Safeguarding Policy

Edward Goredema
Jun 2
17 min read

Revised February 2025, to be reviewed February 2026

Introduction

The intention of this policy is to safeguard the people who use our services from

suffering any form of abuse or improper treatment while receiving care and

treatment. This policy shows how The Warren Neurodiversity Service protects its

patients from abuse or harm in line with its legal requirements and best safe

guarding practice guidance. It reflects in particular:

• Regulation 13: Safeguarding Patients from Abuse and Improper Treat

ment of the Health and Social Care Act 2008 (Regulated Activities)

Regulations 2014

• The statutory guidance for the Care Act 2014 (Chapter 14: Safeguarding),

which describes the duties and responsibilities of local authorities and its

partner organisations to protect adults with care and support needs from

abuse, neglect and other sources of harm, and to make enquiries if they

suspect or have evidence of people being abused.

• More specifically, it also reflects the (local safeguarding adults’ authority)

policies and procedures.

• The Warren Neurodiversity Service shares and is committed to the vision of

the local safeguarding authority, which is to empower and protect adults

who are at risk of abuse and neglect, as defined in legislation and stat

utory guidance.

The Warren Neurodiversity Service understands that local safeguarding ar

rangements and developments follow a government strategy based on. All

adult safeguarding should reflect the following principles:

• Empowerment – supporting people to make decisions and have a say in their care

• Protection – support and representation for those in greatest need

• Prevention – it is better to take action before harm occurs

• Proportionality – safeguarding must be built on proportionality and a

consideration of people’s human rights

• Partnership – local solutions through services working with their communities

• Accountability – safeguarding practice and arrangements should

be accountable and transparent.

Improper treatment includes discrimination or unlawful restraint, which in

cludes inappropriate deprivation of liberty under the Mental Capacity act

2005. We take a zero-tolerance approach to abuse, unlawful discrimination

and restraint which includes:

• Neglect

• Subjecting people to degrading treatment

• Unnecessary or disproportionate restraint

• Deprivation of liberty

We recognise that safeguarding involves a range of responses to different forms

of abuse and potential sources of harm and the different contexts in which

abuse occurs. Accordingly, this policy should be read and used in association

with a suite of policies all designed to make sure that users are safe from abuse

and the risks of their coming to harm are kept to the minimum and well man

aged.

Aims

The central aim of this safeguarding policy is to set out:

• Principles and values underlying this service’s approach to the safeguarding of its service users

• Steps taken to avoid abuse/harm taking place

• Actions taken to deal with abuse/harm if it occurs

• How it learns from incidents of abuse to prevent reoccurrence.

The Warren Neurodiversity Service works on the principle that it is the right of

vulnerable patients to be kept safe from all forms of abuse/harm. Being and

feeling safe will contribute a great deal to their wellbeing and quality of life.

Therefore, we recognise it must always protect our patients identify and deal

with specific instances of abuse/harm if they occur, following the required procedures and best practice guidance. The Warren Neurodiversity Service is always aiming for the very best quality of care and will not be satisfied with anything that falls short of this. It takes every possible action to prevent abuse/harm and associated risks and to deal with the issues as promptly and effectively as possible when they arise.

The Warren Neurodiversity Service seeks to work in line with local safeguarding

adults’ authority policies and procedures (or, in relation to services to children

and families, to work in line with local safeguarding children authority policies

and procedures) and guidance from the Care Quality Commission (CQC). It

recognises the importance of government and national guidance and seeks to

comply in all respects with current safeguarding legislation and regulations.

The Warren Neurodiversity Service recognises that patients who lack mental capacity are particularly exposed to abuse/harm and exploitation. It is accordingly mindful of the need to follow the principles and practice guidance that has accompanied the Mental Capacity Act 2005. These apply particularly to investigations of possible abuse/harm in which it is important to seek means of ascertaining the experiences and views of any victim, or indeed alleged perpetrator who might lack capacity, eg through the services of independent advocates.

The Warren Neurodiversity Service recognises anyone who needs the help of

an independent advocate, when engaged in safeguarding enquiries, is entitled

to one (as legislated for by the Care Act 2014). It will always support a person

to have advocacy help where required in line with its (separate) advocacy

policy.

The Warren Neurodiversity Service has all required systems in place to track and

monitor incidents, accidents, disciplinary action, complaints and safeguarding

concerns, and to identify patterns of potential abuse/harm to its patients.

