Suffolk Safeguarding Safeguarding Children and Adult Policies

This is a joint policy for IESCC and WSCCG CCG safeguarding adults. (North East Essex CCG have their own adult and children policy).

This statement has been developed in order to strengthen the ‘Think Family’ approach and for all staff to see that safeguarding is everyone’s business.

Every organisation must ensure that they promote the duty of care and protection of vulnerable people and have a clear, well publicised policy of zero tolerance of abuse.

The key principles which underpin the attached policies, support both adults and children at risk.

For children:

• Safeguarding is essentially another way of saying ‘keeping children and young people safe’ and that wherever they are and whatever they are doing, whether at home, at school or online, young people have the right to feel safe and happy, be healthy, have an education and a home and grow up safe from people hurting them or failing to ensure that they are cared for.
• Every young person has a right to be safe when accessing health in order to make sure children and young people are safe from any type of harm or neglect.

For adults:

• Every person has the right to live a life free from abuse, exploitation and neglect.
• Adults at risk of abuse must be made aware of their rights and given information, advice and support, and must be encouraged and enabled to access protection from the law and legal processes.
• Every effort must be made to promote the well-being, security and safety of adults at risk of abuse consistent with their rights, mental capacity and personal choices.
• In most cases, the adult at risk of abuse should be the person who decides on the chosen course of action, whilst being given all possible support to do so.
• In some cases, an adult with mental capacity may choose to remain in an abusive environment or situation. In these cases it is still extremely important to consider what advice and support can be offered to reduce their risk from harm.

For every staff member of the CCG, safeguarding is a golden thread that goes through all our work.

The safeguarding teams contacts are:

Caroline Holt, Designated Nurse for Safeguarding Children: caroline.holt5@nhs.net
Caroline Pyrozuk, Safeguarding Children and Children in Care Administrator: caroline.pyrozuk@nhs.net
Cindie Dunkling, Designated Nurse for Safeguarding Children and Child Death Review: Cindie.dunkling@nhs.net”
Dr Ninethrie Weerashinghe, Designated Doctor for Looked After Children: Ninethrie.Weerasinghe@nhs.net
Dr Rachel Furley, Designated Doctor for Safeguarding Children: rachel.furley2@nhs.net
Jo Hutchings, Deputy Designated Nurse for Safeguarding Children and Primary Care: johannahutchings@nhs.net
Jane Hatchard, Safeguarding Adults Administrator: johannahutchings@nhs.net
Tabitha Griffin, Designated Adult Safeguarding Lead: tabitha.griffin@nhs.net

Safeguarding Children And Young People Policy

The target audience for this policy is all CCG employees (permanent, seconded or temporary). This policy details the robust structures, systems and standards in place for Ipswich and East Suffolk CCG (IESCCG) and West Suffolk CCG (WSCCG) as an employer and across its commissioned services. These are also in accordance with the Suffolk Safeguarding Partnership (SSP) procedures and guidance.

Safeguarding is the responsibility of everyone in the CCG’s and its commissioned providers, providers of services and those who work in partnership with the above (e.g. volunteers). All staff must be aware of their individual responsibility and accountability.

Following approval, the policy will be made available to all staff via the intranet.

Document Information

Title /Version Number/Date: Safeguarding Children and Young People Policy Version V2.01 April 2020
Accountable Executive: Director of Nursing and Quality
Responsible Post holder/Policy Owner: Designated Nurse Safeguarding Children, Designated Nurse Looked After Children, Deputy Designated Nurse Safeguarding Children
Date Approved: October 2020
Approved By: CCG Clinical Scrutiny Committees
Review Date: April 2022
Authors: Designated Nurse Safeguarding Children, Deputy Designated Nurse Safeguarding Children, Designated Nurse Looked After Children
Stakeholders engaged in development/review: Further consultation with members of the wider Nursing and Quality Directorate of the CCG.

Equality Impact Assessment

This document has been assessed for equality impact on the protected groups, as set out in the Equality Act 2010. This Policy is applicable to the Board, every member of staff within the CCG irrespective of their age, disability, sex, gender reassignment, pregnancy, maternity, race (which includes colour, nationality and ethnic or national origins), sexual orientation, religion or belief, marriage or civil partnership, and those who work on behalf of the CCG

Contact details for further information: please contact the IESCCG & WSCCG Safeguarding Children Team. wscgg.suffolksafeguardingchildren@nhs.net

Version History

Version	Date	Author	Reason for change
V.0.01	July 2015	Designated Nurse Safeguarding Children	Policy Updates to meet latest legislation.
V.0.02	July 2015	Designated Doctor Safeguarding Children	Consultation
V.0.03	N/A	N/A	N/A
V.0.04	18 August 2015	Information Governance and Risk Manager	Formatting changes placed policy into approved format
V.0.05	September 2015	Designated Nurse Safeguarding Children	Policy review to ensure its fit for purpose and incorporate Safeguarding Adults Policy
V.1.00	October 2015	Information Governance and Risk Manager	Presented for approval
V.2.01	April 2020	Designated Nurse Safeguarding Children, Designated Nurse safeguarding adults	Due for review Policy Updates to meet latest legislation. New Working Together to Safeguard Children June 2018 new adult legislation Policy review to ensure in line with North East Essex (NEE)CCG policy formatting

Review and Approval

Reviewed/Approved	Date
Reviewed by Designated Nurse	July 2015
Reviewed by Designated Doctor	July 2015
Review by Chief Nursing Officer	September 2015
Presented to Clinical Scrutiny for Approval Ipswich and East Suffolk CCG	3 November 2015
Presented to Clinical Scrutiny for Approval West Suffolk CCG	4 November 2015
Review by Director of Nursing	N/A
Presented to IESCCG and WSCCG Clinical Scrutiny for approval	27th and 28th October 2020

Next Review Date: April 2022

This policy progresses the following Authorisation Domains and Equality Delivery System:

• Clear and Credible Plan
• Collaborative Arrangements
• Clinical Focus and Added Value
• Engagement with Patients/Communities
• Leadership Capacity and Capability
• Equality Delivery System
• NHS Constitution ref

This policy does not progress the following Authorisation Domains/Equality Delivery System:

• Commissioning processes

Associated Legislation Policy and Guidance Documents

• The Children Act 1989.
• The Children Act 2004.
• The Mental Capacity Act 2005.
• Department for Education / Department of Health (2015) ‘Promoting the Health and Well- Being of Looked After Children: Statutory Guidance for Local Authorities, Clinical Commissioning Groups and NHS England’.
• HM Government (2018) ‘Working Together to Safeguard Children: A Guide to Inter-Agency Working to Safeguard and Promote the Welfare of Children’.
• Royal College of Nursing (2019) ‘Safeguarding Children and Young People: Roles and Competencies for Health Care Staff’ Intercollegiate Document.
• RCPCH (2015) ‘Looked After Children: Knowledge, Skills and Competences of Health Care Staff’ Intercollegiate Document.
• NHSE/I Safeguarding Vulnerable People in the NHS – Accountability and Assurance Framework (2019)
• Human Rights Act (1998)
• Mental Capacity Act (2005)
• Safeguarding Vulnerable Groups Act (2006)
• Counter Terrorism & Security Act 2015 – PREVENT Duty Guidance
• Building Partnerships and Staying Safe – Prevent Strategy (2011)
• Controlling or Coercive Behaviour In An Intimate Or Family Relationship (2015)
• Professional Codes of Conduct
• Disciplinary Policy
• Safeguarding Adults at Risk Policy
• Safeguarding Through Commissioning Policy
• Equality and Diversity Policy
• Whistleblowing Policy
• Complaints Policy
• Patient Engagement Strategy
• Recruitment and Retention Policy
• Information Governance Policy
• Information Sharing Policy
• Managing Investigations Guidelines
• Constitution

Glossary

Term	Definition
SSP	Suffolk Safeguarding Partnership
LAC	Looked After Child/ren
LADO	Local Authority Designated Officer
NHSE/I	NHS England/Improvement
Children	Children and young people

Contents

1. Introduction
2. Aims
3. IESCCG &WSCCG Strategic Vision
4. Definitions
5. Categories of Abuse
6. PREVENT
7. Safeguarding Roles and Responsibilities
8. Procedural Requirements
9. CCG Staff
10. Safeguarding Standards in Recruitment and Employment
11. Review and Maintenance of This Policy
Appendix 1: Types of Abuse
Appendix 2: PREVENT
Appendix 3: Safeguarding Supervision Guidance
Appendix 4: IESCCG & WSCCG Safeguarding Children Team Contact Details and IESCCG & WSCCG Child Death Review Team Contact Details

1 Introduction

This policy applies to Ipswich and East Suffolk and West Suffolk Clinical Commissioning Group (IESCCG and WSCCG) staff (permanent, fixed term, seconded, temporary and volunteers). Safeguarding and promoting the welfare of children and young people at risk must be an integral part of the care offered to all children and their families by all staff working within the Suffolk health economy.

2 Aims

2.1 This policy provides the framework that ensures a robust and safe system is in place to safeguard children and young people at risk, who reside either permanently or temporarily in our area or who are registered with GPs within Suffolk. This includes commissioners of services, providers of services and those who work in partnership with the commissioners and providers (e.g. volunteers / contractors).

2.2 This policy sets out the roles and responsibilities of the CCG’s in working together with other professionals and agencies in promoting the welfare of children and safeguarding them from abuse and neglect.

2.3 Commissioned provider services, services that work in partnership with other providers and independent contractors are expected to have robust policies and guidelines in place to support their staff in relation to their responsibilities for safeguarding children.

2.4 This policy describes how the CCG’s discharges its safeguarding responsibilities for commissioning health services. It should be read in conjunction with: IESCCG &WSCCG Safeguarding Adult Policy

2.5 This policy outlines how the CCG’s fulfil their statutory duties to safeguard children and young people at risk. The Policy is underpinned by legislation and best practice guidance, including amongst others:

• ‘The Children Act’ (1989 & 2004)
• ‘Working Together to Safeguard Children’ (2018)
• ‘Safeguarding Children and Young People: Roles and Competences for Health Care Staff: Intercollegiate Document’ (2019)
• ‘Promoting the Health and Well-Being of Looked After Children: Statutory Guidance for Local Authorities, Clinical Commissioning Groups And NHS England’ (2015)
• ‘Looked After Children: Knowledge, Skills and Competence of Health Care Staff: Intercollegiate Role Framework’ (2015)
• The Care Act (2014)
• The Mental Capacity Act (2005)
• NHS England/Improvement (NHSE/I) ‘Safeguarding Vulnerable People in the NHS – Accountability and Assurance Framework’ (2019)

2.6 Within this policy the term ‘children’ is inclusive of children and young people.

3 IESCCG WSCCG Strategic Vision

3.1 The CCG’s are committed to delivering safe and effective safeguarding services and to strengthening arrangements for safeguarding children across the Suffolk area and wider.

3.2 To ensure safeguarding, protection and promoting well-being features in all its activities with children and their parents, adults at risk and their carers/families and staff.

3.3 No single agency can deal with safeguarding alone. We work closely with our partners in the NHS, Suffolk Police and Suffolk Social Care to ensure we have a joined up, robust approach to safeguarding children who may be at risk of harm or abuse.

3.4 The CCG will include the requirement to safeguard and promote safeguarding into Corporate Plans, and the Transformation and Delivery Committee will assess any proposals for service development for its impact on safeguarding children and young people.

4 Definitions

4.1 A Child is anyone who has not reached their 18th birthday. The fact that a child has reached 16 years of age, is living independently or is in further education, is a member of the armed forces, is in hospital; or in custody in the secure estate, does not change his/her status or entitlements to services or protection.’

4.1 Safeguarding and Promoting the Welfare of Children is defined within ‘Working Together to Safeguard Children’ (2018) as:

• Protecting children from maltreatment;
• Preventing impairment of children’s health or development;
• Ensuring that children grow up in circumstances consistent with the provision of safe and effective care; and
• Taking action to enable all children to have best outcomes.

