Safeguarding

Relevant legislation:

• Protection of Freedoms Act 2012 (Disclosure and Barring Service Transfer of Functions) Order 2012

• Public Interest Disclosure Act 1998

• The Criminal Justice and Courts Act 2015 Section 20-25

• Anti-social Behaviour, Crime and Policing Act 2014

• The Modern Slavery Act 2015

• The Counter Terrorism and Security Act 2015

• Domestic Violence, Crime and Victims Act 2004

• Serious Crime Act 2015 Section 76

• FGM Act 2003

• Sexual Offences Act 2003

• The Care Act 2014

• Care Quality Commission (Registration) Regulations 2009

• Equality Act 2010

• The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014

• Human Rights Act 1998

• Mental Capacity Act 2005

• Safeguarding Vulnerable Groups Act 2006

• Data Protection Act 2018

• UK GDPR

Purpose

1.1 To ensure that this policy includes and refers to LANCASHIRE COUNTY COUNCIL policy and procedures and details clearly who is responsible and accountable for managing safeguarding concerns within this service:

1.2 Overall accountability for managing safeguarding concerns: TONI LANCASTER TONI LANCASTER is responsible for the governance and authorisation of this policy.

Safeguarding Lead at this service: Registered Manager

Local Authority: LANCASHIRE COUNTY COUNCIL

Local Authority Main Contact Details: Adults Social Services on 0300 123 6701

1.3 To set out the key arrangements and systems that Mind Map Focus has in place for safeguarding and promoting the welfare of adults at risk and children and to ensure compliance with local policies and procedures. Adults are those aged 18 years and over.

1.4 To meet the legal requirements of the regulated activities that MIND MAP FOCUS is registered to provide:

• Protection of Freedoms Act 2012 (Disclosure and Barring Service Transfer of Functions) Order 2012

• Public Interest Disclosure Act 1998

• The Criminal Justice and Courts Act 2015 Section 20-25

• Anti-social Behaviour, Crime and Policing Act 2014

• The Modern Slavery Act 2015

• The Counter Terrorism and Security Act 2015

• Domestic Violence, Crime and Victims Act 2004

• Serious Crime Act 2015 Section 76

• FGM Act 2003

• Sexual Offences Act 2003

• The Care Act 2014

• Care Quality Commission (Registration) Regulations 2009

• Equality Act 2010

• The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014

• Human Rights Act 1998

• Mental Capacity Act 2005

• Safeguarding Vulnerable Groups Act 2006

Data Protection Act 2018

UK GDPR

Objectives

 2.1 To ensure that the LANCASHIRE COUNTY COUNCIL Safeguarding Policy and Procedure is understood by all staff at Mind Map Focus and that the LANCASHIRE COUNTY COUNCIL safeguarding procedures dovetail with the policy and procedure of Mind Map Focus.

2.2 To ensure that all staff working for, or on behalf of, Mind Map Focus understand their responsibilities in relation to safeguarding adults at risk and know who to escalate concerns to within Mind Map Focus and externally if needed and appropriate to do so.

2.3 To protect the Service User's right to live in safety, free from abuse and neglect.

2.4 To have a clear, well publicised policy of zero-tolerance of abuse within Mind Map Focus.

2.5 To identify lessons to be learnt from cases where Service Users have experienced abuse or neglect.

Policy

3.1 What is Safeguarding? Mind Map Focus recognises the definition of 'safeguarding' as the actions taken to keep Service Users safe from harm and neglect.

 3.2 The Care Act 2014 sets out that adult safeguarding duties apply to any adult who:

• Has care and support needs, and

• Is experiencing, or is at risk of, abuse and neglect, and

• As a result of those care and support needs is unable to protect themselves from either the risk of, or the experience of, abuse or neglect

3.3 Children’s Act sets out that child safeguarding duties apply to any child who:

• Is under the age of 18, and 

• Is experiencing, or is at risk of, abuse or neglect, and 

• May not be able to protect themselves from harm due to their age, developmental stage, or other vulnerabilities. 

3.4 Safeguarding adults includes:

• Protecting their rights to live in safety, free from abuse and neglect

• People and organisations working together to prevent the risk of abuse or neglect, and to stop them from happening

• Making sure people's wellbeing is promoted, taking their views, wishes, feelings and beliefs into account

• This must recognise that adults sometimes have complex interpersonal relationships and may be ambivalent, unclear or unrealistic about their personal circumstances

 3.5 Safeguarding children includes: 

• Protecting their right to grow up in a safe, supportive environment, free from abuse and neglect 

• Ensuring that individuals and organisations work together to identify risks, prevent harm, and respond effectively when concerns arise 

• Promoting the child’s welfare by listening to their views, wishes, and feelings—taking into account their age, understanding, and experiences 

• Recognising that children may struggle to communicate concerns or understand their circumstances, and may be influenced by complex family or social relationships 

 3.6 Mind Map Focus should always promote the Service User's wellbeing in its safeguarding arrangements. Service Users have complex lives and being safe is only one of the things they want for themselves. Staff should work with the Service User to establish what being safe means to them and how that can be best achieved. Staff should not be advocating ‘safety’ measures that do not take account of individual wellbeing.

3.7 What Constitutes Abuse? Employees at Mind Map Focus understand that the Service Users it supports can be extremely vulnerable to abuse and neglect, especially if they have care and support needs.

 Abuse is a violation of an individual's human or civil right by any other person. It is where someone does something to another person, or to themselves, which puts them at risk of harm and impacts on their health and wellbeing.

Abuse can have a damaging effect on the health and wellbeing of Service Users. These effects may be experienced in the short and long term and can sometimes be lifelong.

The signs of abuse are not always obvious, and a victim of abuse may not tell anyone what is happening to them. Sometimes they may not even be aware they are being abused.

The robust governance processes at Mind Map Focus will make sure that staff working for, and on behalf of, Mind Map Focus recognise and respond to the main forms of abuse which are set out in the Care Act 2014 Statutory Guidance Chapter 14.

3.8 The local authority is the lead agency for adult and child safeguarding and should be notified whenever abuse or neglect is suspected. It will decide whether a safeguarding enquiry is necessary, and if so, who will conduct it. The decision to conduct an enquiry depends on the criteria set out in the Care Act 2014, and not on whether a Service User is eligible for, or receiving, services funded by the local authority.

 3.9 Everybody has the right to live a life that is free from harm and abuse. Mind Map Focus recognises that safeguarding individuals at risk of abuse or neglect is everybody's business. Mind Map Focus aims to ensure that all individuals at risk of abuse or neglect are enabled to live and work, be cared for and supported in an environment free from abuse, harassment, violence or aggression.

 3.10 The safeguarding policies and procedures of Mind Map Focus will dovetail with the LANCASHIRE COUNTY COUNCIL multi-agency policy and procedures, which we understand take precedence over those of Mind Map Focus. We will ensure that the LANCASHIRE COUNTY COUNCIL policies and procedures are reflected within our own policy and procedure, that this is shared with all staff and is accessible and available for staff to follow.

3.11 This service aims to provide services that will be appropriate to the people risk and not discriminate because of disability, age, gender, sexual orientation, race, religion, culture, or lifestyle.

It will make every effort to enable Service Users to express their wishes and make their own decisions to the best of their ability, recognising that such self-determination may well involve risk.