References:

This Policy will also be consistent with and mindful of a range of legislation and

guidance. Notably including:

Adults at Risk

• Modern Slavery Act 2015

• Care Act 2014

• Domestic Violence Crime and Victims (Amendment) Act 2012

• Human Rights Act 2008

• Mental Capacity Act 2005

Defining Abuse

Adults at Risk

Aged 18 years or over; Who may be in need of community care services by rea

son of mental or other disability, age or illness; and who is, or may be, unable to

take care of him or herself, or unable to protect him or herself against significant

harm or exploitation.

Safeguarding

Safeguarding and promoting the welfare of adults at risk can be defined as:

• Protecting vulnerable individuals from maltreatment

• Preventing impairment of vulnerable individuals health or care

• Ensuring that adults at risk are living in circumstances consistent with the provision of safe and effective care

• Taking action to enable all adults at risk to have the best outcomes

Types of abuse

Types of abuse that can given rise to safeguarding concern can be described as:

• Physical abuse

• Domestic abuse

• Sexual abuse

• Psychological abuse

• Financial or material abuse

• Modern slavery

• Discriminatory abuse

• Organisational abuse

• Neglect and acts of omission

• Self neglect

Safeguarding commitment

• Be able to recognise and respond appropriately to any potential or actual threat to the wellbeing of the child, young person or adult at risk.

All of our employees who are in contact with our commercial clients, patients and their families members have a responsibility to:

• Protect the welfare of children, young people and adults at risk;

• Safeguard any child, young person or adult at risk;

and

• Protect from abuse and improper treatment in accordance with this policy and

regulations.

• Establish and effectively operate within the processes to investigate, immediately upon becoming aware of any allegation of such abuse.

• Where appropriate we will follow national and local safeguarding arrangements.

We will ensure that:

All front-line employees are trained to recognize the signs of a person who could be at risk / suffering neglect and/or abuse

• We know our customers and hold up to date customer data

• We are assertive in working with statutory agencies

• We have and will continue to implement and update robust process and procedures that make sure service users and all parties involved are protected

• Induct new staff members with safeguarding training that is suitable and relevant for their role, with continual CPD and training for all staff members

• Train staff to be aware of their individual responsibilities to prevent, identify and report abuse when providing care and treatment

• Review incidents and complaints to identify potential abuse, take preventative action, and escalate where appropriate

• Work within the requirements of the Mental Capacity Act 2005 when working with people who may lack the mental capacity to make certain decisions

• We will know, understand and internally update local safeguarding arrangements so that all staff are aware and can act appropriately

• Recruit the right people into the business to ensure that we mitigate any risk of safeguarding incidents, this is covered within our recruitment policy. Management has the responsibility to ensure that all staff members have the correct experience, qualifications, DBS checks and references in place prior to any employment contract offers made.

• Ensure that when creating or reviewing care plans for service users, that the risk assessments include safeguarding factors such are money management, manual handling and their ability to consent.

Identifying Abuse

The Warren Neurodiversity Service accepts that abuse/harm can be committed by a range of possible people. It therefore accepts its responsibility to protect its patients from possible abuse from all sources, which include:

• The staff and management of The Warren Neurodiversity Service

• Volunteers working in The Warren Neurodiversity Service

• Visiting health and social care practitioners and other official visitors to the person’s home

• Patient’s relatives and friends

• People who have contact with patients

The Role and Accountability of Staff

The Warren Neurodiversity Service insists that all its staff have a responsibility to:

• Report any incidents of abuse or potential abuse to an appropriate manager

• Respect people’s privacy, dignity and human rights always, and treat people with sensitivity, respect and thoughtfulness, adhering to individual care programmes

• Understand their individual responsibilities in preventing discrimination

in relation to protecting the protected characteristics set out in the Equality Act 2010.

• Regularly monitor and review the approach to, and use of, restraint and restrictive practices.

• Take all reasonable steps to make sure patients are not subject to any

degradation or treated in a manner that may be viewed in a degrading way.

• Always deliver care and treatment that enables all Patient’s needs to be met in accordance with their set needs and preferences

• Act always in accordance with the Mental Capacity Act 2005 Deprivation of Liberty safeguards

• Wherever possible support people's independence and freedom of choice

• Comply with and implement the home’s policies and procedures

• Act within the limits of their training at all times

The Warren Neurodiversity Service requires its Managers have a responsibility to:

• Develop the systems and structures within which it is possible to deliver the best possible care

• Encourage a culture and ethos that is hostile to any sort of abuse/harm

• Produce and regularly revising the policies and procedures to prevent and deal

with abuse

• Operate personnel policies which identify, appropriately deal with and, if necessary, exclude from practice potential or actual abusers

• Provide training and guidance as appropriate and ensure the attendance of staff on induction, briefings, ongoing training and updates as required which will usually be annually or sooner if needed. This will include role play of safeguarding scenarios and testing their knowledge

of how to deal with them and what they would do if an incident occurred.