4.2 Child Protection – is part of safeguarding and promoting welfare. This refers to the activity that is undertaken to protect specific children who are suffering, or likely to suffer, significant harm. All agencies should aim to proactively safeguard children so that the need for action to protect children from harm is reduced.

4.3 Child in Need – defined as being “in need” when they are unlikely to reach or maintain a satisfactory level of health or development, or it will be significantly impaired without the provision of services. (Children Act 1989 section 17)

4.4 Significant Harm – the threshold that justifies compulsory intervention in family life in the best interests of children and gives local authorities a duty to make enquiries. (Children Act 1989 section 47)

4.5 The term ‘Looked After Child/ren’ (LAC) was introduced by The Children Act 1989 and refers to a child or young person: who is ‘accommodated’ by the Local Authority, a child who is the subject to an Interim Care Order, Full Care Order or Emergency Protection Order; or a child who is remanded by a court into Local Authority accommodation or Youth Detention accommodation.

4.5.1 Looked after Children may be placed with parents, foster carers (including relatives and friends), in Children’s Homes, in Secure Accommodation or with prospective adopters

4.6 Private Fostering describes an arrangement that lasts for 28 days or more, where a child (under 16 years, or 18 years if disabled) is cared for by someone who is not a close relative. Close relative means a grandparent, uncle, aunt, step parent or older brother or sister.

4.6.1 By law, parents and carers must notify their local authority of any private fostering arrangement. Further information regarding Private Fostering can be located on the SSP web pages.

4.7 Child Death Review Process reviews the deaths of all children normally resident within the local area to understand what has happened and determine if there are any lessons to be learned. National and local guidance for managing the child death process in Suffolk can be found on the Suffolk SUDIC website

5 Categories of Abuse

5.1 Physical Abuse: may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating, or otherwise causing physical harm to a child.

5.1.1 This category includes Fabricated or Induced Illness, see appendix one for further information.

5.2 Emotional Abuse: the persistent emotional maltreatment of a child such as to cause severe and persistent effects on the child’s emotional development

5.3 Sexual Abuse: involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening

5.3.1 Sexual abuse includes child sexual exploitation (see appendix one)

5.4 Neglect: the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development

5.5 Included in the four categories of child abuse and neglect, are a number of factors relating to the behaviour of the parents and carers and threats from others which have significant impact on children, such as domestic abuse and gang violence. Risks and threats may also be from areas outside of the family home and parents/carers. Contextualised safeguarding is an approach to understanding, and responding to, young people’s experiences of significant harm beyond their families. It recognises that the different relationships that young people form in their neighbourhoods, schools and online can feature violence and abuse. Refer to the SSP for further guidance.

5.6 Child Abuse Linked to Faith or Culture may also include:

5.6.1 Honour based abuse (including female genital mutilation)

5.6.2 Forced marriage of a child

5.6.3 Male circumcision

5.6.4 Spirit possession or witchcraft

5.6.5 See appendix one for further guidance.

5.7 Domestic abuse is defined (Home Office) as ‘Any incident or pattern of incidents of controlling, coercive or threatening behaviour, violence or abuse between those aged 16 or over who are or have been intimate partners or family members regardless of gender or sexuality.’ See appendix one.

5.8 Appendix one provides further guidance relating to the exploitation of children.

6 PREVENT

6.1 The Government’s anti-terrorism strategy, known as CONTEST, encourages co-operation between public service organisations.

6.2 CONTEST has four key principles:

• PURSUE: to stop terrorists
• PREVENT: to stop people becoming terrorists or supporting violent extremism.
• PROTECT: to strengthen our overall protection against terrorist attacks
• PREPARE: where we cannot stop an attack, to mitigate its impact.

6.3 The NHS has been identified as a key partner in the Prevent stream. The current level of terrorist attack can be located via Terrorism and national emergencies: Terrorism threat levels – GOV.UK (www.gov.uk)

6.4 The Suffolk CCG’s are committed to the Prevent strategy. Staff have a responsibility to help the CCG’s fulfil their obligation to minimise risks by identifying and supporting individuals who may be prone to radicalisation and influence of violent extremism.

6.5 Reporting Concerns of Radicalisation

6.5.1 If you have a concern about a vulnerable child or young person who may be at risk of being exploited by radicalisers and subsequently drawn into violent extremism then please discuss with a member of the CCG Safeguarding Team as onward referrals may be needed.

6.5.2 In the absence of the CCG Safeguarding Team being available please contact the following:

• Emergency, immediate threat: 999
• Suffolk MASH consultation Line 0345 606499 for advice in office hours
• SSP how to make a referral if concerned web page
• For adults, please refer to the CCG’s Safeguarding Adults Policy.
• Further guidance about Prevent is given in Appendix 2.

7 Safeguarding Roles and Responsibilities

7.1 IESCCG WSCCG

7.1.1 Both CCG’s have a strategic Governing Body lead for safeguarding children, to promote their needs across service planning and delivery.

7.1.2 Complies with Section 10 and Section 11 of the Children Act 2004 and any subsequent statutory guidance relating to vulnerable groups.

7.1.3 Participates in the Multiagency Safeguarding Arrangements (MASA) as one of the three Statutory Partners, alongside the Local Authority and Police.

7.1.4 Promotes the commissioning of services which prioritise the safety and welfare of children through local partnership arrangements and discharges its functions having regard to the need to safeguard and promote the welfare of vulnerable individuals. The CCG’s Safeguarding through Commissioning Policy describes these functions.

7.1.5 Promotes the planning and provision of a range of safeguarding training to enable staff to recognise and report safeguarding issues.

7.1.6. Suffolk CCG’s have identified leads for the following functions:

i. Executive lead for safeguarding children and adults (this role is undertaken by the Director of Nursing and Quality, with delegation to the Deputy Chief Nurse).

ii. Named Senior Officer for Allegations Against Staff who will inform the Local Authority Designated Officer (LADO) of all allegations and concerns of abuse made against an employee, agency worker, volunteer or contracted staff (this role is undertaken by the Director of Nursing and Quality).

iii. Lead for PREVENT the Government Counter Terrorism Strategy (this role is undertaken by the Adult Safeguarding Lead).

iv. Designated Nurse and Doctor for Safeguarding Children (supported by the Deputy Designated Nurse Safeguarding Children).

v. Designated Nurse and Doctor for Looked After Children.

vi. Designated Doctor for Child Deaths.

7.2 Monitoring Safeguarding Quality and Performance
The document Safeguarding Children, Young People and Adults at Risk in the NHS: Safeguarding Accountability and Assurance Framework 2019 sets out clearly the safeguarding roles and responsibilities of all organisations and individuals working in and commissioned by NHS England

7.2.1 As part of its quality monitoring and scrutiny role, the CCG’s will monitor the following across all organisations/services with which they have a commissioning role:

7.2.2 Safe recruitment policies in place as set out in 6 NHS standards of recruitment which include recommendations relating to relevant checks with the Disclosure and Barring Service.

7.2.3 Comprehensive and effective single and multi-agency policies and procedures to safeguard children and looked after children are in place, which are in line with Working Together to Safeguard Children; SSP and NHSE/I policies and procedures.

7.2.4 Co-operation and compliance with performance indicators and inspections required by the SSP and by any other national regulatory bodies, such as the Care Quality Commission, Ofsted or NHSE/I.

7.2.5 Compliance with the Government PREVENT Anti-Terrorism Strategy and where appropriate provide training and raise awareness of staff.

7.2.6 Compliance with the Mental Capacity Act (in respect of 16 and 17 year olds) and, where appropriate, providing training and awareness of staff.

7.2.7 Effective incident reporting which links to the SSP Safeguarding Children Practice Review (previously referred to as Serious Case Review) processes where appropriate.

7.2.8 Lessons learned from serious incidents, individual management reviews or near misses inform practice and result in improved outcomes for children and young people.

7.2.9 Service Specifications which promote quality standards around the safety and welfare of children and young people including a ‘Think Family’ approach between children and adult services.

7.2.10 Providers offering residential care for children and young people have appropriate standards in place and a policy to inform the Local Authority if a child is resident in hospital or hospice care for 12 weeks or more, a requirement under Section 85/86 of the Children Act 1989.

7.2.11 Providers of mental health in-patient care have policies to inform NHSE/I if children under 18 are housed in the same wards as adults, to ensure that they are transferred to more suitable accommodation within 48 hours, and have an appropriate policy regarding children visiting in-patients on all wards.

7.3 IESCCG WSCCG Nursing and Quality Directorate

7.3.1 Must maintain a continued awareness of safeguarding issues and the CCG’s responsibilities/accountability, and maintain a knowledge base by reviewing reports, newsletters and attending training/development sessions as required.

7.3.2 Monitor that all commissioned services have robust policies and procedures embedded to safeguard and promote the welfare of children and young people which are in accordance with the SSP Procedures.

7.3.3 Promote the safeguarding and welfare of children and young people in all activity related to their role.

7.3.4 Inform the CCG safeguarding Executive Lead of any deficits in health e.g. vacancies, pandemic sickness, which may impact on inter-agency working, and potentially put children and young people at risk.

7.4 Responsibility of Employees (including contracted staff)

7.4.1 Comply with all IES & WSCCG and SSP policies, procedures and guidance on safeguarding children and young people.

7.4.2 Attend safeguarding children training at the appropriate level to their role as outlined in the Intercollegiate Documents: ‘Safeguarding Children and Young People: Roles and Competencies for Health Care Staff’ (2019) and ‘Looked After Children: Knowledge, Skills and Competences of Health Care Staff’ (2015) and maintain a level of knowledge and skills appropriate to their role.

7.4.3 Safeguard children and young people by recognising and responding to abuse and neglect and know what action to take to make appropriate referrals, and where appropriate contribute to multi-agency activity as per SSP procedures.

7.4.4 Access safeguarding advice and supervision at the appropriate level for their role as outlined in the Intercollegiate Documents.

7.4.5 Take part in audits and evaluations regarding safeguarding as appropriate.

7.4.6 Take immediate and appropriate action regarding allegations against people who work with children and young people.

7.5 Responsibility of ALL Staff

7.5.1 All staff must always be alert to the possibility of significant harm to children through abuse or neglect, or to a child who is ‘in need’. All staff should be able to recognise indicators and know how to act upon concerns, their depth of knowledge being commensurate with their roles and responsibilities.

7.5.2 All staff must be aware of the vulnerabilities of certain groups of children such as those who are disabled, ‘Looked After’ or privately fostered. Looked After Children are identified as a population who may have significant health and social difficulties, which may make them more susceptible to risk taking behaviours and can be more at risk of sexual exploitation. They are shown to be a population who have poorer outcomes than that of their peers who have not been in care to the local authority.

7.5.3 All staff must be aware of the vulnerabilities of certain groups of adults who may find parenting difficult. For example, those experiencing domestic abuse, unstable mental health problems, uncontrolled substance or alcohol misuse, learning disabilities or those with unmet support needs. All staff working primarily with adults who are parents or carers should always consider the effects on parenting capacity and subsequent implications for children of the adult’s illness or behaviour.

7.5.4 All staff must recognise that sharing information is vital for early intervention to ensure that children are protected from abuse and neglect and that the safeguarding of children is paramount and can override any duty of confidentiality.

7.5.5 All staff must be aware of implications of Mental Capacity as this is applicable in the care of young people (16-18 year olds).

7.6 Safeguarding Governance and Reporting Arrangements

7.6.1 Safeguarding governance arrangements for the CCG’s are monitored through the Clinical Executive Committee. The Committee meets monthly and reports directly into the Board. The following areas will be reported on

• Safeguarding policy and procedure monitoring and ratification.
• Performance and quality monitoring around safeguarding.
• Monitoring of safeguarding governance arrangements.
• Areas of risk and concerns related to safeguarding.
• Feedback from safeguarding meetings e.g. SSP, regional safeguarding networks.
• Looked After Children.
• Key topic areas, including domestic abuse, female genital mutilation, forced marriage, child sexual exploitation.
• New documents, legislation and research in safeguarding.
• Serious incidents which relate to identifiable individuals
• Serious Case Reviews/Child Safeguarding Practice Reviews (and other reviews), Independent Management Reviews, Domestic Homicide Reviews which relate to identifiable individuals.