We will work with Service Users and others involved in their Care to ensure they receive the support and protection they may require, that they are listened to and treated with respect (including their property, possessions and personal information) and that they are treated with compassion and dignity.

3.12 A chaperone is always present when a Service User needs treatment and missed healthcare appointments must be monitored to consider signs of abuse or neglect. These must be followed up with the healthcare provider and information shared in the best interests and safety of the Service User.

3.13 We will follow the six principles as set out in guidance to the Care Act 2014 and this will inform practice with all Service Users:

• Empowerment – People being supported and encouraged to make their own decisions and informed consent

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

• Proportionality – The least intrusive response appropriate to the risk presented

• Protection – Support and representation for those in greatest need

• Partnership – Local solutions through services working with their communities. Communities have a part to play in preventing, detecting and reporting neglect and abuse

• Accountability – Accountability and transparency in delivering safeguarding

 3.14 Mind Map Focus is committed to the principles of 'Making Safeguarding Personal' and aims to ensure that safeguarding is person-led and focused on the outcomes that Service Users want to achieve. It will engage Service Users in a conversation about how best to respond to their safeguarding situation in a timely way that enhances involvement, choice and control as well as improving quality of life, wellbeing and safety.

 3.15 Mind Map Focus understands the importance of working collaboratively to ensure that:

• The needs and interests of adults at risk are always respected and upheld

• The human rights of adults at risk are respected and upheld

• A proportionate, timely, professional and ethical response is made to any adult at risk who may be experiencing abuse

• All decisions and actions are taken in line with the Mental Capacity Act 2005

• Each adult at risk maintains:

• Choice and control

• Safety

• Health

• Quality of life

• Dignity and respect

 3.16 Whistleblowing

Mind Map Focus has a clear Freedom to Speak Up Policy in place which staff are frequently reminded about and with which they must be familiar. They must also understand how to escalate and report concerns.

 Whistleblowing is an important aspect of the support and protection of adults at risk of harm where staff are encouraged to share genuine concerns about safety or wrongdoing within Mind Map Focus.

3.17 Staff Responsibilities

• To be able to recognise and respond to suspected abuse and substandard practice

• To report concerns of harm or poor practice that may lead to harm

• To remain up to date with training

• To read and follow the policy and procedure

• To know how and when to use the whistleblowing procedures

• To understand the Mental Capacity Act and how to apply it in practice

3.18 The Registered Manager Responsibilities

To establish the facts about the circumstances giving rise for concern

To identify sources and level of risk

To ensure that information is recorded and that the LANCASHIRE COUNTY COUNCIL Adult

Safeguarding Team is contacted to inform them of the concern or harm

If a Service User is at immediate risk of harm, the Registered Manager will contact the police. The CQC will also be informed

In all cases of alleged harm, there will be early consultation between the registered manager, LANCASHIRE COUNTY COUNCIL and the police to determine whether a joint investigation is required. Mind Map Focus understands that it may also be necessary to advise the relevant Power of Attorney if there is one appointed. In dealing with incidents of potential harm, people have rights which must be respected, and which may need to be balanced against each other

The wishes of the person harmed will be taken into account whenever possible. This may result in no legal action

Documentation of any incidents of harm in the Service User's file and using body maps to record any injuries

Follow LANCASHIRE COUNTY COUNCIL policy guidelines where applicable

Report any incidents of abuse to the relevant parties

Work with multi-agencies

Advise and support staff

Ensure staff are trained during induction, assess knowledge annually and run refresher training if needed

Actively promote the whistleblowing policies

Ensure that agency staff working at Mind Map Focus have completed the necessary safeguarding training for their role

Participate in local Safeguarding Adults Board arrangements for sharing experiences about managing safeguarding concerns in care homes

Share relevant information from Safeguarding Adults Board meeting minutes and reports with staff

3.19 General Principles

We will have robust recruiting and safer staffing policies in place to make sure that our staff are fit to work with adults at risk and children. They are compliant with national, safe recruitment and employment practices, including the requirements of the Disclosure and Barring Service

Safeguarding responsibilities should be included in the job description of all staff

A named safeguarding lead will be in place who is responsible for embedding safeguarding practices and improving practice in line with national and local developments. At Mind Map Focus this person is Toni Lancaster. 

Any staff member who knows or believes that harm is occurring will report it to their line manager as quickly as possible, or if they feel they cannot follow the regular reporting procedure, they must use the whistleblowing process

Mind Map Focus will work collaboratively with other agencies, including liaison in relation to the investigation of allegations and will ensure its procedures dovetail with the LANCASHIRE COUNTY COUNCIL multi-agency procedures

Mind Map Focus will use incident reporting, root cause analysis, lessons learned and auditing to determine themes to improve practice

Mind Map Focus will have a learning and development strategy which specifically addresses adult safeguarding. Mind Map Focus will provide training on the identification and reporting of harm, as well as training on the required standards in relation to procedures and processes should something need to be reported

Mind Map Focus recognises its responsibilities in relation to confidentiality and will share information appropriately

Mind Map Focus will have zero tolerance to harm

Mind Map Focus will work in partnership with other agencies to ensure that concerns or allegations of abuse are appropriately referred for investigation to the most appropriate agency

Mind Map Focus will ensure that any action that is taken is assessed, proportionate and reflective of the risk presented to the people who use the services

Mind Map Focus will report any incidents in line with its regulatory requirements

Mind Map Focus will adhere to the Code of Conduct for Care Workers

There is a clear, well publicised Freedom to Speak Up Policy and Procedure in place that staff know how to use

3.20 Leadership, Staff and Culture

The registered manager is responsible for providing leadership.

Good governance in safeguarding will follow where it is seen as an integral part of Service

User care and all staff take responsibility. Risks of neglect, harm and abuse will be reduced where there is strong leadership and a shared value base where:

• The Service User is the primary concern

• Service Users and staff are partners in their care

• Quality is prioritised and measured

• Staff understand the risks of neglect, harm and abuse

• There is a culture of learning and improvement

• There is openness and transparency, and all staff are listened to

 3.21 Prevention - Providing information to support Service Users

Mind Map Focus will support Service Users by providing accessible, easy to understand information on what abuse is and what signs to look out for

Mind Map Focus will comply with the Accessible Information Standard

All Service Users will receive a copy of the Service User Guide, have access to the Complaints, Suggestions and Compliments Policy and Procedure and be given information on how to escalate any concerns to the Commissioner, CQC, advocacy or Local

Government and Social Care Ombudsman should they not be satisfied with the approach taken by this service or at any time they wish

 3.22 Prevention - Raising awareness

Staff will need to be trained and understand the different patterns and behaviours of abuse as detailed in the Care Act 2014, Chapter 14 and Mind Map Focus will ensure that it is able to respond appropriately

Mind Map Focus will ensure that all staff are trained on the Raising Concerns, Freedom to Speak Up and Whistleblowing Policy and Procedure

During induction training, all employees will complete the 'Understanding Abuse' workbook, as part of the Care Certificate

Procedure

• Forms of Abuse and Neglect

• High Risk Groups

• Child Abuse 

• Who Abuses and Neglects?

