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Safeguarding Adults Policy and Procedure

This policy details our approach to safeguarding adults, to support staff with identifying and reporting suspected abuse.

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1. Governance

1.1. This is the Safeguarding Adults Policy and Procedure for The Good Place Home Care Services Limited.

1.2. The Good Place Home Care Services Limited will be referred to in this document as "The Good Place Home Care Services Limited","The Good Place","We","Us", or "Our".

1.3. Our registered address is: 186 Wetmore Road, Burton-on-Trent, Staffordshire, DE14 1QZ.

1.4. We can be contacted by:-

1.5. Words importing one gender include all genders, and words in the singular include the plural and vice versa, unless the context requires otherwise.

1.6. Document control sheet:-

MetadataValue
Document fingerprintSG-2163-V3
Document ownerDean Hill (Safeguarding Lead)
Document version3
Document statusApproved following a scheduled review on 22/04/2026 by Dean Hill (Safeguarding Lead)
Document review cycleAnnually or sooner if legislation or guidance changes. Next review planned for April 2027
Summary of changesFollowing an internal governance review informed by current CQC guidance and feedback, we have made a number of changes to include specific contact information for the Local Authority Safeguarding Team, our Safeguarding Lead, and the CQC. We have also added details on how people can raise concerns about abuse, who to contact if allegations of abuse are against the Registered Manager, and who to report an allegation to if the Registered Manager and Nominated Individual are the same person. We have also included details on Regulation 13: Safeguarding service users from abuse and improper treatment.

2. Purpose

2.1. To meet our responsibilities for safeguarding adults as required by law and best practice.

2.2. To ensure that we fulfil the legal and regulatory responsibilities.

2.3. To support us to meet, and be able to evidence compliance with, the following CQC Single Assessment Framework quality statements:-

3. Scope

3.1. This policy applies to all personnel of The Good Place. That includes full-time and part-time employees, care & support workers, agency or temporary staff, contractors, volunteers, and anyone else working on behalf of the company.

3.2. It covers all interactions with adults at risk in the context of the services we provide (domiciliary care in service users’ own homes). Everyone must follow this policy and the related procedures, regardless of role or seniority. We also expect our partners or subcontractors to adhere to equivalent safeguarding standards.

3.3. The policy is focused on safeguarding adults at risk – i.e. adults who have care and support needs, who may be unable to protect themselves from abuse or neglect (as defined below).

4. Policy Statement

4.1. The policy is written in accordance with the Care Act 2014 and its statutory guidance, which provides the legal framework for adult safeguarding in England. It also reflects the requirements of our regulator, the Care Quality Commission (CQC), and the standards they expect from care providers. Furthermore, this policy is aligned with the local authority’s safeguarding adult guidelines for Staffordshire County Council. We will adhere to the multi-agency safeguarding procedures of the local Safeguarding Adults Board and cooperate fully with the local authority, which is the lead agency for adult safeguarding.

4.2. This policy underpins The Good Place’s compliance with the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (including Regulation 13: Safeguarding service users from abuse and improper treatment) and the Care Quality Commission (Registration) Regulations 2009 (including Regulation 18: Notification of other incidents) and Regulation 20 (Duty of Candour). It aligns with the Care Act 2014 statutory guidance and local multi-agency procedures of Staffordshire County Council.

4.3. Safeguarding means protecting an adult’s right to live in safety, free from abuse and neglect. It is about preventing harm and enabling adults at risk to maintain control over their lives. Abuse and neglect can have devastating consequences, so safeguarding is a fundamental priority in our care delivery. We recognise that effective safeguarding is essential to providing high-quality care and protecting the dignity and well-being of our service users.

4.4. The Good Place is fully committed to safeguarding adults at risk. We have a zero-tolerance approach to any form of abuse. All staff are expected to uphold this commitment and foster a culture where the safety and human rights of service users are paramount. As the Care Quality Commission (CQC) states, “Safeguarding is everybody’s business.”

4.5. Each member of our team has a responsibility to act on any concerns to protect adults in our care. We will work proactively to prevent abuse, and respond decisively to any safeguarding issues, in line with our legal and moral obligations.

4.6. Safeguarding governance and oversight

4.6.1. Overall accountability for safeguarding sits with the board-level equivalent (the Nominated Individual) of The Good Place. They receive regular assurance reports from the Registered Manager on incidents, themes, training compliance and the effectiveness of systems to prevent and investigate abuse. The Registered Manager is responsible for day-to-day implementation. This ensures robust oversight in line with Regulation 13(1).

4.7. CQC Regulation 13 – Safeguarding from Abuse and Improper Treatment

4.7.1. We operate a zero-tolerance approach to abuse, including neglect, degrading treatment, unlawful discrimination, and improper restraint. All staff must prevent, identify, report and escalate any suspected abuse in line with this policy and local authority procedures.

4.8. How to Contact the Local Authority Safeguarding Adults Team

4.8.1. Local Authority (Staffordshire County Council):-

4.8.2. Staff must use the LA online portal where required and follow any locality-specific referral forms. Record the referral reference in the person’s record and notify the Registered Manager.

4.8.3. Safeguarding duties apply regardless of who funds the care (local authority, NHS, direct payments, or self-funding). Our duties extend to adults with care and support needs whom we encounter in the course of our work, whether or not we provide a regulated activity at the time.

5. Definitions and Types of Abuse

5.1. For the purposes of this policy, the following definitions apply:-

  • a. Safeguarding - In this context, safeguarding refers to all steps taken to protect an adult’s health, wellbeing and rights, enabling them to live free from abuse and neglect. It is both proactive (preventing abuse before it occurs) and reactive (taking action when concerns arise). Safeguarding is not just about responding to incidents, but also about promoting the person’s welfare, respecting their wishes, and ensuring they receive care in a safe, person-centered manner. It involves individuals and organisations working together to prevent and stop the risk of harm, while also making sure to empower adults to make their own choices (often referred to as Making Safeguarding Personal).
  • b. Adult at Risk - An “adult at risk” (sometimes called a vulnerable adult) is a person aged 18 or over who has needs for care and support (whether or not those needs are being met), is experiencing or is at risk of abuse or neglect, and due to their care and support needs is unable to protect themselves from that abuse or neglect. This definition comes from the Care Act 2014. Adults at risk may include, for example, older people with frailty or dementia, people with physical or learning disabilities, people with mental health needs, or anyone who depends on others for care and is therefore potentially vulnerable to exploitation or harm. In our service, most service users would be considered adults at risk due to their care needs. Safeguarding duties under this policy apply to any such adult who we encounter through our work.
  • c. Abuse - Abuse is a violation of an individual’s human or civil rights by another person or persons. It can consist of single or repeated acts. Abuse might be deliberate, or the result of neglectful care or ignorance. Importantly, abuse can occur in any relationship and often involves an imbalance of power. It can be perpetrated by anyone: family members, professional caregivers, friends, strangers, or even other service users. The Department of Health defines abuse as “a violation of an individual’s human and civil rights by another person or persons.” Abuse can take many different forms, as described below.
  • d. Neglect - Neglect is a related concept, meaning the failure to meet an adult’s basic needs or to protect them from harm. Whether an act is intentional or unintentional, if it harms or risks harming an adult, it may be considered abuse or neglect. All forms of abuse are unacceptable and inexcusable.
  • e. Restraint - Restraint includes any act that restricts a person’s liberty of movement or free will, including physical holding, chemical restraint/over-medication, mechanical devices, or blanket restrictions (e.g., locking exits).

5.2. Types of Abuse

5.2.1. Under the Care Act 2014 statutory guidance, abuse and neglect can take many forms. The main categories of abuse we recognise (including those explicitly referenced in law and guidance) are detailed below.

5.2.2. Physical Abuse

5.2.2.1. Any deliberate act of violence or use of force against an adult that results in pain, injury or impairment. This includes hitting, slapping, pushing, kicking, shaking, biting, hair-pulling, pinching, or misuse of medication or restraints. Inappropriate physical sanctions or force-feeding are also physical abuse. Physical abuse often leaves visible marks like bruises or cuts, but not always. Staff must never use physical punishment or rough handling.

5.2.3. Emotional/ Psychological Abuse

5.2.3.1. Acts or words that cause emotional pain, distress, fear, or mental anguish. This includes verbal abuse, threats of harm or abandonment, humiliation, harassment, intimidation, bullying, and controlling or coercive behavior. Deliberately depriving someone of social contact or affection is also emotional abuse. Cyber abuse (online bullying or harassment via social media, texting, etc.) is considered a form of psychological abuse as well. Emotional abuse can seriously damage a person’s self-esteem and mental health.

5.2.4. Sexual Abuse

5.2.4.1. Any sexual activity with an adult without their full understanding and consent. This includes rape, sexual assault, sexual harassment, inappropriate touching, indecent exposure, forced viewing of pornography, or coercing someone into sexual acts they do not or cannot consent to. Sexual abuse can occur even within a relationship or marriage if consent is not given. It also covers situations where an adult is unable to give consent (due to lack of capacity or being under duress).

5.2.5. Financial or Material Abuse

5.2.5.1. The illegal or improper use of an adult’s finances, property, or resources. This includes theft, fraud, exploitation, scams (including internet scamming), coercion in money matters, or misuse of power of attorney. Examples are stealing cash or valuables, misusing someone’s benefits or bank cards, pressuring a person about wills or property, or charging them for unnecessary services. Financial abuse can severely affect an adult’s economic well-being and ability to care for themselves.

5.2.6. Neglect and Acts of Omission

5.2.6.1. Failing to provide necessary care, assistance, or attention, thus causing harm or risking harm. Neglect can be intentional or unintentional (e.g., due to lack of knowledge). It includes ignoring medical, physical or emotional needs, not providing adequate nutrition or heating, failing to ensure appropriate hygiene or medication, or not protecting someone from hazards. In domiciliary care, neglect might involve missing visits, leaving someone without help for long periods, or not responding to their needs. Neglect robs individuals of basic necessities and dignity.

5.2.7. Discriminatory Abuse

5.2.7.1. Harassment, unfair treatment, or abuse targeted at a person because of their protected characteristics (such as age, disability, gender, gender identity, race, religion or belief, or sexual orientation). This includes racist or sexist remarks, homophobic or transphobic abuse, disability-based harassment, or any form of hate crime. Discriminatory abuse violates a person’s rights and can be deeply damaging emotionally. It might involve slurs, slander, intimidation, or denying culturally appropriate care. Everyone has equal worth, and no form of biased abuse is tolerated.