8 Procedural Requirements

8.1 What to do if you are Worried about the Safety of a Child or Young Person

8.1.1 If someone is danger and in immediate need of safety and protection ring the police and/or ambulance services as appropriate on 999.

8.1.2 The SSP provides detail of the processes to follow when there are safeguarding concerns regarding the safety of a child (processes are therefore not replicated here in detail). Procedures can be accessed on the SSP website.

8.1.3 Advice can also be sought from the CCG Safeguarding Children Team, located within the Nursing and Quality Directorate of IESCCG.

8.2 Information Sharing

8.2.1 Where there are safeguarding concerns staff have a duty to share relevant and proportionate information. It is important to remember that in most Serious Case Reviews information sharing is often a significant contributory factor when things have gone wrong and harm and abuse have occurred. Early sharing of information is key to providing effective help where there are emerging concerns.

8.2.2 The HM Government guidance Information sharing Advice for practitioners providing safeguarding services to children, young people, parents and carers (2018) provides specific advice around information sharing.

8.3 Statutory reviews

8.3.1 A number of statutory and non-statutory reviews are required to be undertaken by relevant agencies including health when particular circumstances arise. All agencies including IES &WSCCG that are asked to participate in a statutory review must do so. The different types of review include:

8.4 Child Safeguarding Practice Reviews (previously known as Serious Case Reviews)

8.4.1 When a child is known or suspected to have been abused or neglected and the child dies or is seriously harmed, the Multiagency Safeguarding Partnership is required to conduct a Child Safeguarding Practice Review into the involvement of organisations and professionals with the child and family.

8.4.2 The purpose of each review is to:

• Establish whether there are lessons to be learned from the case about the way in which local professionals and organisations work together to safeguard and promote the welfare of children;
• Identify clearly what those lessons are, how they will be acted upon, and what is expected to change as a result; and
• As a consequence, to improve inter-agency working and better safeguard and promote the welfare of children.

8.4.3 Where the criteria for a Child Safeguarding Practice Review is not met, an alternate review may be conducted.

8.5 Domestic Homicide Reviews

8.5.1 These are convened by the Local Community Safety Partnership when the defined criteria has been met following the death of a person aged 16 or over has, or appears to have resulted from violence, abuse or neglect.

9 IESCCG WSCCG Staff

9.1 Training

9.1.1 Safeguarding Children Training is mandatory and is part of the CCG’s mandatory training programme.

9.1.2 All staff should receive safeguarding children training at a competency level according to their role and as deemed by the CCG’s mandatory training matrix. This should be refreshed as a minimum every three years for all staff.

9.1.3 A database is maintained that enables this to be monitored on a regular basis by the Safeguarding Children Team, the Quality Committee and the Board.

9.1.4 The CCG has appropriately trained and experienced staff to review and manage safeguarding concerns. Their duties and responsibilities are set out. The training and development requirements associated with their job role will be specified, and progress in meeting these requirements will be monitored by the named Director and reported to the CCG Board.

9.2 Supervision

9.2.1 Where the CCG staff have specific responsibilities in safeguarding and promoting the welfare of children and young people, this will be incorporated in the job description and work objectives of the individual, and the supervision and support structure for those individuals will be clearly documented.

9.2.2 Staff can arrange Safeguarding Supervision and case discussions with the Safeguarding Children Team professionals when and where necessary.

9.2.3 See Appendix 4 Supervision Guidance document

10 Safeguarding Standards in Recruitment and Employment

10.1 The CCG adopts safe recruitment procedures in accordance with best practice guidance within the NHS and ESCB Safer Recruitment Guidance (2018), and ensure that any organisation delivering its recruitment function can demonstrate awareness of the requirements, and systems of practice that ensure that there are ‘fail-safe’ checks.

10.1.1 The CCG ensures that where disciplinary action has been taken against an employee of the CCG the appropriate action has been taken in respect of notification to Professional Bodies or reporting under the Safeguarding Vulnerable Groups Act (2006).

10.1.2 There is a statutory scheme for vetting people working with children and adults at risk of abuse and neglect. It is administered by the Disclosure and Barring Service. This system provides checks on people entering the workforce, and maintains lists of individuals who are barred from undertaking regulated activity with either children or adults at risk of abuse and neglect.

10.2 Allegation Of Abuse Against A Staff Member

10.2.1 In accordance with Working Together 2018, this section of the policy relates to a staff member who may have:

• Behaved in a way that has harmed a child, or may have harmed a child;
• Possibly committed a criminal offence against or related to a child;
• Behaved towards a child or children in a way that indicates he or she would pose a risk of harm to children

This may be in their professional or personal life.

10.2.2 Any member of staff who becomes aware of a concern about an allegation of concerns in relation to safeguarding children (or an adult at risk) by an employee of the CCG must report it to the line manager of that employee.

10.2.3 The Line Manager must take advice from a senior member of the Human Resources Department and must report any allegations to the Named Senior Officer for the CCG (Director of Nursing) at the earliest opportunity (the recipient of the allegation must not try to unilaterally determine the validity of the allegation).

10.2.4 The Named Senior Officer, or deputy, informs the Local Authority Designated Officer within one working day of allegation being made, regardless of the nature of allegations and who receives the allegation. This must include situations where the worker resigns. Compromise agreements are not acceptable in such circumstances and may put others at risk in the future.

10.2.5 The Named Senior Officer works collaboratively with other agencies contributing to a strategy meeting and taking appropriate action as agreed.

10.2.6 Consideration is given in regard to Disciplinary Procedures e.g. suspension, referral to Disclosure and Barring Service (DBS). Employees must be aware that abuse is a serious matter that can lead to a criminal conviction. Where applicable the organisation’s Disciplinary Policy will be implemented.

10.2.7 If concerns arise about a member of staff’s behaviour towards any vulnerable individual, Social Care and/or Police must inform the organisation in order to assess whether there may be implications for children or adults at risk with whom the person has contact at work.

11 Review and Maintenance of this Policy

11.1. This policy will be subject to a two-yearly review and, if revised, all stakeholders will be alerted to the new version.

11.2. This policy is issued and maintained by IES & WSCCG Safeguarding Team on behalf of all stakeholders.

Appendix One

This section covers:

• Child Abuse Linked to Faith or Culture
• Honour Based Abuse (including Forced Marriage and Female Genital Mutilation)
• Child Exploitation
• Child Trafficking and Modern Slavery
• Gang Violence/Serious Youth Violence
• Domestic Abuse
• Fabricated/Induced Illness

Violence and abuse in the name of honour covers a variety of behaviours (including crimes), mainly but not exclusively against women where the person is being punished by their family and/or community for a perceived transgression against the ‘honour’ of the family or community. This includes:

• Physical abuse
• Financial abuse
• Sexual abuse
• Forced marriage
• Emotional and psychological abuse
• Female genital mutilation

Honour Based Abuse (HBA) can be distinguished from other forms of abuse, as it is often committed with some degree of approval and/or collusion from family and/or community members. Victims will have multiple perpetrators not only in UK but can be abroad, HBA can be a trigger for Forced Marriage.

Honour abuse cuts across all cultures and communities and cases encountered in the UK have involved families from Turkish, Kurdish, Afghani, South Asian, African, Middle Eastern, South and Eastern European communities and Gypsy, Romany and Traveller communities. This is not an exhaustive list (SET).

If you suspect someone is suffering from honour-based abuse, contact the police or the honour-based lead in children’s social care. DO NOT inform or discuss anything with family.

Practice guidance can be located in SSP Procedures. For further information on Honour Based Abuse see the SSP website.

Another organisation that offers advice on HBA and FM is Anglia Care Trust.

Karma Nirvana:
Helpline: 0800 5999 247
Email: info@karmanirvana.org.uk

Female Genital Mutilation

Female Genital Mutilation is the collective term used for procedures which include the partial or total removal of the external female genital organs for cultural or other non-therapeutic reasons. Female Genital Mutilation is typically performed on girls aged between 4 and 13years of age but also at times occurs from birth or in young women before marriage or pregnancy. The Prohibition of Female Circumcision Act 1985 made this practice illegal in this country. The Female Genital Mutilation Act 2003 replaced the 1985 Act and it is now illegal for girls to be taken abroad for this procedure.

Agencies need to work together to promote a better understanding of Female Genital Mutilation and the potential damaging effects upon health. By working in partnership with families and raising their awareness we will be more able to protect children and young females from this type of abuse.

All health professionals have a legal duty to report and share information to the police and social care if they are aware that a child under 18 has had or is at risk of FGM. Professionals must also consider the risks to other girls and women who may be related to or living with an individual with FGM as it is an inter-generational practice, their girls and young women may also be at significant risk of harm.

Mandatory Reporting of FGM to NHS Digital

Collection and submission of the new dataset became mandatory for acute trusts from July 2015, and Mental Health Trusts and GPs from October 2015. The FGM Enhanced Information Standard (SCCI2026) instructed all clinicians to record into clinical notes when a patient with FGM is identified, and what type it is. Data must be submitted every time the woman or girl has treatment related to her FGM or gives birth to a baby girl, and every time FGM is identified (by a clinician or self-reported), not just the first time. The dataset includes: patient demographic data, specific FGM information, referral and treatment information.

Further information can be located on the NHS Digital website.

FGM Helpline- 0800 028 3550

Forced Marriage

A child who is being forced into marriage is at risk of significant harm from physical, sexual and emotional abuse. Forced marriage is an abuse of human rights. “Marriage shall be entered into only with the free and full consent of the intending spouses” (Universal Declaration of Human Rights, Article 16(2)).

A forced marriage is where one or both people do not consent to the marriage and pressure, coercion or abuse is used.

Forced marriages reported to date in the UK have involved families from South Asia, Europe, E Asia, the Middle East and Africa, Some forced marriages take place in the UK with no overseas element while others involve a partner coming from overseas or a British national being taken abroad.

Forced marriage is a safeguarding issue and now a criminal offence. It is expected that all staff follow the SET Safeguarding and Child Protection Procedures and also make reference to the SET Safeguarding Adult guidelines.

The Forced Marriage Unit can provide support advice and offer safe accommodation. Below are the contact details and a link if you have concerns about someone being forced into marriage.

Website: https://www.gov.uk/guidance/forced-marriage
Email: fmu@fco.gov.uk

Male Circumcision

Please refer to the relevant guidance within SSP, Multi-Agency Guidance on safeguarding in relation to male circumcision for detailed information as to when the male circumcision may constitute significant harm to a child.

Spirit Possession or Witchcraft

SSP Safeguarding and Child Protection Procedures outline that a child may suffer emotional abuse if they are labelled and treated as being possessed with an evil spirit. In addition, significant harm to a child may occur when an attempt is made to ‘exorcise or ‘deliver’ the evil spirt from the child.

Exploitation

Child Sexual Exploitation

Child sexual exploitation is a form of child sexual abuse. It occurs where an individual or group takes advantage of an imbalance of power to coerce, manipulate or deceive a child or young person under the age of 18 into sexual activity (a) in exchange for something the victim needs or wants, and/or (b) for the financial advantage or increased status of the perpetrator or facilitator. The victim may have been sexually exploited even if the sexual activity appears consensual. Child sexual exploitation does not always involve physical contact; it can also occur through the use of technology (HM Government 2017).

• Sexually exploited children should be treated as victims of abuse, not as offenders;
• Sexual exploitation includes sexual, physical and emotional abuse and, in some cases, neglect;
• Children do not make informed choices to enter or remain in sexual exploitation, but do so from coercion, enticement, manipulation or desperation;
• Children under sixteen cannot consent to sexual activity;
• Children over sixteen can be victims of sexual exploitation regardless of their legal capacity to consent to sexual activity;
• Child sexual exploitation covers a range of offences which will need differing responses from a range of agencies;
• Young people who are sexually exploited or at risk of being sexually exploited will have varying levels of need, may have multiple vulnerabilities and be caught up in different risks situations. This calls for a multi-agency response and good co- ordination;
• Many sexually exploited children have difficulty distinguishing between their own choices and the sexual activities they are coerced into;
• Law enforcement must direct resources against the coercers and sex abusers, who are often adults, but could also be the child’s peers. However, it is important to recognise that these young people may also be victims themselves;
• Sexually exploited children are children in need of services under the Children Act 1989 and 2004. They may also be children in need of immediate protection.