• Incidents of Abuse

• Concerns

• Staff who Consider or Suspect Abuse or Neglect

• Responding to a Disclosure or Suspicion of Abuse or Neglect

• Documenting a Disclosure

• Response by registered manager or Safeguarding Lead to Reports of Abuse or Neglect

• Consent

• Referral to the LANCASHIRE COUNTY COUNCIL Safeguarding Adults Team

• Local Authority Safeguarding Enquiry

• Involve the Service User Concerned Throughout the Enquiry

• After An Enquiry

• If a Safeguarding Concern is Not Agreed

• Informing the Relevant Inspectorate

• Support and Supervision

• Confidentiality and Information Sharing

• Staff Alleged to be Responsible for Abuse or Neglect

• Disclosure and Barring Service (DBS) Referral

• Abuse by Another Adult at Risk

• Management of Allegations Against People in Positions of Trust (PiPoT)

• Allegations Against People who are Relatives or Friends

• Pressure Ulcers

• Medication Errors

• Exploitation by Radicalisers who Promote Violence

• Self-neglect and Refusal of Care

• Abuse and Sexual Safety

• Criminal Offences

• Risk Assessment and Management

• Training and Competence

• Audit and Compliance

• Forms of Abuse and Neglect

4.1 There are different types of abuse and signs and indicators for each. While indicators are not proof of abuse or neglect, they should alert staff to follow the Safeguarding Policy.

It is important that staff at Mind Map Focus are aware of the signs of abuse and what to look out for.

 4.2 Physical abuse includes:

• Being hit, slapped, pushed or restrained

• Being denied food or water

• Not being helped to go to the bathroom when you need to

• Misuse of medication

• Restraint

• Inappropriate physical sanctions

4.3 Signs and indicators of physical abuse include:

• No explanation for injuries or inconsistency with the account of what happened

• Injuries are inconsistent with the person’s lifestyle

• Bruising, cuts, welts, burns and/or marks on the body or loss of hair in clumps

• Frequent injuries

• Unexplained falls

• Subdued or changed behaviour in the presence of a particular person

• Signs of malnutrition

• Failure to seek medical treatment for frequent changes of GP

• Domestic violence or abuse.

 4.4 This is typically an incident or pattern of incidents of controlling, coercive or threatening behaviour, violence, or abuse by someone who is, or has been, an intimate partner or family member and can be:

• Psychological

• Physical

• Sexual

• Financial

• Emotional

• Female genital mutilation and forced marriage

• So called ‘honour’ based violence

 4.5 Signs and indicators of domestic violence or abuse include:

• Low self-esteem

• Feeling that the abuse is their fault when it is not

• Physical evidence of violence such as bruising, cuts, broken bones

• Verbal abuse and humiliation in front of others

• Fear of outside intervention

• Damage to home or property

• Isolation – not seeing friends and family

• limited access to money

4.6 Sexual abuse includes:

• Indecent exposure

• Sexual harassment

• Inappropriate looking or touching

• Sexual teasing or innuendo

• Sexual photography

• Being forced to watch pornography or sexual acts

• Being forced or pressured to take part in sexual acts

• Rape

• Sexual assault

4.7 Signs and indicators of sexual abuse include:

• Bruising, particularly to the thighs, buttocks and upper arms and marks on the neck

• Torn, stained or bloody underclothing

• Bleeding, pain or itching in the genital area

• Unusual difficulty in walking or sitting

• Foreign bodies in genital or rectal openings

• Infections, unexplained genital discharge, or sexually transmitted diseases

• Pregnancy in a woman who is unable to consent to sexual intercourse

• The uncharacteristic use of explicit sexual language or significant changes in sexual

• behaviour or attitude

• Incontinence not related to any medical diagnosis

• Self-harming

• Poor concentration, withdrawal, sleep disturbance

• Excessive fear/apprehension of, or withdrawal from, relationships

• Fear of receiving help with personal care

• Reluctance to be alone with a particular person

4.8 Psychological or emotional abuse include:

• Threats to hurt or abandon

• Deprivation of contact

• Humiliating

• Blaming

• Controlling

• Intimidation

• Harassment

• Verbal abuse

• Cyberbullying

• Isolation

• Unreasonable and unjustified withdrawal of services or support networks

 4.9 Signs and indicators or psychological or emotional abuse include:

• An air of silence when a particular person is present

• Withdrawal or change in the psychological state of the person

• Insomnia

• Low self-esteem

• Uncooperative and aggressive behaviour

• A change of appetite, weight loss/gain

• Signs of distress: tearfulness, anger

• Apparent false claims, by someone involved with the person, to attract unnecessary treatment

4.10 Financial or material abuse include:

• Theft

• Fraud

• Internet scamming

• Coercion in relation to a service users financial affairs or arrangements, including in connection with wills, property, inheritance or financial transitions

• Misuse or misappropriation of property, possessions or benefits

 4.11 Signs and indicators of financial abuse include:

• Missing personal possessions

• Unexplained lack of money or inability to maintain lifestyle

• Unexplained withdrawal of funds from accounts

• Power of attorney or lasting power of attorney (LPA) being obtained after the person has ceased to have mental capacity

• Failure to register an LPA after the person has ceased to have mental capacity to manage their finances, so that it appears that they are continuing to do so

• The person allocated to manage financial affairs is evasive or uncooperative

• The family or others show an unusual interest in the assets of the person

• Signs of financial hardship in cases where the persons financial affairs are being managed by a court appointed deputy, attorney or LPA

• Recent changes in deeds or title to property

• Rent arrears and eviction notices

• A lack of clear financial accounts held by a care home or service

• Failure to provide receipts for shopping or other financial transactions carried out on behalf of the person

• Disparity between the person’s living conditions and their financial resources, e.g. insufficient food in the house

 4.12 Modern slavery includes:

• Slavery

• Human trafficking

• Forced labour and domestic servitude

• Traffickers and slave masters using whatever means they have at their disposal to coerce, deceive and force individuals into a life of abuse, servitude and inhumane treatment

 4.13 Signs and indicators of modern slavery include:

• Signs of physical or emotional abuse

• Appearing to be malnourished, unkempt or withdrawn

• Isolation from the community, seeming under the control or influence of others

• Living in dirty, cramped or overcrowded accommodation and or living and working at the same address

• Lack of personal effects or identification documents

• Always wearing the same clothes

• Avoidance of eye contact, appearing frightened or hesitant to talk to strangers

• Fear of law enforcers

 4.14 Discriminatory abuse includes:

• Some forms of harassment, slurs or unfair treatment because of:

• Race

• Sex

• Gender and gender identity

• Age

• Disability

• Sexual orientation

• Religion

 4.15 Signs and indicators of discriminatory abuse include:

• The person appears withdrawn and isolated

• Expressions of anger, frustration, fear or anxiety

• The support on offer does not take account of the person’s individual needs in terms of a protected characteristic

 4.16 Organisational or institutional abuse:

• Including neglect and poor care practice within an institution or specific care setting, or in relation to care provided in a Service User's own home, this may range from one-off incidents to ongoing ill-treatment. It can be through neglect or poor professional practice because of the structure, policies, processes and practices within this business:

• Discouraging visits or the involvement of relatives or friends

• Run-down or overcrowded establishment

• Authoritarian management or rigid regimes

• Lack of leadership and supervision

• Insufficient staff or high turnover resulting in poor quality care

• Abusive and disrespectful attitudes towards people using the service

• Inappropriate use of restraints

• Lack of respect for dignity and privacy

• Failure to manage residents with abusive behaviour

• Not providing adequate food and drink, or assistance with eating

• Not offering choice or promoting independence

• Misuse of medication

• Failure to provide care with dentures, spectacles or hearing aids

• Not taking account of individuals’ cultural, religious or ethnic needs

• Failure to respond to abuse appropriately

• Interference with personal correspondence or communication

• Failure to respond to complaints

 4.17 Signs and indicators of organisational abuse include:

• Lack of flexibility and choice for people using the service

• Inadequate staffing levels

• People being hungry or dehydrated

• Poor standards of care

• Lack of personal clothing and possessions and communal use of personal items

• Lack of adequate procedures

• Poor record-keeping and missing documents

• Absence of visitors

• Few social, recreational and educational activities

• Public discussion of personal matters

• Unnecessary exposure during bathing or using the toilet

• Absence of individual care plans

• Lack of management overview and support

 4.18 Neglect or acts of omission include:

• Ignoring medical emotional or physical care needs

• Failure to provide access to appropriate health, care and support or educational services

• Withholding of the necessities of life, such as medication, adequate nutrition and heating

• Failure to administer medication as prescribed

• Not taking account of individuals cultural, religious or ethnic needs

• Signs and indicators of neglect or acts of omission include:

• Poor environment – dirty or unhygienic

• Poor physical condition and/or personal hygiene

• Pressure ulcers

• Malnutrition or unexplained weight loss

• Untreated injuries and medical problems

• Inconsistent or reluctant contact with medical and social care organisations

• Accumulation of untaken medication

• Uncharacteristic failure to engage in social interaction

• Inappropriate or inadequate clothing

 4.19 Self-neglect includes:

• A wide range of behaviour neglecting to care for one’s personal hygiene, health or surroundings and includes behaviour such as hoarding. It should be noted that self-neglect may not prompt a section 42 enquiry. An assessment should be made on a case by case basis. A decision on whether a response is required under safeguarding will depend on the

• Service User’s ability to protect themselves by controlling their own behaviour. There may come a point when they are no longer able to do this, without external support.

• Lack of self-care to an extent that it threatens personal health and safety

• Neglecting to care for one’s personal hygiene, health or surroundings

• Inability to avoid self-harm

• Failure to seek help or access services to meet health and social care needs

• Inability or unwillingness to manage ones person affairs

 4.20 Signs and indicators of self neglect include:

• Very poor personal hygiene

• Unkempt appearance

• Lack of essential food, clothing or shelter

• Malnutrition and/or dehydration

• Living in squalid or unsanitary conditions

• Neglecting household maintenance

• Hoarding

• Collecting a large number of animals in inappropriate conditions

• Non-compliance with health or care services

• Inability or unwillingness to take medication or treat illness or injury

 4.21 High Risk Groups

Certain groups of people may be at higher risk of abuse or neglect, including:

Those with care and support needs, such as older people or people with disabilities. They may be seen as an easy target and may be less likely to identify abuse themselves or to report it

Those with communication difficulties because they may not be able to alert others

Those with a cognitive impairment, as they may not even be aware that they are being abused

4.22 Child Abuse 

Child abuse is any form of mistreatment or harm that causes significant harm to a child’s physical, emotional, or psychological health, development, or well-being. Children and young people are particularly vulnerable and may experience abuse in various forms, which can have long-term effects on their mental health and development. Abuse can include:

Physical Abuse: Hitting, shaking, burning, or inflicting any other physical harm.

Sexual Abuse: Any form of sexual activity with a child or young person, including grooming, exploitation, or assault.

Emotional or Psychological Abuse: Excessive criticism, rejection, or other forms of emotional harm that affect the child’s self-esteem.

Neglect: Failing to provide the necessary care, nutrition, shelter, or medical attention required for the child’s physical and emotional well-being.

Bullying: Including verbal, physical, and online bullying.

Financial Abuse: Taking advantage of a child’s or young person's personal funds or resources.

Exploitation: Any form of manipulation for financial gain, including child labor or sexual exploitation.

Domestic Violence: Exposure to domestic violence or abuse within the home 

4.23 Who Abuses and Neglects?

Anyone in contact with the Service User can perpetrate abuse or neglect, including:

• Volunteers

• Family members

• Friends

• People who deliberately exploit adults they perceive as vulnerable to abuse

• Staff

• Professionals

• Other Service Users

 4.24 Incidents of Abuse

Patterns of abuse vary and include:

Serial abuse - in which the perpetrator seeks out and ‘grooms’ individuals. Sexual abuse sometimes falls into this pattern as do some forms of financial abuse

Long-term abuse - in the context of an ongoing family relationship such as domestic violence between spouses or generations, or persistent psychological abuse

Opportunistic abuse - such as theft occurring because money or jewellery has been left lying around Abuse may be one-off or multiple and affect one Service User or more. Staff should look beyond single incidents or Service Users. This service should have systems in place to track and monitor incidents, accidents, disciplinary action, complaints and safeguarding concerns, to identify patterns of potential harm..

 Repeated instances of poor care may be an indication of more serious problems (organisational abuse). In order to see these patterns, it is important that information is recorded and appropriately shared.

 4.25 Concerns

A concern might arise from:

• Something you observe (for example: bruises, a marked change in behaviour)

• An allegation that is made (for example, you are told that someone has behaved inappropriately or put a Service User or colleague at risk)

• A disclosure where a Service User tells you something about themselves or their circumstances that lead you to believe that they are being abused or are at risk of abuse

 4.26 Staff must be able to:

Recognise: Identify that the Service User at risk may be describing abuse, even when they may not be explicit

Respond: Stay calm, listen and show empathy

Record: Write up notes of the conversation clearly and factually as soon as possible

Report in a timely manner to the appropriate people and organisations

 4.27 Staff who Consider or Suspect Abuse or Neglect

If staff observe something that causes concern, they should ask the Service User what happened, unless this would be inappropriate or cause further distress.

If the Service User does not communicate with speech, they should help them explain what has happened as far as possible.

The staff member should document what they have seen or been told and report to nominated individual or Registered Manager.

If staff are unsure if there is an indicator of abuse or neglect with a Service User, they should discuss this with nominated individual or Registered Manager at this service.

Nominated Individual or Registered Manager will decide whether to make a safeguarding referral or to seek further advice form LANCASHIRE COUNTY COUNCIL.

Staff who suspect abuse or neglect must act on it; staff must not assume that someone else will do this.

 If someone makes an allegation to a member of staff about them or another member of staff or volunteer, that staff member must listen carefully and explain that they will need to pass these concerns to nominated individual or Registered Manager, reassuring them that their concerns will be taken seriously.

 4.28 If the allegation is made by a family member or a worker from another agency, the staff member should take their name and contact details and assure them that Registered

Manager will contact them as soon as possible. The staff member must pass the information to Registered Manager immediately.