5.2.8. Domestic Abuse

5.2.8.1. Any incident or pattern of controlling, coercive, threatening, or violent behavior between people who are (or have been) intimate partners or family members. Domestic abuse can encompass physical, emotional, sexual, or financial abuse, as well as so-called “honour-based” violence or forced marriage. It often involves an ongoing pattern designed to exert power and control over the victim. Victims may feel trapped or afraid to disclose abuse. Domestic abuse is a crime and a serious safeguarding issue; even if it occurs outside our service setting, we have a duty to respond if it affects an adult at risk we support. Controlling or coercive behaviour is a criminal offence, including post-separation abuse; staff must treat disclosures seriously and follow the reporting flow.

5.2.9. Modern Slavery

5.2.9.1. Situations where individuals are exploited and denied freedom by others for personal or commercial gain. Modern slavery includes human trafficking, forced labour, domestic servitude, sexual exploitation, and other forms of coerced work. An adult at risk might be made to work against their will, have their movements restricted, or be kept in inhumane conditions. Traffickers and slave-masters use violence, threats, deception or other manipulative tactics to trap people in slavery. Modern slavery is a gross violation of human rights and is illegal under the Modern Slavery Act 2015. Care workers should be alert to signs that a person may be a victim of trafficking or slavery (e.g., unexplained fear, working long hours for little or no pay, signs of physical abuse, or someone speaking for them all the time).

5.2.10. Self-Neglect

5.2.10.1. This occurs when an adult neglects their own health, hygiene, or surroundings, to the extent that it poses a risk to their well-being. Self-neglect can manifest as refusing care or support, not eating or hydrating properly, poor personal hygiene, living in unsafe or unclean conditions, or hoarding behavior. While self-neglect does not involve a perpetrator, it is a safeguarding concern because the individual may be unable to meet their own basic needs or may be unaware of the risks. Our staff must recognize severe self-neglect and report it, so that we can work with the person (respecting their wishes and mental capacity) to mitigate risks.

5.2.11. Organisational Abuse

5.2.11.1. Also known as institutional abuse, this is poor practice or abuse that is systemic within a care service. It can occur in residential facilities, hospitals, but also in how domiciliary care is organised. Organisational abuse might include neglect of service users’ needs, rigid routines that disregard individual preferences, inappropriate use of restraint or medication, substandard care due to poor staffing or training, or a culture that tolerates unsafe practices. In home care, it could be reflected in how the agency operates – for example, consistently shortening visit times, ignoring complaints, or prioritising schedules over the service user’s needs. Organisational abuse often arises from a failure of management, policies, or practices. The Good Place is committed to avoiding any practices that could be deemed organisational abuse, by putting the person at the center of our services and ensuring quality care.

5.2.12. Online / Technology-facilitated abuse

5.2.12.1. Bullying, harassment, stalking, grooming, scams, fraud, or the non-consensual creation/sharing of intimate images via phones, email, messaging or social media. These behaviours often sit within other categories (e.g., psychological, sexual, or financial abuse) but are called out here due to rising prevalence.

5.2.12.2. Abuse that is carried out via technology and online means. This can include cyber-bullying, online harassment, stalking or exploitation through social media, email or messaging, or the sharing of intimate images without consent. With increasing use of the internet and devices, adults at risk may be targeted by scammers or bullies remotely. Cyber abuse can lead to psychological harm, financial loss (e.g., through online scams), or exploitation. It is often linked to other forms of abuse (for example, an abuser may send threatening messages as part of psychological abuse, or groom someone online for sexual or financial exploitation). Staff should be aware of the risks service users might face via phones, computers, or other devices, and report any concerns (such as a service user receiving abusive messages or being defrauded online). Education on safe internet use may be part of prevention. Note: While cyber abuse is not a separate category in the Care Act guidance, we highlight it as an emerging form of harm that staff should be vigilant about.

5.3. Note on Patterns and Intent

5.3.1. Abuse can consist of a single act or a repeated pattern over time. It can occur in the person’s own home, in the community, or online. Also, abuse may not always be obvious – it can be subtle or hidden. All staff should stay alert to indicators of possible abuse or neglect, such as unexplained injuries, sudden changes in behavior, withdrawn or fearful demeanor, unexplained financial problems, poor living conditions, etc. Remember that abuse is abuse, regardless of whether the person appears to accept it or whether there is intent to harm. The severity or extent of abuse is less important than getting help for the person. Whenever in doubt, it is better to err on the side of caution and report a concern.

5.4. No degrading treatment

5.4.1. The Good Place prohibits any care or treatment that could reasonably be viewed as degrading. Examples include (not exhaustive): leaving a person in soiled clothing or on the toilet without prompt assistance or a way to call; leaving a person undressed or inadequately covered; ridiculing, belittling, or requiring demeaning tasks; or failing to provide necessary help or equipment for continence and personal care. Any report or observation of degrading treatment will be treated as a safeguarding concern and escalated without delay.

5.5. Recognising Indicators of Abuse

5.5.1. Staff must be alert to common indicators, including (but not limited to): unexplained injuries or frequent falls; fearfulness, withdrawal, or changes in mood/behaviour; poor hygiene, malnutrition or dehydration; missing medication or repeated errors; sudden changes in finances, unpaid bills, or missing belongings; controlling third parties speaking on someone’s behalf; signs of self-neglect or hoarding; evidence of online scams or threatening messages. Where any indicator is observed, follow the reporting flow immediately. Document facts and observations only, using the person’s words where possible.

5.6. Safeguarding Principles, Consent and Information Sharing

5.6.1. We act in line with the six safeguarding principles: Empowerment, Prevention, Proportionality, Protection, Partnership, and Accountability. We follow Making Safeguarding Personal (MSP) by agreeing desired outcomes with the person wherever possible.

5.6.2. We seek consent before sharing information unless doing so would place the person or others at risk, a serious crime is suspected, or there is a legal/public-interest justification. Where a person lacks capacity for the specific decision, we act under the Mental Capacity Act 2005, involve those lawfully acting on their behalf, and offer independent advocacy where required. All decisions and rationales are recorded clearly.

5.7. No unlawful discrimination

5.7.1. Care or treatment will never be delivered in a way that discriminates against a person on any protected characteristic under the Equality Act 2010 (age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, sexual orientation). Allegations or indicators of discriminatory practice will be investigated and, where substantiated, corrective action will be taken to prevent recurrence. This includes supporting the person to raise concerns and ensuring they are not victimised for doing so.

6. Roles and Responsibilities

6.1. Safeguarding adults is a shared responsibility. Every member of staff at The Good Place has a duty to act if they suspect an adult is at risk of abuse. This section outlines the general responsibilities of all staff, as well as specific roles for key individuals in our company’s safeguarding structure. We have designated leads to ensure there is always someone accountable and available to manage safeguarding issues. However, this does not reduce the obligation on each staff member to be vigilant and proactive in protecting people from harm.

6.2. Responsibilities All Staff (Employees, Volunteers, Contractors)

6.2.1. All staff and volunteers at The Good Place are responsible for upholding safe practices and reporting any concerns. In particular, every staff member must:

  • a. Be Vigilant: Stay alert to signs of abuse or neglect. Understand the types of abuse (as defined above) and potential indicators. If you see something or sense something is wrong, you must not ignore it. Safeguarding is part of your day-to-day duty of care.
  • b. Act Immediately on Concerns: If you have any suspicion or evidence that an adult may be experiencing abuse or is at risk, you must report it without delay (see Reporting Concerns section). Do not assume someone else will take action. It is better to raise a concern that turns out to be minor than to miss a serious problem.
  • c. Follow Procedures: Adhere to this Safeguarding Policy and the related procedures at all times. This includes following the proper reporting channels, maintaining confidentiality, and cooperating with any investigations or safeguarding processes. Do not try to address the issue on your own beyond the steps outlined (for instance, do not investigate allegations yourself; that is the role of management and external authorities).
  • d. Promote a Safe Culture: Treat all service users with respect, compassion, and professionalism. Use person-centered care approaches that uphold individuals’ rights, dignity, and choice. By building trust and rapport, staff can encourage people to speak up about any concerns. Also, create an environment where abuse is not tolerated – challenge or report any inappropriate behavior by colleagues or others.
  • e. Attend Training and Refresh Knowledge: Complete all required safeguarding training (initial and annual refreshers – see Training section). Make sure you understand your responsibilities and stay updated on any changes in policies or best practices. If you are unsure about any aspect of safeguarding, seek guidance from a manager or the Safeguarding Lead.
  • f. Whistleblowing: If you feel unable to report a concern through normal management channels (for example, if the concern involves your supervisor or you believe it has not been taken seriously), you have the right and responsibility to escalate the issue through our Raising Concerns, Freedom to Speak Up and Whistleblowing Policy and Procedure or directly to external authorities (such as the local safeguarding team or CQC). There will be no retaliation for reporting genuine concerns in good faith – we support and protect whistleblowers.
  • g. Professional Boundaries: Maintain clear professional boundaries with service users. Do not engage in any behavior that could be misinterpreted or could lead to exploitation. Report any potential conflicts of interest or incidents immediately.
  • h. Recording: Document any incidents, disclosures, or concerns appropriately as per company guidelines. A Statement document will be handed to those involved; events will be described in a chronological order. Accurate records can be critical in investigations. (Only record facts and observations, not personal opinions or accusations.)
  • i. Cooperation: Work collaboratively with the Registered Manager, Safeguarding Lead, and external agencies during any safeguarding inquiry. This may include providing statements, attending strategy meetings, or implementing protection plans.
  • j. Ongoing Support: Continue to support the adult at risk as appropriate, reassuring them and helping them to feel safe, while the concern is being handled. Also, look after your own wellbeing – dealing with safeguarding issues can be stressful, so seek support from your manager if needed.

6.2.2. By following these responsibilities, staff help ensure that “people using services are safeguarded” at all times. Remember, failing to report or ignoring abuse is a serious breach of this policy and could lead to disciplinary action, as well as leaving an individual at risk of harm.