Access the SSP Child Sexual Exploitation toolkit via the SSP website.

Child Trafficking and Modern Slavery

Modern slavery is the recruitment, movement, harbouring or receiving of children, women or men through the use of force, coercion, abuse of vulnerability, deception or other means for the purpose of exploitation. Individuals may be trafficked into, out of or within the UK, and they may be trafficked for a number of reasons including sexual exploitation, forced labour, domestic servitude and organ harvesting (NHS England 2018). The Home Office estimates there are 13,000 victims and survivors of modern slavery in the UK; 55% of these are female and 35% of all victims are trafficked for sexual exploitation. In the year to March 2017 the police in England and Wales recorded 2,255 modern slavery crimes. However, many more crimes and victims go undetected.

Children, young people and adults may be trafficked for many reasons, including:

• Sexual exploitation – includes the abuse of children for the production of child abuse images/videos.
• Domestic servitude – involves a victim being forced to work in usually private households, usually performing domestic chores and childcare duties. Their freedom may be restricted and they may work long hours often for little or no pay, often sleeping where they work.
• Forced labour – victims are forced to work long hours for little or no pay in poor conditions under verbal or physical threats of violence to them or their families. It occurs in various industries including construction, manufacturing, hospitality; food packaging, agriculture, maritime and beauty (nail bars). Often victims are housed together in one dwelling.
• Criminal exploitation – exploitation of a person to commit a crime, such as pickpocketing, shoplifting, cannabis cultivation, drug trafficking and other similar activities that are subject to penalties and imply financial gain for the trafficker.
• Organ removal; forced begging; forced benefit fraud; forced marriage and illegal adoption.

Gang Violence/Serious Youth Violence

SET Safeguarding and Child Protection Procedures outline that a child who is affected by gang activity or serious youth violence may have suffered, or may likely to suffer, significant harm through physical, sexual and emotional abuse.

Domestic Abuse

Domestic abuse is about the power and control of one person over another and can take many forms.

Many people think that domestic abuse is about intimate partners, but it is clear that other family members are included and that much safeguarding work that occurs at home is, in fact concerned with domestic abuse. This confirms that domestic abuse approaches and legislation can be considered safeguarding responses in appropriate cases. Such abusive behaviour can include, for example:

• Constant criticism and belittling comment;
• Verbal abuse and threats (including threats to harm the children);
• Isolation and control of contact with family and friends;
• Restrictions on entry/exit from home;
• Intimidation;
• Controlling and coercive behaviour;
• Denial of privacy;
• Oppressive control of finances and withholding of food;
• Destruction of personal property and valued possessions.

Fabricated or Induced Illness

Physical harm may also be caused when a parent fabricates the symptoms of, or deliberately induces illness in a child.

For fabricated illness discrepancy in the clinical picture with one or more of the following:

• Reported signs or symptoms only in the presence of the carer;
• Multiple second opinions being sought;
• Inexplicably poor response to medication or excessive use of aids;
• Biologically unlikely history of events even if the child has a current or past physical or psychological condition.

FII is an extremely rare diagnosis and where cases are suspected they must always be raised to the NEE CCG Safeguarding Children Team

Further detailed information on all these topics can be located in the relevant sections of the SSP web page.

Appendix Two: Prevent

Please read in conjunction with the CCG’s Safeguarding Adults Policy.

The NHS has been identified as a key partner in the Prevent stream. The current level of terrorist attack can be located at Terrorism and national emergencies: Terrorism threat levels – GOV.UK (www.gov.uk)

Any worker who has concerns that someone is vulnerable to radicalisation should contact the Suffolk Police Prevent team. If you have concerns a crime is being committed, planned, or you are aware of any terrorist activity please contact the Police on either 999 (if urgent) or 101 (for all other enquiries).

Parents and carers should be involved in discussion about any extremism concerns at the earliest point possible unless this would increase risk to a child or young person.

Appendix Three: Safeguarding Supervision Guidance

Introduction

Many of the inquiries into child deaths and serious incidents involving children have demonstrated serious failings in the effectiveness of professionals. This has been in part attributed to not receiving appropriate supervised support. Working to ensure children are protected from harm requires sound professional judgments to be made. It is demanding work that can be distressing and stressful and those involved must have access to advice and support from professionals experienced in the field of safeguarding children.

This guidance is on the implementation and utilisation of supervision within the context of safeguarding children. Good quality supervision can help to:

• Keep a focus on the child
• Avoid drift
• Maintain objectivity and challenge fixed views
• Test and assess the evidence base for decisions; and
• Address the emotional impact of the work

Roles and Responsibilities

All staff in the CCGs are responsible for adhering to and complying with the requirements of the policies, procedures, guidelines and protocols contained within and applicable to their area of operation. All staff have a duty to safeguard children by recognising abuse and neglect and referring onwards as required (Working Together 2013/15/18).

Individual Accountability

The process of supervision is underpinned by the principle that each practitioner remains accountable for their own practice and as such their own actions within supervision. Safeguarding children supervision does not replace nor should it delay the individual’s responsibility to make a referral to statutory agencies where there are concerns that a child may be suffering or likely to suffer from significant harm. In such cases staff should refer to the Suffolk Safeguarding Partnership guidance.

Organisational Accountability

Under Section 11 of the Children Act 2004 all health care organisations have a duty to make arrangements to safeguard and promote the welfare of children and young people, and to cooperate with other agencies to protect individual children and young people from harm.

The organisation must ensure that staff who work predominately with children, young people and adults who are parents/carers have access to safeguarding children supervision.

The organisation will ensure that those practitioners providing supervision are adequately trained in supervision skills and have up to date knowledge of the legislation, policy and research relevant to safeguarding and promoting the welfare of children. This must reflect the requirements set out in Working Together (2013/15/18), the Intercollegiate Document (2019).

Supervisor Responsibilities

Designated Nurses are responsible for providing safeguarding children supervision to CCG staff on regular or ad hoc basis depending on role.

All safeguarding children supervisors will ensure that they:

• have received professionally recognised supervision skills training (e.g. NSPCC) and ensure that their knowledge remains current through relevant course updates and accessing relevant literature.
• have up to date knowledge in legislation, policy and research relevant to safeguarding children
• be accountable for the advice that they give ensure those receiving mandatory safeguarding children supervision
• identify when they do not have the necessary skills/knowledge to safely address issues raised and redirect the supervisee accordingly discuss management of individual safeguarding children cases to explore and clarify the management and thinking relating to the case.
• share information knowledge and skills with the supervisee
• if required, constructively challenge any personal and professional areas of concern

Supervisee Responsibilities

The practitioner has certain responsibilities to ensure that they receive the most effective and timely support, which is:

• to access timely advice and support from the Designated/Specialist/Named Professional for Safeguarding Children (or delegated person) as and when required.
• For Specialist/Named professionals for Safeguarding Children to take responsibility for ensuring they receive safeguarding children supervision at least quarterly.
• For Specialist/Named professionals for Safeguarding Children undertaking mandatory supervision, to agree, sign and adhere to a supervision contract.
• maintain accurate, meaningful and contemporaneous records and documentation as per record keeping policy/professional guidance
• be prepared for constructive feedback/challenge
• develop skills in reflective practice
• document the agreed summary of the discussion with clear action plan indicating responsibility for each action.

Appendix Four: WSCCG IESCCG Safeguarding Children Team contact details

Caroline Holt, Designated Nurse for Safeguarding Children: caroline.holt5@nhs.net

Cindie Dunkling, Designated Nurse for Safeguarding Children and Child Death Review: Cindie.dunkling@nhs.net

Jo Hutchings, Deputy Designated Nurse for Safeguarding Children and Primary Care: johannahutchings@nhs.net

Dr Rachel Furley, Designated Doctor for Safeguarding Children: rachel.furley2@nhs.net

Beaulah Chizimba: Designated Nurse for Children in Care: beaulah.chizimba@nhs.net

Dr Ninethrie Weerashinghe, Designated Doctor for Looked After Children: Ninethrie.Weerasinghe@nhs.net

Caroline Pyrozuk, Safeguarding Children and Children in Care Administrator: caroline.pyrozuk@nhs.net

Safeguarding Children Team telephone number: 01473 264357

Safeguarding Children Team Email: WSCCG.suffolksafeguardingchildren@nhs.net

Child Death Review Team contact details

Dr Sarah Steel, Designated Doctor for Child Death: sarah.steel@nhs.net

Cindie Dunkling, Designated Nurse for Safeguarding Children and Child Death Review: Cindie.dunkling@nhs.net

Bernie Spiller, Child Death Review Nurse: bernadette.spiller@nhs.net

Jacky Wood, Child Death Review Nurse: jacquelyn.wood@nhs.net

Lucy Lavender, Child Death Review Nurse

Karen Ghosh, Child Death Review Administrator: karen.ghosh@nhs.net

Child Death Review Team telephone number: 01473 770089

Safeguarding Adults at Risk Policy

This policy is supplementary to the ICS safeguarding adults guidelines (2020) and associated material to be found on the Suffolk Safeguarding Partnership website.

The target audience for this policy is all CCG employees (permanent, seconded or temporary).

This policy details the robust structures, systems and standards in place for IES&WSCCG as an employer and across its commissioned services.

Safeguarding is the responsibility of everyone in both CCGs and its commissioned providers. All staff must be aware of their individual responsibility and accountability.

Tohis policy must be approved by the IES&WSCCG Quality Committee and made available to all staff via the intranet.

The policy will be used as a clear statement of CCGs’ responsibilities to all CCG employees.

Document information

Title: Safeguarding Adults at Risk policy
Version number and date: Version 4.0, May 2020
Document Status: For circulation to all staff, and immediate implementation
Accountable Executive: Director of Nursing and Clinical Quality
Responsible post holder/policy owner: Safeguarding Adult Lead
Date Approved: 2020
Approved by: CCG Board
Review Date: 2021
Stakeholders engaged in development/review: Clinical Quality Lead, Director of Nursing, Safeguarding team, Quality Committee

Equality Impact Assessment

This document has been assessed for equality impact on the protected groups, as set out in the Equality Act 2010. This Policy is applicable to the Board, every member of staff within both CCGs irrespective of their age, disability, sex, gender reassignment, pregnancy, maternity, race (which includes colour, nationality and ethnic or national origins), sexual orientation.

Contact details for further information: please contact the Safeguarding team for any queries.

Amendment History

Comments

Version	Date	Reviewer Name(s)
1.0	March 2013	N/A	Policy developed
2.0	May 2016	Safeguarding Adult Lead, Quality Committee Members	Policy review undertaken. Updated with the Care Act 2014 legislation. Title change in line with Care Act 2014. Update on procedural requirements and duty to make enquiries. Updates on the staff section, including training and allegations.
3.0	August 2018	Safeguarding Adult Lead	Policy review undertaken. Key date changes made to the document. Updates and link made to Suffolk Safeguarding Boar Modern Slavery guidance and Prevent. Slight wording changes to Section 6.6 Deprivation of Liberty Safeguards. Slight wording changes to Section 6.6 Deprivation of Liberty Safeguards.
4.0	April 2019	Safeguarding Adult Lead	Key date changes to the updated Suffolk safeguarding adult guidelines. Update on the Prevent wording. Update on the training section in line with Adult Intercollegiate document. Link to domestic abuse website.
5.0	May 2020	Designated Safeguarding Adult Nurse	Key date changes to the updated Suffolk safeguarding adult guidelines. Update on Deprivation of Liberty and Liberty Protection Safeguards.