Responding to a Disclosure or Suspicion of Abuse or Neglect

5.1 If a Service User discloses potential or actual abuse, staff will:

Straight away:

Remain calm and non judgemental

Try not to show shock or disbelief

Not interrupt the Service User who is freely recalling significant events, allow them to tell you whatever they want to share

Some Service Users may simply be telling a story and not realise that they are subject to abuse. It is important to keep this in mind and be thoughtful in response

Take whatever action is required to ensure the immediate safety or medical welfare of the Service User at risk

Where appropriate, call 999 for the emergency services if there is a medical emergency, other danger to life or risk of imminent injury, or if a crime is in progress. Where a crime is suspected of being committed, leave things as they are wherever possible

Call for medical assistance from the GP or NHS 111 if there is a concern about the Service

User's need for medical assistance or advice, when the situation is not life-threatening or is out of hours

Reassure the Service User that they are right to share this information with you; show empathy with them

Do not press for more detail

Do not make promises that cannot be kept

Remain sympathetic and attentive

Then:

Listen carefully and reflect back what you are being told to ensure you have correctly grasped what is being said

Use simple and open questions, do not ask leading questions, (e.g. ‘So was it Peter who did that?’) or attempt to ‘investigate’ in any way

Explain carefully that what they have said is worrying and that you have to share that with your line manager.

Explain the safeguarding process to the Service User and discuss the next steps

Explain that your manager may contact the LANCASHIRE COUNTY COUNCIL

Safeguarding Adults Team and/or the Police

Seek the Service User's consent to share this information

As soon as you can, write down an account of your conversation, try to use the words/phrases that the Service User used. Sign and date your record

Preserve evidence (physical evidence - for example, ask the Service User to not wash or bathe)

Inform Registered Manager as soon as possible to inform them of the incident or concern:

Registered Manager will be contacted on PLACE NUMBER HERE

Do not share this information with anyone else

Do not contact the alleged abuser about the incident yourself, unless this is essential (for example, if registered manager needs to immediately suspend a member of staff)

The Service User may feel frightened, so ask whether they want someone they feel comfortable with to stay with them

5.2 Staff must inform Registered Manager (unless they are the alleged abuser; if this is the case, then support should be sought directly from another manager, this service or LANCASHIRE COUNTY COUNCIL.

 5.3 Staff must also take action without the immediate authority of Registered Manager:

If a discussion with them would involve a delay in an apparently high-risk situation

If they have raised concerns with Registered Manager and they have not taken appropriate action (whistleblowing)

 5.4 There should be effective and well publicised ways of escalating concerns where Registered Manager does not take action in response to a concern being raised.

 5.5 Registered Manager will:

Listen to any staff member if they speak up about abuse or neglect, take them seriously and act accordingly

Consider if there are other adults or children with care and support needs who are at risk of harm and take appropriate steps to protect them

Registered Manager will support and encourage the Service User to contact the police if a crime has been, or may have been, committed

 When responding to indicators of abuse and neglect, staff must:

Follow the principles of the Making Safeguarding Personal Framework:

Ensure that any actions are guided by the wishes and feelings of the Service User

Be aware that Service Users experiencing abuse or neglect may be influenced, coerced or controlled by someone else

Be aware that duties of care and public interest can override personal preference, for example, there is a risk that a perpetrator could abuse again - this needs to be addressed and prevented

Staff must also follow the principles of the Mental Capacity Act 2005 if the Service User lacks capacity

5.6 Documenting a Disclosure

We must ensure that staff:

Record what the Service User actually said, using their own words and phrases

Describe the circumstance in which the disclosure came about

Note the setting and anyone else who was there at the time

When there are cuts, bruises or other marks on the skin, use a body map to indicate their location, noting the colour of any bruising

Record information that is factual

Use a pen with black ink so that the report can be photocopied

Keep writing clear

Sign and date the report, noting the time and location

Are aware that the report may be needed later as part of a legal action or disciplinary procedure registered manager must ensure they preserve any evidence relating to a safeguarding concern, including care records, as these may be required in future for local authority enquiries or police investigations.

 5.7 Response by Registered Manager to Reports of Abuse or Neglect

Registered Manager at Mind Map Focus should treat any report of abuse or neglect as a safeguarding concern and:

Ask the Service User at risk what they would like to happen next

Ensure that they have access to communication support

Explain that they have a responsibility to report concerns to LANCASHIRE COUNTY

COUNCIL, and tell the Service User who they will report to, why, and when

5.8 Decision-Making pre-referral to the LANCASHIRE COUNTY COUNCIL Safeguarding

Adults Team:

• The Registered Manager will usually lead on decision-making.

• When considering if a safeguarding concern needs to be completed, the Registered Manager must consider the three duties in Section 42 (1) of the Care Act 2014:

• Does the person have needs for care and support (whether or not the authority is meeting any of those needs)?

• Are they experiencing, or at risk of, abuse or neglect? and

• As a result of those needs, are they unable to protect themself against the abuse or neglect or the risk of it?

• When using professional judgement to determine whether an incident is reported to the local authority safeguarding team/police, Registered Manager should consider the following:

• The consequences to the alleged victim and the equality of the relationship between the alleged perpetrator and the alleged victim

• The ability of the alleged victim to consent

• The mental capacity of the alleged perpetrator to understand the consequences of their decision to act in the way that is alleged

• The intent of the alleged perpetrator

• The frequency of this and similar allegations regarding the alleged perpetrator

• The alleged victim considers the actions against them to be abusive

• The alleged victim or carer is distressed, fearful or feels intimidated by the incident

• You believe that there is a deliberate attempt to cause harm or distress

• Incidents are repetitive and targeted to either the Service User or others

• The action resulted in a physical injury

• A crime has been committed

• The incident involves a member of staff

• If any other people (including children) are at risk as well as the Service User you are concerned about In the decision-making process, they must evidence the following:

• Why does this adult(s) need safeguarding – what are the risks?

• What actions need to be taken to reduce that risk?

• Do they consent to this action?

• Are others potentially at risk?

 5.9 The Registered Manager will document their decision-making process.

5.10 If Registered Manager is not sure whether to make a safeguarding referral to LANCASHIRE COUNTY COUNCIL (because they are not sure whether they suspect abuse or neglect), they should discuss with LANCASHIRE COUNTY COUNCIL.

 5.11 If a Service User does not want any safeguarding actions to be taken, but abuse or neglect is suspected, a safeguarding referral must still be made.

 5.12 We will ensure that staff are aware of the LANCASHIRE COUNTY COUNCIL reporting procedures and timescales for raising safeguarding concerns.

If a referral is made but the Service User at risk is reluctant to continue with an investigation, this must be recorded and brought to the attention of the LANCASHIRE COUNTY COUNCIL safeguarding adults team. This will enable a discussion on how best to support and protect the Service User at risk.

 Consent

6.1 When reporting information that directly concerns the safety of an individual at risk of harm, consent from the Service User is not required. However, informing the Service User of your concerns and your referral is good practice unless it would put you or your colleagues at risk or it would put the adult at further risk.

6.2 When reporting allegations or concerns about an adult at risk of harm to the Local Authority, the Local Authority must be informed whether or not the Service User is aware of the report.

6.3 In reporting all suspected or confirmed cases of harm, an employee has a responsibility to act in the best interest of the Service User but still operate within the relevant legislation and the parameters of the codes and standards of their practice.

 Referral to the LANCASHIRE COUNTY COUNCIL Safeguarding Adults Team

7.1 We must ensure that the LANCASHIRE COUNTY COUNCIL safeguarding adult referral process is followed and must collect the following information to assist with the referral. The referral process must be clearly visible with contact numbers, including out-of-hours, where staff can access the information.

