioural development
'No Secrets' puts forward the following factors to be taken into account when making an assessment of the seriousness of the risk to the person:
- Vulnerability of the person
- Nature and extent of the abuse or neglect
- Length of time the abuse or neglect has been occurring
- Impact of the alleged abuse
- Impact of the alleged abuse
- Risk of repeated or increasingly serious acts of abuse or neglect
- Risk that serious harm could result if no action is taken
- Illegality of the act
D. Categories of abuse: signs and possible indicators
Physical Abuse
Is the physical mistreatment or non-accidental injury of an adult. Some possible signs of abuse are detailed as follows:
- Slapping
- Kicking
- Punching
- Shaking
- Bruising
- Burns
- Cutting
Indicators of possible physical abuse may include, but are not limited to:
- An injury not fitting the explanation given
- Unexplained or unusual fractures in various stages of healing
- Bruises or burns in the shape of objects e.g. cigarette burns, belt buckles or water
- Bruising in well protected areas e.g. behind the ears, on face, inside of the upper arms or thighs, buttocks, breasts, genital or rectal area
- Lacerations
- Unlawful or inappropriate use of restraint and/or deprivation of liberty is physical abuse
Neglect or Acts of Omission
This includes deliberate refusal to meet basic needs. Signs of neglect can include individuals experiencing the following:
- Lack of choice, denied diversity
- Poor judgemental attitudes
- Derogatory terms used about the adult or their situation
- Failure to ensure appropriate privacy and dignity
- Poor surroundings e.g. neglect of repairs, inadequate heating
- Over or under protective practices
Behaviour that can lead to neglect includes:
- Ignoring medical or physical needs
- failing to allow access to appropriate health, social and educational services
Indicators of possible neglect or omission may include, but are not limited to:
- Loss of weight
- Clothing in a poor condition
- Failure to access appropriate health, educational services or social care
Unintentional neglect could result from a professional failing to meet the needs of the adult at risk because they do not understand the needs or may not know about the services available. It may also occur if the individuals are unaware of or do not understand the possible effect of the lack of action on the adult at risk.
Psychological or Emotional Abuse
This includes threats of harm, abandonment, isolation or humiliation which may result in the adult feeling in low mood, undervalued and perhaps unnecessarily dependant.
Some ways in which psychological/emotional abuse can take the form of are detailed below:
- Failure to respond adequately to emotional needs
- Failure to protect from the emotional abuse of others
- Harassment or humiliation (bullying)
- Intimidation
- Failure to meet cultural requirements
- Unreasonable demands
- Denial of choice
- Controlling or creating over dependence
- Verbal abuse
- Cyber bullying
- Mental distress
- Negating the right of the adult at risk to make choices and undermining their self esteem
- Isolation and over dependence
Indicators of possible psychological or emotional abuse may include, but are not limited to:
- Low self esteem
- Tearfulness
- Alteration in psychological state e.g. may appear to be withdrawn, agitated or anxious in general
- Aggressive or challenging behaviour
- Attention seeking behaviour
- Self harm
- Depression
- Insomnia
- Unexplained paranoia
Sexual Abuse
This is the involvement of any individual in any sexual activity to which they either cannot or have not given their consent or does not truly comprehend and so cannot give consent. Or where the other party is in a position of trust, power or authority and uses this to override or overcome lack of consent. Sexual abuse includes:
- Rape or sexual assault
- Inappropriate touching
- Fondling
- Sexual intercourse/buggery or attempted sexual intercourse/buggery
- Inflicting pornography on an individual
- Offensive or inappropriate language including sexual innuendos and sexual teasing
Indicators of possible sexual abuse may include, but are not limited to:
- Change in usual behaviour
- Overt sexual behaviour/language
- Bleeding or pain in the genital/rectal area
- Disturbed sleep pattern
- Torn, stained or bloody underwear
- Self‐harming
Financial or Material Abuse
This can be considered as unauthorised extraction of the adult at risk’s resources or their resources being withheld or misused by someone else and including:
- Misuse, embezzlement or theft of a person’s money, property or possessions
- Failing to account satisfactorily for the use of a person’s money, property or possessions, fraudulent use of money
- Extortion of money, property, possessions through theft
Indicators of possible financial or material abuse may include, but are not limited to:
- Lifestyle does not reflect known income
- Unexplained withdrawals from account
- Unexplained/sudden inability to pay service charge/bills etc.
Financial abuse is a crime.
Discriminatory Abuse
The inappropriate treatment of an adult at risk because of their age, gender, race, religion, cultural background, sexuality, disability, etc.
Discriminatory abuse exists when values, belief or culture result in a misuse of power that denies opportunity to some groups or individuals.
Discriminatory abuse links to all other forms of abuse and can include:
- Unequal treatment
- Inappropriate use of language:
- Racist remarks
- Sexist remarks
- Derogatory remarks or verbal abuse
- Comments about disability
- Bullying or other forms of harassment
- Deliberate exclusion
Indicators of possible discriminatory abuse may include, but are not limited to:
- Inappropriate remarks or comments
- Lack of respect shown to people
- Staff member/volunteer may avoid being with certain groups of people
Institutional Abuse
Institutional abuse is the mistreatment or abuse or neglect of an adult at risk by individuals within an organisational setting where routines, systems and practices result in denying, restricting or curtailing the dignity, privacy, choice, independence or fulfilment of an adult at risk.
A number of inquiries into institutional abuse have shown that abuse is most likely to occur when staff:
- Receive little support from management
- Are inadequately trained
- Are poorly supervised
- Receive inadequate guidance
E. Key Principles
The most important priority is to ensure that the most urgent medical and welfare requirements of the adult at risk are met.
Preserve any potential forensic opportunities, record verbatim the disclosure made by the adult at risk.
Any sexual activity that is not freely consented to is criminal and should be reported to the police immediately, before any internal investigation.
Sexual relationships, or inappropriate sexual behaviour between a member of staff (or volunteer) and a service user are always abusive and will lead to disciplinary hearings. This will be in addition to any criminal actions taken.
A sexual relationship between the service user and a care worker is a criminal offence under Sections 38-42 of the Sexual Offences Act 2003.
There may be Safeguarding Adults referrals that involve sexual innuendo or remarks that will not result in a criminal investigation; however, all Safeguarding Adults referrals that indicate any form of sexual abuse require a risk assessment, intelligence gathering and appropriate information sharing with relevant partners.
F. Responsibilities
Duty Of Care
All staff & volunteers of Luminary have a ‘duty of care’ towards those who use our services.
This means taking action whenever there is a concern of possible mistreatment or abuse to an adult at risk. The procedural guidelines supporting this Policy are intended to provide a good practice framework and to support staff; staff are therefore expected to comply with them.