This policy progresses the following Authorisation Domains and Equality Delivery System:

• Clear and Credible Plan
• Collaborative Arrangements
• Engagement with Patients/Communities
• Commissioning processes
• Leadership Capacity and Capability
• NHS Constitution ref

This policy does not progress the following Authorisation Domains/Equality Delivery System:

• Clinical Focus and Added Value
• Equality Delivery System

Glossary

Term	Definition
Accountable Executive	CCG Executive accountable for development, implementation and review of the policy
Policy Owner	Post holder responsible for the development, implementation and review of the policy
Document definitions	These are provided in Section 1
SSPB	Suffolk Safeguarding Partnership Board
IES&WSCCG	Ipswich and East Suffolk and West Suffolk Clinical Commissioning Group
DoLS	Deprivation of Liberty Safeguards
SCC	Suffolk County Council
SI	Serious Incident
CQRG	Clinical Quality Review Group
DHR	Domestic Homicide Review
SAR	Safeguarding Adult review
QCPM	Quality Contract Performance Meetings
DHR	Domestic Homicide Review
IMR	Independent Management Review
DoH	Safeguarding Alert Form

Associated Legislation, Policy or Guidance Documents

• Southend Essex and Thurrock (SET) Safeguarding Adults Guidelines (2019)
• Adult Safeguarding Intercollegiate: Roles and Competencies for Health care staff (2018)
• Suffolk Safeguarding Adults Board Safer Recruitment Guidelines (2017)
• Suffolk Safeguarding Adults Handbook (2019)
• Care Act (2014)
• Human Rights Act (1998)
• Safeguarding Vulnerable People in the Reformed NHS Accountability and Assurance Framework March (2015)
• Adult Safeguarding Best Practice Guidance for Providers of Healthcare in East Anglia and Essex March 2017
• Mental Capacity Act (2005)
• Safeguarding Vulnerable Groups Act (2006)
• Deprivation of Liberty Safeguards (DH 2008)
• Care Quality Commission (Registration) Regulations (2009)
• Health and Social Care Act 2008 (Regulated Activities) Regulations (2010)
• Counter Terrorism & Security Act 2015 – PREVENT Duty Guidance
• Building Partnerships and Staying Safe – Prevent Strategy (2011)
• Controlling or Coercive Behaviour In An Intimate Or Family Relationship (2015)
• Professional Codes of Conduct
• Suffolk Mental Capacity and Deprivation of Liberty Safeguards Guidance (MCA +DoLs) (2018)
• IES&WSCCG Disciplinary Policy
• IES&WSCCG Safeguarding Children and Families Guidance and Policies
• IES&WSCCG Equality and Diversity Policy
• IES&WSCCG Whistleblowing Policy
• IES&WSCCG Complaints Policy
• IES&WSCCG Patient Engagement Strategy
• IES&WSCCG Integrated Risk Management Framework
• IES&WSCCG Serious Incident (SI) Management Policy
• IES&WSCCG Recruitment and Retention Policy
• IES&WSCCG Information Governance Policy
• IES&WSCCG Information Sharing Policy
• IES&WSCCG Managing Investigations Guidelines
• IES&WSCCG Constitution

Contents

1. Introduction
2. Purpose
3. IES&WSCCG Strategic Vision
4. Definitions
5. Safeguarding Roles and Responsibilities
6. Procedural Requirements
7. IES&WSCCG Staff
Appendix 1: NHS England- Safeguarding Vulnerable People in the NHS- Accountability and Assurance Framework
Appendix 2: SSAB Safeguarding Guidelines 2019
Appendix 3: Domestic violence
Appendix 4: Modern Slavery Guidance
Appendix 5: Prevent
Appendix 6: Safeguarding Flowchart for IES&WSCCG

1. Introduction

Safeguarding is everyone’s responsibility and everyone has a duty to recognise abuse and take action to protect adults at risk of abuse or neglect.

The NHS Ipswich and East Suffolk and West Suffolk Clinical Commissioning Groups (IES&WSCCG) is committed to:

• Ensuring that the welfare of adults is paramount at all times
• Maximising people’s choice, control and inclusion and protecting their human rights
• Working in partnership with others in order to safeguard adults
• Ensuring safe and effective working practices are in place.
• Supporting staff within the organisation.

2. Purpose

2.1 Aims

2.11 This policy provides the framework that ensures a robust and safe system is in place to safeguard adults who may be at risk from harm and abuse.

2.12 This policy sets out the roles and responsibilities of IES&WSCCG in working together with other professionals and agencies in promoting the welfare of adults at risk and safeguarding them from abuse and neglect.

2.13 This policy describes how IES&WSCCG discharges its safeguarding responsibilities for commissioning health services. It should be read in conjunction with: Safeguarding Vulnerable People in the Reformed NHS Accountability and Assurance Framework March (2015). See Appendix 1

2.14 This policy is intended to support staff working within IES&WSCCG; it does not replace but is supplementary to the Suffolk Safeguarding Adults Guidelines. (See Appendix 2)

2.15 This policy applies to all IES&WSCCG staff (permanent, fixed term, seconded, temporary and volunteers).

2.16 Commissioned provider services, services that work in partnership with other providers and independent contractors are expected to have robust policies and guidelines in place to support their staff in relation to their responsibilities for safeguarding adults at risk

2.2 Principles

In May 2011 the Department of Health (DoH) issued a statement on Safeguarding Adults which sets out six safeguarding principles which should underpin all safeguarding work.

Principle 1: Empowerment: presumption of person led decisions and consent
Principle 2: Protection: Support and representation for those in greatest need
Principle 3: Prevention: Prevention of neglect harm and abuse is a primary objective
Principle 4: Proportionality: Proportionality and least intrusive response appropriate to the risk presented
Principle 5: Partnerships: Local solutions through services working with their communities
Principle 6: Accountability and transparency in delivering safeguarding

3. IES&WSCCG Strategic Vision

3.11 IES&WSCCG is committed to delivering safe and effective safeguarding services and to strengthening arrangements for safeguarding adults at risk across the Suffolk area and wider. Our vision is to provide services to promote and protect individual human rights, independence and well-being and ensure that the welfare of adults at risk from harm and abuse is paramount at all times.

3.12 IES&WSCCG ensures safeguarding, protection and promoting well-being features in all its activities with children and their parents, adults at risk and their carers/families and staff.

3.13 IES&WSCCG is committed to preventing harm and abuse of adults. Where we suspect or identify that harm, crime, neglect or abuse is happening, we will respond quickly to protect the person and those around them.

3.14 No single agency can deal with safeguarding adults at risk alone. We work closely with our partners in the NHS, independent sector, Care Quality Commission (CQC), Suffolk Police and Suffolk Social Care (SCC) to ensure we have a joined up, robust approach to safeguarding adults who may be at risk of harm or abuse.

3.15 In partnership with the population IES&WSCCG will develop a strategic plan that ensures safeguarding adults is incorporated into the organisational approach to quality, risk management and communication.

3.16 In applying its Patient Engagement and Communication Strategy, the CCGs will consider and address the ways in which the experiences and views of adults who potentially may be at risk and their carers can be incorporated.

3.17 As part of the CCGs commitment to Equality and Diversity, the CCGs will work with carer and patient representatives on its forums and with partner agencies and providers to establish the most effective way of engaging with and gaining the views of adults at risk and their carers in the development of services.

3.18 The complaints arrangements within the CCGs and its commissioned services will be designed to highlight and report safeguarding issues.

3.19 The CCGs will include the requirement to safeguard and promote adult welfare into Corporate Plans, and the Transformation and Delivery Committee will assess any proposals for service development for its impact on safeguarding adults.

4 Definitions

Adult Safeguarding

4.1.1 Adult at risk

The term ‘adult at risk’ has been used to replace the term ‘vulnerable adult’. Equally the Care Act (2014) safeguarding guidance has replaced No secrets (2000).

4.1.2 The purpose of adult safeguarding is to prevent harm and reduce the risk of abuse or neglect to adults with care and support needs. The statutory framework introduced under the Care Act (2014) applies to any person aged 18 or above who:

Has needs for care and support (regardless of the level of need and whether or not the local authority is meeting any of those needs)

• Is experiencing, or is at risk of abuse or neglect, and
• As a result of those needs, is unable to protect themselves against the abuse or neglect or the risk of it.

4.1.3 Duty to Safeguard Adults

Human Rights Act (1998)

It must be remembered that everyone has the right to live their lives free from violence and abuse. This right is underpinned by the duty on public agencies under the Human Rights Act (1998) to intervene proportionately to protect the rights of citizens. These rights include:

Article 2: ‘the Right to Life’;
Article 3: ‘the Right to Freedom from torture’ (including humiliating and degrading treatment);
Article 5: the right to liberty and security of person
Article 8: ‘the Right to family life’ (one that sustains the individual).

4.2 Abuse

Abuse and neglect can take many forms. It may be an isolated incident, a series of incidents or a long-term pattern of behaviour and could affect one person or more, whether in someone’s home, in public or in an institutional setting. It may be deliberate or the result of negligence or ignorance. Anyone can carry out abuse or neglect.

4.21 Categories of Abuse

• Physical abuse – The non-accidental infliction of physical force that results (or could result) in bodily injury, pain or impairment including; assault, hitting, slapping, pushing, misuse of medication, restraint or inappropriate physical sanctions.
• Domestic violence – This includes: psychological, physical, sexual, financial, emotional abuse; so called ‘honour’ violence including Female Genital Mutilation; forced marriage. For further information on domestic violence and the honour based violence see www.suffolksp.org.uk/Appendix 3
• Sexual abuse – Direct or indirect involvement in sexual activity without consent. Could include: rape, indecent exposure, sexual harassment including rape, inappropriate looking or touching, sexual teasing or innuendo, sexual photography, subjection to pornography or witnessing sexual acts, indecent exposure and sexual assault or sexual acts to which the adult has not consented or was pressured into consenting.
• Psychological abuse – Acts or behaviour which impinge on the emotional health of, or which causes distress or anguish to, individuals. Including emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, cyber bullying, isolation or unreasonable and unjustified withdrawal of services or supportive networks.
• Financial or material abuse – Unauthorised, fraudulent obtaining and improper use of funds, property or any resources of an adult at risk from abuse. Including theft, fraud, internet scamming, coercion in relation to an adult’s financial affairs or arrangements, including in connection with wills, property, inheritance or financial transactions, or the misuse or misappropriation of property, possessions or benefits.
• Modern slavery – encompasses slavery, human trafficking, forced labour and domestic servitude. Traffickers and slave masters use whatever means they have at their disposal to coerce, deceive and force individuals into a life of abuse, servitude and inhumane treatment. See Appendix 4 for more information.
• Discriminatory abuse – Discriminatory abuse exists when values, beliefs or culture result in a misuse of power that denies mainstream opportunities to some groups or individuals. Examples including forms of harassment, slurs or similar treatment; because of race, gender and gender, age, disability, sexual orientation or religion.
• Organisational abuse – Institutional abuse occurs where the culture of the organisation (such as a care home) places emphasis on the running of the establishment and the needs of the staff above the needs and care of the person including neglect and poor care practice within an institution or specific care setting such as a hospital or care home, for example, or in relation to care provided in one’s own home from domiciliary services. This may range from one off incidents to ongoing ill-treatment. It can be through neglect or poor professional practice as a result of the structure, policies, processes and practices within an organisation.
• Neglect and acts of omission – Including ignoring medical, emotional or physical care needs, failure to provide access to appropriate health, care and support or educational services, the withholding of the necessities of life, such as medication, adequate nutrition and heating.
• Self-neglect – this covers a wide range of behaviour neglecting to care for one’s personal hygiene, health or surroundings and includes behaviour such as hoarding. Self-neglect may or may not be a safeguarding issue, however agencies must assess concerns raised under their statutory duties; having consideration for an individual’s right to choose their lifestyle, balanced with their mental health or capacity to understand the consequences of their actions. Once identified as a situation that cannot be managed through regular case management, high risk or self-neglect situations will be managed through the safeguarding process. Self- neglect is characterised as the behaviour of a person that threatens his/her own health or safety.

