Safeguarding policy

This policy sets out how Example Housing CIC keeps residents, visitors and anyone else affected by our service safe from abuse, neglect and exploitation. It applies to all staff, volunteers, agency workers and contractors working at any of our schemes. It explains who leads on safeguarding, how to spot and report a concern, how we refer to the local authority, and how we record and follow up every concern.

Safeguarding is everyone's responsibility. Our ethos is: Everyone deserves a safe, stable home and the support to build the life they choose. We listen first, and we work with residents, not for them.

We follow the six principles of adult safeguarding in the Care Act 2014 statutory guidance: empowerment, prevention, proportionality, protection, partnership and accountability. We also make safeguarding personal: we ask the adult what outcome they want, and involve them in every decision about them as far as we can. We assume a resident can make their own decisions unless it is shown that they cannot, as the Mental Capacity Act 2005 says.

This policy is about the safeguarding measures we have in place. Safeguarding training is covered in our staff training policy. Training helps staff use this policy, but it does not replace it.

Who this policy covers

Most of our residents are adults, and many have support needs that can make them more at risk of harm. This includes people who have been homeless, people leaving care, custody or hospital, and people living with mental ill health, substance use or domestic abuse. Our residents are:

• Example House (Birmingham): Men aged 25 and over who need support to keep a home
• Sample Court (Birmingham): Young people aged 18 to 24 who have left care

This policy also covers children. A child is anyone under 18. Children may visit residents, and some residents are parents who do not live with their children. If a child is at risk, we act in the same way, following Working Together to Safeguard Children (the government's statutory guidance), but we refer to the children's services team of the local council rather than adult safeguarding.

A resident aged 16 or 17 is a child. If we find that a resident is under 18, the designated safeguarding lead tells the council's children's services the same day. Supported accommodation for looked after children and care leavers aged 16 or 17 must be registered with Ofsted under the Supported Accommodation (England) Regulations 2023.

When we are worried about an adult, we also think about any children in their life, including an unborn baby.

Our designated safeguarding lead

Our named designated safeguarding lead is Sam Example (Service Manager).

Our deputy designated safeguarding lead is Jo Sample (Service Manager). The deputy covers when the lead is on leave or cannot be reached.

Out of hours, staff contact our on-call contact: the on-call manager on 0121 000 0004. The on-call contact can make an urgent referral and must tell the designated safeguarding lead by the next working day.

The designated safeguarding lead:

• gives advice to staff who are worried about a resident or a child
• decides, with the member of staff, whether to refer to the local authority
• makes sure every concern is recorded and followed up
• keeps the safeguarding log up to date and reviews it at least monthly
• is the main contact for the local authority, police and other agencies on safeguarding matters
• reports themes and numbers of concerns to senior management at least every quarter
• makes sure staff know this policy and where to find it, including during induction

Every scheme displays the name of the designated safeguarding lead and how to contact them, so residents and staff can find it easily.

How to recognise and report a concern

Types of abuse and harm

Abuse can happen anywhere and can be caused by anyone, including other residents, visitors, family members, partners, staff or strangers. Watch for:

