Terms and conditions

Sensory Services by Sight for Surrey believes everyone has the fundamental right of living a life that is free from harm and abuse. We are committed to preventing abuse and harm and will always put any adult at risk, or in need, at the centre of the services we deliver.

Every organisation and person who meets an adult who could be considered to be vulnerable has a duty and role to play to help keep them safe and to protect them from harm. We know this cannot be achieved by any single organisation.
We will always promote the wellbeing of adults we offer services to and will always recognise that each person’s needs are different and respond accordingly.
We will ensure that adults at risk or in need are kept at the centre of safeguarding and recognise that it is the person not the process that determines the safeguarding work we do.

If abuse or neglect takes place or is suspected, we will act swiftly, effectively and in ways which are proportionate to the concerns that have been identified.
This policy is for those working with adults who are aged 18 years and above. All adults, regardless of age, disability, gender, racial heritage, religious belief and sexual orientation or identity have the right to protection from harassment, harm, neglect, or abuse.

We recognise that people are not a homogenous group, and their individual needs and their experiences of abuse and neglect will be unique to them.
We recognise that some groups of people could be exposed to additional challenges or disadvantages, leading to multiple layers of disadvantage and greater risks. For example, people who experience sensory impairments.

We recognise that adults with capacity have the right to make their own choices, even where these choices may appear to be unwise, or those that put them at risk of harm. In recognising when a person is making an unwise choice, we will always consider the risk of coercion.

This policy is written for anyone that works for Sensory Services by Sight for Surrey, these are both paid employees and unpaid volunteers including Trustees.

1.
Safeguarding Commitment
Our commitment is to safeguard all those we provide services to, and those who work with us. Where someone is in touch with, or supported by, multiple agencies, we will share the responsibility for the protection of vulnerable adults as we know people are safeguarded only when we all accept responsibility and cooperation with one another.

We will ensure that our safeguarding policies, procedures, and processes, which all who work for us will have access to, are up to date and are strengthened by good practice briefings.

We will create and maintain a culture of safety, with an environment that all people feel valued and respected by, where people are encouraged and supported to raise concerns about their own safety and wellbeing and that of others.

We will abide by the statutory duties set out by the Care Act, Government legislation and Surrey Safeguarding Adult’s Board. Safeguarding policies, procedures and processes will provide a clear framework for raising concerns or worries about a vulnerable adult and will be read and understood by everyone.
Anyone that holds a position with us where they are in regular contact with adults who could be vulnerable will have an Enhanced Disclosure and Baring Service (DBS) check, alongside an interview and reference checks, to ensure that they are suitable and not disqualified from working with vulnerable adults.

Any individual who is suffering from, or at risk of suffering from, significant harm is identified, and appropriate action is taken to see that they are kept safe, or fully aware of the risk and supported to make a decision regarding this risk.

All those holding positions of responsibility and trust, whether paid or unpaid, clearly understand the need to maintain appropriate boundaries when supporting and or providing a service to adults, who could be vulnerable.

Disclosures about abuse or neglect, and allegations against a person in a position of trust, will always be taken seriously and reported in line with our procedures and with due regard to the privacy of the individual.

2.
Six Safeguarding Principles
We recognise safeguarding must be person led, focused on real outcomes, and will always endeavour to empower people to make their own choices.
We recognise the following principles in all the work we do:

• Empowerment – to support and encourage people to make their own decisions and to have informed consent.
• Prevention – to act before harm occurs.
• Proportionality – to adopt the least intrusive response appropriate to the risk presented.
• Protection – to support and represent those in the greatest need.
• Partnership – to seek local solutions through services collaborating with their communities, to prevent, detect and report neglect and abuse.
• Accountability – to always be accountable and transparent in safeguarding practice.

3.
Policy Scope
Safeguarding is everyone’s responsibility. This policy applies to all team members that work for Sensory Services by Sight for Surrey, both as paid employees and those who are volunteers and Trustees.

We will ensure that everyone who works for us (paid and unpaid) and/or in a position of trust undergoes a safer recruitment procedure and this is reflected in everyday practices. Everyone will be inducted and receive training in safeguarding policy, procedures, and processes.

We will recognise that adults with capacity have the right to make their own choices, even where these choices may appear to be unwise, or those that put them at risk of harm. In recognising when a person is making an unwise choice, we will always consider the risk of coercion.

Where people may be of concern, but do not come under what would be considered as a formal safeguarding concern, we will support and signpost them to other services which are able to provide the support they require.

