Safeguarding Adults Policy & Procedure
Safeguarding Adults Policy
1. Purpose and scope
1.1 Sight Loss Ministries is committed to safeguarding and protecting the welfare of all who use its services. We recognise that we have a particular responsibility to ensure that adults who may be at risk are protected.
1.2 Policy objectives
The objectives of this policy and procedure are to:
• contribute to the successful achievement of Sight Loss Ministries’ aims and excellent standards of service for people affected by sight loss
• ensure that adults who may be at risk and who are in contact with Sight Loss Ministries are protected effectively from abuse/harm
• ensure all the organisation’s beneficiaries are protected from harm
• provide a clear framework for action whenever abuse is disclosed or suspected
• ensure all Sight Loss Ministries’ workers (paid or voluntary) are clear about their responsibilities
• ensure Sight Loss Ministries complies with best practice in this area
1.3 This policy and procedure applies to all Sight Loss Ministries’ workers based in Northern Ireland engaging with service users and others who come into contact with the organisation.
2. Definitions
2.1 Adult at risk of harm
The term ‘adult at risk of harm’ has been used to replace ‘vulnerable adult’. This is because the term ‘vulnerable adult’ may wrongly imply that some fault for the abuse lies with the abused adult.
The term ‘adult at risk of harm’ is used as an exact replacement for ‘vulnerable adult’. The information below gives more detail as to what this term can mean in practice.
An ‘adult at risk of harm’ is a person aged 18 or over, whose exposure to harm through abuse, exploitation or neglect may be increased by their:
a) Personal characteristics
and/or
b) Life circumstances
Personal characteristics may include, but are not limited to, age, disability, special educational needs, illness, mental or physical frailty or impairment of, or disturbance in, the functioning of the mind or brain.
Life circumstances may include, but are not limited to, isolation, socio- economic factors and environmental living conditions.
2.2. Adult in need of protection
An ‘adult in need of protection’ is a person aged 18 or over, whose exposure to harm through abuse, exploitation or neglect may be increased by their:
a) Personal characteristics
and/or
b) Life circumstances
and
c) who is unable to protect their own wellbeing, property, assets, rights or other interests;
and
d) where the action or inaction of another person or persons is causing, or is likely to cause, him/her to be harmed.
In order to meet the definition of an ‘adult in need of protection’ either (a) or (b) must be present, in addition to both elements (c) and (d). The decision as to whether the definition of an ‘adult in need of protection’ is met will demand the careful exercise of professional judgement applied on a case by case basis.
2.3 For definitions for Scotland, England and Wales, see Appendix C.
2.4 Harm and abuse
The Northern Ireland Adult Safeguarding Prevention and Protection in Partnership Policy defines ‘harm’ and ‘abuse’.
https://www.health-ni.gov.uk/sites/default/files/publications/dhssps/adult-safeguarding-policy.pdf
‘Harm’ is ‘the impact on the victim of abuse, exploitation or neglect. It is the result of any action whether by commission or omission, deliberate, or as the result of a lack of knowledge or awareness which may result in the impairment of physical, intellectual, emotional, or mental health or wellbeing’.
‘Abuse’ is ‘a single or repeated act, or lack of appropriate action, occurring within any relationship where there is an expectation of trust, which causes harm or distress to another individual or violates their human or civil rights’. Some of the main forms of abuse are outlined in The Northern Ireland Adult Safeguarding Prevention and Protection in Partnership Policy and include:
Physical abuse
Physical abuse is the use of physical force or mistreatment of one person by another which may or may not result in actual physical injury. This may include hitting, pushing, rough handling, exposure to heat or cold, force feeding, improper administration of medication, denial of treatment, misuse or illegal use of restraint and deprivation of liberty.
Sexual violence and abuse
Sexual abuse is any behaviour perceived to be of a sexual nature which is unwanted or takes place without consent or understanding. Sexual violence and abuse can take many forms and may include non-contact sexual activities, such as indecent exposure, stalking, grooming, being made to look at or be involved in the production of sexually abusive material, or being made to watch sexual activities. It may involve physical contact, including but not limited to non-consensual penetrative sexual activities or non-penetrative sexual activities, such as intentional touching (known as groping). Sexual violence can be found across all sections of society, irrelevant of gender, age, ability, religion, race, ethnicity, personal circumstances, financial background or sexual orientation.