• Physical abuse: unexplained injuries, bruising, burns, or a resident who flinches or avoids contact.
• Sexual abuse and exploitation: any sexual activity a person has not agreed to or cannot agree to, including being pressured to exchange sex for drugs, money or a place to stay.
• Psychological or emotional abuse: threats, intimidation, humiliation or controlling behaviour.
• Financial abuse: money, benefits or belongings taken or controlled by someone else; a resident who is suddenly unable to pay for food or bills.
• Neglect: someone who should care for a resident fails to meet their needs, for example by withholding medication, food or heating, or stopping them getting health care or support.
• Self-neglect: a resident not eating, not managing their health, hoarding, or living in unsafe conditions in their room. Self-neglect can be serious even when the person says they are fine.
• Domestic abuse: physical, sexual, violent or threatening behaviour, controlling or coercive behaviour, economic abuse, or psychological or emotional abuse. Under the Domestic Abuse Act 2021, both people are aged 16 or over and are personally connected, for example a partner, former partner or relative. This includes abuse by a visitor and abuse that continues after the person has moved in with us. A child who sees, hears or lives with the effects of domestic abuse is a victim too.
• So-called honour-based abuse, forced marriage and female genital mutilation (FGM): these are forms of abuse and are crimes. If we learn that a girl under 18 has had FGM, we tell the police and children's services straight away.
• Exploitation: including cuckooing (someone taking over a resident's room to deal drugs or for other crime), county lines (gangs using vulnerable people to move drugs or money), mate crime (someone pretending to be a friend in order to use or harm a resident), and criminal or sexual exploitation, including online.
• Modern slavery: slavery, human trafficking, forced labour and domestic servitude. Signs include a resident who is forced to work, has their documents held by someone else, or is controlled by others.
• Radicalisation: a resident being drawn into terrorism, or into extremist views that support terrorism or violence. Concerns go to the designated safeguarding lead, who may seek advice from the council or police about a referral to Prevent, the government's programme to stop people being drawn into terrorism.
• Discriminatory abuse: harassment, slurs or harm because of someone's race, religion, disability, sex, sexual orientation, gender identity or age. This includes hate crime.
• Organisational abuse: neglect or poor practice caused by the way a service is run, including ours. Examples are rigid routines, a culture that ignores residents' wishes, or too few staff to keep people safe.

Warning signs include new or unexplained visitors, a resident who seems frightened of someone, changes in behaviour, missed support sessions, unexplained money or new phones, and damage to doors or locks.

What to do if you are worried

1. If anyone is in immediate danger, call 999. Then tell the designated safeguarding lead or the on-call contact straight away.
2. Listen. If a resident tells you something, stay calm, listen and take them seriously. Do not ask leading questions or investigate yourself.
3. Do not promise secrecy. Explain that you may need to share what they have told you to keep them or others safe.
4. Report it the same day. Tell the designated safeguarding lead (or the deputy or on-call contact) as soon as possible and always before the end of your shift.
5. Record it. Write down what you saw or were told, in the person's own words where you can, with the date and time. Record it in Stedwise within 24 hours.
6. Preserve evidence. Do not clean up or move anything if a crime may have happened.

Residents, visitors and neighbours can also raise a concern with any member of staff, or directly with the designated safeguarding lead.

Concerns about staff

If a concern involves a member of staff, volunteer or contractor, report it straight away to the designated safeguarding lead. If it involves the designated safeguarding lead, report it to a senior manager on the escalation list: Alex Example, Director: 0121 000 0001; Sam Example, Service Manager: 0121 000 0002.

• We tell the local authority about any allegation that a member of staff has harmed a resident, and we follow the local Safeguarding Adults Board's process for concerns about people in a position of trust.
• If the person's behaviour may affect whether they are safe to work with children, we also tell the council's local authority designated officer (LADO).
• We consider whether the person should be removed from work while it is looked into. We treat them fairly and tell them where they can get support.
• The Safeguarding Vulnerable Groups Act 2006 gives us a legal duty to refer a person to the Disclosure and Barring Service (DBS) if both of these apply: we remove them from regulated activity with children or adults (or would have done if they had not left), and we think they have harmed someone, put someone at risk of harm, or may harm someone. Regulated activity is work defined in that Act. It is an offence not to refer without good reason. We still refer if we have already told the council or the police.

Staff can also use our whistleblowing policy.

Local authority safeguarding contact and referral route

Adult safeguarding is led by the local council for the area where the resident lives. Under section 42 of the Care Act 2014, the council must make enquiries, or ask others to, where an adult with care and support needs is experiencing, or is at risk of, abuse or neglect and cannot protect themselves because of those needs.

Our local authority safeguarding contact(s): Birmingham City Council adult safeguarding: 0121 000 0003 (sample number)

We follow the multi-agency safeguarding procedures of the local Safeguarding Adults Board and the local children's safeguarding partnership for each area.