Failure to report any concerns may be viewed as being negligent or agreeing with the abuse, which in some cases could lead to disciplinary action.
All staff should:
- Be aware that they must call the police/ambulance where appropriate
- Share their concerns with appropriate colleagues and seek advice and support unless they are implicated in the abuse
- Know they must inform the appropriate safeguarding officer as per escalation chart
- Know that they must make a clear, factual record of their concern and the action taken using the Safeguarding Incident Reporting Form
In addition, Support Workers & Safeguarding Staff should:
- Know what services are available and how to access help and advice
- Know how and where to make a referral via Adult Social Care
Responsibility of Managers:
- To ensure that the alleged victim is safe
- To ensure that any staff or volunteer who may have caused the harm is not in contact with service users and others who may be at risk
- To ensure that information is provided in a timely manner
- Operate safe recruitment practices and ensure reference checks are made
- Support staff who raise concerns
Monitoring
Safer Recruitment
All staff who work in a support-work capacity with our service users are subject to an enhanced disclosure check from the Disclosure and Barring Service.
For any team recruitment, an interview should be conducted, and two satisfactory references received, to assess an applicant’s suitability prior to an offer of employment or volunteering being made. On appointment staff and volunteers serve a probationary period for performance monitoring.
Volunteers within projects are recruited within the same processes as those for paid members of staff.
The named Safeguarding Adults Co-ordinator (SAC)- Alice Williams (Luminary CEO) will monitor any concerns and keep a record of safeguarding prompt logs compiled by staff. The SAC will report to the Charity Board on a quarterly basis.
G. Training
This policy and associated procedures are to be rolled out across Luminary through in- house training and in addition staff may access local authority Safeguarding Adult training.
- WEDDINGS
-
LUMINARY CHARITY
16.1 Safeguarding Adults at Risk Policy & Procedure
Page Navigation
A. Introduction
The Safeguarding Adults at Risk Policy and Procedure represent Luminary’s commitment to safeguard adults at risk of harm.
The policy and procedure apply to ALL Luminary staff and volunteers. They represent Luminary’s commitment to:
- working together with other agencies to prevent and protect adults at risk of abuse
- empower and support people to make their own choices
- investigate actual or suspected abuse or neglect
- support adults and provide a service to adults at risk who are experiencing exploitation, abuse or neglect
B. Context
Unlike Child Protection, there is no statutory protection for, or definition of adults at risk of abuse.
There is a presumption that adults have the mental capacity to make informed decisions about their lives. If someone has been assessed as not having mental capacity, then decisions should be made in their best interests as set out in the Mental Capacity Act 2005.
Adults at risk should be given information, advice and support in a form they can understand and have their views included when decisions are being taken about their lives. All decisions taken about another person’s life should be timely, reasonable, justified, proportionate and ethical.
- All staff have a duty to report any concerns or suspicions that an adult at risk is being, or is at risk of being, abused.
- Actions to protect the adult from abuse should always be given a high priority by all organisations involved. Concerns or allegations should be reported without delay and given high priority.
- Luminary will work to safeguard adults at risk, making their dignity, safety and well-being a high priority.
- All staff have a duty to understand their role and responsibilities in regard to this policy and procedure.
- Every effort should be made to ensure that adults at risk are afforded appropriate protection under the law.
- As far as possible Luminary staff and volunteers must respect the rights of the person causing harm. If that person is also an adult at risk, they must receive support and their needs should be addressed.
- Luminary staff will work effectively with interagency working in order to provide the most effective means of safeguarding adults.
C. Definitions
'Adult At Risk'
‘Adult at risk’ means adults who need community care services because of mental or other disability, age or illness and who is, or may be, unable to take care of themselves against significant harm or exploitation.
- An adult at risk may therefore be a person who:
- is unable to look after their own wellbeing, property, rights or other interests
- misuses substances or alcohol
- has a learning disability
- has a physical disability and/or a sensory impairment
- has mental health needs including dementia or a personality disorder
- has been groomed, trafficked or exploited
- has a long term illness or condition
- is in need of care and support but is unable to demonstrate the capacity to make an informed decision about themselves
- is elderly and frail due to ill health, physical disability, or cognitive impairment
- Actions to protect the adult from abuse should always be given high priority. The dignity, safety and wellbeing of an individual should be a priority within any action taken.
- In the context of safeguarding adults, the extent to which the adult is at risk is related to how able they are to make and exercise their own informed choices free from duress, pressure or undue influence of any sort, and to protect themselves from abuse, neglect and exploitation. It is important to note that people with capacity can also still be ‘at risk’.
- It is always essential in safeguarding to consider whether the adult at risk is capable of giving informed consent. If they are, their consent to any course of action should be obtained. This may be in relation to whether they give their consent to:
- An activity that may be abusive – if consent to abuse or neglect was given under duress, for example, as a result of exploitation, pressure, fear, intimidation – this apparent consent should be. disregarded.
- A Safeguarding Adults investigation going ahead in response to a concern that has been raised. Where an adult at risk with capacity has made a decision that they do not want action to be taken and there are no public interest considerations, their wishes must be respected. The person should be given information and have the opportunity to consider all the risks and fully understand the likely consequences of their decision over the short and long term.
- If after discussion with the adult at risk who has mental capacity, they refuse any intervention, their wishes must be respected unless:
- there is a public interest – eg not acting will put other adults or children at risk
- there is a duty of care to intervene eg a crime has been, or will be, committed
- We recognise that there are often complex issues and factors that many of the individuals may have experienced throughout some point in their lives. Such factors should be taken into consideration when looking at who an adult at risk may be. Many of the women that we will encounter will have various experiences of being homeless, fleeing exploitation and/or trafficking, prostitution, suffering from low self esteem, self harm, substance misuse, learning difficulties, emotional wellbeing needs or mental health issues such as Borderline Personality Disorder.
- At all times Luminary will consider the welfare of the Adult at Risk to be of high importance. We are committed to achieving this by:
- Actively striving to promote the empowerment and wellbeing of adults at risk through respectful and responsive high quality service provision.
- Helping to prevent the physical, sexual, emotional or psychological, financial and discriminatory abuse and neglect of adults at risk and to report any such abuse that is discovered or suspected.
- Believing and promoting that all individuals have the right to be able to live their lives free from exploitation, fear, abuse, harm or degrading treatment. All individuals have the right to protection from any such mistreatment and harm.
- Believing and promoting that all individuals have the right to make choices and that their right to independence is actively encouraged. We acknowledge that such choices may at times involve an element of risk. We are committed to ensuring that any such risks are formally acknowledged and understood by all concerned, taking all reasonable measures to ensure risks are minimized wherever possible.