Psychological / emotional abuse
Psychological / emotional abuse is behaviour that is psychologically harmful or inflicts mental distress by threat, humiliation or other verbal/non-verbal conduct. This may include threats, humiliation or ridicule, provoking fear of violence, shouting, yelling and swearing, blaming, controlling, intimidation and coercion.
Financial abuse
Financial abuse is the actual or attempted theft, fraud or burglary. It is the misappropriation or misuse of money, property, benefits, material goods or other asset transactions which the person did not or could not consent to, or which were invalidated by intimidation, coercion or deception. This may include exploitation, embezzlement, withholding pension or benefits or pressure exerted around wills, property or inheritance.
Institutional abuse
Institutional abuse is the mistreatment or neglect of an adult by a regime or individuals in settings which adults who may be at risk reside in or use. This can occur in any organisation, within and outside the HSC sector. Institutional abuse may occur when the routines, systems and regimes result in poor standards of care, poor practice and behaviours, inflexible regimes and rigid routines which violate the dignity and human rights of the adults and place them at risk of harm. Institutional abuse may occur within a culture that denies, restricts or curtails privacy, dignity, choice and independence. It involves the collective failure of a service provider or an organisation to provide safe and appropriate services, and includes a failure to ensure that the necessary preventative and/or protective measures are in place.
Neglect
Neglect occurs when a person deliberately withholds, or fails to provide, appropriate and adequate care and support which is required by another adult. It may be through a lack of knowledge or awareness, or through a failure to take reasonable action given the information and facts available to them at the time. It may include physical neglect to the extent that health or well-being is impaired, administering too much or too little medication, failure to provide access to appropriate health or social care, withholding the necessities of life, such as adequate nutrition, heating or clothing, or failure to intervene in situations that are dangerous to the person concerned or to others particularly when the person lacks the capacity to assess risk.
2.5 While most abuse takes place when people are in physical contact, it can also take place in a virtual environment, such as an online discussion board or chat room.
2.6 It should be noted that all children (up to the age of 18 years) are potentially vulnerable to abuse. Details of legislation and guidance regarding safeguarding children can be found on the NSPCC website: https://learning.nspcc.org.uk/safeguarding-child-protection/managing-allegations-made-against-a-child#skip-to-content
3. Responsibilities
3.1 Adult Safeguarding Champion (ASC)
To ensure compliance with the Northern Ireland Adult Safeguarding Prevention and Protection in Partnership 2015, Leonard Campbell is the designated Adult Safeguarding Champion for Sight Loss Ministries. In the absence of Leonard Campbell, Ian Wilson will act as the deputy ASC.
Full details of the role and responsibilities of the ASC are as laid down in the Health and Social care Board Northern Ireland Adult Safeguarding Partnership Adult safeguarding Operational Procedures.
https://www.rqia.org.uk/RQIA/files/19/1990cfc5-6653-4a18-8e8f-1e669d5e11c6.pdf
3.2 All workers have a duty to report any concerns about actual or suspected abuse.
3.3 The ASC supported by the trustees responsible for safeguarding will make all decisions about safeguarding issues, including questions of mental capacity and consent. When required they will make referrals and liaise with the local Health and Social Care Trust, or local council as appropriate.
3.4 The ASC has a responsibility to:
• respond to internal safeguarding reports in a timely manner
• consider all the issues carefully
• consult with the trustees
• ensure all records are kept as agreed and the monitoring log is completed
• where appropriate, make a referral to the relevant authorities
3.5 The trustees will have responsibility for:
• reviewing on a regular basis the volume and pattern of reported safeguarding concerns
• agreeing the organisation’s policies, approach, procedures and risk management relating to safeguarding
• ensuring the regular review and effective working of this policy
3.6 Adult Safeguarding Enquiries
• In Northern Ireland - a designated adult protection officer within the Health and Social Care Trust must make enquiries in all cases of alleged abuse under the Adult Safeguarding: Prevention and Protection in Partnership 2015.
• In Scotland - a Scottish council must make inquiries about a person's well-being, property or financial affairs under The Adult Support and Protection (Scotland) Act 2007: Code of Practice if it knows, or believes: (a) that the person is an adult at risk; and (b) that it might need to intervene (by performing functions under this Part or otherwise) in order to protect the person's well-being, property or financial affairs.