4.
Roles and responsibilities
Everyone has the responsibility to safeguard vulnerable adults and promote wellbeing.

We recognise that it is better to report a potential issue or concern and for it to be unfounded, rather than not to report something that could potentially lead to the harm of a vulnerable adult.

5.1
All employees and volunteers, including Trustees must:
• Read, understand, and adhere to Safeguarding Adults Policy and Procedures.
• Take all reasonable actions to prevent abuse and neglect.
• Able to identify signs of abuse and neglect.
• Understand what is expected if they become aware that an adult is experiencing or is at risk of abuse or neglect.
• Understand how to report it accurately to their line manager and/or the Designated Safeguarding Lead/Deputy.
• Escalate to a Senior Manager any suspicion that a colleague may be a potential perpetrator of abuse or neglect.
• Ensure accurate record keeping is maintained in line with SFS policies and procedures. Located: Staff Information – Current Policies Manuals.
• Complete the appropriate level of training and learning to maintain knowledge and skills expected of your role.

5.2 Senior Management and Line Managers must:
• Ensure that everyone you manage (including volunteers) understands and adheres to the Safeguarding Adults Policy and Procedures.
• Ensure that everyone you manage (including volunteers) recognises the signs and indicators of abuse or neglect and understand their responsibility to prevent abuse and neglect.
• Provide advice, support on safeguarding concerns, and know when to seek guidance from the Designated Safeguarding Lead on referrals to the local authority and what other actions may be needed to mitigate risk.
• Ensure appropriate investigations and timely action is taken for all safeguarding concerns and enquiries.
• Oversee the recording of incidents, alerts, grievances, and complaints ensuring the correct reporting procedures are used.
• Act on what we have learnt, and help team members to do so, to promote continuous improvement.
• Provide support to team members in their roles who are supporting victims of abuse and neglect, both formally through One to One’s/supervision, reflective spaces, and informal structures.
• Provide the capacity, with a budget for team members to attend the appropriate level of training and/or to host this training in-house where appropriate.
• Ensure compliance of SFS training standards.
• Create a culture of safety, providing a safe and trusted environment enabling open dialogue and prioritising safeguarding.
• Be aware of the Surrey Safeguarding Adults Board/ Surrey Adult Safeguarding Policy and Procedures.

5.3 Designated Safeguarding Lead (DSL) (Deputy is the appointed named manager in the absence of the DSL) must:
• Have oversight of the advice and support on all adult safeguarding concerns.
• Help support the decision making around whether it is appropriate to refer to the local authority (as a Care Act Safeguarding concern) and what other actions may be needed to mitigate the risk.
• Ensure the Safeguarding Adults Policy and Procedures is reviewed annually.
• Complete full reviews of safeguarding concerns and enquiries and identify lessons learned to inform and shape best practice.
• Regularly monitor and evaluate the impact of the interventions and capture any learnings which are then reported to the quarterly safeguarding meeting.
• Provide advice for managers when supporting victims or alleged perpetrators, alongside HR input, where required.
• Represent the organisation at strategic multi agency forums to keep abreast of best practice.

Please see Appendix C Designated Safeguarding Leads and Contact Details

5.4 Board
• Provide the strategic governance of Adult Safeguarding.
• Ensure there is a Designated Safeguarding Trustee on the board with oversight of safeguarding who meets periodically to monitor and review safeguarding concerns.
• Ensure that safeguarding has an appropriate place on the board agenda and in governance plans.

6.
Legislative Framework
Safeguarding policies are written in the context of Government legislation alongside the local context of the service. The following frameworks that apply to safeguarding policies and procedures:
• The Care Act 2014
• The Care and Support Guidance
• Mental Capacity Act 2005 (MCA)
• Safeguarding at Risks Groups Act 2006
• The Human Rights Acts 1998
• The Public Interests Disclosure Act 1998
• Protection of Freedom Act 2012
• The Equality Act 2010

We primarily work in the county of Surrey.

Please see Surrey Safeguarding Adult’s Board recommendations: www.surreysab.org.uk

If a person being supported is outside of Surrey, the relevant local authorities’ procedures should be referred to.

Please see Appendix F – Safeguarding Legislative Framework for more information.

