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Safeguarding Adults Policy

This document was prepared and reviewed by the safeguarding leads of the organisation. Reviewed February 2024

To be reviewed in February 2025

This policy applies to all Switchback staff members and forms part of your employment contract. Switchback has a safeguarding adult’s policy, so that staff are aware of and understand what safeguarding means, how to identify a safeguarding issue and how to report it.

Introduction & Purpose

Switchback is committed to Safeguarding Adults in line with national legislation and relevant national and local guidelines. We will safeguard adults by ensuring that our services are delivered in a way which keeps all adults safe.

Switchback is committed to creating a culture of zero-tolerance of harm to adults which necessitates: the recognition of adults who may be at risk and the circumstances which may increase risk; knowing how adult abuse, exploitation or neglect manifests itself; and being willing to report safeguarding concerns.

Switchback is committed to best safeguarding practice and to uphold the rights of all adults to live a life free from harm from abuse, exploitation and neglect.

The purpose of this policy is to demonstrate our commitment to safeguarding adults and to ensure that everyone involved in Switchback is aware of:

  • The legislation, policy and procedures for safeguarding adults.
  • Their role and responsibility for safeguarding adults.
  • What to do or who to speak to if they have a concern relating to the welfare or wellbeing of an adult within the organisationThis policy applies to all Switchback staff, including employees, consultants, independent contractors and agency workers, whether on a temporary or permanent basis. It also applies to all volunteers, including Trustees.

Policy Statement

Switchback believes everyone has the right to live free from abuse or neglect regardless of age, ability or disability, sex, race, religion, ethnic origin, sexual orientation, marital or gender status.

Switchback is committed to creating and maintaining a safe and positive environment and an open, listening culture where people feel able to share concerns without fear of retribution.

Switchback acknowledges that safeguarding is everybody’s responsibility and is committed to prevent abuse and neglect through safeguarding the welfare of all adults involved.

Switchback recognises that every individual participating in the Switchback programme has the right to do so in a safe and secure environment. This policy covers disclosure and safeguarding for everyone Switchback works with including all Trainees (someone who is taken onto case load – stage C). Switchback Trainees are not by virtue of being part of the programme, vulnerable adults, but we recognise that our caseload may from time to time include vulnerable adults.

This policy includes Switchback’s procedures for identifying and responding to concerns regarding the safeguarding of vulnerable adults. Actions taken by Switchback will be consistent with the principles of adult safeguarding ensuring that any action taken is prompt, proportionate and that it includes and respects the voice of the adult concerned.

Legislation (supporting information)

Safeguarding Adults is covered by the following legislation:

  • Human Rights Act 1998
  • Equalities Act 2010
  • The Care Act 2014
  • Public Disclosure (Whistleblowing) Act 1998
  • Mental Capacity Act 2005
  • The Data Protection Act 2018
  • General Data Protection Regulations 2018

The Definition of a Vulnerable Adult (supporting information)

The Care Act 2014 defines a Vulnerable Adult as:

  • An individual aged 18 years and over who:
    1. has needs for care and support (whether or not the local authority is meeting any of those needs) AND;
    2. is experiencing, or at risk of, abuse or neglect, AND;
    3. 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.

Switchback recognises that as well as the above definition, a vulnerable adult may also include those in vulnerable situations such as victims of domestic abuse, hate crime and anti-social abuse.

Abuse and Neglect (supporting information)

Abuse is a violation of an individual’s human and civil rights by another person or persons. It can occur in any relationship and may result in significant harm to, or exploitation of, the person subjected to it. Any or all of the types of abuse detailed below may be perpetrated as the result of deliberate intent, negligence, omission or ignorance.

The Care Act 2014 defines categories of adult abuse and harm as follows:

  • Physical
  • Sexual
  • Emotional/Psychological/Mental
  • Neglect and acts of Omission
  • Financial or material abuse
  • Discriminatory
  • Organisational / Institutional
  • Self-neglect
  • Domestic Abuse (including coercive control)
  • Modern slavery

There are different types and patterns of abuse and neglect and different circumstances in which they may take place.

Abuse can take place in any relationship and there are many contexts in which abuse might take place, e.g. Institutional abuse, Domestic Abuse, Forced Marriage, Human Trafficking, Modern Slavery, Sexual Exploitation, County Lines, Radicalisation, Hate Crime, Mate Crime, Cyber bullying, Scams.