• In England & Wales - when a local authority believes an adult at risk is experiencing or at risk of experiencing abuse or neglect, it must make enquiries (this is not necessarily an investigation), or cause others to do so. This is a duty under s.42 of The Care Act 2014.
3.6.1 Enquiries should establish whether any action needs to be taken to prevent or stop abuse or neglect, and if so, by whom.
3.6.2 The objectives of an adult safeguarding enquiry are to:
• Establish facts.
• Ascertain the adult’s views and wishes.
• Assess and address their need for protection and support, in accordance with the wishes of the adult.
• Make decisions as to what follow-up action should be taken.
• Enable the adult to achieve resolution and recovery.
3.7 The Northern Ireland Charity Commission should be advised of the incident in accordance with their Serious Incident Reporting Guidance. Reporting to other Regulators should also be carried out as required in line with their guidance.
3.8 The ASC will email the trustees the file number of any safeguarding concern referred to a Health and Social Care Trust, the PSNI or any other Statutory Body.
See Appendix B for details of those responsible for safeguarding within the organisation.
4. Policy principles
4.1 The following principles underpin this policy and accompanying procedure:
• It is every individual’s right to live in a safe environment and to be free from abuse or the threat of abuse
• It is every individual’s right to live an independent life based on self- determination and personal choice and this includes the right to take risks
• The overall aim of safeguarding is to restore the power back to the adult at risk of harm, so that they can exercise choice and control over their life
• All workers will promote the empowerment and wellbeing of people affected by sight loss
• Safeguarding adults at risk of harm is everyone’s business: all workers engaging with blind or partially sighted people through Sight Loss Ministries’ activities will be aware of the policy and procedures for safeguarding adults at risk of harm
• Workers will have an appropriate AccessNI check when required
• Workers engaging with blind or partially sighted people through Sight Loss Ministries’ activities will have appropriate support and training to ensure they are able to recognise and act on the suspicion or disclosure of abuse
• Workers with concerns or suspicions that an adult at risk of harm is being or is at risk of being abused have a duty to report these concerns or suspicions within Sight Loss Ministries in a timely way
• Details giving rise to concerns or suspicions of abuse will only be shared with the limited number of individuals who need them in order to make decisions about next steps and referrals. Beyond this, all details will remain confidential
• Where other Sight Loss Ministries’ policies and procedures apply to a disclosure of abuse the welfare and safety of the adult at risk of harm remains paramount
4.2 The Five Principles of Adult Safeguarding (Northern Ireland Adult Safeguarding Prevention and Protection in Partnership Policy) are also incorporated into this policy and accompanying procedure:
Principle 1 – A Rights-Based Approach
To promote and respect an adult’s right:
• to be safe and secure
• to freedom from harm and coercion
• to equality of treatment
• to the protection of the law
• to privacy
• to confidentiality
• to freedom from discrimination
Principle 2 – An Empowering Approach
To empower adults:
• to make informed choices about their lives
• to maximise their opportunities to participate in wider society
• to keep themselves safe and free from harm in ways that manage their own decisions in respect of exposure to risk
Principle 3 – A Person-Centred Approach
To promote and facilitate full participation of adults in all decisions affecting their lives taking full cognisance of their views, wishes, feelings and where appropriate, the views of others who have an interest in his or her safety and wellbeing.
Principle 4 – A Consent-Driven Approach
To make a presumption that the adult has the ability:
• to give or withhold consent
• to make informed choices
To help inform choice through:
• the provision of information
• advocacy
• the identification of options and alternatives
To have particular regard to the needs of individuals who lack the capacity to consent and intervene in the life of an adult against his or her wishes only in particular circumstances, for very specific purposes and always in accordance with the law.
Principle 5 – A Collaborative Approach
To acknowledge that safeguarding will be most effective when it has the full support of the wider public and of safeguarding partners across the statutory, voluntary, community and independent sectors working together and is delivered in a way where roles, responsibilities and lines of accountability are clearly defined and understood. Partnership and person-centredness will work hand-in-hand.
4.3 Advice and procedural support
The trustees are available to support the ASC and provide procedural guidance throughout this process.
4.4 Timescales
All timescales in this policy refer to calendar days. All timescales will be met as far as is reasonably practicable.