6.3. Registered Manager

6.3.1. The Registered Manager holds overall accountability for safeguarding within The Good Place. Dean Hill is the named Registered Manager for our service, and can be contacted for any safeguarding issues via:-

6.3.2. The Registered Manager’s key safeguarding responsibilities include:-

  • a. Leadership and Oversight: Ensuring that a strong safeguarding culture is embedded in the organisation. The Registered Manager leads by example in promoting a zero-tolerance approach to abuse and is proactive in improving safeguarding practices. They make sure all staff know that safeguarding is a priority.
  • b. Policy Implementation: Ensuring that this Safeguarding Adults Policy is effectively implemented and kept up to date. The Registered Manager must review the policy regularly (see Review section) and whenever legislation or best practice changes. They are responsible for communicating any updates to staff and making sure everyone understands and follows the policy.
  • c. Training and Competence: Making certain that all staff and volunteers receive appropriate safeguarding training on induction and ongoing refreshers. The Registered Manager monitors compliance with training requirements and can arrange additional training if needed (for example, in response to a particular issue or learning from a case). They may also undertake higher-level safeguarding training themselves to stay current.
  • d. Receiving and Responding to Reports: Acting as one of the primary points of contact for reporting safeguarding concerns internally. Staff are directed to report concerns to the Registered Manager (or Safeguarding Lead). When a concern is raised, the Registered Manager must take it seriously and act promptly, following the procedure in section 6. This includes assessing the information, ensuring immediate safety actions are taken, and making decisions about next steps (such as referral to external agencies).
  • e. Safeguarding Referrals and Liaison: The Registered Manager is usually responsible for notifying and liaising with external authorities in the event of a safeguarding concern. They will contact the local authority Adult Safeguarding team to raise a safeguarding alert/referral as required by the Care Act (normally immediately or within 24 hours of a concern). They will also inform the police if a crime is suspected and ensure any urgent actions are coordinated. The Registered Manager serves as the main link between The Good Place and the Local Authority Safeguarding Team, attending strategy meetings or case conferences as needed. They also handle required notifications to the CQC (the CQC must be informed of certain safeguarding incidents under regulation).
  • f. Investigation and Follow-up: In coordination with the Safeguarding Lead and external agencies, the Registered Manager may carry out or contribute to internal investigations of allegations against staff or incidents within The Good Place. They must do so in a way that does not compromise any official safeguarding inquiry by the local authority or police. The Registered Manager might suspend or reassign staff accused of abuse, pending investigation, to ensure service user safety. They will gather facts, secure records, and provide information to the local authority’s inquiry. After investigations, the Registered Manager is responsible for implementing any recommendations or improvement actions to prevent recurrence.
  • g. Support and Advocacy: Ensuring that the adult at risk (and any others involved, such as whistleblowers or accused staff) are given appropriate support. For the adult affected, the Registered Manager should ensure they are kept informed (if appropriate), their wishes are considered (per Making Safeguarding Personal principles), and they have access to advocacy services if needed (especially if they have substantial difficulty in being involved or lack mental capacity, an independent advocate may be required under the Care Act). For staff who report concerns, the Registered Manager should reassure them of support and protection (no blame for speaking up). For staff who are accused, the Manager ensures fair treatment and confidentiality during the process.
  • h. Recording and Confidentiality: Overseeing the maintenance of confidential safeguarding records. The Registered Manager ensures that all safeguarding incidents and actions are documented thoroughly and stored securely (in line with data protection laws). They control access to these records on a need-to-know basis. They also must ensure information is shared appropriately with other professionals (e.g., GP, social worker) when it’s in the person’s best interests and in line with multi-agency safeguarding protocols.
  • i. Quality Assurance: Monitoring safeguarding activity within the service. The Registered Manager will review all incidents, analyse any patterns (e.g., repeated falls or medication errors that might indicate neglect), and report to higher management or trustees if applicable. They might produce reports or statistics on safeguarding for internal governance or for CQC inspections. They use this information to improve practice – for example, updating training or procedures if gaps are identified.
  • j. Whistleblowing and Openness: The Registered Manager fosters an open environment where staff feel comfortable raising concerns. They ensure the Whistleblowing Policy is effective and that staff can bypass them to report externally if necessary (without repercussions). If a concern is raised about the Registered Manager themselves (or there is a conflict of interest), the Registered Manager acknowledges that the Safeguarding Lead or other appropriate senior person will handle that case to maintain objectivity.
  • k. Multi-Agency Working: Participating in local safeguarding networks or forums if possible. The Registered Manager may attend Safeguarding Adults Board provider forums or training events to stay informed. They keep contact information for local authority safeguarding personnel up to date (see Reporting section for details) and build relationships that facilitate smooth collaboration when issues arise.

6.3.3. In summary, the Registered Manager is accountable for ensuring that The Good Place meets its safeguarding responsibilities. The Registered Manager will be the one to answer to regulators or adult safeguarding boards about how we protect people from abuse. Therefore, the Registered Manager will always prioritise any safeguarding concern and use the full resources of the company to address it effectively.

6.3.4. Allegations Against the Registered Manager

6.3.4.1. If a safeguarding concern involves the Registered Manager or there is a conflict of interest, staff must report directly to the Nominated Individual.

6.3.4.2. We will:-

6.3.4.3. Staff may always escalate directly to the local authority, police, or CQC if internal routes are compromised:-

6.3.4.4. Where the Nominated Individual and Registered Manager are the same person, staff must bypass internal reporting to that individual and make an external referral to our Independent Reviewer and inform the police if a crime is suspected and notify CQC as applicable:-

6.4. Nominated Individual

6.4.1. The Nominated Individual provides board-level oversight of safeguarding, ensures adequate resources (training, supervision, safe recruitment), reviews themes and learning from incidents, and assures timely statutory notifications and DBS referrals. The Nominated Individual acts where there is any conflict of interest involving the Registered Manager. Our Nominated Individual is Dean Hill, and can be contacted via:-

6.4.2. Where the Nominated Individual and Registered Manager are the same person, staff should contact our Independent Reviewer:-

6.4.3. Allegations Against the Nominated Individual

6.4.3.1. If a safeguarding concern involves the Nominated Individual or there is a conflict of interest, staff must report directly to our Independent Reviewer:-

6.4.3.2. They will:-

6.4.3.3. Staff may always escalate directly to the local authority, police, or CQC:-

6.5. Safeguarding Lead

6.5.1. The Good Place has appointed Dean Hill as the Safeguarding Lead, who serves as a dedicated point of expertise and coordination for safeguarding matters. The Safeguarding Lead’s role is to support the team in all aspects of adult safeguarding. Key responsibilities of the Safeguarding Lead include:

  • a. Day-to-Day Safeguarding Contact: Acting as an accessible figure for staff to approach with any safeguarding questions or reports. Staff can go to the Safeguarding Lead (as an alternative or in addition to the Registered Manager) to discuss concerns. Dean Hill will be trained and knowledgeable in safeguarding, enabling him/her to advise staff on the correct steps.
  • b. Receiving Reports: The Safeguarding Lead, alongside the Registered Manager, is an internal “go-to” for reporting concerns. When a staff member raises a safeguarding alert, the Safeguarding Lead will acknowledge it, ensure immediate safety measures are taken, and notify the Registered Manager. If the concern implicates the Registered Manager or there’s any reason the staff member prefers not to go directly to the Manager, the Safeguarding Lead can take the report and then handle it appropriately (escalating externally if needed).
  • c. Expertise and Advice: Keeping up to date with safeguarding best practices, legislation, and local procedures. The Safeguarding Lead may attend additional training or networking events (for example, courses offered by the local Safeguarding Adults Board). They serve as an internal consultant on safeguarding – for example, advising on whether a concern meets the threshold for external referral, or how to support a service user who has refused help. They might maintain a file of relevant safeguarding guidance and contacts.
  • d. Policy and Procedure Development: Working with the Registered Manager to review and update the Safeguarding Policy and related procedures. The Safeguarding Lead might draft revisions, collect feedback from care staff on what is working, and ensure the policy stays aligned with current guidance. They also help integrate safeguarding considerations into other policies (like risk assessments, care planning, etc.).
  • e. Training and Awareness: Assisting in the delivery or arrangement of staff training on safeguarding. The Safeguarding Lead might run internal workshops, toolbox talks, or one-to-one coaching for staff on identifying and reporting abuse. They can also disseminate learning from any safeguarding case (e.g., if an incident occurred, the Lead can share anonymized lessons learned with the team to prevent future occurrences).
  • f. Lead on Specific Safeguarding Cases: The Safeguarding Lead may be tasked by the Registered Manager to take the lead on certain safeguarding incidents – for instance, conducting an initial internal fact-finding or compiling documentation needed by the local authority. They might coordinate communication between different parties (family members, social workers, police, etc.) with the oversight of the Registered Manager. Essentially, they help manage the workflow of a safeguarding case, ensuring nothing is overlooked.
  • g. Recording and Monitoring: The Safeguarding Lead often keeps the internal log of safeguarding concerns. They ensure that all concerns are logged chronologically, with details of actions taken. They also monitor the status of open safeguarding cases (e.g., awaiting outcome from local authority) so that the service can follow up if needed. If patterns or repeated issues are noticed, the Safeguarding Lead will alert the Registered Manager.
  • h. Acting in Manager’s Absence: If the Registered Manager is unavailable (e.g., on leave or it’s out-of-hours), the Safeguarding Lead can act on their behalf to respond to urgent safeguarding matters. This ensures there is no delay – for example, the Safeguarding Lead can call the emergency duty social services team or police if something happens at night and then inform the Registered Manager as soon as possible.
  • i. Promoting a Safeguarding Culture: The Safeguarding Lead champions safeguarding within the organization. They might share reminders or updates in staff newsletters, put up posters (like “See something, say something”), and encourage open discussions about how to improve safety. Staff should see the Safeguarding Lead as an approachable and supportive figure who will listen to concerns seriously.

6.5.2. The Safeguarding Lead role is essentially about focus – having someone whose primary focus is adult protection ensures that this critical area does not get lost among other operational demands.

6.5.3. The Safeguarding Lead will collaborate closely with the Registered Manager to ensure every safeguarding issue is handled effectively. Both the Registered Manager and Safeguarding Lead can be contacted directly by any staff member or service user/ family member regarding safeguarding problems.

7. Reporting Concerns

7.1. Anyone can raise a safeguarding concern about abuse or neglect. You do not need proof — if something doesn’t feel right, report it. Concerns can be raised verbally or in writing, including by telephone, email, or post.

7.2. You can report a concern to The Good Place by:-

7.3. You can also report directly to external agencies at any time:-

7.4. We will make reasonable adjustments and provide communication support (for example large print, easy read, translations, or assisted reporting) so that safeguarding concerns can be raised accessibly. See our Accessible Information Standard (AIS) Policy and Procedure for full details.

7.5. Safeguarding reporting flow (quick guide for everyone)

7.5.1. If the concern involves management or there is a conflict of interest, follow the “Allegations Against Senior Management” process (above) and/ or report directly to the Staffordshire County Council team.