• Investigate any evidence of abuse/harm speedily and sympathetically

• Implement improvements to procedures if an enquiry into abuse/harm reveals deficiencies in the way in which the service operates

• The Safeguarding lead will take the ultimate decision on suspensions in relation to staff conduct where this is not clear from an HR perspective.

• All safeguarding incidents will be reviewed by the Registered manager in team meetings with other members of the management teams to discuss lessons learned, policy and procedure reviews to integrate preventative actions moving forward.

• All incidents will be shared with staff to educate them in how to deal with these scenarios moving forward. This is integral to the continuous improvement within the service and form part of ongoing training for the staff.

• Collaborate with all other relevant agencies in combating abuse/harm and improving the safeguarding and protection of patients

• Liaise with the relevant safeguarding adults/children authority teams and following their guidance and instructions where applicable, including the issues arising from multi-the clinic involvement

• Notify the Care Quality Commission of all instances of abuse, alleged or suspected abuse, using CQC’s online reporting procedures.

Recruitment Practices

The Warren Neurodiversity Service takes great care in the recruitment of staff,

carries out all possible checks on recruits to ensure that they are of a high

standard and co-operates in all initiatives regarding the sharing of information on staff members who are found to be unsuitable to work with people at risk.

The clinic ensures that new employees employed in regulated activity have

been checked against the Disclosure and Barring Service (DBS) criminal records and barred lists in line with the current requirements.

Preventing Abuse from Occurring

The Warren Neurodiversity Service is committed to taking all possible steps to

prevent abuse or harm of service users from occurring, including:

• Setting out and making widely known the procedures for responding to suspicions or evidence of abuse/harm

• Operating personnel policies which ensure that all potential staff in regulated activity are rigorously checked, by the taking up of references and clearance through DBS criminal records and barred list checks, with equivalent checks for staff employed from

• Incorporating material relevant to abuse/harm into staff training at all levels

• Maintaining vigilance concerning the possibility of abuse/harm of service users from whatever source

• Encouraging among staff, service users and all other stakeholders a climate of openness and awareness that makes it possible to pass on concerns about behaviour that might be abusive or that might lead to abuse/harm

• Maintaining effective procedures for regulating any contact that staff members need to have with service users’ property, money or financial affairs

• Communicating concerns to the local Adults’ Safeguarding Board or, where applicable, Safeguarding Children Board

• Helping service users as far as possible to avoid or control situations or relationships that would make them vulnerable to abuse/harm.

Identifying Abuse

• The Warren Neurodiversity Service will identify any instances of actual

or possible abuse/harm involving our service users by all possible

means including:

• Fostering an open and trusting communication structure so that staff, patients and others feel able to discuss their concerns with someone authorised to take action

• Ensuring that all staff and patients know whom they may turn to for advice and action if they become aware or suspect that abuse/harm is occurring

• Encouraging staff to recognise that a commitment to the highest possible standards of care must, when necessary, overrule loyalty to colleagues individualy or corporately

• Making it clear to staff that failing to report incidents or suspicions of abuse is itself abusive and may lead to disciplinary or criminal proceedings

• Operating systems of management, supervision, internal inspection and

quality control that have the potential to reveal abuse/harm where it exists.

Procedures For When Abuse Has Occurred

If abuse/harm is clearly occurring or is alleged to have occurred, the Service

takes swift action to limit the damage to service users and to deal with the abuse, as follows.

Initial procedures

A staff member who witnesses a situation in which a patient is in actual or imminent danger must use their judgment as to the best way to stop what is happening without further damage to anyone involved, including themselves, either by immediately intervening personally or by summoning help, which could include phoning the police on 999.

Any staff to whom actual or suspected abuse/harm is reported — usually the

manager or a senior staff member — must immediately act to protect, support

or arrange additional care to a patient who has been harmed.

The manager will discuss with the known or suspected abused/harmed person

what actions they consider to be appropriate. In some circumstances, the per

son might not wish any action to be taken or agree to a referral being made

on their behalf (though this would not apply to children).