- Being committed to respecting equal opportunities, anti -discriminatory practise and diversity issues.
- All staff and volunteers are required not to share any private information or photos about the service users in any context.
- Ensuring that the law and statutory requirements which relate to adults at risk are known and put into practice.
- Safe recruitment, supervision and training for all those working with adults at risk within Luminary.
'Abuse'
‘Abuse’ is an emotive term and can be subject to interpretation, Luminary recognises that abuse can be “a violation of an individual’s human and civil rights by any other person or persons” (“No Secrets”, Department of Health 2000).
Abuse may be:
- A single or repeated act
- An act of neglect; lack of appropriate action taking place
- Multiple acts; an adult at risk may be neglected and also financially abused
'The Abuser'
It is important to recognise that the ‘abuser’ could be anyone, including friends, relatives, family members, other Service Users, professional paid staff, volunteers and persons unknown to the adult at risk. They may also themselves be an adult at risk.
'Exploitation'
Exploitation is exerting undue influence or forcing an adult at risk to perform services for the benefit of others.
'SIGNIFICANT HARM’
The Law Commissioner’s Green Paper ‘Who Decides’ 1997 builds on the concept introduced in the Children Act, 1989 and suggests:
"Harm should be taken to include not only ill treatment (including sexual abuse and forms of ill treatment that are not physical); but also the impairment of, or an unavoidable deterioration in physical or mental health, and the impairment of physical, intellectual, emotional social or behavioural development.”
'No Secrets' also uses the concept of significant harm. This refers to:
- Ill treatment
- Impairment of physical or mental health
- Impairment of physical, intellectual, emotional social or behavioural development
'No Secrets' puts forward the following factors to be taken into account when making an assessment of the seriousness of the risk to the person:
- Vulnerability of the person
- Nature and extent of the abuse or neglect
- Length of time the abuse or neglect has been occurring
- Impact of the alleged abuse
- Impact of the alleged abuse
- Risk of repeated or increasingly serious acts of abuse or neglect
- Risk that serious harm could result if no action is taken
- Illegality of the act
D. Categories of abuse: signs and possible indicators
Physical Abuse
Is the physical mistreatment or non-accidental injury of an adult. Some possible signs of abuse are detailed as follows:
- Slapping
- Kicking
- Punching
- Shaking
- Bruising
- Burns
- Cutting
Indicators of possible physical abuse may include, but are not limited to:
- An injury not fitting the explanation given
- Unexplained or unusual fractures in various stages of healing
- Bruises or burns in the shape of objects e.g. cigarette burns, belt buckles or water
- Bruising in well protected areas e.g. behind the ears, on face, inside of the upper arms or thighs, buttocks, breasts, genital or rectal area
- Lacerations
- Unlawful or inappropriate use of restraint and/or deprivation of liberty is physical abuse
Neglect or Acts of Omission
This includes deliberate refusal to meet basic needs. Signs of neglect can include individuals experiencing the following:
- Lack of choice, denied diversity
- Poor judgemental attitudes
- Derogatory terms used about the adult or their situation
- Failure to ensure appropriate privacy and dignity
- Poor surroundings e.g. neglect of repairs, inadequate heating
- Over or under protective practices
Behaviour that can lead to neglect includes:
- Ignoring medical or physical needs
- failing to allow access to appropriate health, social and educational services
Indicators of possible neglect or omission may include, but are not limited to:
- Loss of weight
- Clothing in a poor condition
- Failure to access appropriate health, educational services or social care
Unintentional neglect could result from a professional failing to meet the needs of the adult at risk because they do not understand the needs or may not know about the services available. It may also occur if the individuals are unaware of or do not understand the possible effect of the lack of action on the adult at risk.
Psychological or Emotional Abuse
This includes threats of harm, abandonment, isolation or humiliation which may result in the adult feeling in low mood, undervalued and perhaps unnecessarily dependant.
Some ways in which psychological/emotional abuse can take the form of are detailed below:
- Failure to respond adequately to emotional needs
- Failure to protect from the emotional abuse of others
- Harassment or humiliation (bullying)
- Intimidation
- Failure to meet cultural requirements
- Unreasonable demands
- Denial of choice
- Controlling or creating over dependence
- Verbal abuse
- Cyber bullying
- Mental distress
- Negating the right of the adult at risk to make choices and undermining their self esteem
- Isolation and over dependence
Indicators of possible psychological or emotional abuse may include, but are not limited to:
- Low self esteem
- Tearfulness
- Alteration in psychological state e.g. may appear to be withdrawn, agitated or anxious in general
- Aggressive or challenging behaviour
- Attention seeking behaviour
- Self harm
- Depression
- Insomnia
- Unexplained paranoia
Sexual Abuse
This is the involvement of any individual in any sexual activity to which they either cannot or have not given their consent or does not truly comprehend and so cannot give consent. Or where the other party is in a position of trust, power or authority and uses this to override or overcome lack of consent. Sexual abuse includes:
- Rape or sexual assault
- Inappropriate touching
- Fondling
- Sexual intercourse/buggery or attempted sexual intercourse/buggery
- Inflicting pornography on an individual
- Offensive or inappropriate language including sexual innuendos and sexual teasing
Indicators of possible sexual abuse may include, but are not limited to:
- Change in usual behaviour
- Overt sexual behaviour/language
- Bleeding or pain in the genital/rectal area
- Disturbed sleep pattern
- Torn, stained or bloody underwear
- Self‐harming
Financial or Material Abuse
This can be considered as unauthorised extraction of the adult at risk’s resources or their resources being withheld or misused by someone else and including:
- Misuse, embezzlement or theft of a person’s money, property or possessions
- Failing to account satisfactorily for the use of a person’s money, property or possessions, fraudulent use of money
- Extortion of money, property, possessions through theft
Indicators of possible financial or material abuse may include, but are not limited to:
- Lifestyle does not reflect known income
- Unexplained withdrawals from account
- Unexplained/sudden inability to pay service charge/bills etc.
Financial abuse is a crime.
Discriminatory Abuse
The inappropriate treatment of an adult at risk because of their age, gender, race, religion, cultural background, sexuality, disability, etc.
Discriminatory abuse exists when values, belief or culture result in a misuse of power that denies opportunity to some groups or individuals.