Abuse or neglect could be carried out by:

  • A spouse, partner or family member
  • Neighbours or residents
  • Friends, acquaintances or strangers
  • People who deliberately exploit adults they perceive as vulnerable
  • Paid staff, professionals or volunteers providing care and support

Often the perpetrator is known to the adult and may be in a position of trust and/or power.

Signs and Indicators of Abuse and Neglect (supporting information)

All members of staff should be aware that abuse, neglect and safeguarding issues are rarely stand-alone events that can be covered by one definition or label. In most cases multiple issues will overlap with one another. Individual indicators will rarely, in isolation, provide conclusive evidence of abuse. They should be viewed as part of a jigsaw, and each small piece of information will help decisions about how to proceed. It is very important that members of staff report concerns – they do not need ‘absolute proof’ that the person is at risk.

An adult may confide to a member of staff, volunteer or another participant that they are experiencing abuse inside or outside of the organisation’s setting. Similarly, others may suspect that this is the case.

There are many signs and indicators that may suggest someone is being abused or neglected. There may be other explanations, but they should not be ignored. The signs and symptoms include but are not limited to:

  • Physical abuse signs:
    • A history of unexplained falls or minor injuries
    • Bruising in well protected areas, or clustered from repeated striking
    • Finger marks
    • Burns of unusual location or type
    • Injuries found at different states of healing
    • Injury shape similar to an object
    • Weight loss due to malnutrition, or rapid weight gain
  • Sexual abuse signs:
    • Disclosure or partial disclosure (use of phrases such as ‘It’s a secret’)
    • Disturbed behaviour e.g. depression, sudden withdrawal from activities
    • Loss of appetite or difficulty in keeping food down
    • Behaviour of others towards the vulnerable adult
  • Psychological/emotional signs:
    • Isolation
    • Unkempt, unwashed, smell
    • Over meticulous
    • Inappropriately dressed
    • Withdrawn, agitated, anxious or not wanting to be touched
    • Change in appetite
    • Tearfulness
    • Unexplained paranoia, or excessive fears
    • Confusion
  • Neglect signs:
    • Poor physical condition
    • Clothing in poor condition
    • Poor personal hygiene
  • Financial or material signs:
    • Unexplained or sudden inability to pay bills
    • Disparity between assets and satisfactory living conditions
  • Extraordinary interest by family members and other people in the vulnerable person’s assets

Information Sharing (procedures)

Information about concerns of abuse will likely include personal data. Records relating to safeguarding concerns must be accurate, relevant and stored confidentially.

Sharing information, with the right people, is central to good practice in safeguarding adults. However, information sharing must only ever be with those with a ‘need to know’. This does NOT automatically include the persons spouse, partner, adult, child, unpaid or paid carer. Information should only be shared with family and friends and/or carers with the consent of the adult or if the adult does not have capacity to make that decision and family/ friends/ carers need to know, in order to help keep the person safe.

There are many situations in which it is perfectly legal to share information about adult safeguarding concerns outside the organisation. Importantly, personal information can be shared with the consent of the adult concerned. However, the adult may not always want information to be shared. This may be because they fear repercussions from the person causing harm or are scared that they will lose control of their situation to statutory bodies or because they feel shame. Their wishes should be respected unless there are over-riding reasons for sharing information.

The circumstances when we need to share information without the adult’s consent include those where:

  • it is not safe to contact the adult to gain their consent – i.e. it might put them or the person making contact at further risk.
  • you believe they or someone else is at risk, including children.
  • you believe the adult is being coerced or is under duress.
  • it is necessary to contact the police to prevent a crime, or to report that a serious crime has been committed.
  • the adult does not have mental capacity to consent to information being shared about them.
  • the person causing harm has care and support needs.

When information is shared without the consent of the adult this must be explained to them, when it is safe to do so, and any further actions should still fully include them.

Any decision to share or not to share information with an external person or organisation must be recorded together with the reasons to share or not share information.