7.2 Where the ICB is the commissioner, they must also be informed.

7.3 The referral information will also be required for some of the CQC notification of abuse

documentation. We must use any up-to-date service user information where possible and have the following information available where possible:

• Contact details for the individual at risk, the person who raised the concern and for any other relevant individual, and next of kin

• Basic facts, focusing on whether or not the Service User has care and support needs including communication and ongoing health needs

• Factual details of what the concern is about; what, when, who, where?

• Immediate risks and action taken to address risk

• Preferred method of communication

• If reported as a crime, details of which police station/officer; crime reference number

• Whether the adult at risk has any cognitive impairment which may impede their ability to protect themselves

• Any information on the person alleged to have caused harm

• Wishes and views of the adult at risk, in particular consent

• Advocacy involvement (includes family/friends)

• Information from other relevant organisations, for example, the CQC

• Any recent history (if known) about previous concerns of a similar nature or concerns raised about the same person, or someone within the same household

• Names of any staff involved

 Local Authority Safeguarding Enquiry

8.1 LANCASHIRE COUNTY COUNCIL may well be reassured by the response of this service so that no further action is required. However, LANCASHIRE COUNTY COUNCIL would have to satisfy itself that the response of Mind Map Focus has been sufficient to deal with the safeguarding issue and, if not, to undertake any enquiry of its own. This will identify if action needs to be taken and who needs to take that action.

8.2 The enquiry:

• Could be an informal conversation with the Service User at risk

• Could be a more formal multi-agency discussion

• Does not have to follow a formal safeguarding process The objectives of an enquiry are to:

• Establish facts

• Ascertain the Service User’s views and wishes

• Assess the needs of the Service User for protection, support and redress and how they might be met

• Protect from the abuse and neglect, in accordance with the wishes of the Service User

• Make decisions as to what follow-up action should be taken with regard to the person or organisation responsible for the abuse or neglect

• Enable the Service User to achieve resolution and recovery

 8.3 If LANCASHIRE COUNTY COUNCIL decides that Mind Map Focus should make the enquiry, then LANCASHIRE COUNTY COUNCIL should be clear about timescales, the need to know the outcomes of the enquiry and what action will follow if this is not done.

8.4 What happens as a result of an enquiry should reflect the Service User's wishes wherever possible, as stated by them or by their representative or advocate. If they lack capacity, it should be in their best interests if they are not able to make the decision, and be proportionate to the level of concern. The Service User should always be involved from the beginning of the enquiry.

 8.5 Strategy Meeting/Case Conference:

Following the investigation or at any time during the process, a case conference with all relevant agencies may be called to make decisions about future action to address the needs of the Service User

Any agency involved in the case may ask for a case conference to be held but the final decision to hold a conference is with the LANCASHIRE COUNTY COUNCIL Safeguarding Adults Team Manager

Mind Map Focus must ensure that it attends this meeting when invited and that all relevant information about the incident is available. A timeline of events is a useful document to prepare in complex cases

 8.6 Safeguarding Adults Reviews:

Safeguarding adults reviews (SARs) are a statutory requirement for Safeguarding Adults

Boards with the purpose of promoting learning and improving safeguarding practice

A safeguarding adults review must be arranged by a Safeguarding Adults Board if:

There is reasonable cause for concern that partner agencies could have worked more effectively to protect an adult and serious abuse or neglect is known or suspected and certain conditions are met, in line with section 44 of the Care Act 2014 and related statutory guidance

8.7 Child Safeguarding Practice Reviews 

A Child Safeguarding Practice Reviews (CSPRs) is a formal process undertaken to understand what happened in cases where a child has been seriously harmed or has died, and abuse or neglect is known or suspected. Its purpose is not to assign blame, but to learn lessons and improve how professionals and agencies work together to safeguard children in the future. 

These are conducted by local safeguarding partnerships, or nationally if the case has wider significance. The review involves a detailed analysis of the circumstances, decision-making, and systems involved, and leads to recommendations aimed at improving safeguarding practices and preventing future harm. 

8.8 Involve the Service User Concerned Throughout the Enquiry: The process must be explained to the Service User in a way they will understand and their consent to proceed with the enquiry obtained, if possible

Arrangements will be made to have a relative, friend or independent advocate present if the Service User so desires. The relative, friend or independent advocate must not be a person suspected of being in any way involved or implicated in the abuse A review of the Service User's Care Plan and risk assessments must be undertaken to ensure individualised support following the incident

8.9 The Service User will be supported by Mind Map Focus to take part in the safeguarding process to the extent to which they wish, or are able to, having regard for their decisions and opinions. They must be kept informed of progress . 

•  Desired Outcomes Identified by the Service User:

•  The desired outcome by the Service User at risk must be clarified and confirmed:

•  To ensure that the outcome is achievable

•  To manage any expectations that the Service User may have

•  To give focus to the enquiry

8.10 Registered manager will support Service Users at risk to think in terms of realistic outcomes but must not restrict or unduly influence the outcome that the Service User would like. Outcomes must make a difference to risk and, at the same time, satisfy the Service User's desire for justice and enhance their wellbeing.

The Service User’s views, wishes and desired outcomes may change throughout the course of the enquiry process

There must be an ongoing dialogue and conversation with the Service User to ensure that their views and wishes are gained as the process continues and enquiries re-planned if the Service User changes their views

The Service User will be informed of the outcome of any investigation, but guidance will be sought from the LANCASHIRE COUNTY COUNCIL Safeguarding Adults Team before any outcome is shared

 8.11 After An Enquiry

Once an initial enquiry has been undertaken, discussions should be had with the Service User as to whether a further enquiry is needed and what further action could be taken. That action could include disciplinary, complaints or criminal investigations or work by contracts managers and CQC to improve care standards.

 8.12 LANCASHIRE COUNTY COUNCIL must determine what further action is necessary.

One outcome may be the formulation of agreed action or a safeguarding plan for the Service User which should be recorded in their Care Plan. This will be the responsibility of the relevant agencies to implement. This will entail joint discussion, decision taking and planning with the Service User for their future safety and wellbeing.

 8.13 In relation to the Service User, this could set out:

• What steps are to be taken to assure their safety in future

• The provision of any support, treatment or therapy including ongoing advocacy

• The need for fuller assessments by health and social care agencies

• Any modifications needed in the way services are provided (for example, same gender care or placement; appointment of an OPG deputy)

• How best to support the Service User through any action they take to seek justice or redress

• Any ongoing risk management strategy as appropriate

• Any action to be taken in relation to the person or organisation that has caused the concern

 8.14 If a Safeguarding Concern is not agreed

If LANCASHIRE COUNTY COUNCIL decides not to investigate, staff must ensure the continual safety of Service Users.

 8.15 Staff should:

• Evaluate existing risk assessments and Care Plans. Ensure that there is clear, documented evidence that this has occurred

• If the existing risk assessments and Care Plans do not cover the current risk(s), staff must implement new ones to ensure measures have been put in place to reduce future risk

• Staff can consider other referral options (this list is not exhaustive):

• Human resources (capability/disciplinary routes)

• Health and safety

• Complaints

• LANCASHIRE COUNTY COUNCIL care management, request review of current Care Plan, request for a case conference

• NHS continuing care team, request a review

• Request for a best interest meeting

8.16 Informing the Relevant Inspectorate

By law, we must notify the Care Quality Commission without delay of incidents of abuse and allegations of abuse, as well as any incident which is reported to, or investigated by, the police

We must notify CQC about abuse or alleged abuse involving a person(s) using the service, whether the person(s) is/are the victim(s), the abuser(s), or both

We must also alert the relevant local safeguarding authority when notification is made to CQC about abuse or alleged abuse

The forms are available on CQC's website

If a concern is received via the whistleblowing procedure, we must inform the LANCASHIRE COUNTY COUNCIL Safeguarding Team and CQC Support and Supervision

9.1 We will recognise that dealing with situations involving abuse and neglect can be stressful and distressing for staff and workplace support should be available.