4.3. PREVENT

The Government’s anti-terrorism strategy, known as CONTEST, encourages co-operation between public service organisations. CONTEST has four key principles:

• PURSUE: to stop terrorists
• PREVENT: to stop people becoming terrorists or supporting violent extremism.
• PROTECT: to strengthen our overall protection against terrorist attacks
• PREPARE: where we cannot stop an attack, to mitigate its impact.

The NHS has been identified as a key partner in the Prevent stream.

The current level of terrorist attack can be located via Terrorism and national emergencies: Terrorism threat levels – GOV.UK (www.gov.uk)

4.3.1 Both CCGs are committed to the Prevent strategy. Staff have a responsibility to help IES&WSCCG fulfil its obligation to minimise risks by identifying and supporting individuals who may be prone to radicalisation and influence of violent extremism.

4.3.2 Reporting Concerns of Radicalisation

If you have a concern about a vulnerable individual who may be at risk of being exploited by radicalisers and subsequently drawn into violent extremism then please discuss with a member of the CCG Safeguarding team as onward referrals may be needed.

In the absence of the CCG Safeguarding Team being available please contact the following:

• Emergency, immediate threat: 999
• Non-emergency: 101 and ask for the Counter Terrorism Police
• Confidential anti-terrorist hotline: 0800 789 321
• Alternatively seek advice via an email to the police on prevent@norfolk.pnn.police.uk

It is also important to complete the relevant Social Care referral form as being vulnerable to radicalisation is an important aspect of safeguarding. For adults this is the link for the alert form preventreferrals@suffolk.pnn.police.uk.

Further guidance about Prevent is given in Appendix 5 with a link to the Suffolk Prevent policy.

5. Safeguarding Roles and Responsibilities.

5.1. IES&WSCCG

5.1.1 IES&WSCCG is statutorily responsible for ensuring that the organisations from which it commissions services provide a safe system that safeguards adults at risk of abuse and neglect.

5.1.2 IES&WSCCG has a statutory duty to be a member of the Suffolk Safeguarding Partnership (SSP) and must cooperate with the local authority in the operation of Health and Well-being Boards.

5.1.3 IES&WSCCG ensures that robust processes are in place to learn lessons from cases where adults die or are seriously harmed, and abuse and neglect is known or suspected.

5.1.4 IES&WSCCG has a clear line of accountability for safeguarding reflected in its governance arrangements.

5.1.5 IES&WSCCG provides training to staff in recognising and reporting safeguarding issues.

5.1.6 IES&WSCCG ensures that there are effective arrangements in place for information sharing on safeguarding.

5.1.7 IES&WSCCG has secured the expertise of designated clinical experts with the authority to influence local thinking and practice in relation to safeguarding.

5.2. The CCG Board

The Clinical Commissioning Groups (CCG) Board is committed to:

• Ensuring that the welfare of adults at risk from harm and abuse is paramount at all times
• Maximising people’s choice, control and inclusion and protecting their human rights
• Working in partnership with others in order to safeguard adults at risk.
• Ensuring safe and effective working practices are in place.
• Supporting staff within the organisation.

5.2.1 In accordance with section 6 of the CCG Constitution, the CCG Board ensures that there are clear lines of accountability and systems in place for safeguarding within the governance structure of the CCG that take into account the mechanisms and policies recommended by the Local Safeguarding Partnership Boards. The Board has appointed a lay member and named director (referred to as the nominated leads) to provide leadership of safeguarding adults issues and the Mental Capacity Act within the CCG. This responsibility has been reflected within their portfolio/job descriptions and is clearly identified within the organisation and on external communications.

5.2.2 The nominated leads are responsible for establishing robust internal and external assurance systems, encompassing practice, training and workforce issues, and provide reports to the Board. In addition the board receives an annual Safeguarding Adults Report.

5.2.3 The nominated leads ensure that there are strong and effective links with the SSP and that all strategic safeguarding issues are incorporated into both the CCGs commissioning intentions.

5.2.4 Board members receive safeguarding adult’s awareness training in line with the IES&WSCCG mandatory training programme and the Adult safeguarding intercollegiate document. They are clearly briefed on the responsibilities and requirements of the CCG in respect of safeguarding adults at their induction, regardless of their level of training in any other role which they may hold. Board members must attend a safeguarding training and/or development event at least annually.

5.2.5 Board members must maintain a continued awareness of current safeguarding issues and IES&WSCCG’s responsibilities/accountability. They must maintain a knowledge base through reports, newsletters and training/development sessions regarding the above.
5.2.6 Board members must promote the welfare of adults at risk in both personal and CCG activity and comply with all organisational and SSP multi-agency policies and procedures relating to safeguarding and adults at risk.
5.3. Chief Officer

5.3.1 The Chief Officer has responsibility for ensuring the provision of high quality, safe and effective services within the CCG. He/she has overall responsibility and is accountable for ensuring a safe and effective response to adults experiencing and exposed to abuse and neglect in line with statutory duties.

5.4. Director of Nursing and Clinical Quality

5.4.1 The CCG Director of Nursing and Clinical Quality is the named director and nominated lead for safeguarding and is responsible for the execution of all safeguarding responsibilities on behalf of the Accountable Officer and the Board members.

5.4.2 The Director of Nursing and Clinical Quality ensures that the CCG works closely with partner organisations and provides appropriate representation for the Local Safeguarding Partnership Board as required through the statutory duty imposed by the Care Act (2014).

5.4.3 The Director of Nursing and Clinical Quality works in partnership with NHS England in complying with the revised Accountability and Assurance Framework (2015) and works closely with other regulators through the Suffolk wide Quality Surveillance Group to ensure sharing and learning of key information relating to all aspects of patient safety and quality, including safeguarding.

5.4.4 The Director of Nursing and Clinical Quality promotes the safeguarding of adults at risk within commissioning arrangements to meet identified quality standards through quality scrutiny processes and ensures that adults safeguarding is a standing agenda item at all Quality Contract Performance Meetings (QCPM) or Clinical Quality Review Group (CQRG) meetings. He/She are also responsible for ensuring providers and contracted services are aware of their responsibilities in relation to reporting safeguarding incidents.

5.4.5 The Director of Nursing and Clinical Quality monitors the progress of recommendations and outcomes from Serious Incidents (SIs), Individual Management Reviews (IMRs), Safeguarding Adult Reviews (SAR) and Domestic Homicide Reviews (DHRs).

5.4.6 The Director of Nursing and Clinical Quality commissions and signs off IMR’s and recommendations for SARs and DHRs and ensures attendance at relevant multi-agency panels in relation to these.

5.4.7 The Director of Nursing and Clinical Quality reports any safeguarding risks/activity and/or achievements to the Chief Officer and Board through the CCG Quality Committee or direct to the Board, reporting as required to partner agencies. He/she will keep the Board informed of any immediate concerns or media interest regarding safeguarding issues.
5.5 Quality Committee

5.5.1 The Board sub-committee responsible for the oversight of Adult Safeguarding issues is the Quality Committee which reports to the IES&WSCCG Board directly. An annual Safeguarding Adults report is received by the Quality Committee. The annual report consists of but is not limited to the following; feedback from SSP, regional and national networks, new documents, legislation and research in safeguarding, feedback on any SAR, DHR recommendations and action plans.

5.5.2 The Quality Committee ensures that there is a clear internal process within the CCG of enabling all staff and volunteers to be clear of their roles in respect of safeguarding.

5.5.3 The Quality Committee ensures that systems and processes are in place and aligned to SSP Safeguarding Adult processes to review adult safeguarding issues, ensuring action plans are implemented and lessons learned.

5.5.4 The Quality Committee discusses and scrutinises performance and quality monitoring around safeguarding and the monitoring of governance arrangements within the CCG and commissioned providers. Any significant risks and mitigation plans are identified and discussed.

5.5.5 Any reports and papers regarding any specific safeguarding issues are brought to Quality Committee for approval or decision.

5.6. The Safeguarding Adults Team

A Safeguarding Adult Lead is identified within the Suffolk health economy as a clinician with significant roles and responsibilities for safeguarding adults at risk and takes delegated responsibility from the nominated Executive Lead. Their role involves them to:

• Take a strategic lead on adult safeguarding and ensure that the CCG meets its statutory responsibilities in relation to safeguarding adults.
• Be responsible for ensuring comprehensive and robust adult safeguarding arrangements are in place in the IES&WSCCG and in all services commissioned by them.
• Lead on all aspects of safeguarding adults within the IES&WSCCG and will link with other designated leads in other CCGs.
• Monitor contracts with the commissioned providers and be a point of contact for advice and support with regard to safeguarding adults and the Mental Capacity Act (2005)
• Be actively involved in relevant SSP subgroups
• Provide an annual report to the Quality Committee.
• Develop and provide a training programme for all staff groups in relation to safeguarding adults within the CCG.
• Undertake relevant audit and ensure that any recommendations identified through the audit will be shared and implemented across CCG and monitored through an appropriate action plan.
• Provide expert professional support and advice on matters relating to safeguarding adults for other professionals, the CCGs, Local Authority Adult Social Care Departments, the Local SSP Board and its sub-committees and partner agencies.
• Advise on the safeguarding adult aspects of SIs, IMRs, DHRs and SARs and monitor implementation and outcomes of agreed actions.
• Participate as a panel member on any local DHR’s and SAR’s.
• Advise and input into the development of organisational and multi-agency strategy, policy procedures and projects relating to safeguarding adults.
• Alert IES&WSCCG to situations which compromise the CCGs ability to discharge its responsibility in relation to safeguarding adults.
• Challenge decisions in multi-agency arenas, where adults are believed to remain at risk via escalation processes outlined in health guidance and in SSP Procedures.

5.7 All IES&WSCCG Staff

All CCG staff will:

• Follow the safeguarding policies and procedures at all times, particularly if concerns arise about the safety or welfare of an adult at risk.
• Complete safeguarding adults training and maintain their working knowledge.
• Discuss any concerns about the welfare of an adult at risk with their line manager and /or the Safeguarding Adult Lead and complete a Suffolk Adult Care Portal to formally report those concerns.
• Contribute to actions required including information sharing and attending meetings.
• Work collaboratively with other agencies to safeguard and protect the welfare of people who use services.
• Remain alert at all times to the possibility of abuse.
• Recognise the impact that diversity, beliefs and values of people who use services can have.

In addition, Managers have the following responsibilities:

Ensure that their team members have adequate and appropriate training for their roles and responsibilities within Adult Safeguarding in line with the IES&WSCCG mandatory training programme and the Adult Safeguarding Intercollegiate document.

• Provide support and advice (within their own competency) to all staff when dealing with Adult Safeguarding issues and to provide support, advice and resources to enable the Safeguarding Adults Lead to fulfil their role.
• Provide a safe environment in which to work and receive services, without fear of reprisal in accordance with the CCG’s Whistleblowing Policy.
• Encourage an atmosphere of openness so that staff can approach them with any concerns regarding the adult at risk from harm and abuse.
• Ensure that safeguarding adults becomes fully integrated into the CCG systems and processes.

5.8 IES&WSCCG Monitoring of provider organisations.

Safeguarding forms part of the NHS standard contract. As part of its quality monitoring and scrutiny role, IES&WSCCG monitors the organisations/services which it has a commissioning role in.