In such cases, the manager will consider whether there are reasons for overriding the person’s wishes, eg because it is in the public interest and to prevent further harm or because the harmed individual is a child. This could include seeking advice from the Safeguarding Adults’ Authority or Safeguarding Children Authority.

Any adult “victim” whom it is thought might lack mental capacity to give their

consent for the abuse/harm to be reported will be assessed for their capacity

to decide and a “best interests” decision will be taken in line with Mental Capacity Act procedures.

Once a person has consented to further action being taken, or for someone

unable to give their consent, it has been decided that it is in their best interests

to do so, the senior staff member or manager (or whoever has authority at the

time) will then alert the local Safeguarding Adults’ Authority or Safeguarding

Children Authority and follow its procedures and guidance from that point on.

This could involve a strategy meeting and a safeguarding plan to be implemented from the strategy meeting.

The specific procedures to be followed and referral forms are those available on the local SAB website.

In some instances, the registered manager/person responsible for safeguarding might need to report the matter directly to the police and take guidance from them on the measures to be taken.

The registered manager must ensure that there is no further risk of the victim being

harmed further.

The registered manager must address the needs of the alleged victim of the

abuse/harm for any special or additional care, support or protection or for

checks on health or wellbeing as set out in the person’s safeguarding plan.

If the alleged abuser is a staff member and there is sufficient evidence that

abuse/harm has or might have occurred, the manager will suspend the person

from duty pending the outcome of a disciplinary investigation. The manager will

receive guidance on the steps to be taken following the local safeguarding

adults/children authority strategy meeting, which will be held following the

reporting of the abuse or suspected abuse/harm.

If the evidence is insufficiently strong to warrant suspension, the staff member

against whom the allegation has been made will be instructed not to have

further unsupervised contact with any service users until the matter is resolved.

However, it should be noted that in the event of a referral being made to the

police because a criminal offence might have been committed the police investigation will take precedence and no action should be taken that might jeopardize its enquiries, which might contaminate the evidence it is seeking and collecting.

Investigating Alleged Abuse

Investigations are based on a person-centered approach in which the wellbeing of the victim or alleged victim is the central focus of all the activities involved. In many cases, enquiries will be carried out or led by a member of an external the clinic in line with the action plan determined by the initial strategy meeting convened by the local SAB or Safeguarding Children Authority. If a

staff member is expected to carry out an enquiry of its own, it will proceed as

follows.

The person appointed to make the enquiries will usually consult the person who

may have been abused/harmed to hear their account of what has occurred and their views about what actions should be taken, involving service users’ relatives, friends or representatives if that is appropriate and in line with the wishes of the service user.

The enquiries should take into account:

➢ The fears and sensitivity of the abused/harmed person

➢ Any risks of intimidation or reprisals

➢ The need to protect and support witnesses

➢ Any confidentiality or data protection issues

➢ The possible involvement of other agencies, including the police, local safeguarding team and the CQC

➢ The obligation to keep the abused/harmed person and, in specific in

stances, the alleged perpetrator informed on the progress of the investigation.

It will be important to assure the person who may have been abused/harmed that they will be taken seriously, that their comments will as far possible be treated confidentially, that they will be protected from reprisals and intimidation, and that they will be kept informed of actions taken and of the outcome.

It is important to consider if the patient needs independent help or representation, including the services of an independent advocate, in presenting their evidence. The service manager will, if necessary, arrange for the appropriate help or support to be made available.

If the abused/harmed person expressly states a wish that no further action should be

taken, the safeguarding enquiry will consider if:

➢ a danger to others exists from not investigating further

➢ in the light of that assessment it is possible to follow the person’s wishes

➢ in any case precautionary measures should be taken to protect others

from the possibility of abuse from the same source

➢ the person will be informed of what is to happen.

Once decided that enquiries should proceed, they will look into all aspects of

the situation discreetly and respecting their sensitive and confident nature.

The enquiry could include interviewing the staff involved in the incident or circumstances up to that point, hearing and assessing evidence from any others who might be in a position to supply information, exploring every other possible source of evidence, maintaining appropriate contact with any other agencies involved, and if necessary seeking expert advice on any technical aspects of the situation which are outside the knowledge or expertise available within the service.

Any staff from whom evidence is taken will be assured that they will be dealt

with in a fair and equitable manner and informed of their employment, legal

and procedural rights.