Discriminatory abuse links to all other forms of abuse and can include:
- Unequal treatment
- Inappropriate use of language:
- Racist remarks
- Sexist remarks
- Derogatory remarks or verbal abuse
- Comments about disability
- Bullying or other forms of harassment
- Deliberate exclusion
Indicators of possible discriminatory abuse may include, but are not limited to:
- Inappropriate remarks or comments
- Lack of respect shown to people
- Staff member/volunteer may avoid being with certain groups of people
Institutional Abuse
Institutional abuse is the mistreatment or abuse or neglect of an adult at risk by individuals within an organisational setting where routines, systems and practices result in denying, restricting or curtailing the dignity, privacy, choice, independence or fulfilment of an adult at risk.
A number of inquiries into institutional abuse have shown that abuse is most likely to occur when staff:
- Receive little support from management
- Are inadequately trained
- Are poorly supervised
- Receive inadequate guidance
E. Key Principles
The most important priority is to ensure that the most urgent medical and welfare requirements of the adult at risk are met.
Preserve any potential forensic opportunities, record verbatim the disclosure made by the adult at risk.
Any sexual activity that is not freely consented to is criminal and should be reported to the police immediately, before any internal investigation.
Sexual relationships, or inappropriate sexual behaviour between a member of staff (or volunteer) and a service user are always abusive and will lead to disciplinary hearings. This will be in addition to any criminal actions taken.
A sexual relationship between the service user and a care worker is a criminal offence under Sections 38-42 of the Sexual Offences Act 2003.
There may be Safeguarding Adults referrals that involve sexual innuendo or remarks that will not result in a criminal investigation; however, all Safeguarding Adults referrals that indicate any form of sexual abuse require a risk assessment, intelligence gathering and appropriate information sharing with relevant partners.
F. Responsibilities
Duty Of Care
All staff & volunteers of Luminary have a ‘duty of care’ towards those who use our services.
This means taking action whenever there is a concern of possible mistreatment or abuse to an adult at risk. The procedural guidelines supporting this Policy are intended to provide a good practice framework and to support staff; staff are therefore expected to comply with them.
Failure to report any concerns may be viewed as being negligent or agreeing with the abuse, which in some cases could lead to disciplinary action.
All staff should:
- Be aware that they must call the police/ambulance where appropriate
- Share their concerns with appropriate colleagues and seek advice and support unless they are implicated in the abuse
- Know they must inform the appropriate safeguarding officer as per escalation chart
- Know that they must make a clear, factual record of their concern and the action taken using the Safeguarding Incident Reporting Form
In addition, Support Workers & Safeguarding Staff should:
- Know what services are available and how to access help and advice
- Know how and where to make a referral via Adult Social Care
Responsibility of Managers:
- To ensure that the alleged victim is safe
- To ensure that any staff or volunteer who may have caused the harm is not in contact with service users and others who may be at risk
- To ensure that information is provided in a timely manner
- Operate safe recruitment practices and ensure reference checks are made
- Support staff who raise concerns
Monitoring
Safer Recruitment
All staff who work in a support-work capacity with our service users are subject to an enhanced disclosure check from the Disclosure and Barring Service.
For any team recruitment, an interview should be conducted, and two satisfactory references received, to assess an applicant’s suitability prior to an offer of employment or volunteering being made. On appointment staff and volunteers serve a probationary period for performance monitoring.
Volunteers within projects are recruited within the same processes as those for paid members of staff.
The named Safeguarding Adults Co-ordinator (SAC)- Alice Williams (Luminary CEO) will monitor any concerns and keep a record of safeguarding prompt logs compiled by staff. The SAC will report to the Charity Board on a quarterly basis.
G. Training
This policy and associated procedures are to be rolled out across Luminary through in- house training and in addition staff may access local authority Safeguarding Adult training.
16.1 Safeguarding Adults at Risk Policy & Procedure
Page Navigation
A. Introduction
The Safeguarding Adults at Risk Policy and Procedure represent Luminary’s commitment to safeguard adults at risk of harm.
The policy and procedure apply to ALL Luminary staff and volunteers. They represent Luminary’s commitment to:
- working together with other agencies to prevent and protect adults at risk of abuse
- empower and support people to make their own choices
- investigate actual or suspected abuse or neglect
- support adults and provide a service to adults at risk who are experiencing exploitation, abuse or neglect
B. Context
Unlike Child Protection, there is no statutory protection for, or definition of adults at risk of abuse.
There is a presumption that adults have the mental capacity to make informed decisions about their lives. If someone has been assessed as not having mental capacity, then decisions should be made in their best interests as set out in the Mental Capacity Act 2005.
Adults at risk should be given information, advice and support in a form they can understand and have their views included when decisions are being taken about their lives. All decisions taken about another person’s life should be timely, reasonable, justified, proportionate and ethical.
- All staff have a duty to report any concerns or suspicions that an adult at risk is being, or is at risk of being, abused.
- Actions to protect the adult from abuse should always be given a high priority by all organisations involved. Concerns or allegations should be reported without delay and given high priority.
- Luminary will work to safeguard adults at risk, making their dignity, safety and well-being a high priority.
- All staff have a duty to understand their role and responsibilities in regard to this policy and procedure.
- Every effort should be made to ensure that adults at risk are afforded appropriate protection under the law.
- As far as possible Luminary staff and volunteers must respect the rights of the person causing harm. If that person is also an adult at risk, they must receive support and their needs should be addressed.
- Luminary staff will work effectively with interagency working in order to provide the most effective means of safeguarding adults.
C. Definitions
'Adult At Risk'
‘Adult at risk’ means adults who need community care services because of mental or other disability, age or illness and who is, or may be, unable to take care of themselves against significant harm or exploitation.
- An adult at risk may therefore be a person who:
- is unable to look after their own wellbeing, property, rights or other interests
- misuses substances or alcohol
- has a learning disability
- has a physical disability and/or a sensory impairment
- has mental health needs including dementia or a personality disorder
- has been groomed, trafficked or exploited
- has a long term illness or condition
- is in need of care and support but is unable to demonstrate the capacity to make an informed decision about themselves
- is elderly and frail due to ill health, physical disability, or cognitive impairment
- Actions to protect the adult from abuse should always be given high priority. The dignity, safety and wellbeing of an individual should be a priority within any action taken.
- In the context of safeguarding adults, the extent to which the adult is at risk is related to how able they are to make and exercise their own informed choices free from duress, pressure or undue influence of any sort, and to protect themselves from abuse, neglect and exploitation. It is important to note that people with capacity can also still be ‘at risk’.
- It is always essential in safeguarding to consider whether the adult at risk is capable of giving informed consent. If they are, their consent to any course of action should be obtained. This may be in relation to whether they give their consent to:
- An activity that may be abusive – if consent to abuse or neglect was given under duress, for example, as a result of exploitation, pressure, fear, intimidation – this apparent consent should be. disregarded.