If you have a safeguarding concern, you must report it immediately. Early reporting can save lives and prevent further harm. This section explains how staff should raise concerns within The Good Place and to external agencies. All employees are expected to be familiar with these procedures through training and this policy. We encourage a “speak up” culture: no matter how small a concern might seem, report it. The company will support those who raise concerns and ensure they are addressed appropriately.

7.6. Internal Reporting (Within The Good Place)

7.6.1. If the person is in immediate danger or needs urgent medical attention, address this first. For example, if you believe a crime is in progress or someone is at risk of imminent harm, call 999 for emergency services without delay. Similarly, if urgent medical care is required (e.g., the person is injured), call an ambulance. Once emergency actions are taken, you should then proceed with reporting the incident internally. Do not place yourself in harm’s way; call professionals if the situation is dangerous. Removing the adult from immediate danger and securing the situation is the top priority.

7.6.2. As soon as it is safe and feasible, inform the Registered Manager or Safeguarding Lead about the concern. Time can be critical in safeguarding, so do not wait until the end of a shift or the next day – report it immediately (even if it’s after hours, contact the on-call manager or Safeguarding Lead).

7.6.3. You may report verbally (in person or via phone) and follow up in writing. Provide as much detail as possible about what you observed or what was disclosed. If the concern involves an allegation against a staff member, and that person is your line manager, you should go directly to the Safeguarding Lead or another senior manager to report (bypassing the usual line management if necessary). At any time. you can contact the Registered Manager (Dean Hill) at 01283 296 337 / [protected:adean][protected:athegoodplace.care], or the Safeguarding Lead (Dean Hill) at 01283 296 337 / [protected:adean][protected:athegoodplace.care]. Ensure the words “safeguarding” or “adult protection” are made clear so the urgency is understood.

7.6.4. Be prepared to share all relevant information you have: who is involved (the adult at risk, the person alleged to have caused harm, any witnesses), what exactly happened or what was observed, when and where it occurred, and any immediate actions taken. Stick to the facts as you know them. As soon as possible (ideally immediately after notifying management), write down a factual account of the concern. Use the company’s Safeguarding/ Incident Reporting Form if available, or otherwise write a report including dates, times, names, and a description of events or disclosures in the person’s own words. Do not delay reporting to write the report – you can jot down brief notes if needed and then fill in details after you’ve informed the Manager/Lead. Submit your written report to the Manager/Lead for safekeeping. This documentation is important for any investigation.

7.6.5. In cases of alleged abuse, there might be physical evidence (for example, bedding or clothing in a sexual assault, financial records in a financial abuse case, emails or texts in cyber abuse). Do your best to preserve any evidence and do not disturb or clean up anything that might be relevant. For instance, do not tidy the environment or wash clothes if you suspect they might contain evidence of a crime. If the abuse is physical or sexual, try to ensure the person does not wash or change clothing until medical examination (if they are amenable and it’s safe). For financial concerns, save documents or screenshots. Your goal is to leave things as they are until professionals can review them. Mention to the Manager/ Safeguarding Lead what evidence might exist. They will guide on next steps (and police can advise on evidence preservation if contacted).

7.6.6. It is crucial to keep the matter confidential and only discuss it with those who need to know. After reporting to the Manager/Safeguarding Lead, do not share information about the incident with other colleagues or anyone outside the organisation unless authorised. Gossip or unauthorised disclosure can compromise investigations and the privacy of those involved. You can reassure the adult who is the subject of concern that you have reported it to the right people and it will be addressed, but do not promise them secrecy (explain you have to tell those who can help). Likewise, if a colleague or another person asks about the situation, politely say you cannot discuss it. All media or external inquiries should be referred to the Registered Manager. Internally, the Manager/Safeguarding Lead will coordinate who else (if anyone) should be informed.

7.6.7. Once you have reported, management will take charge of the response. Follow any instructions given by the Registered Manager or Safeguarding Lead. They may ask you for additional information, or ask you to not confront the alleged abuser, etc. Cooperate fully. Continue to support and observe the adult at risk as appropriate – for example, if you are still on duty with them, ensure they are comfortable and safe while the next steps are initiated. If you feel the situation is not being addressed promptly, you should escalate the concern (see Whistleblowing below). But in most cases, your job after reporting is to support any ensuing process and care for the individual’s immediate needs.

7.7. Whistleblowing/ Internal Escalation

7.7.1. If for any reason you feel that your report is not being taken seriously or appropriate action is not occurring, do not hesitate to escalate. This might mean reporting the concern to a higher level of management (if available) or using the whistleblowing route (contacting external authorities directly).

7.7.2. Our Raising Concerns, Freedom to Speak Up and Whistleblowing Policy and Procedure protects employees who raise concerns in good faith about malpractice, including failure to act on a safeguarding concern.

7.7.3. We would rather you go around the normal process than stay silent. Remember that all staff have a duty to safeguard – if the normal chain of command fails, use another route. You will not be penalised for doing so. In fact, regulators expect providers to have effective whistleblowing procedures, and CQC is receptive to receiving concerns from staff or the public if needed. Contact details for CQC and the local authority are provided below:-

7.7.4. Staff must use the Local Authority online portal where required and follow any locality-specific referral forms. Record the referral reference in the person’s record and notify the Registered Manager.

7.7.5. While internal reporting is critical, there are times when concerns need to be raised with external agencies. In many cases, the Registered Manager will take responsibility for this. However, any person can directly report abuse to external authorities if they feel the situation warrants immediate outside intervention or if internal channels might be compromised. Under the Care Act, the local authority is the lead agency for adult safeguarding, so most external reporting will involve the local authority’s Safeguarding Adults team. Below are the primary external contacts and guidelines:

7.7.6. Local Authority Adult Safeguarding Team (Staffordshire County Council)

7.7.6.1. This is the first point of contact for reporting a safeguarding concern outside the organisation. The Good Place will report all allegations or suspicions of abuse to the local authority without delay, as required by law.

7.7.6.2. The Registered Manager or Safeguarding Lead will typically make this referral. They will provide the local authority with all relevant information to enable them to decide on a Safeguarding Enquiry (often referred to as a Section 42 Enquiry under the Care Act). We will cooperate fully with the local authority’s processes.

7.7.6.3. The Local Authority's Adult Safeguarding contact information can be found below:-

7.7.6.4. Staff should familiarise themselves with these contact details during training. If for some reason you need to make an external report yourself (e.g., you cannot reach any manager and the situation is urgent), you can call the local authority’s safeguarding line directly and explain you are calling from a care provider to report an urgent concern. They will guide you. Always inform the Registered Manager as soon as possible after you have contacted external agencies directly.

7.7.7. Police

7.7.7.1. As mentioned earlier, the police should be contacted immediately via 999 if a crime is in progress or if someone is in immediate danger.

7.7.7.2. For non-emergency situations where a crime is suspected (e.g., financial abuse or historic physical abuse that is not urgent), the police non-emergency number 101 can be used.

7.7.7.3. The local authority will also consult the police as part of their safeguarding response if a criminal offense may have occurred.

7.7.7.4. Our role is to involve the police when appropriate and to preserve any evidence as noted. We will support any criminal investigation – providing statements, information, or access as needed.

7.7.7.5. If a staff member is the alleged perpetrator, we will facilitate police interviews and internal HR processes in tandem.

7.7.8. Care Quality Commission (CQC)

7.7.8.1. The CQC is the regulator of care services. While the CQC does not investigate individual safeguarding incidents (that’s the local authority’s role), they must be notified by the provider when certain serious incidents occur, including abuse or allegations of abuse involving a person using the service (especially if the police are involved) – this is a statutory notification requirement.

7.7.8.2. The Registered Manager will send these notifications to the CQC as required. Additionally, staff or members of the public can report concerns to the CQC if they feel the provider is not taking appropriate action.

7.7.8.3. The CQC has a dedicated line for whistleblowing. We prefer to address issues internally and with the local safeguarding team, but the CQC is an option if other routes fail or if you think the service itself is colluding in abuse.

7.7.8.4. Remember, the CQC will protect whistleblowers and it monitors services’ safeguarding practice closely.

7.7.9. Whistleblowing to Other Bodies

7.7.9.1. Aside from the CQC, staff can also seek advice or report concerns to bodies like Public Concern at Work (Protect): Tel: 020 3117 2520 – an independent whistleblowing charity that provides confidential advice, or to professional bodies if applicable.

7.7.9.2. However, for safeguarding, the most direct external route is usually the local authority or police. Family members or the public can also report directly to the local authority if they suspect abuse – indeed we encourage an open approach where service users and families know how to “speak up”.

7.7.9.3. Our Complaints Policy and Procedure is another route for concerns that might not initially be identified as safeguarding, but any complaint alleging abuse will be treated under safeguarding procedures as well.

7.7.10. Notification to CQC – abuse/ allegations

7.7.10.1. We submit the current “Allegations of abuse (safeguarding)” statutory notification without delay via the CQC provider portal (or latest prescribed form) for any abuse or alleged abuse concerning a person using our service, including where police or other agencies are involved. We also assess whether the Duty of Candour applies and, where it does, we notify the person/representative, provide a truthful account, apologise, keep records of all communications, and follow up in writing.

7.7.10.2. When a safeguarding concern is reported externally, The Good Place will cooperate fully with all agencies. We will attend multi-agency meetings, provide information promptly, and take any interim actions advised (for example, suspending a staff member, increasing observation of a service user, etc.). We will never obstruct or cover up information; transparency is essential. Information sharing will be done in line with agreed protocols – normally, confidential details can be shared with the safeguarding team under public interest exemptions in data protection law, as safeguarding an adult at risk is a legitimate reason to share personal data with authorities.

7.7.11. Whistleblowing Protection

7.7.11.1. To reiterate, if a staff member has reported internally and does not see appropriate action, or feels unable to do so, they should use whistleblowing channels. The law (Public Interest Disclosure Act 1998) protects whistleblowers from unfair treatment. Our Raising Concerns, Freedom to Speak Up and Whistleblowing Policy and Procedure provides guidance and assurance that you can raise concerns without fear. Even if you choose to report externally first, you should inform a senior person in the company as well (unless the allegation is about them), so we can also take action. Ultimately, the safety of the adult is the priority, and all else is secondary.

7.7.11.2.

7.7.12. Accessibility of Safeguarding Reporting Processes

7.7.12.1. The Good Place is fully committed to meeting the requirements of the Accessible Information Standard (AIS), as set out by NHS England. This means we will ensure that people with a disability, impairment, or sensory loss receive information and communication support that they can understand and use effectively. This may include large print, easy-read versions, audio formats, or the use of interpreters and communication aids. See our Accessible Information Standard (AIS) Policy and Procedure for further details.