9.2 During safeguarding enquiries, registered manager should:

• Be aware of how safeguarding allegations can affect the way other staff and Service Users view a Service User subject to a safeguarding enquiry

• If staff are concerned about working with a Service User who has made allegations, registered manager should provide support, additional training and supervision to address these concerns and ensure that the Service User is not victimised by staff

• Acknowledge that enquiries are stressful and that morale may be low

• Think of ways to support staff (such as one-to-one supervision and team meetings)

• Provide extra support to cover absences as part of the enquiry, and to help staff continue providing consistent and high-quality care

• Direct staff to sources of external support or advice if needed

 9.3 Regular face-to-face supervision and reflective practice from skilled line managers is essential to support staff, and to enable staff to work confidently and competently with difficult and sensitive situations.

The registered manager has a central role in ensuring high standards of practice at Mind Map Focus and that staff are properly equipped and supported.

 Confidentiality and Information Sharing

10.1 In seeking to share information for the purposes of protecting adults at risk, this service is committed to the following principles:

Personal information will be shared in a manner that is compliant with the statutory responsibilities of this service

• Adults at risk will be fully informed about information that is recorded about them and, as a general rule, be asked for their permission before information about them is shared with colleagues or another agency. However, there may be justifications to override this principle if the adult or others are at risk

• Staff will receive appropriate training on Service User confidentiality and secure data sharing

• The principles of confidentiality designed to protect the management interests of Mind Map Focus must never be allowed to conflict with those designed to promote the interests of the adult at risk

• Staff will follow policies at this service on UK GDPR, data protection, confidentiality and comply with the Caldicott principles

 Staff Alleged to be Responsible for Abuse or Neglect

11.1 This service does not only have a duty to the Service User, but also a responsibility to take action in relation to the employee when allegations of abuse are made against them.

We should ensure that their disciplinary procedures are compatible with the responsibility to protect adults at risk of abuse or neglect.

11.2 When a member of staff is subject to a safeguarding enquiry, The registered manager should:

Tell them about any available Employee Assistance Programme

Tell them about professional counselling and occupational health services (if available)

Make them aware of their rights under employment legislation and any internal disciplinary procedures

Nominate someone to keep in touch with them throughout the enquiry (if they are suspended from work)

They should be able to request that the nominated person be replaced, if they think there is a conflict of interest

The nominated person should not be directly involved with the enquiry

If the police are involved, tell them who the nominated person is

11.3 For members of staff who return to work after being suspended, The registered manager should:

Arrange a return-to-work meeting when the enquiry is finished, to give them a chance to discuss and resolve any problems

Agree a programme of guidance and support with them

11.4 Where appropriate, the registered manager should report staff to the statutory and other bodies responsible for professional regulation such as the Nursing and Midwifery Council.

If the registered manager is subject to a safeguarding enquiry, this service should put an acting manager in their place if required.

 Disclosure and Barring Service (DBS) Referral

12.1 There is a statutory requirement for providers of Care to refer workers to the DBS for inclusion on the DBS Vetting and Barring scheme list if they consider that the person is guilty of misconduct such that an adult at risk was harmed or placed at risk of harm.

12.2 The legal duty to refer to the Disclosure and Barring Service also applies where a staff member leaves their role to avoid a disciplinary hearing following a safeguarding incident and this service feels they would have dismissed the person based on the information they hold.

 Abuse by Another Adult at Risk

13.1 Mind Map Focus recognises that they may also have responsibilities towards the person causing the harm, and certainly will have if they are both in a care setting or have contact because they attend the same place (for example, a day centre).

13.2 The person causing the harm may themselves be eligible to receive an assessment. In this situation, it is important that the needs of the Service User at risk who is the alleged victim are addressed separately from the needs of the person causing the harm. It will be necessary to reassess the adult allegedly causing the harm.

13.3 Under the Mental Capacity Act 2005, people who lack capacity and are alleged to be responsible for abuse, are entitled to the help of an Independent Mental Capacity Advocate to support and represent them in the enquiries that are taking place. This is separate from the decision whether or not to provide the victim of abuse with an independent advocate under the Care Act.

 Management of Allegations Against People in Positions of Trust (PiPoT)

14.1 A relationship of trust is one in which one person is in a position of power or influence over the other person because of their work or the nature of their activity. Any allegation against a person who works with adults with care and support needs must be reported immediately to the registered manager.

 14.2 When an allegation is made against a PiPoT, we refer this to LANCASHIRE COUNTY COUNCIL as part of the safeguarding process.

14.3 Where the person alleged to have caused the harm or neglect is a volunteer or a member of a community group, we must work with adult social services to support any action under this policy.

14.4 Where the person alleged to have caused the harm is a neighbour, a member of the public, a stranger or a person who deliberately targets vulnerable people, the Service User at risk should receive the services and support that they may need. In all cases, issues of consent, confidentiality and information sharing must be considered.

Allegations Against People who are Relatives or Friends

15.1 There is a clear difference between unintentional harm caused inadvertently by a relative or friend and a deliberate act of either harm or omission, in which case the same principles and responsibilities for reporting to the police apply.

15.2 In cases where unintentional harm has occurred, this may be due to lack of knowledge or due to the fact that the relative’s own physical or mental needs make them unable to care adequately for the adult at risk. The relative may also be an adult at risk. In this situation, the aim is to protect the adult from harm, work to support the relative to provide support and to help make changes in their behaviour in order to decrease the risk of further harm to the person they are caring for.

15.3 A carer’s assessment will take into account a number of factors and a referral to LANCASHIRE COUNTY COUNCIL will be made as part of the safeguarding process.

 Pressure Ulcers

16.1 We must follow local safeguarding reporting requirements and the Department of Health and Social Care (DHSC) guidance 'Pressure Ulcers: How to Safeguard Adults'.

16.2 The aim of the DHSC guidance is to provide a national framework, identifying pressure ulcers as primarily an issue for clinical investigation rather than a safeguarding enquiry led by the local authority. Indicators to help decide when a pressure ulcer case may additionally need a safeguarding enquiry are included. 'It is the responsibility of the designated safeguarding lead in each setting to appropriately triage any safeguarding concerns and ensure that referrals to the local authority for consideration of a section 42 (2) enquiry are appropriate.' (GOV.UK 2024)

16.3 Safeguarding Concern Assessment Guidance:

A history of the development of the skin damage should first be obtained by a clinician, usually a nurse

Where there is concern from the clinician assessing the pressure ulcer that there has been abuse or neglect that can be directly associated with the pressure ulcer, there is a need to raise it as a safeguarding concern within this service

In some cases it may warrant raising a safeguarding concern with LANCASHIRE COUNTY COUNCIL

If the Service User’s care has recently been transferred, this may require contact being made with former care providers for information to seek clarification about the cause and timing of the skin damage. This is the responsibility of this service, and a concern should not be raised with LANCASHIRE COUNTY COUNCIL until this has been done

If a concern is raised that a Service User has severe damage, The registered manager should:

Complete the adult safeguarding decision guide

Raise an incident immediately as per the policy of Mind Map Focus

(Severe damage in the case of pressure ulcers may be indicated in some cases by multiple category 2 or single category 3 or 4 ulcers, but could also be indicated by the impact the pressure damage has on the Service User affected (for example, pain)

16.4 Adult Safeguarding Decision Guide:

The decision guide should be completed by a qualified member of staff who is a practising registered nurse (RN) with experience in wound management and not directly involved in the provision of care to the Service User at the time the pressure ulcer developed.