- A Safeguarding Adults investigation going ahead in response to a concern that has been raised. Where an adult at risk with capacity has made a decision that they do not want action to be taken and there are no public interest considerations, their wishes must be respected. The person should be given information and have the opportunity to consider all the risks and fully understand the likely consequences of their decision over the short and long term.
- If after discussion with the adult at risk who has mental capacity, they refuse any intervention, their wishes must be respected unless:
- there is a public interest – eg not acting will put other adults or children at risk
- there is a duty of care to intervene eg a crime has been, or will be, committed
- We recognise that there are often complex issues and factors that many of the individuals may have experienced throughout some point in their lives. Such factors should be taken into consideration when looking at who an adult at risk may be. Many of the women that we will encounter will have various experiences of being homeless, fleeing exploitation and/or trafficking, prostitution, suffering from low self esteem, self harm, substance misuse, learning difficulties, emotional wellbeing needs or mental health issues such as Borderline Personality Disorder.
- At all times Luminary will consider the welfare of the Adult at Risk to be of high importance. We are committed to achieving this by:
- Actively striving to promote the empowerment and wellbeing of adults at risk through respectful and responsive high quality service provision.
- Helping to prevent the physical, sexual, emotional or psychological, financial and discriminatory abuse and neglect of adults at risk and to report any such abuse that is discovered or suspected.
- Believing and promoting that all individuals have the right to be able to live their lives free from exploitation, fear, abuse, harm or degrading treatment. All individuals have the right to protection from any such mistreatment and harm.
- Believing and promoting that all individuals have the right to make choices and that their right to independence is actively encouraged. We acknowledge that such choices may at times involve an element of risk. We are committed to ensuring that any such risks are formally acknowledged and understood by all concerned, taking all reasonable measures to ensure risks are minimized wherever possible.
- Being committed to respecting equal opportunities, anti -discriminatory practise and diversity issues.
- All staff and volunteers are required not to share any private information or photos about the service users in any context.
- Ensuring that the law and statutory requirements which relate to adults at risk are known and put into practice.
- Safe recruitment, supervision and training for all those working with adults at risk within Luminary.
'Abuse'
‘Abuse’ is an emotive term and can be subject to interpretation, Luminary recognises that abuse can be “a violation of an individual’s human and civil rights by any other person or persons” (“No Secrets”, Department of Health 2000).
Abuse may be:
- A single or repeated act
- An act of neglect; lack of appropriate action taking place
- Multiple acts; an adult at risk may be neglected and also financially abused
'The Abuser'
It is important to recognise that the ‘abuser’ could be anyone, including friends, relatives, family members, other Service Users, professional paid staff, volunteers and persons unknown to the adult at risk. They may also themselves be an adult at risk.
'Exploitation'
Exploitation is exerting undue influence or forcing an adult at risk to perform services for the benefit of others.
'SIGNIFICANT HARM’
The Law Commissioner’s Green Paper ‘Who Decides’ 1997 builds on the concept introduced in the Children Act, 1989 and suggests:
"Harm should be taken to include not only ill treatment (including sexual abuse and forms of ill treatment that are not physical); but also the impairment of, or an unavoidable deterioration in physical or mental health, and the impairment of physical, intellectual, emotional social or behavioural development.”
'No Secrets' also uses the concept of significant harm. This refers to:
- Ill treatment
- Impairment of physical or mental health
- Impairment of physical, intellectual, emotional social or behavioural development
'No Secrets' puts forward the following factors to be taken into account when making an assessment of the seriousness of the risk to the person:
- Vulnerability of the person
- Nature and extent of the abuse or neglect
- Length of time the abuse or neglect has been occurring
- Impact of the alleged abuse
- Impact of the alleged abuse
- Risk of repeated or increasingly serious acts of abuse or neglect
- Risk that serious harm could result if no action is taken
- Illegality of the act
D. Categories of abuse: signs and possible indicators
Physical Abuse
Is the physical mistreatment or non-accidental injury of an adult. Some possible signs of abuse are detailed as follows:
- Slapping
- Kicking
- Punching
- Shaking
- Bruising
- Burns
- Cutting
Indicators of possible physical abuse may include, but are not limited to:
- An injury not fitting the explanation given
- Unexplained or unusual fractures in various stages of healing
- Bruises or burns in the shape of objects e.g. cigarette burns, belt buckles or water
- Bruising in well protected areas e.g. behind the ears, on face, inside of the upper arms or thighs, buttocks, breasts, genital or rectal area
- Lacerations
- Unlawful or inappropriate use of restraint and/or deprivation of liberty is physical abuse
Neglect or Acts of Omission
This includes deliberate refusal to meet basic needs. Signs of neglect can include individuals experiencing the following:
- Lack of choice, denied diversity
- Poor judgemental attitudes
- Derogatory terms used about the adult or their situation
- Failure to ensure appropriate privacy and dignity
- Poor surroundings e.g. neglect of repairs, inadequate heating
- Over or under protective practices
Behaviour that can lead to neglect includes:
- Ignoring medical or physical needs
- failing to allow access to appropriate health, social and educational services
Indicators of possible neglect or omission may include, but are not limited to:
- Loss of weight
- Clothing in a poor condition
- Failure to access appropriate health, educational services or social care
Unintentional neglect could result from a professional failing to meet the needs of the adult at risk because they do not understand the needs or may not know about the services available. It may also occur if the individuals are unaware of or do not understand the possible effect of the lack of action on the adult at risk.
Psychological or Emotional Abuse
This includes threats of harm, abandonment, isolation or humiliation which may result in the adult feeling in low mood, undervalued and perhaps unnecessarily dependant.
Some ways in which psychological/emotional abuse can take the form of are detailed below:
- Failure to respond adequately to emotional needs
- Failure to protect from the emotional abuse of others
- Harassment or humiliation (bullying)
- Intimidation
- Failure to meet cultural requirements
- Unreasonable demands
- Denial of choice
- Controlling or creating over dependence
- Verbal abuse
- Cyber bullying
- Mental distress
- Negating the right of the adult at risk to make choices and undermining their self esteem
- Isolation and over dependence
Indicators of possible psychological or emotional abuse may include, but are not limited to:
- Low self esteem
- Tearfulness
- Alteration in psychological state e.g. may appear to be withdrawn, agitated or anxious in general
- Aggressive or challenging behaviour
- Attention seeking behaviour
- Self harm
- Depression
- Insomnia
- Unexplained paranoia
Sexual Abuse
This is the involvement of any individual in any sexual activity to which they either cannot or have not given their consent or does not truly comprehend and so cannot give consent. Or where the other party is in a position of trust, power or authority and uses this to override or overcome lack of consent. Sexual abuse includes:
- Rape or sexual assault
- Inappropriate touching
- Fondling
- Sexual intercourse/buggery or attempted sexual intercourse/buggery
- Inflicting pornography on an individual
- Offensive or inappropriate language including sexual innuendos and sexual teasing
Indicators of possible sexual abuse may include, but are not limited to:
- Change in usual behaviour
- Overt sexual behaviour/language
- Bleeding or pain in the genital/rectal area
- Disturbed sleep pattern
- Torn, stained or bloody underwear
- Self‐harming
Financial or Material Abuse
This can be considered as unauthorised extraction of the adult at risk’s resources or their resources being withheld or misused by someone else and including:
- Misuse, embezzlement or theft of a person’s money, property or possessions
- Failing to account satisfactorily for the use of a person’s money, property or possessions, fraudulent use of money
- Extortion of money, property, possessions through theft
Indicators of possible financial or material abuse may include, but are not limited to:
- Lifestyle does not reflect known income
- Unexplained withdrawals from account
- Unexplained/sudden inability to pay service charge/bills etc.