8. Responding to Safeguarding Concerns

8.1. When a safeguarding concern is raised, The Good Place will respond promptly and systematically to protect the adult and address the issue. Our response will be guided by the local authority’s procedures and the principles of good safeguarding (such as ensuring safety, empowerment, proportionality, partnership, accountability, and prevention). The following outlines the steps we take after a concern has been reported, whether internally by a staff member or externally by someone else. The Registered Manager (or Safeguarding Lead) will coordinate the actions below.

8.2. Immediate Action for Safety

8.2.1. Upon becoming aware of any allegation, indication or evidence of abuse, managers will initiate internal fact-finding and make external referrals immediately and without delay in line with local multi-agency procedures, documenting time-stamped actions. If this hasn’t already been done by the reporting staff, management will ensure it now. This might involve calling emergency services (if not already done), arranging medical care for injuries, or separating the adult from the person alleged to be causing harm.

8.2.2. For example, if the alleged abuser is a staff member, we will remove them from any care duties (e.g. ask them to go home pending investigation) to prevent further contact. If the incident involves a potentially unsafe environment or equipment, we will take it out of use. The priority is to stop any further abuse or neglect and tend to the victim’s urgent needs (physical and emotional).

8.2.3. We will also consider others – if one service user is harmed by a staff member, could another service user also be at risk from that staff member? We take any necessary actions to secure overall safety.

8.2.4. Notification and External Referral

8.2.4.1. The Registered Manager or Safeguarding Lead will quickly evaluate the information and decide whether the concern meets the criteria for external reporting (in most cases of suspected abuse or neglect it will). Following the reporting guidelines (above), we will notify the Local Authority Safeguarding Adults Team immediately.

8.2.4.2. We provide them with a clear account of the concern, actions taken, and the current situation. This is often done by phone initially (especially if urgent), followed by a written referral (using the local authority’s safeguarding referral form or system) within the required timeframe. If not already done, we will also notify the police at this stage if a crime is suspected or alleged – usually the local authority and police coordinate, but we ensure law enforcement is aware as needed (particularly for serious physical assault, sexual abuse, theft/fraud, etc.).

8.2.4.3. We will consult the local authority on informing the police if it hasn’t been done yet. Additionally, the Registered Manager will send a Notification to CQC about the safeguarding incident (via their online portal or email, as per CQC regulations) – this is typically done within 1-2 working days at most, or sooner for serious incidents. We document the date and time of all notifications.

8.2.5. Protecting and Supporting the Adult at Risk

8.2.5.1. Throughout the process, we focus on the well-being of the adult concerned. We will involve them as much as possible in decisions, respecting their autonomy. If the adult has capacity and expresses certain wishes (for example, they don’t want a particular person involved or they want a friend present), we will communicate these wishes to the safeguarding authorities and do what we can to honor them, consistent with safety.

8.2.5.2. If the adult has difficulties in understanding or communicating, we will ensure they have appropriate support – such as an advocate. If they lack mental capacity to make decisions about their safety, we will make decisions in their best interests (following the Mental Capacity Act) and involve any Power of Attorney or family as appropriate. The adult will be treated with empathy and respect; we will reassure them that the matter is being handled and that they are not to blame. If they need medical attention or counseling, we facilitate that.

8.2.5.3. We might arrange for a trusted relative or friend to be with them if they desire (unless that person is implicated). The key is that the person feels heard, safe, and supported during what can be a traumatic time.

8.2.5.4. We will involve the person at the centre of the concern as much as possible and agree their desired outcomes (Making Safeguarding Personal). We will:-

  • a. Seek the person’s informed consent to share information and to proceed with actions wherever it is safe to do so;
  • b. Explain what will happen next and provide information in an accessible format;
  • c. Assess mental capacity where there is doubt (decision-specific and time-specific) and record the outcome;
  • d. Where the person lacks capacity, act in their best interests under the Mental Capacity Act 2005 and involve those lawfully acting on their behalf (e.g. attorney/deputy) as appropriate;
  • e. Offer independent advocacy/IMCA where required; and
  • f. Share information without consent only where there is a legal duty, a safeguarding requirement, risk of serious harm, or suspected crime, and always on a need-to-know basis, documenting the lawful basis and rationale.

8.2.6. Internal Fact-Finding (Without Compromising External Inquiry)

8.2.6.1. While the local authority (and possibly police) have primary responsibility to investigate allegations of abuse, The Good Place also has a duty to gather initial information and secure evidence as a provider.

8.2.6.2. The Registered Manager or Safeguarding Lead will conduct a preliminary fact-finding exercise; this can include obtaining statements from the staff who reported or witnessed the concern, reviewing relevant records (e.g., care notes, MAR charts, time sheets, etc.), and preserving any physical evidence as previously mentioned.

8.2.6.3. However, this is done carefully so as not to interfere with any official investigation – for instance, we will not formally interview the alleged perpetrator or take any action that might alert them beyond removing them from duty, as the police may wish to handle such questioning.

8.2.6.4. We coordinate with the local authority on what steps we can take internally. If the safeguarding team advises us to hold off on certain inquiries (to avoid contamination of evidence), we will comply. Our role is to provide information and make sure nothing is lost or forgotten. All information gathered is documented in a secure file.

8.2.7. Internal Actions Regarding Staff (if applicable)

8.2.7.1. If the allegation involves a member of The Good Place staff or volunteer as the perpetrator, immediate management action is taken. The staff member in question will be suspended or reassigned to non-service user duties pending the outcome of the investigation.

8.2.7.2. This is not a disciplinary sanction nor a presumption of guilt – it is a precaution to protect all parties and ensure a fair investigation. They will be informed of the allegation in general terms (unless police advise to delay informing them) and that a safeguarding process is underway. We will follow our HR procedures for suspension (confirm in writing, on full pay if applicable, etc.).

8.2.7.3. The staff member will be instructed not to contact the service user or other staff about the matter. We maintain confidentiality about their identity to those not involved. If the allegation is substantiated, the Registered Manager will take appropriate disciplinary action, up to and including dismissal, and will refer the individual to the Disclosure and Barring Service (DBS) for barring consideration (this is a legal requirement for care providers when staff are fired or resign due to harming vulnerable adults).

8.2.7.4. If the allegation is not substantiated or was malicious, we will support the staff member’s return and address any workplace issues that led to the allegation. In all cases, we treat accused staff fairly and according to policy, while keeping service user safety paramount.

8.2.7.5. Where a staff member or volunteer has been dismissed, removed from regulated activity, or would have been removed had they not resigned, because they harmed or posed a risk of harm to an adult, The Good Place has a legal duty to refer the individual to the Disclosure and Barring Service (DBS). The Registered Manager (or Nominated Individual) will make the referral and retain evidence of submission.

8.2.8. Cooperation with the Safeguarding Enquiry

8.2.8.1. Once the local authority takes on the case, they may initiate a formal Safeguarding Adults Enquiry (under Section 42 of the Care Act). The Good Place (through the Registered Manager or Safeguarding Lead) will work in partnership with the authorities. This means attending any multi-agency meetings (such as strategy meetings or case conferences) to share information and plan actions.

8.2.8.2. We will provide a written report if requested, detailing our involvement and knowledge of the situation. If the Safeguarding team creates a protection plan (actions to ensure the person’s safety during and after the enquiry), we will implement all parts of that plan that fall to our service – for example, assigning only certain experienced staff to care for the person, or increasing visit frequency, or installing assistive technology.

8.2.8.3. We will keep the Safeguarding Lead updated on progress and any further incidents. Additionally, if family members or others need to be contacted as part of the enquiry, we coordinate that with the social worker (we usually let the social services handle informing next-of-kin unless agreed otherwise). Essentially, we follow the lead of the multi-agency process, doing what is asked of us promptly and thoroughly.

8.2.8.4. We acknowledge that the local authority may make findings and recommendations at the end of the enquiry, which we will accept and act upon.

8.3. Our Approach to Restraint & Restrictive Practices

8.3.1. Restraint is a last resort, proportionate, necessary, and time-limited to prevent immediate harm, and is never used as punishment or for staff convenience. Use of restraint must comply with Regulation 13 and, where the person lacks capacity, with the MCA 2005 (least-restrictive option; best-interests decision).

8.3.2. Process:-

  • a. Try de-escalation and alternatives;
  • b. If restraint is unavoidable, use the minimum force for the shortest time;
  • c. Monitor the person’s wellbeing;
  • d. Record the incident (what/why/duration/people involved/aftermath);
  • e. Notify the Registered Manager;
  • f. Review the care plan and risk assessment;
  • g. Where required, notify CQC and the Local Authority and consider safeguarding referral.

8.3.3. Any use of medication to restrict behaviour without clinical indication or consent is improper treatment and a safeguarding concern.

8.3.4. The Good Place does not use restraint as a routine part of care. Any restrictive practice (including physical restraint, chemical restraint/ PRN for behaviour control, mechanical restraint, seclusion or long-term segregation, and blanket rules) is exceptional, time-limited, and used only when:-

  • a. There is an immediate risk of harm to the person or others;
  • b. Actions are necessary, proportionate and the least restrictive option; and
  • c. Actions are in line with the Mental Capacity Act 2005 (including best-interests decisions where the person lacks capacity for the specific decision).

8.3.5. Before use:-

  • a. Consider de-escalation, environmental and relational strategies.

8.3.6. During use:-

  • a. Keep the person’s dignity and human rights central;
  • b. Use only staff who are trained and competent for the technique;
  • c. Continuously review and stop as soon as the risk reduces.

8.3.7. After use:-

  • a. Provide support/ debrief to the person and staff;
  • b. Record the rationale, type/ duration, staff involved, injuries, views of the person/ representative, alternatives tried, and review actions;
  • c. Report incidents internally and, where applicable, to Staffordshire County Council, CQC and/ or police;
  • d. Update risk assessments and care plans to reduce future use.

8.3.8. We do not use seclusion/ long-term segregation in domiciliary settings. Covert medication for behavioural control will not be used unless authorised via MCA best-interests decision-making with pharmacy/GP input and regular review. We operate a restrictive-practice reduction plan, review PRN protocols at least 3-monthly, and audit all incidents to drive down use over time.

8.3.9. We analyse every incident to reduce future use of restrictions, report patterns through governance, and evidence improvement against CQC’s quality statements for safety and learning.