Safeguarding Adults Procedure
1. Safer recruitment
• Any new roles will have a written job description, which outlines the responsibilities, as well as a person specification.
• All applicants shall be required to complete an application form.
• Applications will be assessed against the person specification and the requirements of the role responsibilities.
• Short-listed applicants will be invited to an interview.
• Applicants will be required to provide the names of two referees, who will be requested to complete a reference form.
• If the role is eligible, an AccessNI check will be completed at the appropriate level on the successful applicant. A new check will usually be obtained every three years.
• Successful applicants shall receive an induction suitable to the role during their probationary period (usually three to six months). This will include training to ensure they are able to recognise and act on the suspicion or disclosure of abuse for those working with adults with sight loss.
• A copy of this Safeguarding Policy and Procedure will be provided along with any other relevant policies. The appointee will be asked to confirm they have read and understood these documents and will adhere to them.
2. Boundaries
2.1 All workers are expected to be committed and reliable in their role(s) within the organisation and not use their position to pursue inappropriate personal relationships with beneficiaries of the organisation’s services.
2.1 Workers within Sight Loss Ministries should be in agreement with the Sight Loss Ministries Code of Conduct and carry out their duties in accordance with the code.
3. Responding to disclosure, suspicion or witnessing of abuse
3.1 For all cases of suspected or reported abuse identified or advised, the following procedure applies:
No suspicion of abuse or harm should be ignored. Workers may become aware of possible abuse when they:
• witness a form of abuse
• recognise one or more of the abuse indicators listed in appendix A
• are told about abuse by the person with sight loss
• are told about abuse by a visitor, carer, relative or friend
• observe online abuse on forums and discussion boards
• receive a complaint.
3.2 Where an adult at risk of harm discloses or discusses potential abuse or harm the worker should be able to:
• Recognise: identify that the adult at risk of harm may be describing abuse, even when they may not be explicit.
• Respond: stay calm, listen and show empathy. Reassure them that it will be taken seriously and explain that there is a duty to report the issues internally and what may happen next.
• Record: write up notes of the conversation clearly and factually as soon as possible using the ‘Record of Safeguarding Concerns and Actions’ form. Try to capture as much of the conversation verbatim as possible.
• Report: email the ‘Record of Safeguarding Concerns and Actions’ form to Leonard Campbell (ASC).
3.3 Sight Loss Ministries does not provide an emergency service. If there is an emergency, the worker should inform the adult at risk of harm to call the Police Service of Northern Ireland (PSNI). This includes an emergency outside of normal office hours.
3.4 Confidentiality must be maintained. Details giving rise to concerns or suspicions of abuse will only be shared with the limited number of individuals who need them in order to make decisions about next steps and referrals. Beyond this, all details will remain confidential.
3.5 No worker should start any investigation or confront or make contact with the alleged perpetrator.
3.6 Deciding to refer
On receiving an internal report the ASC will confer with the trustees (and possibly seek informal advice from the appropriate Health and Social Care Trust).
3.7 The ASC will confirm whether this is a safeguarding issue and requires referral to a Health and Social Care Trust or if a crime may have been committed and therefore requires referral to the Police Service of Northern Ireland.
3.8 When considering the internal report and deciding whether to refer a case to the local authority, if the ASC is in any doubt as to whether to refer or not, they should err on the side of caution and refer to the local authority.
3.9 Seeking consent
The lead safeguarding responder will contact the adult at risk of harm to seek their consent to inform the necessary authorities and make the referral.
3.10 Capacity to consent will be assumed unless there is evidence to the contrary. Decisions regarding an individual’s capacity must be specific to this decision at this time.
3.11 Where the individual seems unable to give consent, the ASC will consider and seek advice on their mental capacity to make this decision. If they do not have sufficient mental capacity a referral will be made without their consent.
3.12 Where the individual does not wish to give consent, the ASC will consider and seek advice on whether there is a wider public interest issue (such as other adults at risk of harm or children who may be at risk) which would warrant overriding the individual’s wishes. In such an instance all efforts should be made to explain to the individual concerned what is being done and why.
3.13 Making a referral
Generally a referral would only be made to the appropriate Health and Social Care Trust once the adult at risk of harm had given their consent. The ASC should also seek consent to contact the Police Service of Northern Ireland where there is a possibility that a criminal act has occurred.