Financial abuse is a crime.
Discriminatory Abuse
The inappropriate treatment of an adult at risk because of their age, gender, race, religion, cultural background, sexuality, disability, etc.
Discriminatory abuse exists when values, belief or culture result in a misuse of power that denies opportunity to some groups or individuals.
Discriminatory abuse links to all other forms of abuse and can include:
- Unequal treatment
- Inappropriate use of language:
- Racist remarks
- Sexist remarks
- Derogatory remarks or verbal abuse
- Comments about disability
- Bullying or other forms of harassment
- Deliberate exclusion
Indicators of possible discriminatory abuse may include, but are not limited to:
- Inappropriate remarks or comments
- Lack of respect shown to people
- Staff member/volunteer may avoid being with certain groups of people
Institutional Abuse
Institutional abuse is the mistreatment or abuse or neglect of an adult at risk by individuals within an organisational setting where routines, systems and practices result in denying, restricting or curtailing the dignity, privacy, choice, independence or fulfilment of an adult at risk.
A number of inquiries into institutional abuse have shown that abuse is most likely to occur when staff:
- Receive little support from management
- Are inadequately trained
- Are poorly supervised
- Receive inadequate guidance
E. Key Principles
The most important priority is to ensure that the most urgent medical and welfare requirements of the adult at risk are met.
Preserve any potential forensic opportunities, record verbatim the disclosure made by the adult at risk.
Any sexual activity that is not freely consented to is criminal and should be reported to the police immediately, before any internal investigation.
Sexual relationships, or inappropriate sexual behaviour between a member of staff (or volunteer) and a service user are always abusive and will lead to disciplinary hearings. This will be in addition to any criminal actions taken.
A sexual relationship between the service user and a care worker is a criminal offence under Sections 38-42 of the Sexual Offences Act 2003.
There may be Safeguarding Adults referrals that involve sexual innuendo or remarks that will not result in a criminal investigation; however, all Safeguarding Adults referrals that indicate any form of sexual abuse require a risk assessment, intelligence gathering and appropriate information sharing with relevant partners.
F. Responsibilities
Duty Of Care
All staff & volunteers of Luminary have a ‘duty of care’ towards those who use our services.
This means taking action whenever there is a concern of possible mistreatment or abuse to an adult at risk. The procedural guidelines supporting this Policy are intended to provide a good practice framework and to support staff; staff are therefore expected to comply with them.
Failure to report any concerns may be viewed as being negligent or agreeing with the abuse, which in some cases could lead to disciplinary action.
All staff should:
- Be aware that they must call the police/ambulance where appropriate
- Share their concerns with appropriate colleagues and seek advice and support unless they are implicated in the abuse
- Know they must inform the appropriate safeguarding officer as per escalation chart
- Know that they must make a clear, factual record of their concern and the action taken using the Safeguarding Incident Reporting Form
In addition, Support Workers & Safeguarding Staff should:
- Know what services are available and how to access help and advice
- Know how and where to make a referral via Adult Social Care
Responsibility of Managers:
- To ensure that the alleged victim is safe
- To ensure that any staff or volunteer who may have caused the harm is not in contact with service users and others who may be at risk
- To ensure that information is provided in a timely manner
- Operate safe recruitment practices and ensure reference checks are made
- Support staff who raise concerns
Monitoring
Safer Recruitment
All staff who work in a support-work capacity with our service users are subject to an enhanced disclosure check from the Disclosure and Barring Service.
For any team recruitment, an interview should be conducted, and two satisfactory references received, to assess an applicant’s suitability prior to an offer of employment or volunteering being made. On appointment staff and volunteers serve a probationary period for performance monitoring.
Volunteers within projects are recruited within the same processes as those for paid members of staff.
The named Safeguarding Adults Co-ordinator (SAC)- Alice Williams (Luminary CEO) will monitor any concerns and keep a record of safeguarding prompt logs compiled by staff. The SAC will report to the Charity Board on a quarterly basis.
G. Training
This policy and associated procedures are to be rolled out across Luminary through in- house training and in addition staff may access local authority Safeguarding Adult training.
16.1 Safeguarding Adults at Risk Policy & Procedure
Page Navigation
A. Introduction
The Safeguarding Adults at Risk Policy and Procedure represent Luminary’s commitment to safeguard adults at risk of harm.
The policy and procedure apply to ALL Luminary staff and volunteers. They represent Luminary’s commitment to:
- working together with other agencies to prevent and protect adults at risk of abuse
- empower and support people to make their own choices
- investigate actual or suspected abuse or neglect
- support adults and provide a service to adults at risk who are experiencing exploitation, abuse or neglect
B. Context
Unlike Child Protection, there is no statutory protection for, or definition of adults at risk of abuse.
There is a presumption that adults have the mental capacity to make informed decisions about their lives. If someone has been assessed as not having mental capacity, then decisions should be made in their best interests as set out in the Mental Capacity Act 2005.
Adults at risk should be given information, advice and support in a form they can understand and have their views included when decisions are being taken about their lives. All decisions taken about another person’s life should be timely, reasonable, justified, proportionate and ethical.
- All staff have a duty to report any concerns or suspicions that an adult at risk is being, or is at risk of being, abused.
- Actions to protect the adult from abuse should always be given a high priority by all organisations involved. Concerns or allegations should be reported without delay and given high priority.
- Luminary will work to safeguard adults at risk, making their dignity, safety and well-being a high priority.
- All staff have a duty to understand their role and responsibilities in regard to this policy and procedure.
- Every effort should be made to ensure that adults at risk are afforded appropriate protection under the law.
- As far as possible Luminary staff and volunteers must respect the rights of the person causing harm. If that person is also an adult at risk, they must receive support and their needs should be addressed.
