Safeguarding Vulnerable Adults
Kennedy Scott is committed to ensuring that vulnerable adults who use our services are not exploited or abused and that working practices minimise the risks of such abuse.
Statement of Commitment
Our corporate values state that we aim:
"To demonstrate respect and courtesy at all times and to promote a culture where all are free to work and learn, safe from any form of abuse, harm or exploitation"
We commit to providing a safe physical and emotional environment which promotes well being, fairness and equality and discourages any form of abuse. This policy refers to all vulnerable adults regardless of race, ethnicity, gender, age, religion or belief, disability and sexual orientation. It is the duty of all employees and subcontractors to Kennedy Scott to adhere to this policy.
Definition of Vulnerable Adult
The broad definition of a vulnerable adult is:
“ a person who is 18 yrs of age or older and who is, or maybe, in need of community care services by reason of mental or other disability, age or illness and who is, or maybe, unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation”
The main categories of individuals covered by this definition of vulnerable adults include people:
- Who have a learning disability
- Who have physical or sensory impairments
Who have mental health issues - Who are or have been detained in custody or under a probation order
- Who are considered vulnerable and who may experience abuse due to problems with alcohol or drugs
- Who are considered vulnerable due to other circumstances such as being an asylum seeker
Whilst it is important to recognise that certain groups of people are legally defined as vulnerable and to have relevant vulnerable adult policies, procedures and practices in place to cover them, KS believes in adopting fully inclusive and integrated safer practices that apply to all staff, subcontractors and participants on our programmes.
Definition of Abuse
Abuse is a violation of a person’s human rights or dignity by another person. Abuse can be physical, emotional, sexual, financial or in the form of neglect. It can also take the form of discriminatory treatment based on a person’s ethnicity, race, culture, religion and belief, gender, sexual orientation, age or disability.
Procedures
Kennedy Scott will make sure, as far as is reasonably practicable, that all possible precautions will be taken to protect all employees and participants. They will do this by the following:
Risk Management
Kennedy Scott will ensure that a risk assessment is undertaken with regard to safeguarding practices and will be regularly reviewed as required and at least annually. Employees will be provided with guidelines, procedures and processes which are designed to promote a safe working environment for all and to protect them and participants from harm and allegations of abuse.
Existing Kennedy Scott Policies relating to safeguarding include:
- Health & Safety
- Lone working
- Equality and Diversity
- Anti Harassment and Bullying
- Whistleblowing
- Participant Comments and Complaints
- Disability
- Disciplinary and Grievance
- Online Safeguarding
All are available on this website although some are restricted to staff.
Recruitment
In addition to other pre-employment vetting checks, Kennedy Scott will ensure that all new staff members from March 2010 who work directly with vulnerable adults undertake an enhanced criminal records bureau check before appointment and, from July 2010, register with the ISA (Independent Safeguarding Authority)
Existing staff will be required to register with the ISA in line with legislative requirements.
Training
Kennedy Scott will ensure that all staff who work with vulnerable adults will receive specialist training to identify and act upon potential indicators of abuse or neglect amongst participants. We will also ensure that staff will be made aware of the importance of protecting themselves from abuse or allegations of abuse. All existing staff, new staff and participants will be made aware of the Safeguarding Policy and procedures for implementation.
Responsibility for Safeguarding Policy
Responsibility for the development, implementation and monitoring of the Safeguarding Policy will be as follows:
- Allocated Board Level responsibility: Teresa Scott, Managing Director
- Allocated Senior Management responsibility: Laura Dryden, HR & Training Manager
- Designated Safeguarding Officer: Jan Townsend, Business Manager
- Equality and Diversity Officer: Ayiesha Russell, EDC
Procedure for raising allegations and suspicions of potentially abusive behaviour
Kennedy Scott operates a zero tolerance policy for all employees, subcontractors and participants regarding all forms of abuse and behaviour harmful to others.
Participants:
Participant inductions will cover an awareness of rights and responsibilities and the Kennedy Scott commitment to an environment free from abuse. Information about the procedure for raising concerns will also be clearly presented.
Participants should raise any concerns using the Participant Comments and Complaints form which is available in each centre and to download from the intranet. A timely and thorough investigation will take place by the Safeguarding Officer and a Senior Manager. A decision will then be made with regard to further action, including, where appropriate, implementation of the Kennedy Scott disciplinary procedure or referral to external agencies. The Senior Manager will keep the Managing Director informed in writing of all actions taken. The vulnerable adult will also remain informed at all times.
Employees:
All employees have a responsibility to be aware and alert to signs that a vulnerable adult is experiencing problems, although not all concerns relate to abuse and it is important to keep an open mind.