3.14 When referrals are required, the ASC should aim to make them within two working days of receiving the disclosure. There may be exceptional circumstances that extend this time.
3.15 The referral should be made by phone and the ASC should ensure it has been received by someone able to act on the information (e.g. a social worker).
3.16 If the HSC Trust will not accept a safeguarding referral by telephone then it should be made in the manner requested, be as comprehensive as possible and a copy retained in the individual file relating to the concern. The Health and Social Care Trust and/or the Police Service of Northern Ireland will carry out the enquiries or investigation. Under no circumstances should a worker attempt to investigate any suspicions or disclosures of abuse.
3.17 Concerns about abuse by another adult at risk of harm
In cases when a referral is being made and the alleged abuser may also be an adult at risk of harm, they should also be referred to the Health and Social Care Trust, or relevant council. They may need an assessment in their own right to determine whether they need any specialist services.
3.18 Recording and monitoring
The lead ASC will keep the adult at risk of harm informed of their actions and developments.
3.19 Once the matter has been reported, the ASC will ensure that all notes are collected and stored electronically and the monitoring log is completed.
3.20 Support for workers and the ASC
The ASC should be available to provide support if needed, for a worker who has reported a safeguarding concern. Likewise the trustees should be available to provide support for the ASC if required, in relation to safeguarding issues.
4. Safeguarding concerns about workers
4.1 All workers have a duty to report any safeguarding concerns they have about colleagues who may be involved in abuse or harm, to the ASC. In the absence of the ASC, or if an allegation was made concerning the ASC, then a report should be made to the deputy ASC.
4.2 The ASC or deputy ASC in consultation with the trustees will decide what action to take. This may include:
• the suspension of the worker.
• a referral of the allegations to a Health and Social Care Trust or the Police Service for Northern Ireland for investigation.
4.3 No internal procedure such as a disciplinary investigation will be initiated until after the investigation of abuse or when the leading authority advises it is appropriate.
4.4 The Northern Ireland Charity Commission should be advised of the incident in accordance with their Serious Incident Reporting Guidance.
4.5 Disclosure and Barring Service (DBS) referral
Following investigations, it is a legal requirement that a referral must be made to the DBS when:
the organisation has withdrawn permission for an individual to work with adults at risk of harm (or would have done so had that individual not resigned, retired, been made redundant or been transferred into another position)
the organisation believes the individual has engaged in activity that causes concern for the safeguarding of adults at risk of harm
there is harm or risk of harm to adults at risk of harm
an individual has received a caution or a conviction for a relevant offence.
4.6 Workers who are barred
Workers under investigation or reported to DBS will be suspended from regulated activities (if applicable) pending the outcome of the investigation.
4.7 When a worker is barred they may no longer be involved in any regulated activities. It is a legal offence for the organisation to allow them to continue working in such a role.
5. Monitoring and reporting
5.1 The ASC will ensure that all records are kept electronically and stored safely in the safeguarding casework drive and inform the trustees of the file number of any concern reported to a Health and Social Care Trust, the PSNI or any other statutory body.
5.2 The ASC will complete any required annual reporting under the Health and Social Care Board Northern Ireland Adult Safeguarding Partnership Adult Safeguarding Operational Procedures.
5.3 Monitoring information which is anonymous will be kept indefinitely. Individual records which include sensitive personal data will be kept securely indefinitely.
5.4 The trustees will carry out regular reviews of safeguarding incident reports; looking at the number of reports, their source and the outcomes from each.