7.
What is Safeguarding?
The Care and Support Statutory Guidance issued under The Care Act 2014 from the Department of Health and Social Care states safeguarding is:
‘Safeguarding means protecting an adult’s right to live in safety, free from abuse and neglect. It is about people and organisations working together to prevent and stop both the risks and experience of abuse or neglect, while at the same time making sure that the adult’s wellbeing is promoted including, where appropriate, having regards to their views, wishes, feelings and beliefs in deciding on any action. This must recognise that adults sometimes have complex interpersonal relationships and may be ambivalent, unclear, or unrealistic about their personal circumstances.

Organisations should always promote the adult’s wellbeing in their safeguarding arrangements. People have complex lives and being safe is only one of the things they want for themselves. Professionals should work with the adult to establish what being safe means to them and how that can be best achieved. Professionals and other staff should not be advocating ‘safety’ measures that do not take account of individual wellbeing, as defined in Section 1 of the Care Act.’ Making Safeguarding Personal Making safeguarding personal means being person led and outcome focused. It engages the person in a conversation about how best to respond to their safeguarding situation in a way that enhances involvement, choice and control as well as improving quality of life, wellbeing, and safety.

We will do this by:
• Keeping the person at the heart of the process
• Making efforts to understand the outcomes they want to achieve from the safeguarding intervention and support them to achieve those.

7.1 Adults at risk
Safeguarding policy and procedures apply to adults who are included in the following definition:
• aged 18 years or more and
• have needs for care and support (whether or not these are currently being met)
• are experiencing, or are at risk of, abuse or neglect, and
• because of those needs may be unable to protect themselves against the abuse or neglect or the risk of it.

This includes adults with physical, sensory, and mental impairments and learning disabilities, whether present from birth or due to advancing age, chronic illness, or injury. Including adults who experience mental ill health, dementia or memory impairments and people who (mis)use substances or alcohol.

Contextual consideration must always be given to those who may be affected by the abuse or neglect. For example, The Domestic Abuse Act recognises the devastating impact that domestic abuse has on children and specifically provides that a child, (under 18 years old), who sees, hears, or experiences the effects of domestic abuse and is related to the victim or the perpetrator, is also to be regarded as a victim of domestic abuse. Please refer to SFS Domestic Abuse Policy and Procedures.

7.2 Definitions of Abuse
Abuse or neglect can take many forms and the circumstances and context of the individual must always be considered. It may consist of a single or repeated acts.
Abuse can take place in different settings including those that are deemed as ‘safe’ environments. Abuse can occur in any relationship. A wide range of people may harm adults, including those who hold a position of trust to the person and in wider society.

It is important to remember that abuse and neglect may not always be malicious or intended as abuse or neglect. It can occur where the carer cannot properly care for an adult in need, for whatever reason. Regardless of it not being malicious, it must still be regarded and treated as a safeguarding concern.

This is not an exhaustive list, and should anyone identify a potential concern, but find that the abuse is not identifiable on the list, they must raise the concern through the procedures in place. Any adult that expresses concern must be treated seriously and will be responded to in line with the safeguarding procedures.

The following are examples of the main types of abuse or neglect:
• Physical abuse
• Domestic violence and abuse
• Sexual abuse
• Psychological abuse
• Financial and material abuse
• Modern slavery
• Neglect and acts of omission
• Discriminatory abuse
• Organisational abuse
• Self-neglect

Those who experience abuse or neglect often experience many practical and psychological barriers when accessing support. These barriers often include feelings of shame or guilt, fear of what the perpetrator will do to them or a belief that the situation might get better.

Additional barriers of those with protected characteristics and/or language and communication may create specific challenges in communicating the abuse that further hinders them from accessing or seeking assistance.

Recognising the signs of abuse or neglect with early intervention, through working together, can help to protect adults from further harm as well as preventing escalation and recurrence of abuse.

It is imperative everyone knows how to identify the signs and indicators of abuse and neglect and maintain professional curiosity in our response. A non-judgemental, sensitive, and compassionate approach enables us to provide the right response at the right time.

Please see Appendix E Safeguarding Definition of Abuse for further information.

8.
Information Sharing
Safeguarding adults at risk of abuse or neglect can raise concerns in relation to information sharing, especially when trying to balance the rights of an adult to choice.

We recognise that adults, who have capacity, are free to make certain choices which objectively could be considered as choices that put them at risk of abuse or neglect, and they may object to further sharing of information. However, it is also recognised that there might be circumstances where despite the choices made by the adult, information can (and sometimes must) be shared in the context of safeguarding.