- Luminary staff will work effectively with interagency working in order to provide the most effective means of safeguarding adults.
C. Definitions
'Adult At Risk'
‘Adult at risk’ means adults who need community care services because of mental or other disability, age or illness and who is, or may be, unable to take care of themselves against significant harm or exploitation.
- An adult at risk may therefore be a person who:
- is unable to look after their own wellbeing, property, rights or other interests
- misuses substances or alcohol
- has a learning disability
- has a physical disability and/or a sensory impairment
- has mental health needs including dementia or a personality disorder
- has been groomed, trafficked or exploited
- has a long term illness or condition
- is in need of care and support but is unable to demonstrate the capacity to make an informed decision about themselves
- is elderly and frail due to ill health, physical disability, or cognitive impairment
- Actions to protect the adult from abuse should always be given high priority. The dignity, safety and wellbeing of an individual should be a priority within any action taken.
- In the context of safeguarding adults, the extent to which the adult is at risk is related to how able they are to make and exercise their own informed choices free from duress, pressure or undue influence of any sort, and to protect themselves from abuse, neglect and exploitation. It is important to note that people with capacity can also still be ‘at risk’.
- It is always essential in safeguarding to consider whether the adult at risk is capable of giving informed consent. If they are, their consent to any course of action should be obtained. This may be in relation to whether they give their consent to:
- An activity that may be abusive – if consent to abuse or neglect was given under duress, for example, as a result of exploitation, pressure, fear, intimidation – this apparent consent should be. disregarded.
- A Safeguarding Adults investigation going ahead in response to a concern that has been raised. Where an adult at risk with capacity has made a decision that they do not want action to be taken and there are no public interest considerations, their wishes must be respected. The person should be given information and have the opportunity to consider all the risks and fully understand the likely consequences of their decision over the short and long term.
- If after discussion with the adult at risk who has mental capacity, they refuse any intervention, their wishes must be respected unless:
- there is a public interest – eg not acting will put other adults or children at risk
- there is a duty of care to intervene eg a crime has been, or will be, committed
- We recognise that there are often complex issues and factors that many of the individuals may have experienced throughout some point in their lives. Such factors should be taken into consideration when looking at who an adult at risk may be. Many of the women that we will encounter will have various experiences of being homeless, fleeing exploitation and/or trafficking, prostitution, suffering from low self esteem, self harm, substance misuse, learning difficulties, emotional wellbeing needs or mental health issues such as Borderline Personality Disorder.
- At all times Luminary will consider the welfare of the Adult at Risk to be of high importance. We are committed to achieving this by:
- Actively striving to promote the empowerment and wellbeing of adults at risk through respectful and responsive high quality service provision.
- Helping to prevent the physical, sexual, emotional or psychological, financial and discriminatory abuse and neglect of adults at risk and to report any such abuse that is discovered or suspected.
- Believing and promoting that all individuals have the right to be able to live their lives free from exploitation, fear, abuse, harm or degrading treatment. All individuals have the right to protection from any such mistreatment and harm.
- Believing and promoting that all individuals have the right to make choices and that their right to independence is actively encouraged. We acknowledge that such choices may at times involve an element of risk. We are committed to ensuring that any such risks are formally acknowledged and understood by all concerned, taking all reasonable measures to ensure risks are minimized wherever possible.
- Being committed to respecting equal opportunities, anti -discriminatory practise and diversity issues.
- All staff and volunteers are required not to share any private information or photos about the service users in any context.
- Ensuring that the law and statutory requirements which relate to adults at risk are known and put into practice.
- Safe recruitment, supervision and training for all those working with adults at risk within Luminary.
'Abuse'
‘Abuse’ is an emotive term and can be subject to interpretation, Luminary recognises that abuse can be “a violation of an individual’s human and civil rights by any other person or persons” (“No Secrets”, Department of Health 2000).
Abuse may be:
- A single or repeated act
- An act of neglect; lack of appropriate action taking place
- Multiple acts; an adult at risk may be neglected and also financially abused
'The Abuser'
It is important to recognise that the ‘abuser’ could be anyone, including friends, relatives, family members, other Service Users, professional paid staff, volunteers and persons unknown to the adult at risk. They may also themselves be an adult at risk.
'Exploitation'
Exploitation is exerting undue influence or forcing an adult at risk to perform services for the benefit of others.
'SIGNIFICANT HARM’
The Law Commissioner’s Green Paper ‘Who Decides’ 1997 builds on the concept introduced in the Children Act, 1989 and suggests:
"Harm should be taken to include not only ill treatment (including sexual abuse and forms of ill treatment that are not physical); but also the impairment of, or an unavoidable deterioration in physical or mental health, and the impairment of physical, intellectual, emotional social or behavioural development.”
'No Secrets' also uses the concept of significant harm. This refers to:
- Ill treatment
- Impairment of physical or mental health
- Impairment of physical, intellectual, emotional social or behavioural development
'No Secrets' puts forward the following factors to be taken into account when making an assessment of the seriousness of the risk to the person:
- Vulnerability of the person
- Nature and extent of the abuse or neglect
- Length of time the abuse or neglect has been occurring
- Impact of the alleged abuse
- Impact of the alleged abuse
- Risk of repeated or increasingly serious acts of abuse or neglect
- Risk that serious harm could result if no action is taken
- Illegality of the act
D. Categories of abuse: signs and possible indicators
Physical Abuse
Is the physical mistreatment or non-accidental injury of an adult. Some possible signs of abuse are detailed as follows:
- Slapping
- Kicking
- Punching
- Shaking
- Bruising
- Burns
- Cutting
Indicators of possible physical abuse may include, but are not limited to:
- An injury not fitting the explanation given
- Unexplained or unusual fractures in various stages of healing
- Bruises or burns in the shape of objects e.g. cigarette burns, belt buckles or water
- Bruising in well protected areas e.g. behind the ears, on face, inside of the upper arms or thighs, buttocks, breasts, genital or rectal area
- Lacerations
- Unlawful or inappropriate use of restraint and/or deprivation of liberty is physical abuse
Neglect or Acts of Omission
This includes deliberate refusal to meet basic needs. Signs of neglect can include individuals experiencing the following:
- Lack of choice, denied diversity
- Poor judgemental attitudes
- Derogatory terms used about the adult or their situation
- Failure to ensure appropriate privacy and dignity
- Poor surroundings e.g. neglect of repairs, inadequate heating
- Over or under protective practices
Behaviour that can lead to neglect includes:
- Ignoring medical or physical needs
- failing to allow access to appropriate health, social and educational services
Indicators of possible neglect or omission may include, but are not limited to:
- Loss of weight
- Clothing in a poor condition
- Failure to access appropriate health, educational services or social care
Unintentional neglect could result from a professional failing to meet the needs of the adult at risk because they do not understand the needs or may not know about the services available. It may also occur if the individuals are unaware of or do not understand the possible effect of the lack of action on the adult at risk.