8.3.10. All staff receive role-appropriate training at induction and regular refreshers on recognising, preventing and (where unavoidable) safely applying any restrictive practice, consistent with current national guidance and good practice. Only staff trained and deemed competent may use any approved technique. Use of restrictions is monitored via incident review, trend analysis and governance reporting, with actions taken to reduce and, where possible, eliminate use over time.

9. Recording and Confidentiality

9.1. Throughout the response, we maintain a clear safeguarding record. The Registered Manager or Safeguarding Lead will maintain a file (physical and/or electronic) that includes: the initial report, any witness statements or reports, records of phone calls (dates/times and summaries of conversations with external agencies), emails or forms sent, meeting minutes, risk assessments, protection plans, and outcomes/ resolutions.

9.2. Every action we take is logged with date and person responsible. These records are kept confidentially – separate from general care records, with restricted access. Only those directly involved in managing the incident (Registered Manager, Safeguarding Lead, possibly a Director or HR for staff issues) and the authorities will have access.

9.3. Within the service, staff will be informed of updates strictly on a need-to-know basis (for example, the person’s direct caregivers might be briefed that certain precautions are in place, without necessarily knowing all details).

9.4. All documentation will eventually contribute to any official report required.

9.5. We recognise that such records may be inspected by CQC or used in legal proceedings, so we ensure they are accurate, timely, and objective. We also respect the privacy of the individuals involved – information is shared internally or externally only for the purpose of protection and investigation.

9.6. Relevant internal sharing might include informing the Care Coordinator to adjust the staff rota, etc., without exposing unnecessary details.

10. Supporting Staff and Others

10.1. A safeguarding incident can be stressful for everyone involved. The Good Place will provide appropriate support.

10.2. For the adult at risk, as mentioned, we ensure they have emotional support – perhaps a trusted staff member or advocate to talk to, and access to professional counseling if needed. We check in on them regularly to see if they feel safe and if the measures are helping.

10.3. For the staff member who raised the concern, we reassure them that they did the right thing and encourage them to share any further observations. We offer them support too – for instance, if they are upset by witnessing something, we might offer counseling or time off as needed. We want to encourage a learning culture, so we might debrief with them (management will explain what steps are being taken so they aren’t left anxious).

10.4. For the staff member who is accused (if applicable), we make sure they understand the process and that they can contact a union or representative. They will have an opportunity to respond to allegations at the appropriate time, and we ensure the process is as transparent as possible.

10.5. We also consider other service users – if the incident could impact others (say multiple service users cared for by the same worker), we might need to talk to those service users or their families to check if they have any concerns. This will be guided by the safeguarding team’s advice. If the media or other outside parties become aware, we refer to our Media Policy and Procedure (not addressed here, but in principle we protect confidentiality and refer enquiries to a senior manager).

10.6. Outcome and Follow-Up

10.6.1. After the investigation/ enquiry, there will be an outcome. The local authority will usually determine whether the allegation was substantiated, inconclusive, or not substantiated (or malicious).

10.6.2. Whatever the outcome, The Good Place conducts an internal review of the case to see what lessons can be learned.

10.6.3. If the abuse was substantiated, we ensure any corrective actions are fully carried out: e.g., HR actions on staff, updating the person’s care plan, repairing relationships, providing additional support or compensation if needed, etc.

10.6.4. If policies or risk assessments need changes, we do that. If the incident was not substantiated, we still consider whether our staff acted correctly and whether any improvements in practices could prevent misunderstandings. We communicate with the adult at risk (and their representative/ family as appropriate) about the outcome in a sensitive manner, making sure they understand what will happen next.

10.6.5. We also inform the staff who reported and others in the loop about the case closure, thanking them for their vigilance. CQC notifications are updated with outcomes if required.

10.6.6. The Registered Manager will compile a final report on the incident for internal records, and possibly share a summary with higher management or trustees to keep them informed of safeguarding issues in the service.

10.7. Preventing Recurrence

10.7.1. As part of our follow-up, we focus on prevention of future incidents. This may involve additional training for staff involved or the whole team, tightening of certain procedures, or increased supervision/monitoring in certain areas. For example, if an incident revealed that a staff member was stressed and that contributed to unprofessional behavior, we might enhance our staff support and supervision systems. Or if a particular service user was targeted due to isolation, we work on ways to keep them more engaged and observed. We treat every safeguarding case as an opportunity to improve our service and reduce the chance of harm in the future. These preventive actions are recorded in our continuous improvement or action plan and monitored by the Registered Manager for completion.

10.7.2. Throughout all these steps, we adhere to key safeguarding principles: we empower the adult (taking their views into account), we act to prevent further harm, we respond in a proportionate way (least intrusive, but ensuring safety), we seek to protect those in need, we work in partnership with families and professionals, and we maintain clear accountability for our actions. Our actions will always be person-centered, considering the uniqueness of the situation and the individual’s needs and rights.

10.7.3. If at any stage a staff member is unsure what to do, they should consult the Registered Manager or Safeguarding Lead. It is better to ask and clarify than to make a mistake in a safeguarding situation. Also, staff should feel free to suggest ideas to support the person or improve our response – frontline input is valuable.

10.7.4. Finally, know that reporting a concern is just the beginning – The Good Place is committed to seeing each case through to resolution and doing everything in our power to achieve a good outcome for the adult at risk. We do not close a case until the risks are managed and the person is as safe as possible. Safeguarding is an ongoing process of learning and improvement.

11. Training and Awareness

11.1. Training is mandatory for all members of staff to ensure they are competent and confident in safeguarding adults. The Good Place invests in regular training and continuous awareness activities because we recognize that knowledgeable staff are key to preventing and detecting abuse. Our commitments regarding training and awareness are detailed below.

11.2. Induction Training

11.2.1. Every new employee, volunteer, or contractor who will work with service users receives safeguarding adults training as part of their induction (orientation) before they begin unsupervised work. This training covers the basics of what is abuse and neglect, types of abuse, signs and indicators, how to respond to disclosures, the reporting procedure, and their responsibilities under this policy and the law. We also include basic instruction on the Mental Capacity Act and Deprivation of Liberty Safeguards (since those relate to safeguarding). New staff must read this Safeguarding Adults Policy and acknowledge understanding. We do not consider a staff member fully cleared to work alone with service users until this initial safeguarding training is completed.

11.3. Ongoing mandatory training and competence

11.3.1. All staff complete safeguarding training at induction before any unsupervised work and routine refreshers at least annually (or sooner where role-, risk- or incident-driven). We assess competence, not just attendance, using scenarios, supervision, and spot checks, and align content to local Safeguarding Adults Board expectations. Leaders (Registered Manager/Safeguarding Lead) complete enhanced training suitable for decision-making and multi-agency working.

11.4. Specialist Training

11.4.1. Certain roles require more in-depth training. The Registered Manager and Safeguarding Lead, for example, will attend advanced safeguarding courses (often provided by the Local Authority or Safeguarding Adults Board) on topics like managing investigations, legal updates, and multi-agency working. We may also have senior staff attend “Designated Safeguarding Person” trainings to ensure we have qualified people to advise others. Additionally, if we support individuals with specific needs (e.g., learning disabilities or dementia) that raise particular safeguarding concerns, we include training on those. For instance, understanding how to communicate about abuse with someone who has dementia.

11.5. Periodic Refreshers and Toolbox Talks

11.5.1. Apart from the formal annual training, we regularly remind staff about safeguarding through briefings and discussions. Supervisors might incorporate a safeguarding question or scenario in team meetings or one-to-one supervisions. We circulate memos or newsletters that contain safeguarding tips or updates (for example, if there’s a new scam targeting elderly people in the area, we’ll inform staff to be vigilant – tying into financial abuse awareness). We might do quick “toolbox talks” on specific subtopics, such as recognising self-neglect or understanding the six safeguarding principles. These ongoing conversations help keep awareness high year-round, not just at training time.

11.6. Whistleblowing and Reporting Training

11.6.1. We ensure staff are aware of how to escalate concerns beyond their line manager. As part of training, we review the Raising Concerns, Freedom to Speak Up and Whistleblowing Policy and Procedure. We role-play scenarios so staff practice what they would do if, say, their supervisor ignored a report – who would they call next? Staff are given contacts for CQC and local authority as part of their training materials. We emphasise that reporting and recording concerns is a crucial part of their job – so much so that official guidance notes all care workers should be trained in this. Training covers how to record a concern factually and the importance of timely reporting.

11.7. Documenting Training

11.7.1. The Registered Manager maintains a training matrix or database that logs each staff member’s training in safeguarding (and other topics). This helps schedule renewals and evidence to CQC that we meet training requirements. The CQC expects providers to ensure staff have received appropriate safeguarding training and understand the procedures. We are prepared to show our training records during inspections, and staff should be able to speak to inspectors about what they learned.

11.8. Evaluation and Improvement

11.8.1. We evaluate the effectiveness of our safeguarding training. After sessions, we might quiz staff or have them complete a feedback form. If anyone seems uncertain in their duties, we follow up with additional support or mentoring. In light of any safeguarding incidents, we review if there were training gaps – for example, do we need extra training on internet safety if cyber abuse issues arose? Our training program is adjusted accordingly.

11.9. Awareness for service users and Families

11.9.1. While this policy focuses on staff, we also aim to raise awareness among the people we support and their families. We provide information in our service user welcome packs about abuse and how to report concerns (with appropriate contacts). We display or provide easy-read leaflets from the local Safeguarding Adults Board if available. This way, service users and their relatives know their rights and know that our staff are trained to respond.

11.10. Safeguarding is an Ongoing Mindset

11.10.1. We instil that safeguarding is not just a training topic but an everyday mindset. Staff should always be thinking, “Is this person safe? Is there anything worrying here? What can I do to protect them better?” By reinforcing this attitude in training and supervision, safeguarding becomes part of our care quality ethos.

12. Preventative Measures

12.1. Preventing abuse or neglect from occurring in the first place is a core part of our safeguarding strategy. The Good Place is committed to creating an environment and culture where the risk of abuse is minimized and where any potential issues are caught early.

12.2. All these measures together create a robust safeguarding framework aimed at prevention. While no system can remove all risk, we strive to make abuse or neglect as unlikely as possible in our service. Everyone at The Good Place should focus not just on reacting to abuse, but on preventing it – by providing excellent care, staying alert, and creating a supportive environment. Through safe recruitment, good training, supportive management, and a caring culture, we minimise opportunities for abuse to occur. Should any issues start to emerge, our early warning systems (like open communication and monitoring) will hopefully catch them quickly, allowing us to intervene before harm is done. Safeguarding is woven into everything we do, from HR practices to daily care routines.