Our schemes are in the following council areas:

• Birmingham

How we refer

1. The designated safeguarding lead (or the person covering) decides whether the concern meets the threshold for a referral. If in doubt, we refer or ask the council for advice.
2. We make the referral within 24 hours of the concern being raised, or immediately if the risk is high.
3. We use the council's own referral route or form and keep a copy.
4. We seek the resident's consent to refer where we can. We can refer without consent if the resident lacks the mental capacity to decide (assessed under the Mental Capacity Act 2005, with any decision made in their best interests), if others are at risk, if a crime has been committed, or if the risk is serious.
5. For children, we refer to children's services of the council where the child lives. We do not need a child's or parent's consent to refer if a child may be at risk of harm, but we tell them unless that would put the child at more risk.
6. For domestic abuse at high risk, we consider a referral to the local multi-agency risk assessment conference (MARAC).
7. For suspected modern slavery, the designated safeguarding lead contacts a first responder organisation, such as the police or the council. Only first responders can make a referral to the National Referral Mechanism, the government's process for identifying and supporting victims. An adult must agree to be referred. If they do not agree, a first responder may still tell the Home Office without naming them. A child does not need to agree. We still tell the police where a crime may have been committed, and we record every decision.
8. We tell the police when a crime may have been committed.

If the resident receives support from another organisation, or their housing and support are delivered separately, we tell that organisation about the concern the same day, subject to the information sharing rules below.

If we disagree with the council's decision and still think the person is at risk, the designated safeguarding lead will ask for the decision to be reviewed and escalate within the council.

We take part in any safeguarding adult review or child safeguarding practice review, and give the reviewers the records they ask for. Under section 45 of the Care Act 2014, we must give a Safeguarding Adults Board information it asks for to do its work, when the conditions in that section are met. Where a serious incident has happened, we also tell our regulators and funders as they require, for example the Regulator of Social Housing, the Care Quality Commission, the Charity Commission and our commissioners.

Recording and follow-up of concerns

Every safeguarding concern is recorded in the safeguarding log in Stedwise, even if we decide not to refer. The log records:

Follow-up

• The designated safeguarding lead checks every new entry within 1 working day.
• We chase the council for an outcome if we have not heard within 5 working days.
• We update the resident's risk assessment and support plan within 5 working days of a concern.
• We keep the resident informed where it is safe to do so.
• A concern is only closed when the designated safeguarding lead is satisfied the risk has been dealt with.
• The designated safeguarding lead reviews the whole log at least monthly for patterns, such as repeated concerns about the same resident, visitor or scheme.

Information sharing and confidentiality

We respect residents' privacy, but confidentiality never comes before someone's safety. We share information under the Data Protection Act 2018 and UK GDPR. Our data protection lead is Alex Example (Director).

• Data protection law does not stop us sharing information to keep someone safe.
• We share information that is necessary and proportionate, relevant, adequate, accurate and timely, and we share it securely.
• We are open with people about what we share and why, unless that would put someone at risk.
• We ask for consent where it is safe and possible. We can share without consent when someone is at risk of serious harm, a child is at risk, or a crime needs to be prevented or detected.
• If we are unsure, we ask the designated safeguarding lead or the data protection lead, without naming the person where we can.
• We only share with people who need to know, such as the council, police, the resident's support provider or health services.
• We record what we shared, with whom, when and why. If we decide not to share, we record that decision and the reasons too.
• Safeguarding records are kept securely in Stedwise, with access limited to staff who need it.
• Staff must not discuss safeguarding matters with other residents or outside work.

Monitoring this policy

Senior managers review the safeguarding log summary at least every quarter. We look at the number and type of concerns, how quickly we acted, and what we have learned. We share lessons with staff in team meetings and supervision, without identifying residents. We also update this policy straight away if local safeguarding arrangements or contacts change.

Review and adoption

We review this document at least every 12 months. We review it sooner if the law, the standards or the way we work change.

Version history

Stedwise made this document as a starting point. Check it and change it to fit how your organisation works before you adopt it. It is not legal advice and it does not guarantee compliance with any standard, licence condition or law.