The alleged victim of the abuse/harm, and where appropriate their relatives,

friends or representatives, will at all times be kept as fully informed as possible of

what is happening regarding the suspected abuse/harm.

The enquiry will be carried out within an agreed timescale.

The findings will usually be presented to the local safeguarding adults/children

strategy group, which will then decide what further action to take, eg that a

safeguarding plan should be developed and implemented.

Whistleblowing

Staff members who wish to report a safeguarding concern anonymously can

do so by using an anonymous reporting form. The business will ensure that the

anonymity of the whistleblower is protected throughout the process. The reporting form will require as much detail about the incident as possible including the

following:

➢ Patient name, date and time of the findings

➢ The category of safeguarding concern

➢ Any conversations had with the patient that is relevant to this concern

➢ What actions have been taken to ensure they are not in any immediate danger

➢ Names and details of any other parties involved.

We actively encourage all staff members to come forward and have a discussion with any of the management team or the registered manager directly regarding safeguarding concerns. We will look to protect the identity of those who report incidents and take all information and reporting seriously.

Following the Investigation

If it seems from the enquiries that on the balance of probabilities

abuse/harm did indeed take place, the manager will, if the abuser is a staff

member, initiate and carry through proceedings according to the clinic’s disciplinary policy or, if the abuser is not a member of staff, take action to involve other responsible bodies.

If abuse/harm is proved against a staff member, the manager will initiate ap

propriate action, which most likely will be dismissal and referral to the DBS to

prevent them from being employed further in regulated activity.

Other employment sanctions could apply depending on whether there might

have been mitigating or extenuating circumstances. In some cases, retraining

could be appropriate.

The patient or representatives will be informed of the outcome of the investigation and any further action and will be consulted about whether any redress or apology would be appropriate and helpful to them in line with the service’s duty of candor.

The manager will take appropriate steps to inform the DBS for possible inclusion of the person on its barring lists as someone who is unsuitable to work again in regulated activity with at risk adults and/or children.

At all stages of the process, a careful record will be kept of all actions taken,

paying particular attention to the sensitivity of the abused/harmed person.

Where relevant to the resolution of the situation, a plan will be drawn up to

address the issues with the alleged or known perpetrator(s), particularly if

they will be continuing to form part of the victim’s life, directly or indirectly.

Planning Further Action

At the end of an incident involving possible or actual abuse/harm, managers

should review what has happened with a view to assessing whether the clinic

or its management has been in any way culpable, ineffective or negligent,

learning lessons for the way the clinic should operate in the future, and passing on any appropriate information to other agencies.

If necessary, the service will review and revise its policies, procedures and training arrangements in response to any material that has emerged from the incident or the investigation.

The service could carry this out with advice and guidance from the local Safeguarding

Adults’ Authority or Safeguarding Children Authority.

Record Keeping

The Warren Neurodiversity Service will record all details associated with allegations of abuse/harm clearly and accurately. The records are kept securely and

the clinic's rules on confidentiality are carefully followed. Reports are made as

required to the CQC and other safeguarding agencies involved.

Legal Requirement

The Warren Neurodiversity Service will comply with its legal requirement to refer

a staff member, where it has evidence that the staff member in question has

been guilty of misconduct by harming or putting at risk of harm a patient or

other person at risk, during the course of their work, to the DBS barred lists fol

lowing the procedures issued by the DBS.

Training

All staff receive training in recognising abuse or harm and carrying out their

responsibilities under this policy as part of their induction program and further training in line with their training needs as identified from their supervision and appraisals and policy developments and changes. The training is updated on a regular scheduled basis at least annually.

All training, including induction training, is in line with the guidance and

standards produced by the relevant social and healthcare workforce development organisations and the local safeguarding authority training policies and guidance.

The Warren Neurodiversity Service will check their knowledge and competencies to ensure it meets the required standard and provide additional training if

needed.

All staff following induction are expected to proceed to at least a Foundation

Level 2 award and a (Level 3) training in safeguarding.

Managers and staff responsible for safeguarding are required to receive Specialist Safe

guarding Training (Level 4) and, where appropriate, to their roles and responsibilities,

achieve the Safeguarding Leaders Development Program (Level 5).

Local Authority: Surrey

Reporting Concern of a child, contact number: 0300 470 9100

Reporting Concern for an adult, contact number: 0300 470 9100

Out of Hours Contact Number: 01483 517898 (Duty team)

Email: cspa@surreycc.gov.uk (Child)

Email: ascmash@surreycc.gov.uk(Adult)