12.3. Safe Recruitment Practices

12.3.1. Rigorous recruitment and vetting of all employees and volunteers is our first line of defense against abuse. We follow thorough hiring procedures in line with the law and CQC guidance.

12.3.2. This includes:-

  • a. Obtaining and checking at least two professional references (with specific questions about the candidate’s suitability to work with vulnerable adults),
  • b. Verifying identity and full employment history, and
  • c. Conducting an enhanced Disclosure and Barring Service (DBS) check (with barred list check) before any staff member begins unsupervised work.

12.3.3. We will not hire anyone who is barred from working with adults or who has a history of offenses that pose a safeguarding risk.

12.3.4. Additionally, during interviews, we assess candidates’ attitudes towards vulnerable people and understanding of safeguarding (e.g., we may ask scenario questions to gauge their responses).

12.3.5. All new recruits undergo a probationary period where we closely monitor their conduct and interactions.

12.3.6. Safe recruitment extends to checking the credentials of any contractors or independent professionals we might engage – they too must provide evidence of DBS clearance and appropriate qualifications.

12.3.7. By preventing individuals who might abuse from entering the workforce, we significantly reduce risk (Care Act guidance expects clear policies on recruitment as part of safeguarding).

12.4. Staff Conduct and Professional Boundaries

12.4.1. We set clear expectations for professional behavior through our Code of Conduct and staff handbook. This covers appropriate relationships with service users (no borrowing/ lending money, no personal gain, no favoritism, etc.), maintaining boundaries, and reporting any conflicts of interest. We promote a culture where respect, empathy, and person-centered care are the norm.

12.4.2. By ensuring staff know what is acceptable and what is not, and by supervising and observing their work, we prevent situations that could escalate into abuse. Any minor misconduct is addressed swiftly through supervision or retraining so that it doesn’t progress.

12.5. Supervision and Support

12.5.1. Regular supervision meetings and appraisals with staff allow managers to detect any issues with staff performance or stress that might lead to burnout or poor care. We encourage an open dialogue in supervision – staff can talk about challenges they face with service users, and managers can provide guidance or additional resources.

12.5.2. If a staff member is struggling (e.g., feeling frustrated or having difficulty managing a service user’s behaviour), we intervene supportively before frustration could turn into mistreatment. We also conduct spot checks and unannounced visits to observe staff working in service users’ homes, ensuring that high standards are maintained when managers are not present.

12.5.3. Supervisors also review care logs and notes regularly to catch any concerning patterns (like repeatedly missed visits or gaps in records that might suggest neglect).

12.5.4. By actively monitoring and supporting our team, we aim to prevent neglectful or abusive situations born of stress, lack of knowledge, or deliberate misconduct.

12.6. Policies and Procedures

12.6.1. In addition to this Safeguarding Policy, we have a suite of policies designed to protect people. For example, our Medication Management & Administration Policy and Procedure ensures safe administration of meds (preventing medication errors or wilful withholding), our Moving and Handling Policy and Procedure prevents injury and misuse of restraint, and our Maintaining Professional Boundaries Policy and Procedure guides appropriate behaviour.

12.6.2. We enforce compliance with these policies through training and audits. For example, regular medication audits can catch if someone is not giving meds properly (which could be neglect).

12.6.3. By having robust procedures for all aspects of care, we reduce the chance of harm.

12.7. service user Engagement and Empowerment

12.7.1. We adopt a person-centered approach that empowers our service users. We involve adults (and their families where appropriate) in their care planning and decisions. We inform them of their rights and encourage them to speak up if something is not to their liking.

12.7.2. This is based on the principle of Empowerment – individuals are more likely to disclose concerns if they feel listened to and valued. We also endeavor to match service users with caregivers who suit them, and to rotate staff if needed to avoid over-reliance or too much power balance in one caregiver.

12.7.3. Encouraging service users to be active in directing their care helps prevent them from feeling helpless or fearful, which in turn prevents abusers from exerting power.

12.8. Public Awareness and Transparency

12.8.1. We make sure that not only staff, but also service users’ families and representatives, know how to report concerns. Our service users (where able) and their relatives receive information on how to contact the office, the local authority, or CQC if they are worried about anything.

12.8.2. By welcoming feedback and complaints (see Complaints Procedure), we hope issues come to light early. We have a culture of transparency – for instance, our care visit notes are available for service users/families to read, and management regularly asks service users if they are satisfied and feel safe with our service.

12.8.3. Surprise phone calls or visits from a supervisor to service users can provide an opportunity for them to voice any small concerns before they become big problems.

12.9. Risk Assessments

12.9.1. We perform detailed risk assessments for each service user and situation, which include considering any safeguarding risks. For example, if a service user has dementia and lives with a family member, we assess if there’s any risk of that family member experiencing stress or difficulty that could lead to abusive behaviour (and offer support/resources accordingly).

12.9.2. If a service user’s neighbourhood has known issues (like a high crime area), we assess risks of financial exploitation or doorstep scams.

12.9.3. We also continuously re-assess risks during care reviews or after incidents. These risk assessments lead to preventive measures like installing a Keysafe (to prevent unauthorised access to the home), setting up utility account safeguards (so staff cannot exploit finances), or involving occupational therapy (to reduce reliance that could lead to frustration).

12.9.4. Essentially, we try to anticipate potential for harm in every care scenario and plan to mitigate it.

12.10. Encouraging Early Reporting (No Blame)

12.10.1. We stress to staff that reporting “small” concerns is both acceptable and desired. For instance, if a staff member notices a colleague being a bit short-tempered or skipping a task, we encourage them to address it or inform a supervisor before it escalates.

12.10.2. We promote a no-blame culture for raising issues – meaning staff shouldn’t fear reprisal if they speak up about something that’s not right. Management responds to such early reports with support and corrective action rather than punishment (unless warranted).

12.10.3. By catching and correcting borderline behaviour or minor misconduct, we prevent escalation to actual abuse. The message is: “Report concerns when they are concerns, not only when you have proof of abuse.”

12.10.4. Early intervention can be as simple as additional training or a wellness check on a staff member, which can avert future harm.

12.11. Preventing Isolation

12.11.1. Adults who are isolated are at higher risk for abuse. In domiciliary care, service users may only see their caregiver and few others. We try to reduce social isolation as a preventive strategy.

12.11.2. Where possible, we encourage service users to remain socially active (through day centers, community activities, or family visits) and we can signpost to befriending services or community groups.

12.11.3. A service user who has more external contact has more eyes ensuring they are okay, and more confidence perhaps to disclose problems. Internally, we rotate staff or have two staff attend occasionally (for double-handed calls or introductions) so that more than one person sees the service user’s situation.

12.11.4. Also, for service users with capacity, we involve them in monitoring their own service (like giving them logs to record if a carer was late, etc., and reviewing those).

12.11.5. These steps can help prevent any single point of failure and keep the care situation open and observable.

12.12. Environmental Safety and Equipment

12.12.1. Neglect can occur if equipment is lacking or environment is unsafe. We proactively check that all necessary equipment (hoists, alarms, etc.) is in place and functioning. We address maintenance issues quickly (like broken heating which could lead to neglect via cold).

12.12.2. By ensuring a safe care environment, we remove opportunities for neglect or harm through omission.

12.13. Continuous Improvement Mindset

12.13.1. We routinely reflect on our practice through audits, team meetings, and service user feedback. If we identify any weakness – say, staff not fully understanding how to handle someone’s challenging behaviour – we act to strengthen that area (through training or procedure changes). We keep abreast of best practices and recommendations from Safeguarding Adult Reviews (cases where things went wrong in other organizations) to learn lessons. This continuous improvement loop helps us to constantly refine our safeguards.

12.14. Blanket Rules

12.14.1. We avoid blanket restrictions. Any house-wide or service-wide rule that limits people’s rights (for example, locking fridges/ medication cupboards accessible to people, fixed bedtimes, limiting visitors) requires a written risk assessment, individual consent/capacity consideration, and manager approval, and must be reviewed to ensure it remains the least restrictive option.

12.15. Identifying and Authorising Deprivations of Liberty in the Community

12.15.1. Where care arrangements in non-hospital, non-care-home settings (e.g., a person’s own home) the amount to continuous supervision/control and the person is not free to leave, we:-

  • a. Escalate immediately to the Registered Manager/Safeguarding Lead to review and reduce restrictions;
  • b. If the person has capacity, obtain informed consent and review regularly;
  • c. If the person lacks capacity, we seek Court of Protection authorisation under the Mental Capacity Act 2005 (as the Liberty Protection Safeguards are not yet commenced at the time of this policy); and
  • d. Work with commissioners and Staffordshire County Council to monitor restrictions and ensure timely reviews.
    We record capacity assessments, best-interests decisions, advocacy offered, rationales for restrictions, and legal authorisations. We will update this section when/if LPS is commenced by government.

12.16. Deprivation of Liberty (community) – authorisation process and recording

12.16.1. Where restrictions may amount to a deprivation of liberty in a person’s own home the Registered Manager/ Safeguarding Lead will:-

  • a. complete/confirm a capacity assessment for the specific decision(s) and record the outcome;
  • b. complete a best-interests decision (where the person lacks capacity), including consultation with family/representatives/attorney/deputy where appropriate;
  • c. ensure restrictions are necessary, proportionate, time-limited and least restrictive, and try alternatives to reduce restrictions;
  • d. liaise with commissioners and Staffordshire County Council to agree next steps; and
  • e. where the legal threshold is met, support/trigger the appropriate Court of Protection authorisation process and implement interim safeguards while authorisation is progressed.

12.16.2. We will keep a clear record of: capacity assessment, best-interests decision, advocacy offered, the restriction plan, review dates, and any legal authorisation reference numbers/outcomes.