The CCG will ensure that it positively considers issues relating to adults at risk in its planning, decision making and contracting by:

• Ensuring that Adult Safeguarding issues are integrated into the commissioning cycle and procurement processes.
• Understanding and disseminating the priorities of the SSP
• Understanding the priorities of partner organisations, and ensuring that these are considered when developing the CCG Commissioning Intentions
• Engaging with service users
• Incorporating data from provider surveys or engagement into planning and review processes
• Incorporating lessons learned from SARs and DHR’s
• Incorporating a requirement for impact analysis on vulnerable groups within each business case submission
• Incorporating into contracts the requirement to comply with minimum specified legislation and SSP procedures
• Making clear in contracts the expectation that providers will develop internal processes in accordance with SSP guidelines, and provide evidence of engagement with vulnerable service users in any service redesign
• Requiring providers to submit Adult Safeguarding reports at an agreed frequency as part of the service assurance framework, and using information from these within contract monitoring meetings where relevant
• Specifying the requirement to and processes to be used when alerting and escalating adult safeguarding issues

The CCG will ensure that the services it commissions:

• Operate with policies and procedures aligned to the SSP Adult Safeguarding Guidelines, and that these procedures are person centred and include protocols for sharing information across agencies about safeguarding concerns.
• Are compliant with the Mental Capacity Act (MCA) 2005 and Deprivation of Liberty Safeguards (DoLS) 2008.
• Have a process for embedding any lessons learned from serious incidents, SAR’s and DHR’s that inform practice and result in improved outcomes for adults at risk.
• Can evidence leadership to embed the Mental Capacity Act 2005 and connect it to best practice in safeguarding adults
• Have a staff Whistleblowing Policy in place and are able to offer evidence of how issues that staff have raised have been progressed and resolved
• Have reporting structures in place to notify commissioners of any safeguarding concerns
• Have a structured staff training programme which meet the varying levels of specialism related to Safeguarding, Mental Capacity and Deprivation of Liberty Safeguards, which are evaluated and linked to the implementation of policies and procedures relating to consent, capacity and information sharing
• Are able to evidence clear policies and systems for the supervision and support of those staff involved in adult safeguarding investigations or procedures
• Provide information in accessible formats about local adult safeguarding procedures
• Can evidence best interest decision making where adults lack capacity to make decisions, including an audit of referrals to Independent Mental Capacity Advocates
• Have systems in place to monitor the failure of individuals to attend appointments and processes to inform referrers when appointments have been missed.
• Has missing persons protocols in place
• Completes the annual SSP audit when required.
• Follows the Safe recruitment policies in place as set out in NHS standards of recruitment which include recommendations relating to relevant checks with the Disclosure and Barring Service
• Co-operates and complies with any performance indicators set by both the CCGs
• Complies with the Government PREVENT anti-terrorist strategy and delivers training to all staff at the relevant levels.

6. Procedural Requirements

6.1. Reporting Safeguarding Adult concerns

All service users need to be safe. Throughout the safeguarding adult process the service user’s needs remain paramount. This process is about protecting the adult and prevention of abuse. All staff will be required to follow the SSP Guidelines available on https://www.suffolksp.org.uk/

6.1.1 If at the time staff have reason to believe the person is in immediate and serious risk of harm or that a crime has been committed the police must be called on 999.

6.1.2 If at any time staff feel the person needs urgent medical assistance, they have a duty to call 999 or arrange for a doctor to see the person at the earliest opportunity.

1. A Suffolk Adult Care Portal form (safeguarding alert form) must be completed where there are allegations of abuse or concerns for the welfare of an adult who is at risk and sent to the relevant Social Care area. The most current form and guidance notes can be found via www.suffolksp.org.uk then go to the professionals section/reporting concerns or via the CCG’s web page link. The form is not included in the policy as they are updated regularly so the link will take you to the most current one. Telephone numbers are also available on this page.

6.1.3 If you suspect an adult is being abused or is at risk of abuse, you must report the concerns to your line manager (unless you suspect that the line manager is implicated – in such circumstances the Whistleblowing Policy should be followed.

6.1.4 Any safeguarding concerns which meet the criteria of a serious incident must be reported as a Serious Incident.

6.1.5 Additional advice is available if needed from the Safeguarding Adult Lead. Advice can also be found on the SSP website.

6.1.6 See flowchart for how to raise a safeguard in Appendix

6.2. Duty to make enquiries

6.2.1 Under the Care Act 2014 the Local Authority must make enquiries or ensure others do so, if it reasonably suspects that an adult who has care and support needs is being abused or neglected and they are unable to protect themselves against the abuse or neglect because of those needs.

6.2.2 An enquiry should establish whether any action needs to be taken to prevent or stop abuse or neglect and if so by whom. The scope of the enquiry, who leads it and its nature, will depend on the circumstances. If the Local Authority decides that someone else should undertake the enquiry (a provider for example) the Local Authority must specify the timescales for this and be informed about the outcomes of the enquiry.

6.3. Making Safeguarding Personal

The Local authority are the leads in investigating any safeguarding referrals. They are committed to the principles of Making Safeguarding Personal with the aims of ensuring that safeguarding is person-led and focused on the outcomes they want to achieve. 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.

6.4. Choices and Risk

Where a member of staff perceives that the lifestyle choices of the service user or carer is creating a situation where the service user may be seen to be at serious risk of abuse, then the circumstances must be reported by using Suffolk Adult Care Portal form and reviewed through a properly constituted professional meeting. Decisions about risk at this level should never be taken by individual staff.

6.5. Capacity and Consent

6.5.1 The Care Act 2014 stipulates that organisations should always promote the adult’s wellbeing in their safeguarding arrangements. It emphasises that people have complex lives, being safe is only one of the things they want for themselves and that 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 well-being.

6.5.2 Two of the overriding principles in Safeguarding Adults are capacity and consent. Whenever possible every effort must be made to obtain the consent of an adult to report abuse taking into consideration the definitions of the Mental Capacity Act (2005). However, when there is a duty of care due to the adult not having the capacity to protect him / herself a discussion with the safeguarding adult lead/line manager to determine how best to proceed may be needed ensuring that the CCG guidelines on information sharing are followed.

6.5.3 Any patient affected by abuse, who has capacity, should be consulted regarding whether or not they wish action to be taken in relation to their own situation. However, their response will be viewed in the context of the need for any intervention in order to protect other service users and / or staff from harm or risk of harm. If the individual does not wish to report the abuse a discussion must take place with the Safeguarding Adult Lead/line manager regarding the appropriate course of action to safeguard other service users, staff and whether it is in the public interest.

6.6. Deprivation of Liberty Safeguards (MCA DOLS)

6.6.1 The Deprivation of Liberty Safeguards (DoLS) is part of the framework of standards under the Mental Capacity Act 2005. They aim to make sure that people in care homes and hospitals are looked after in a way that does not inappropriately restrict their freedom. The safeguards should ensure that a care home or hospital only deprives someone of their liberty in a safe and correct way that this is only done when it is in the best interests of the person and there is no other way to look after them.

6.6.2 Deprivation of Liberty Outside Hospital or Care Home setting
These are not covered by the Safeguards as mentioned above, but it has been recognised by the Supreme Court (P v Cheshire West and Chester Council 2014, and P&Q v Surrey County Council 2014) that a deprivation of someone’s liberty may also occur in an environment other than a care home.

Where a person does not have the capacity to make decisions about where and how they live there are two key questions that need to be asked.

1. Is the person free to leave?
2. Is the person subject to continuous control and supervision?

If the person is subject to continuous control and supervision and not free to leave, then their circumstances might amount to a deprivation of their liberty and an application should be made to the Court of Protection for authorisation.

6.6.3 IES&WSCCG are responsible to make applications to the Court of Protection for any of the patients they fund where they lack capacity and the care package provided could amount to a Deprivation of Liberty. IES&WSCCG adhere to and follow the SSP and SCC Mental Capacity and Deprivation of Liberty Safeguards Guidance (MCA +DoLs).

6.7. Information Sharing

6.7.1 Where there are safeguarding concerns staff have a duty to share information. It is important to remember that in most SAR’s and DHR’s a lack of information sharing is often a significant contributory factor when things have gone wrong and harm and abuse have occurred. Early sharing of information is key to providing effective help where there are emerging concerns. The wellbeing of adults at risk of abuse is likely to be more important than concerns about sharing information.

6.7.2 Information should be shared with consent wherever possible. A person’s right to confidentiality is not absolute and may be overridden where there is evidence that sharing information is necessary to support an investigation or in best interests e.g. in the interests of public safety, police investigation, implications for regulated service.

6.7.3 The key factors in deciding whether or not to share confidential information are necessity – sharing is likely to make an effective contribution to preventing the risk, and proportionality – the public interest in sharing outweighs the interest in maintaining confidentiality. If there is any doubt about whether to share information, advice should be sought.

6.7.4 Investigating and responding to suspected abuse or neglect requires close cooperation between organisations. Safeguarding adults work is concerned with sharing personal information, both about someone who is alleged to have experienced abuse and the alleged perpetrator.

6.7.5 IES&WSCCG have signed up to the Suffolk Information Sharing framework which is an information sharing protocol. For further information see the Suffolk guidelines in Appendix 2, and IES&WSCCG Information sharing policy.

6.8 Statutory reviews

A number of statutory reviews are required to be undertaken by relevant agencies including health when particular circumstances arise. All agencies including IES&WSCCG that are asked to participate in a statutory review must do so. The different types of review include:

6.81. Domestic Homicide Reviews
These are convened by the local community safety partnership when the defined criteria has been met following the death of a person aged 16 or over has, or appears to have resulted from violence, abuse or neglect.

6.82. Safeguarding Adult Review
These are convened by the local Safeguarding Adults Board for every case where an adult has died from, or experienced serious abuse or neglect and there is reasonable cause for concern about how agencies and service providers involved worked together to safeguard the person.

7. IES&WSCCG Staff

7.1. Training

7.1.1 Safeguarding Adults training is mandatory and is part of the IES&WSCCG mandatory training programme.

7.1.2 All staff should receive safeguarding adult’s awareness training at a competency level according to their role and in line with the Adult Safeguarding: Roles and Competencies for the Health Care staff Intercollegiate Document. This should be refreshed as a minimum every three years for all staff.

7.1.3 Both CCG’s provide training to meet the varying levels of specialism required by both CCG’s workforce. A database is maintained that enables this to be monitored on a regular basis by the Safeguarding Adult Lead, the Quality Committee and the Board.

7.1.4 All staff must receive Prevent awareness/training at a competency level according to their role as per the NHS England – Prevent Training and Competencies Framework (2017).

7.1.5 Both CCG’s have appropriately trained and experienced staff to review and manage safeguarding concerns. Their duties and responsibilities are set out. The training and development requirements associated with their job role will be specified, and progress in meeting these requirements will be monitored by the named director and reported to each CCG Board.

7.2 Supervision

7.1.6 Where IES&WSCCG staff have specific responsibilities in safeguarding and promoting the welfare of adults, this will be incorporated in the job description and work objectives of the individual, and the supervision and support structure for those individuals will be clearly documented.

7.2.1 IES&WSCCG staff can arrange supervision and case discussions with the safeguarding adult lead when and where necessary at a time convenient to both.

7.3. Safer Recruitment

7.3.1 Both CCG’s adopt safe recruitment procedures in accordance with best practice guidance within the NHS and SSP safer recruitment and employment guidance (2010), and ensure that any organisation delivering its recruitment function can demonstrate awareness of the requirements, and systems of practice that ensure that there are ‘fail-safe’ checks.

7.3.2 Both CCG’s ensure that where disciplinary action has been taken against an employee of either CCG the appropriate action has been taken in respect of notification to Professional Bodies or reporting under the Safeguarding Vulnerable Groups Act (2006).

7.3.3 There is a statutory scheme for vetting people working with children and adults at risk of abuse and neglect. It is administered by the Disclosure and Barring service. This system provides checks on people entering the workforce and maintains lists of individuals who are barred from undertaking regulated activity with either children or adults at risk of abuse and neglect.

7.4. Allegation of abuse against a staff member

This section of the policy relates to a staff member who may have behaved in a way that has or may have harmed adults at risk or committed a criminal offence against or related to adults at risk. They may have also behaved toward adults at risk in a way, which indicates s/he is unsuitable to work with adults at risk. This may be in their professional or personal life.

7.4.1 Any member of staff who becomes aware of a concern about an allegation of concerns in relation to safeguarding children or an adult at risk by an employee of either CCG must report it to the line manager of that employee

7.4.2 The Line Manager must take advice from a senior member of the Human Resources Department and must report any allegations to the Named Senior Officer for IES&WSCCG (Director of Nursing) at the earliest opportunity (the recipient of the allegation must not try to unilaterally determine the validity of the allegation)

7.4.3 The Named Senior Officer informs the Local Authority Designated Officer for adults within one working day of allegation being made.