However, if information is disclosed to an employee in confidence about a participant, by that participant or any other person, that raises concerns, the employee must report this to their line manager immediately. The line Manager will then consult discretely and in confidence with the designated Safeguarding Officer. If it is felt that there are genuine grounds for concern the vulnerable adult should be informed that the matter will be discussed with the designated Safeguarding Officer and the allocated Senior Manager responsible for safeguarding. If the vulnerable adult requests that no action is taken they should still be informed that, whilst respecting their request, the information must be shared with the designated Safeguarding Officers.
A decision will then be made with regard to further action, including, where appropriate, referral to external agencies. The Senior Manager will keep the Managing Director informed in writing of all actions taken. The vulnerable adult will also remain informed at all times.
Counselling will be offered to both participants and employees.
Procedure for dealing with allegations of abuse against an employee
The procedure applies to all employees, irrespective of job role. An allegation of abuse may be made against a member of staff for a variety of reasons and may or may not be substantiated. Hasty or ill informed decisions in connection with staff can irreparably damage an individual's confidence, reputation or career. Therefore, it important that those dealing with an allegation maintain an open mind and that investigations are conducted sensitively, thoroughly and promptly.
Any allegation about a staff member's conduct should be reported immediately to the Senior Manager with responsibility for safeguarding, unless it is against that person, in which case the allegation should be referred to the Managing Director. The Senior Manager will obtain details of the allegation in writing from the person who raised it and will consult with the Designated Safeguarding Officer and, if appropriate the Managing Director about further action. If appropriate the case will be referred to an external agency, such as the relevant Social Services Department or Police.
Kennedy Scott may decide that the allegation should be addressed as part of its disciplinary procedure in addition to, or instead of, referring the matter to an external agency. If disciplinary action is being considered, it may be appropriate to suspend the employee pending investigation, in accordance with the company's disciplinary procedure. In either case, the staff member will be advised by the company that he or she should seek advice and potentially be represented at any future meetings by a work colleague or trade union representative. The company will consult with any external agency that is carrying out an investigation and will provide assistance to enable it to complete its enquiries as swiftly as possible. However, it will not hold in abeyance its own investigation pending the outcome of a formal Police or Social Services investigation, unless it considers this is appropriate in the circumstances.
If allegations made against an employee are not substantiated, the employee will be informed that no further action will be taken. The employee will be offered support and counselling from the company's own counsellor.
If a staff member is dismissed or resigns before completion of the disciplinary process, they will be informed that the company has a duty to inform the ISA.
The progress and outcome of internal and external investigations will be notified to the person who raised the allegations.
Confidentiality
Confidentiality is crucial to all our work and relationships between employees and participants. However, the welfare of vulnerable adults is paramount and takes precedence over this. Guarantees of absolute confidentiality should not be given as it may be necessary to make a referral to an appropriate external agency. Any concerns relating to potential abuse of a vulnerable adult must be reported.
If a vulnerable adult discloses abuse to a member of staff, the need to pass on that information must be explained to the person. It is often easier to explain that there is a responsibility to pass on information about certain matters, rather than get into a situation where confidentiality is broken.
Records and Data Protection
Written case records should be passed to the Designated Safeguarding Officer who will keep records in secure conditions for a period of 6 years. These shall include a written record of the allegations, outcome and details of any disciplinary action taken. Where an allegation has been found to be unsubstantiated a record of the allegations, investigation and outcome shall be retained. After the appropriate expiry of the time period, the Designated Safeguarding Officer will arrange for records to be destroyed securely.
Monitoring and Evaluation
The Health & Safety Committee meets every quarter and comprises Teresa Scott (MD), Dave Rawlins (H&S consultant), Steve Woolcock (Commercial Director), Bev Johnson (Staff Representative) Anne Angell (Regional Contract Manager South), Colette Farrell (Regional Contract Manager London & East of England).
This committee is responsible for reviewing the effectiveness of the company's health and safety policy. As part of its commitment to providing a safe working environment for staff and participants, it will review the Safeguarding policy and action plan and consider how safeguarding issues are impacting on health and safety.
The Quality Group meets every quarter and comprises Max Curto (Quality Improvement Manager), Laura Dryden (HR & Training Manager), Janet Waller (Monitoring Manager), Ayiesha Russell (Diversity officer).
This committee is responsible for reviewing participant complaints and monitoring trends and recommending appropriate action. As part of its commitment to ensuring a culture of continuous improvement and the raising of standards, it will review the Safeguarding policy and action plan and consider how safeguarding issues are impacting on Quality.
An action plan has been drawn up to accompany the Safeguarding policy to ensure its effective implementation. The policy will be kept under review and the action plan formally evaluated by the senior management team at bi-monthly intervals.
Links have been made with the Safeguarding Adults Board in Harrow.
(Safeguarding Co-ordinator: Seamus Docherty 020 8420 9453)