13. Links to Other Policies

13.1. Safeguarding does not stand alone – it is closely related to other policies and procedures within The Good Place. To ensure a comprehensive approach, this Safeguarding Adults Policy should be read and understood in conjunction with the following policies:-

  • a.Raising Concerns, Freedom to Speak Up and Whistleblowing Policy and Procedure: This policy outlines the process for staff to raise concerns about wrongdoing, malpractice, or dangers (including abuse or neglect) within the organization, without fear of reprisal. It provides guidance on how to escalate concerns outside the normal management structure if necessary (for example, if the concern is about senior management or if previous reports have not been acted upon). The Whistleblowing Policy is a key support to safeguarding because it empowers employees to report suspected abuse that might otherwise remain hidden. It gives contact details for external bodies (such as CQC or the local authority) that staff can approach. We ensure staff are aware that they can use whistleblowing channels for safeguarding issues, and that doing so is both safe and protected. (All whistleblowing reports related to safeguarding will be handled with the utmost seriousness and urgency, in line with this Safeguarding Policy.)
  • b.Complaints Policy and Procedure: Our Complaints procedure allows service users, their families, or representatives, to formally complain about any aspect of our service. Often, what starts as a “complaint” (e.g., about rough handling by a carer, or missing money) may actually be a safeguarding issue. This policy explains how complaints can be made (verbally or in writing), the timescales for our response, and how we investigate and resolve complaints. We treat any complaint that suggests abuse, neglect, or exploitation as a potential safeguarding matter – meaning we will escalate it per this Safeguarding Policy and involve external agencies as required. The Complaints Procedure also provides information on how to contact external ombudsmen or authorities if the complainant is not satisfied. By having a clear, accessible complaints process, we encourage people to voice concerns early, which can prevent harm from continuing. All staff should welcome complaints and report them to management, as they can be an early alert to safeguarding problems.
  • c.Consent to Care and Support Policy and Procedure: This policy details how we support and protect individuals who may lack the mental capacity to make certain decisions. It explains the principles of the Mental Capacity Act 2005 – presuming capacity, supporting decision-making, allowing unwise decisions, acting in best interests, and choosing the least restrictive option. Safeguarding is closely linked, because adults who lack capacity are particularly vulnerable to abuse, and decisions about their safety (like whether to share information or intervene) must be made in their best interests. Our policy guides staff on assessing capacity, documenting assessments, and involving advocates or representatives. It also covers Deprivation of Liberty Safeguards (DoLS) for those in care environments (though in domiciliary care DoLS might not directly apply, if a person’s liberties need restricting to keep them safe we would involve the Court of Protection). Importantly, if an adult at risk refuses help but we suspect they lack capacity to understand the risk, this policy helps staff navigate that (e.g., by doing a capacity assessment and then possibly overriding their refusal in their best interest, involving social services). Additionally, the Consent to Care and Support Policy and Procedure emphasizes Making Safeguarding Personal – even if someone has capacity, we seek their consent to share information and involve them in safeguarding plans, unless doing so would put them or others at greater risk. This aligns with our approach in the Safeguarding Policy of balancing protection with respecting the individual’s rights and choices. Staff should refer to the Mental Capacity Policy when dealing with situations like self-neglect or refusal of services, as it provides the framework to ensure we act lawfully and ethically.
  • d.Confidentiality and Data Protection (UK GDPR) Policy and Procedure: (Not explicitly listed by the user, but worth mentioning contextually) Safeguarding often involves sharing sensitive personal information. Our confidentiality and GDPR policies set out how we handle personal data. They acknowledge that while confidentiality is important, information must be shared with relevant agencies in a safeguarding situation on a need-to-know basis. We will not use data protection as an excuse to not report abuse. The policy guides the correct sharing – for instance, when we can share without consent (if it’s to prevent a crime or serious harm) – which complements the Safeguarding Policy’s guidance on information sharing.

13.2. Note: If the actual policy documents are separate, staff should ensure they read them. The above links are summarized for coherence. In practice, these policies work together: e.g., a staff member concerned about a colleague’s behavior might use the Raising Concerns, Freedom to Speak Up and Whistleblowing Policy and Procedure to report it externally if needed; a service user complaining of theft triggers both the Complaints and Safeguarding procedures; a service user with dementia refusing care leads us to the Mental Capacity Policy to decide how to act in their best interest and safeguard them.

13.3. All staff must be familiar with these related policies because effective safeguarding may require invoking them. For example, a safeguarding incident may arise from a complaint, require a mental capacity assessment, and lead to a whistleblowing disclosure – all at once. Consistency across policies is maintained; they all reinforce the message that the welfare and rights of adults at risk are paramount.

13.4. We also have other relevant documents, such as Health and Safety Policy and Procedure (to prevent avoidable harm), Discipline Policy and Procedure (to deal with staff misconduct that could include abuse), and Equality and Diversity Policy (to combat discriminatory attitudes) – all of which indirectly support safeguarding aims. By maintaining a strong policy framework, we create multiple layers of defense against abuse. Staff should always consider these policies in conjunction – if unsure, seek guidance from a manager.

13.5. In summary, safeguarding adults is not just about one policy – it is embedded in many aspects of our operations. The Whistleblowing, Complaints, and Mental Capacity policies in particular are critical companions to this Safeguarding Adults Policy. They provide additional tools and guidance to ensure concerns are raised, individuals are heard, and people who may not be able to protect themselves are given the protection they need.

14. Review and Monitoring

14.1. To keep this policy effective and up-to-date, The Good Place will ensure it is regularly reviewed and monitored. Safeguarding is a dynamic area, influenced by changes in law, guidance, and learning from cases; thus, our policy must evolve accordingly.

14.2. Frequency of Review

14.2.1. This policy will be reviewed at least annually. A formal review will be conducted every 12 months to consider any updates needed. In addition to the annual cycle, an immediate review will be triggered if there are significant changes in relevant legislation (e.g., a new amendment to the Care Act or introduction of Liberty Protection Safeguards), changes in CQC regulations or standards, or important lessons from a serious safeguarding incident either within our service or in the sector (for example, if a Safeguarding Adults Review or inquiry report comes out with new recommendations). We want to ensure our policy is never out of step with current requirements. The review date will be recorded the end of this document, so staff can see that it is current.

14.3. Responsibility for Review

14.3.1. The Registered Manager (Dean Hill) holds ultimate responsibility for ensuring the policy is reviewed and updated. The Registered Manager may delegate the task of drafting revisions to the Safeguarding Lead or another competent person, but it is the Manager’s duty to approve the final content and formally adopt the updated policy. As part of the review, the Registered Manager will consult with relevant parties – for example, getting input from frontline staff (to see if procedures are working in practice), incorporating feedback from any audits or inspections, checking with the local Safeguarding Adults Board for any changes in local protocols, and consultancy companies. The Registered Manager will also ensure that any revised policy continues to meet CQC’s expectations and legal standards. Once an updated version is ready, the Registered Manager will sign it off and arrange for distribution to all staff.

14.4. Staff Consultation and Communication

14.4.1. When reviewing the policy, we may involve staff by asking for suggestions or discussing parts of the policy in team meetings. Frontline care workers can often highlight practical issues or suggest clarifications since they use the procedures day-to-day. We value this input to make the policy as user-friendly and clear as possible. After any revision, all staff will be informed of the changes. We will circulate the new policy (or a summary of key changes) and require staff to read and acknowledge it. If changes are substantial, we might hold a briefing or incorporate it into a training session. New copies will replace old ones in our policy manuals and on any digital platforms. We emphasise in communication that following the latest policy is mandatory.

14.5. Monitoring Compliance

14.5.1. Having a policy is not enough; we must ensure it is being followed.

14.5.2. Our internal audits map evidence to CQC Single Assessment Framework quality statements (notably Safe and Well-led) so we can demonstrate assurance during inspection.

14.5.3. The Registered Manager and Safeguarding Lead will monitor compliance with the policy through various means:-

  • a. Supervisions and Appraisals: They will ask staff about safeguarding in one-to-one supervisions – for example, checking if they know how to report and if they have any concerns. This gauges whether the policy is understood and being implemented.
  • b. Incident Monitoring: We keep a log of all safeguarding incidents or alerts. The Registered Manager reviews these to ensure that the response in each case complied with this policy (e.g., was the local authority notified timely? Was the documentation complete?). Any deviations are noted and corrected. We learn from cases to see if any procedure needs reinforcement or if staff need re-training in certain areas.
  • c. Audits: Periodic internal audits may be done, where we take a sample of care records or staff files to check safeguarding elements (for instance, verifying all staff have up-to-date DBS checks and training, or that any noted concerns in daily logs were properly escalated). We might use a checklist based on CQC Key Lines of Enquiry (KLOEs) around safeguarding to self-assess our performance. The results of these audits are used to improve practice.
  • d. External Feedback: We also consider feedback from external sources – such as CQC inspection reports or contract monitoring by the local authority. If any safeguarding-related recommendations are made by inspectors (e.g., “improve record-keeping of incidents” or “ensure all staff can identify types of abuse”), we address them promptly and incorporate into policy or training as needed. Additionally, if the local Safeguarding Adults Board issues any new guidance or if a multi-agency case review suggests better ways to work, we integrate that.
  • e. Service User Feedback: Through surveys or direct conversations, we ask service users if they feel safe and if they know how to report concerns. Consistently positive feedback indicates our processes are working; any negative feedback (someone feeling unsafe or unsure how to complain) would trigger us to reinforce our policy communication and possibly adjust how we educate service users about their rights.
  • f. Records of Safeguarding Concerns: The Registered Manager will maintain oversight of all safeguarding concerns raised. Periodically (e.g., quarterly), they might analyse these records for patterns – such as multiple allegations about a particular staff member, or recurring issues at a specific time or with a certain service user. Identifying patterns can help us take proactive action (like extra training for a staff member or more support for a service user with complex needs). This analysis is part of monitoring the effectiveness of our safeguarding measures. If we find, for instance, that despite training, some staff failed to report something promptly, we know we need to emphasize that aspect more.
  • g. Policy Effectiveness Evaluation: At the annual review, we essentially ask, “Has this policy been effective?” We look at outcomes: Have safeguarding concerns been handled properly? Did our prevention measures reduce incidents? Are staff and service users confident in our safeguarding approach? If we had incidents, did following the policy lead to satisfactory resolution? This evaluation might be informal or included in a management report. If any part of the policy is found lacking, we will revise it. We also ensure alignment with any updated Safeguarding Adult Board policies – since local multi-agency procedures might update, we must mirror those (e.g., new referral pathways or forms).

14.5.4. After the review process, the policy will have a new review date set (usually one year ahead unless changes dictate sooner). We clearly log the last review date and next review due date.

14.5.5. The Registered Manager will report on safeguarding to the organisation’s leadership (owners or board) periodically, including whether the policy is up to date and how safeguarding is being managed generally. This creates accountability at the highest level. Safeguarding is often a standing agenda item in management meetings, ensuring it gets regular attention.

14.5.6. By diligently reviewing and monitoring this policy, we ensure it remains a living document that truly guides best practice. It’s not just a file on a shelf – it’s reviewed, discussed, and improved as needed. Staff can be confident that the procedures they are following are the latest and best. Moreover, regular review demonstrates to regulators and partners that we take safeguarding governance seriously.

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