The adult safeguarding decision guide should be completed immediately or within 48 hours of identifying the pressure ulcer of concern. In exceptional circumstances this timescale may be extended but the reasons for extension should be recorded

The outcome of the assessment should be documented on the adult safeguarding decision guide. If further advice or support is needed with regards to making the decision to raise a concern to LANCASHIRE COUNTY COUNCIL, Registered Manager or The registered manager should be involved

Where the Service User has been transferred into the care of this service it may not be possible to complete the decision guide. Contact should be made with the transferring organisation to ascertain if the decision guide has been completed or any other action taken

16.5 Following this, a decision should be made whether to raise a safeguarding adults concern with LANCASHIRE COUNTY COUNCIL, in line with agreed local arrangements

The decision as to whether there should be a Section 42 enquiry will be taken by the local authority, informed by a clinical view. A summary of the decision should be recorded and shared with all agencies involved

Where an internal investigation is required, this should be completed by the organisation that is or was taking care of the Service User when the pressure ulcer developed, in line with the local policies

The local authority needs to decide or agree after completion of the internal investigation if a full multi- agency meeting (virtual or face to face) needs to be convened to agree findings, decide on safeguarding outcomes and any actions

The safeguarding decision guide assessment considers 6 important questions that together indicate a safeguarding decision guide score. This score should be used to help inform decision making regarding escalation of safeguarding concerns related to the pressure ulceration. It is not a tool to risk assess for the development of pressure damage

The threshold for raising a concern is 15 or above in most instances. However, this should not replace professional judgement.

Photographic evidence to support the report should be provided wherever possible. Consent for this should be sought as per local policy but great sensitivity and care must be taken to protect the identity of the individual

A body map should be used to record skin damage and can be used as evidence, if necessary, at a later date. If 2 workers observed the skin damage, they should both sign the body map where possible

Documentation of the pressure ulcer should include as a minimum:

• Site

• Size (including its maximum length, width and depth in centimetres)

• Tissue type

• Category

Where the decision guide score is 15 or higher, or where professional judgement determines safeguarding concerns, copies of the completed decision guide and safeguarding concern proforma should then be sent to the adult safeguarding team within LANCASHIRE COUNTY COUNCIL. Copies of both should also be retained in the Service User's Care Plan

Where there is no indication that a safeguarding concern needs to be raised, the completed decision guide should be retained in the Service User's Care Plan

 Medication Errors

17.1 We must follow local safeguarding reporting procedures for medication errors and ensure that notifications are made to the CQC in line with statutory requirements. We will have an open and transparent approach to medication incidents, ensure that staff follow the. Medication Errors and Near Misses Policy and Procedure and understand their Duty of Candour responsibilities.

 Exploitation by Radicalisers who Promote Violence

18.1 Individuals may be susceptible to exploitation into violent extremism by radicalisers.

 Self-neglect and Refusal of Care

19.1 We must ensure that staff understand the importance of delivering care as detailed in the Care Plan. Where a Service User refuses Care, this must always be documented. Where refusal occurs repeatedly, it must be escalated by this service as a safeguarding concern and a request for a review of the Service User's Care will be instigated.

 Abuse and Sexual Safety

20.1 We recognise that culture, environment and processes support a Service User's sexuality and keep them and staff safe from sexual harm. As such, we will ensure that sexuality is discussed as part of the Care Plan process and is addressed positively to support people to raise concerns where necessary.

20.2 The CQC publication on sexuality and sexual safety can be referred to for further guidance in this area.

 Criminal offences

21.1 Everyone is entitled to the protection of the law and access to justice. Behaviour which amounts to abuse and neglect, for example physical or sexual assault or rape, psychological abuse or hate crime, wilful neglect, unlawful imprisonment, theft and fraud and certain forms of discrimination also often constitute specific criminal offences under various pieces of legislation.

 21.2 LANCASHIRE COUNTY COUNCIL has the lead role in making enquiries. However, where criminal activity is suspected, the early involvement of the police should take place.

Risk Assessment and Management

22.1 Achieving a balance between the right of the Service User to control their Care package and ensuring that adequate protections are in place to safeguard wellbeing is a very challenging task.

 22.2 The assessment of the risk of abuse, neglect and exploitation of Service Users will be integral in all assessment and planning processes. Assessment of risk is dynamic and ongoing, especially during the adult safeguarding process and must be reviewed throughout so that adjustments can be made in response to changes in the levels and nature of risk.

 Training and Competencies

23.1 Staff, including volunteers at this service are trained in recognising the symptoms of abuse or neglect, how to respond and where to go for advice and assistance.

23.2 Training should take place at all levels in Mind Map Focus and be updated regularly to reflect current best practice. To ensure that practice is consistent, no staff group should be excluded.

23.3 We will ensure that staff receive training in recognising and responding to incidents, allegations or concerns of abuse or harm as part of their induction programme. Mind Map Focus will benchmark its training and competencies within the service with the framework outlined in 'Adult Safeguarding: Roles and Competencies for Health Care Staff' which it recognises applies to social care staff also and does not replace any local or contractual requirements but acts as a minimum benchmark.

 23.4 Mind Map Focus will also refer to the 'NHS Prevent Training and Competencies Framework' for more specific training requirements in relation to the Prevent strategy.

 23.5 Specialist training will be provided for those who will be undertaking enquiries, Registered Manager at this service.

 23.6 Registered Manager will cascade safeguarding information about adults at risk to appropriate staff members. Registered Manager will undertake and provide internal training and attend local safeguarding partnership updates, education and development sessions including regular group-based supervision.

23.7 Training needs to make a difference to the understanding, confidence and competence of staff. Assess what changes it has prompted through regular supervision sessions as well as annually during appraisals. Arrange refresher training if the annual check indicates this is needed.

Audit and Compliance

24.1 It is essential that the implementation of this policy and associated procedures is audited to ensure that Mind Map Focus is doing all it can to safeguard those receiving its services. The audit of this policy will be completed through a systematic audit of:

Recruitment procedures and disclosure and barring checks Incident reporting, frequency and severity

24.2 Training processes, including reviews of uptake of training and evaluations

24.3 Safeguarding concerns and incidents will be reviewed by the senior management team

as part of a root cause analysis with the following terms of reference:

Review incident themes

Reports from the lead responsible for safeguarding within Mind Map Focus

Look in detail at specific cases to determine learning or organisational learning

Ensure implementation of the Safeguarding Adults Policy and Procedure

24.4 Mind Map Focus should maintain and regularly audit care records (in addition to external checks, such as audits or Care Quality Commission inspections) and ensure that they are complete and available in case they are needed if a safeguarding concern is raised.