Building trust is of utmost importance for those who are supporting someone who has disclosed their experience to them. If someone discloses something, you must always inform the person that you must raise the concern in confidence with your manager and/or Designated Safeguarding Lead, as soon as possible.
Nobody, in any role within the organisation, should ever agree to keep a secret where this relates to someone at risk of abuse and neglect. If someone we are working with asks us if they can share in confidence, we must always explain our confidentiality policy and that sometimes we may be legally obligated to share. For example, where we have a concern for safety and potential harm.

We will always seek to gain the persons consent to share information with other services, however information may be shared without consent if there is a significant risk of harm to an adult and/or to a child. For example:
• There is a real risk of serious harm.
• There is a risk of harm to the wellbeing and safety of the adults or others.
• Other adults or children could be at risk of the person causing harm.
• It is necessary to prevent crime or if a crime may have been committed or
• The person lacks capacity to consent.

Information may also be disclosed to the police, and/or Local Authority to protect an adult or child, or if we are otherwise required to share information by law.
We use Caldicott principles as a guide to good practice when determining the sharing of information in connection with safeguarding concerns. https://www.gov.uk/government/publications/the-caldicott-principles.

The processes and the principles for sharing information between each other, with other professionals is outlined in the SFS Data Protection Policy.
We also hold an information sharing agreement to formalise the arrangements with the Surrey Adults Safeguarding Board.

9.
Record keeping
We have a responsibility to keep clear and accurate records. It is fundamental to ensure that evidence is protected, and records show what action has been taken, what decision has been made and why, in a timely manner. This is an essential part of the accountability to those who use our services.

Maintaining good records is vital to an individual’s safety. If records are inaccurate and/or not recorded on our database appropriately, future decisions may be wrong, and harm may be caused to the individual, where there is an allegation of abuse.

It is equally important to record when actions have not been taken and why. For example, if an adult with care and support needs with mental capacity chooses to make decisions that professionals consider to be unwise.

All written records will be kept in a secure area on the system and access is controlled to who needs to know and for all others it will remain confidential. They will be retained or be destroyed in line with the record management policy. Please see SFS Data Protection and Security Handbook and SFS Record Keeping Policy.

An individual can always request information held about them through the Subject Access Request (SAR) process, and records should be written with this in mind. It is also important to know that, should an adult experience a serious incident, or die, that the records relating to that person will be passed to both the Safeguarding Adult’s Board for a review, and in the case of death, it is likely that the coroner will consider the matter.

10.
Role of key agencies
Partnership working, wellbeing and empowerment is at the heart of all agencies responsibility for safeguarding adults who are vulnerable. Once a concern has been raised internally, a decision may be made to refer to another agency.
Adult Social Care is the lead agency, and the adult safeguarding team, or Multi Agency Safeguarding Hub (MASH) is the lead within the local authority for all safeguarding issues concerning an adult. The local authority will have the strategic responsibility for all matters of safeguarding.

If the risk of serious harm is so severe that urgent action is required to prevent it, police are a key partner in safeguarding and have a duty to protect the public and prevent crimes. Health services are also central to safeguarding, including mental health services.

Local authorities make enquiries, or require others to do so on their behalf, if they suspect an adult meets the following criteria:
• They have needs for care and support whether the local authority is meeting any of these needs or not.
• They are experiencing or at risk of abuse or neglect and
• As a result of those care and support need, they may be unable to protect themselves from either the risk of, or the experience of, abuse or neglect.

The local authority will assess whether they consider the individual is unable to protect themselves from either the risk of, or the experience of, abuse or neglect. Where the referral is considered to fall into this category, the local authority will take steps to actively safeguard the individual. The concern will be logged in the local authority database as a safeguarding concern and actions will be taken, this is often together with other agencies and partners.

We may be invited to work in partnership with the assessment or support the individual as part of the safeguarding response.

If the local authority assesses the situation as not meeting their threshold for intervention, this can be challenged by the Designated Safeguarding Lead or the appointed manager.

Should the ultimate decision of the local authority be that the matter does not require a statutory agency response, we will endeavour to ensure that we take appropriate action to support the individual to access the right support. Where this is the case, everyone must ensure that any action is agreed by the Designated Safeguarding Lead and recorded accurately. This record must clearly document the reasons we disagree with the assessment of the local authority. Records must be clear, accurate and in a format that can be shared.

Please see Appendix A Safeguarding Adults Procedures and Appendix C Designated Safeguarding Leads and Contact Details

11.
Safer Recruitment
We are committed to safe employment, to reduce the risk of exposing adults at risk to people unsuitable to work with them.