7.4.4 The Named Senior Officer works collaboratively with other agencies contributing to a strategy meeting and taking appropriate action as agreed.

7.4.5 Consideration is given in regard to Disciplinary Procedures e.g. suspension, referral to disclosure and Barring Service (DBS), even if the allegation is not considered sufficiently harmful under the safeguarding adult guidelines. Employees should be aware that abuse is a serious matter that can lead to a criminal conviction. Where applicable the organisation’s disciplinary policy will be implemented.

7.4.6 If concerns arise about a member of staff’s behaviour towards any vulnerable adult, Adult Social Care and/or Police must inform the organisation in order to assess whether there may be implications for children or adults at risk with whom the person has contact at work.

Appendix 1: NHS England- Safeguarding Vulnerable People in the NHS- Accountability and Assurance Framework

NHS England- Safeguarding Vulnerable People in the NHS- Accountability and Assurance Framework

Appendix 2: SSP Safeguarding Guidelines April 2019

SSP Safeguarding Guidelines April 2019: Safeguarding Framework and Threshold Matrix — Suffolk Safeguarding Partnership (suffolksp.org.uk)

Appendix 3: Domestic Violence

The definition of domestic abuse used by the Home Office and most agencies is:

‘Any incident or pattern of incidents of controlling, coercive or threatening behaviour, violence or abuse between those aged 16 or over who are or have been intimate partners or family members regardless of gender or sexuality.’

Domestic abuse is about the power and control of one person over another and can take many forms. For further information on domestic abuse see www.essexsab.org

Many people think that domestic abuse is about intimate partners, but it is clear that other family members are included and that much safeguarding work that occurs at home is, in fact is concerned with domestic abuse. This confirms that domestic abuse approaches and legislation can be considered safeguarding responses in appropriate cases. Such abusive behaviour can include, for example:

• Constant criticism and belittling comment
• Verbal abuse and threats (including threats to harm the children)
• Isolation and control of contact with family and friends
• Restrictions on entry/exit from home;
• Intimidation
• Controlling and coercive behaviour
• Denial of privacy
• Oppressive control of finances and withholding of food
• Destruction of personal property and valued possessions

Any staff with concerns regarding domestic abuse should follow the SET Safeguarding Adults and child protection Guidelines.

Further useful information can be found at via the Suffolk Safeguarding Partnership domestic abuse and violence web pages.

The Serious Crime Act 2015 created a new offence of controlling or coercive behaviour in intimate or familial relationships (section 76). The new offence closes a gap in the law around patterns of controlling or coercive behaviour in an ongoing relationship between intimate partners or family members. The offence carries a maximum sentence of 5 years’ imprisonment, a fine or both.

The offence closes a gap in the law around patterns of controlling or coercive behaviour that occurs during a relationship between intimate partners, former partners who still live together or family members. This offence sends a clear message that this form of domestic abuse can constitute a serious offence particularly in light of the violation of trust it represents and will provide better protection to victims experiencing repeated or continuous abuse. It sets out the importance of recognising the harm caused by coercion or control, the cumulative impact on the victim and that a repeated pattern of abuse can be more injurious.

Honour Based Abuse (including Forced Marriage and Female Genital Mutilation)

Violence and abuse in the name of honour covers a variety of behaviours (including crimes), mainly but not exclusively against women where the person is being punished by their family and/or community for a perceived transgression against the ‘honour’ of the family or community.

This includes:

• Physical abuse
• Financial abuse
• Sexual abuse
• Forced marriage
• Emotional and psychological abuse
• Female genital mutilation

HBA can be distinguished from other forms of abuse, as it is often committed with some degree of approval and/or collusion from family and/or community members Victims will have multiple perpetrators not only in UK but can be abroad, HBA can be a trigger for Forced Marriage

Honour is normally associated with cultures and communities from Asia, the Middle East and Africa as well as the travelling communities.

If you suspect someone is suffering from honour-based abuse, contact the police or the honour-based lead in social care. DO NOT inform or discuss anything with family.

Another organisation that offers advice on HBA and FM is Karma Nirvana:

Helpline: 0800 5999 247
Email: info@karmanirvana.org.uk

For further information on Honour Based Abuse see the Suffolk Safeguarding Partnership Forced Marriage & Honour Based Abuse web pages.

Forced marriage is an abuse of human rights. “Marriage shall be entered into only with the free and full consent of the intending spouses” (Universal Declaration of Human Rights, Article 16(2)).

A forced marriage is where one or both people do not consent to the marriage and pressure, coercion or abuse is used. Forced marriages can occur in this country and abroad.

Forced marriage is now a criminal offence.

There is a forced marriage unit that can provide support advice and offer safe accommodation. Below are the contact details and a link if you have concerns about someone being forced into marriage.

www.gov.uk/forced-marriage
0207 008 0151
fmu@fco.gov.uk

Female Genital Mutilation

Female Genital Mutilation is the collective term used for procedures which include the partial or total removal of the external female genital organs for cultural or other non-therapeutic reasons. Female Genital Mutilation is typically performed on girls aged between 4 and 13years of age but also at times occurs from birth or in young women before marriage or pregnancy. The Prohibition of Female Circumcision Act 1985 made this practice illegal in this country. The Female Genital Mutilation Act 2003 replaced the 1985 Act and it is now illegal for girls to be taken abroad for this procedure.

There are 4 types of FGM-

Type i – Clitoridectomy
Partial or total removal of the clitoris and sometimes the prepuce (the fold of skin surrounding the clitoris)

Type ii – Excision

Partial or total removal of the clitoris and the labia minora, with or without excision of the labia majora (the labia are the ‘lips’ that surround the vagina

Type iii – Infibulation

Narrowing of the vaginal opening through the creation of a covering seal. The seal is formed by cutting and repositioning the inner and sometimes outer labia, with or without removal of the clitoris.

Type iv – Other

All other harmful procedures to the female genitalia for non-medical purposes.

• Such as pricking, piercing, incising, and cauterization.
• Pulling and stretching the labia and clitoris

Agencies need to work together to promote a better understanding of Female Genital Mutilation and the potential damaging effects upon health. By working in partnership with families and raising their awareness we will be more able to protect children and young females from this type of abuse.

All health professionals have a legal duty to report and share information to the police and social care if they are aware that a child under 18 has had or is at risk of FGM. Professionals must also consider the risks to other girls and women who may be related to or living with an individual with FGM as it is an inter-generational practice, their girls and young women may also be at significant risk of harm.

It is expected that all staff follow the SET Safeguarding Adults Guidelines and also make reference to the SET child protection guidelines.

Mandatory Reporting of FGM to the Health and Social Care Information Centre (HSCIC)

Collection and submission of the new dataset becomes mandatory for all acute trusts from 1 July 2015, and all Mental Health Trusts and GPs from 1 October 2015. The FGM Enhanced Information Standard (SCCI2026) instructs all clinicians to record into clinical notes when a patient with FGM is identified, and what type it is. Data should be submitted every time the woman or girl has treatment related to her FGM or gives birth to a baby girl, and every time FGM is identified (by a clinician or self-reported), not just the first time. The dataset includes patient demographic data, specific FGM information, referral and treatment information. Further information can be located on the NHS Digital website.

FGM Helpline- 0800 028 3550

Appendix 4: Modern Slavery Guidance

Modern Slavery – Suffolk County Council

Appendix 5: PREVENT

1. Introduction

The Government’s anti-terrorism strategy, known as CONTEST, encourages co-operation between public service organisations.

CONTEST has four key principles:

• PURSUE: to stop terrorists
• PREVENT: to stop people becoming terrorists or supporting violent extremism.
• PROTECT: to strengthen our overall protection against terrorist attacks
• PREPARE: where we cannot stop an attack, to mitigate its impact.

The NHS has been identified as a key partner in the Prevent stream.
The current level of terrorist attack can be located via Terrorism and national emergencies: Terrorism threat levels – GOV.UK (www.gov.uk)

2. What is Prevent?

The aim of Prevent is to stop people from becoming terrorists or supporting violent extremism. The Prevent objectives that relate to health organisations are to:

• challenge the ideology behind violent extremism and support mainstream voices;
• disrupt those who promote violent extremism and support the places where they operate;
• support individuals who are vulnerable to recruitment, or have already been recruited by violent extremists;
• increase the resilience of communities to violent extremism; and
• to address the grievances which ideologues are exploiting.

Prevent is one of the most challenging parts of the counter terrorism strategy because it operates in the pre-criminal space before any criminal activity has taken place and it is about supporting and protecting those people that might be susceptible to radicalisation, ensuring that individuals and communities have the resilience to resist violent extremism.

3. How does this affect you in your work?

Healthcare workers will be the key to the success of Prevent. The focus of Prevent is working with vulnerable individuals who may be at risk of being exploited by radicalisers and subsequently drawn into violent extremism. Prevent does not require you to do anything additional to your normal duties. What is important is that if you are concerned that a vulnerable individual is being exploited by people involved in violent extremism you can raise these concerns.

4. Practical steps for healthcare staff

In your work you may notice unusual changes in the behaviour of patients and/or colleagues that are sufficient to cause concern. It is important that any member of staff who has cause for concern, and has given their concerns due consideration, knows how to escalate them and has confidence that they will be taken seriously and handled appropriately and that, where necessary, specialist advice will be available.

5. What factors might make people vulnerable to exploitation

Some of the following factors are known to contribute to the vulnerability of individuals and could out them at risk of exploitation by radicalisers.

• Identity crisis – adolescents/vulnerable adults exploring issues of identity can feel distant from their family and/or cultural and religious heritage, and uncomfortable with their place in society. Extremists can exploit this by providing a sense of purpose or feeling of belonging
• Personal crisis – this may include significant tensions within a family that produce a sense of isolation. A sense of personal crisis may manifest itself in unusual changes in areas such as behaviour, circle of friends or interaction with others
• Personal circumstances – the experience of migration, local tensions or events affecting family members in other countries may lead to alienation and a decision to act violently
• Unemployment or under-employment – individuals may feel that their aspirations for career and lifestyle are undermined by limited prospects. This may translate to a generalised rejection of civic life and the adoption of violence

Any change in an individual’s behaviour should not be viewed in isolation and you will need to consider how significant the changes are. You will need to use your judgement in determining the significance of any unusual behaviour, and where you have concerns you should escalate in line with local policies and procedures.

6. What should I do if I have concerns?

In the first instance you should contact a member of the safeguarding team. This should be done immediately that concerns are raised. A discussion will then take place to determine whether this is a concern that needs to be referred onwards to the police. This may then lead on to a referral to the CHANNEL programme.

In the absence of the Safeguarding Adult Lead please contact the following:
In an emergency i.e. immediate threat: 999 Police
Non-emergency: 101 and ask for the Counter terrorism police. Confidential anti-terrorist hotline: 0800 789 321

Alternatively seek advice via an email to the police on prevent@suffolk.pnn.police.uk

Please find below further information and guidance on SSP Prevent reporting policy.

Appendix 6: Safeguarding Flowchart for IES&WSCCG

The information conveyed via this flowchart is also described below.

How to raise a Safeguard

This procedure is aimed at all staff.

1. Safeguarding incident occurs/concerns raised
2. Is immediate medical attention required? Is incident so serious that immediate police attendance is required (e.g. rape, serious physical or sexual assault, robbery)?

If the answer to step 2 is “yes”, then:

• Provide First Aid
• Ensure safety of victim
• Call ambulance/ doctor
• Call Police (999)
• Think ‘preservation of evidence’ – see guidance notes (see paragraph 5.4.4)
• Complete SSP / notify manager or Safeguarding Lead

If the answer to step 2 is “no”, then:

• Notify manager, unless manager is alleged perpertrator or implicated in the concern. In these circumstances identify an alternative manager or discuss directly with social services.
• Complete form SSP following local instructions for reporting.
• Discussion can take place with Safeguarding Adult Lead if available.