Relevant legislation
• Human Rights Act 1998
• Safeguarding Adults - National Framework of Standards 2005
• Safeguarding Vulnerable Groups Order NI 2007
• Protection of Freedoms Act 2012
• The Northern Ireland Adult Safeguarding Prevention and Protection in Partnership Policy Document 2015
Appendix A
Indicators of abuse
Indicators of physical abuse or harm
• A history of unexplained falls, cuts or minor injuries
• Bruising on soft parts of the body; crusted as if from repeated striking, in well protected areas not normally prone to injury such as thighs, or inside upper arm
• Finger marks
• Burns of an unusual kind or in an unusual place
• Injuries shaped like an object
• Injuries to head or face
• A reluctance to seek medical or other help
• Frequent attendance at hospital accident and emergency department
Indicators of sexual abuse or harm
• Withdrawal, choosing to be alone
• Explicit or untypical sexual language or behaviour
• Self inflicted injuries
• Self neglect
Indicators of psychological/emotional abuse or harm
• Change in appetite/unusual weight loss or gain
• Inability to sleep
• Low self esteem
• Confusion, fearfulness, agitation
• Unexplained uneasiness, particularly in the presence of particular people
• Becoming withdrawn
Indicators of financial or material abuse or harm
• Unexplained or sudden inability to pay bills
• Unexplained or sudden withdrawal from accounts
• Large withdrawals from accounts
• Inconsistency between standard of living and income
Indicators of institutional or organisational abuse or harm
• Inflexible daily routines, e.g. set bedtimes/deliberate waking up
• Dirty clothing and bed linen
• Lack of personal clothing and possessions
• Inappropriate use of power, control, restriction or confinement
• Misuse of finances
• Failure to record incidents or concerns
• Lack of training, risk assessment, supervision or management
Indicators of neglect or acts of omission
• Inadequate physical care
• Frequent use of emergency or out of hours services in preference to mainstream services
Appendix B
Trustees responsible for safeguarding
• Ian Wilson
• Eric Wilkinson (chair of trustees)
• Gareth Smyth
Sight Loss Ministries’ Adult Safeguarding Champion (ASC) is:
Leonard Campbell (Services Coordinator)
Telephone: 075166 36741
Email: info@sightlossministries.org
Deputy ASC:
Ian Wilson
Telephone: 02891 463124
jiw52@hotmail.com
Appendix C
Legislation - Definitions for the Devolved Nations:
Adults with Care and Support Needs (England and Wales), Adults at Risk (Scotland and Northern Ireland) collectively known as Vulnerable Groups or Adults.
Scotland
"Adult" means a person aged 16 or over. (with some exceptions, see Section 21 of Scotland’s National Guidance for Child Protection 2014). “Adults at risk” are adults who:
• are unable to safeguard their own well-being, property, rights or other interests,
• are at risk of harm, and because they are affected by disability, mental disorder, illness or physical or mental infirmity, are more vulnerable to being harmed than adults who are not so affected.
And if:
another person's conduct is causing (or is likely to cause) the adult to be harmed, or the adult is engaging (or is likely to engage) in conduct which causes (or is likely to cause) self-harm.
And that:
• any intervention must provide benefit to the adult,
• that this benefit could not have reasonably achieved without intervention and
• that any intervention is the least restrictive option to the adult's freedom
And must have due regard to the following:
• the wishes of the adult
• the views of others
• the importance of the adult participating as fully as possible
• that the adult is not treated less favourably
• the adult’s abilities, background and characteristics
England and Wales
The Care Act 2014 Central to the Act is the concept of wellbeing and a duty to consider the physical, mental and emotional wellbeing of the individual needing care and to provide preventative services to maintain people’s health. Key features of the Act include:
• Carers having rights to assessment and to support to meet their eligible needs.
• Being Person Centred and having choice and control.
The Care Act 2014 defines who might need to be safeguarded as anyone who is 18 years or over who:
• has needs for care and support (whether or not the local authority is meeting
any of those needs and regardless of whether the adult lacks mental capacity or not) and;
• is experiencing, or at risk of, abuse or neglect; and
• as a result of those care and support needs is unable to protect themselves from either the risk of, or the experience of abuse or neglect.
Where someone is 18 or over but is still receiving children’s services and a
safeguarding issue is raised, the matter should be dealt with through adult
safeguarding arrangements.
However, the level of needs is not relevant, and the young adult does not need to have eligible needs for care and support under the Care Act, or be receiving any particular service from the local authority, in order for the safeguarding duties to apply – so long as the conditions set out in the bullet points above are met.
The statutory guidance in England and Wales for Adults with Care and Support Needs enshrines the six principles of safeguarding:
1. Empowerment - presumption of person led decisions and informed consent
2. Prevention - it is better to take action before harm occurs
3. Proportionality - proportionate and least intrusive response appropriate to the risk presented
4. Protection - support and representation for those in greatest need
5. Partnerships - local solutions through services working with their communities
6. Accountability - accountability and transparency in delivering safeguarding.
Social Services and Well-being (Wales) Act 2014
Date of last review: 29th October 2024