To achieve best practice, we will:
• Adopt best practice guidance for the safer recruitment of employees and volunteers.
• All recruitment panels will have a panel member trained in safer recruitment practices. Please refer to SFS Recruitment and Selection Policy
• Everyone will be appropriately DBS checked in accordance with their role and in line with the current law. Please refer to SFS Disclosure and Barring Service Policy
• We will ensure that all new team members are inducted on safeguarding adults and children within the first two weeks of their employment.
Please refer to the Employee Handbook and Volunteer Handbook.

12.
Allegations against those who work for us and are in a position of trust
All employees and volunteers must be aware the position of trust they have and the responsibility they hold, when supporting adults who may be vulnerable. It is therefore everyone’s duty to raise concerns about the attitude or actions of colleagues that compromise safeguarding principles.

Any allegation against people who work with adults should be reported immediately to a senior manager, who will seek appropriate advice, including legal and HR advice where required, for dealing with such concerns. Please refer to the disciplinary procedures in the Employee Handbook.

We have a duty to report the concerns to a commissioning body and other relevant partners. Should we remove an individual from work because the person is deemed to pose a risk of harm to vulnerable adults, we will make a referral to the Disclosure and Barring service (DBS). It is an offence to make a referral without good reason.

Where an employee or volunteer feels that their safeguarding concern has not been responded to appropriately, they should refer to the whistleblowing policy. Please refer to SFS Speaking Out Policy

13.
Training and Supervision
We will ensure that all those who work with us, employees, and volunteers, are inducted on safeguarding adults and children (as appropriate for their role) within the first two weeks of their start date. The understanding of these will be observed, discussed, and evidenced during their probationary period, and throughout their employment by their line manager.

Everyone must undertake and pass a basic safeguarding training course which must be updated every two years. This can be delivered by the local authority, an online certified supplier, or by Sensory Services by Sight for Surrey.

Team members will receive mandatory training regularly that is relevant to their respective roles, and they are expected to undertake this training.

Accompanying policies and procedures that support safeguarding, will be regularly reviewed, shared, and discussed in meetings with teams. Team members will be supported in team meetings and One to One meetings and/or supervision to aide their understanding and application.

We will have an up-to-date record of training provided and completed on Breathe.

Designated Safeguarding Leads complete an annual skills audit and analysis of our organisations training needs. Progress is monitored and reported via the quarterly safeguarding meeting.

14.
Quality Assurance Framework
The quality audit framework ensures that we meet the quality standards expected of delivering care and support to people in Surrey with a sensory impairment and the Deaf community. These audits will identify good practice, and where practice needs to be improved. These will be reported quarterly with an annual review in each part of the service.

15. Regular reporting We report quarterly to the Safeguarding Meeting and Service Committee. We will support those who work for us to understand our adult safeguarding work, what is going well, what can be improved, any lessons learned and what risk issues we need to pay attention to through regular performance reporting.

16.
Safeguarding Strategy
Surrey Safeguarding Adults Strategy sets out the strategic commitment and measures to minimise the circumstances, including isolation, which makes vulnerable adults vulnerable to abuse.

The Senior Management Team embed safeguarding into the Sensory Services by Sight for Surrey five-year strategic plan and align this with the Surrey Safeguarding Adults Board.

17.
Implementation
To achieve the aims of this policy Sensory Services by Sight for Surrey will consult with the people we support and those we work with.

We will:
• Monitor and report on all safeguarding and domestic abuse incidents.
• Publicise the policy, including a version in British Sign Language (BSL).
• Enable key staff to attend relevant training.
• Publicise contact details of local support agencies.

18.
Supporting Policies
This policy should be read in conjunction with and can be found Staff Information -Current Policies Manuals:
• Confidentiality Policy
• Complaints Policy
• Data Security and Protection Handbook
• Data Protection and Privacy Notice
• Disciplinary Procedures (within Employee Handbook)
• Disclosure and Barring Service Policy
• Domestic Abuse Policy and Procedures
• Employee Handbook – behaviour policy / code of conduct
• Health and Safety Policy
• Incident Policy
• Lone Working Policy
• Recruitment and Selection Policy
• Record Keeping Policy
• Risk Management Policy
• Safeguarding Children Policy
• Social Media Policy
• Speaking Out Policy
• Volunteer Handbook
• Volunteer Policy