Psychological or Emotional Abuse
This includes threats of harm, abandonment, isolation or humiliation which may result in the adult feeling in low mood, undervalued and perhaps unnecessarily dependant.
Some ways in which psychological/emotional abuse can take the form of are detailed below:
- Failure to respond adequately to emotional needs
- Failure to protect from the emotional abuse of others
- Harassment or humiliation (bullying)
- Intimidation
- Failure to meet cultural requirements
- Unreasonable demands
- Denial of choice
- Controlling or creating over dependence
- Verbal abuse
- Cyber bullying
- Mental distress
- Negating the right of the adult at risk to make choices and undermining their self esteem
- Isolation and over dependence
Indicators of possible psychological or emotional abuse may include, but are not limited to:
- Low self esteem
- Tearfulness
- Alteration in psychological state e.g. may appear to be withdrawn, agitated or anxious in general
- Aggressive or challenging behaviour
- Attention seeking behaviour
- Self harm
- Depression
- Insomnia
- Unexplained paranoia
Sexual Abuse
This is the involvement of any individual in any sexual activity to which they either cannot or have not given their consent or does not truly comprehend and so cannot give consent. Or where the other party is in a position of trust, power or authority and uses this to override or overcome lack of consent. Sexual abuse includes:
- Rape or sexual assault
- Inappropriate touching
- Fondling
- Sexual intercourse/buggery or attempted sexual intercourse/buggery
- Inflicting pornography on an individual
- Offensive or inappropriate language including sexual innuendos and sexual teasing
Indicators of possible sexual abuse may include, but are not limited to:
- Change in usual behaviour
- Overt sexual behaviour/language
- Bleeding or pain in the genital/rectal area
- Disturbed sleep pattern
- Torn, stained or bloody underwear
- Self‐harming
Financial or Material Abuse
This can be considered as unauthorised extraction of the adult at risk’s resources or their resources being withheld or misused by someone else and including:
- Misuse, embezzlement or theft of a person’s money, property or possessions
- Failing to account satisfactorily for the use of a person’s money, property or possessions, fraudulent use of money
- Extortion of money, property, possessions through theft
Indicators of possible financial or material abuse may include, but are not limited to:
- Lifestyle does not reflect known income
- Unexplained withdrawals from account
- Unexplained/sudden inability to pay service charge/bills etc.
Financial abuse is a crime.
Discriminatory Abuse
The inappropriate treatment of an adult at risk because of their age, gender, race, religion, cultural background, sexuality, disability, etc.
Discriminatory abuse exists when values, belief or culture result in a misuse of power that denies opportunity to some groups or individuals.
Discriminatory abuse links to all other forms of abuse and can include:
- Unequal treatment
- Inappropriate use of language:
- Racist remarks
- Sexist remarks
- Derogatory remarks or verbal abuse
- Comments about disability
- Bullying or other forms of harassment
- Deliberate exclusion
Indicators of possible discriminatory abuse may include, but are not limited to:
- Inappropriate remarks or comments
- Lack of respect shown to people
- Staff member/volunteer may avoid being with certain groups of people
Institutional Abuse
Institutional abuse is the mistreatment or abuse or neglect of an adult at risk by individuals within an organisational setting where routines, systems and practices result in denying, restricting or curtailing the dignity, privacy, choice, independence or fulfilment of an adult at risk.
A number of inquiries into institutional abuse have shown that abuse is most likely to occur when staff:
- Receive little support from management
- Are inadequately trained
- Are poorly supervised
- Receive inadequate guidance
E. Key Principles
The most important priority is to ensure that the most urgent medical and welfare requirements of the adult at risk are met.
Preserve any potential forensic opportunities, record verbatim the disclosure made by the adult at risk.
Any sexual activity that is not freely consented to is criminal and should be reported to the police immediately, before any internal investigation.
Sexual relationships, or inappropriate sexual behaviour between a member of staff (or volunteer) and a service user are always abusive and will lead to disciplinary hearings. This will be in addition to any criminal actions taken.
A sexual relationship between the service user and a care worker is a criminal offence under Sections 38-42 of the Sexual Offences Act 2003.
There may be Safeguarding Adults referrals that involve sexual innuendo or remarks that will not result in a criminal investigation; however, all Safeguarding Adults referrals that indicate any form of sexual abuse require a risk assessment, intelligence gathering and appropriate information sharing with relevant partners.
F. Responsibilities
Duty Of Care
All staff & volunteers of Luminary have a ‘duty of care’ towards those who use our services.
This means taking action whenever there is a concern of possible mistreatment or abuse to an adult at risk. The procedural guidelines supporting this Policy are intended to provide a good practice framework and to support staff; staff are therefore expected to comply with them.
Failure to report any concerns may be viewed as being negligent or agreeing with the abuse, which in some cases could lead to disciplinary action.
All staff should:
- Be aware that they must call the police/ambulance where appropriate
- Share their concerns with appropriate colleagues and seek advice and support unless they are implicated in the abuse
- Know they must inform the appropriate safeguarding officer as per escalation chart
- Know that they must make a clear, factual record of their concern and the action taken using the Safeguarding Incident Reporting Form
In addition, Support Workers & Safeguarding Staff should:
- Know what services are available and how to access help and advice
- Know how and where to make a referral via Adult Social Care
Responsibility of Managers:
- To ensure that the alleged victim is safe
- To ensure that any staff or volunteer who may have caused the harm is not in contact with service users and others who may be at risk
- To ensure that information is provided in a timely manner
- Operate safe recruitment practices and ensure reference checks are made
- Support staff who raise concerns
Monitoring
Safer Recruitment
All staff who work in a support-work capacity with our service users are subject to an enhanced disclosure check from the Disclosure and Barring Service.
For any team recruitment, an interview should be conducted, and two satisfactory references received, to assess an applicant’s suitability prior to an offer of employment or volunteering being made. On appointment staff and volunteers serve a probationary period for performance monitoring.
Volunteers within projects are recruited within the same processes as those for paid members of staff.
The named Safeguarding Adults Co-ordinator (SAC)- Alice Williams (Luminary CEO) will monitor any concerns and keep a record of safeguarding prompt logs compiled by staff. The SAC will report to the Charity Board on a quarterly basis.
G. Training
This policy and associated procedures are to be rolled out across Luminary through in- house training and in addition staff may access local authority Safeguarding Adult training.
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