Ministry of Justice:

  • Switchback have a robust service level agreement with the Ministry of Justice outlining terms under which we share relevant data. Any information about serving prisoners is sent via secure CJSM email accounts or if in hard copy form, must be anonymised.
  • A written record should be kept about any concern regarding a vulnerable adult. This must include details of the person involved, the nature of the concern and the actions taken.
  • All records must be securely and confidentially filed.
  • Switchback’s database is set up to automatically alert any users of concerning situations or disclosures,including anything that makes the Trainee vulnerable.

Recording and Logging Information (procedures)

For any safeguarding concern or incident, a safeguarding form will need to be filled out in detail. You can find a blank copy in the shared area, in the ‘Area for all Staff’ folder. There are instructions and guidelines in the form on how to fill these out and what information is required but ask your line manager if you are still unsure.

All completed forms need to be sent to your line manager, with the head of your department cc’d in (if you aren’t directly line managed by them). Forms must be kept up to date regularly with ongoing actions as and when, and the form re-sent to your line manager for sign off each time. The head of the department will be saving the forms in a secure folder that will only be accessible to the leadership team and HR (‘HR confidential’ folder in the shared area), for confidentiality reasons. You will have to be mindful deleting updated forms and not saving them in shared folders.

The Leadership Team review Safeguarding incidents on a monthly basis and are specifically looking to identify any recurring themes so that they can be addressed where required.

A summary of safeguarding incidents is reviewed by the Board of Trustees at each Board meeting with new incidents and actions taken highlighted.

The trustees are mindful of their reporting obligations to the Charity Commission in respect of Serious Incident Reporting. They are aware of the Government guidance on handling safeguarding allegations.

Prison specific

For any safeguarding concerns witnessed in prison, it is important that it is reported directly to the prison through an intelligence report. A Switchback safeguarding form will also have to be completed, and your line manager and Head of Delivery notified. In some cases where applicable, it will be appropriate to report any incidences directly to the Prison Governor. The Head of Delivery will be able to support you with this.

General good practice

Successful safeguarding requires diligent record keeping. It is good practice to update data systems with as much detail as possible, keep email correspondence with relevant services (if any are involved) and to keep emails in a chain if possible. This should support you in accessing and sharing information (if appropriate) in a quick, effective manner.

For Trainees, it is also good practice to know and log (on the database) who their GP practice is, so that we can easily and quickly report any mental or physical health concerns.

Reporting Safeguarding Concerns (procedures)

If a crime is in progress, or an individual is in immediate danger, call the police on 999.

Trainees:

  • Safeguarding concerns about a Trainee should be escalated to your line manager and Head of Delivery.
  • If a Trainee is presenting concerning behaviour, i.e. threatening language, suicide ideation or likelihood of harm to themselves or others, this should be immediately escalated to your line manager and Head of Delivery, as well as statutory services (NHS, police and probation if applicable). Your line manager and Head of Delivery will be able to support you with this.
  • If a Trainee is already supported by mental health teams and raises the above concerns, escalate to your line manager and Head of Delivery who will then contact and consult with the relevant practitioners about the concerning behaviours.

Staff and Others:

  • Safeguarding concerns about a member of staff and anyone other than a trainee should be escalated to your line manager and Director of Finance & Operations.If the Head of Delivery and Director of Finance & Operations are not available, then you should escalate to the CEO or other member of the Leadership team.

Responding to disclosures of abuse and safeguarding concerns:

DO

  • Make sure the individual is safe.
  • Assess whether emergency services are required and if needed call them.
  • Listen and offer support and reassurance.
  • Ascertain and establish the basic facts.
  • Make careful notes and obtain agreement on them.
  • Ensure notation of dates, time and persons present are correct and agreed.
  • Take all necessary precautions to preserve forensic evidence.
  • Explain areas of confidentiality; immediately speak to your manager for support and guidance
  • Explain the procedure to the individual making the allegation.

DON’T

  • Confront the alleged abuser.
  • Be judgmental or voice your own opinion.
  • Be dismissive of the concern.
  • Investigate or interview beyond that which is necessary to establish the basic facts.
  • Disturb or destroy possible forensic evidence.
  • Consult with persons not directly involved with the situation.
  • Ask leading questions.
  • Assume information.
  • Make promises.
  • Elaborate in your notes.

It is important to remember that the person who first encounters a case of alleged abuse is not responsible for deciding whether abuse has occurred. This is a task for the professional adult protection agencies, following a referral from Switchback.

Switchback responds swiftly and appropriately to all Safeguarding concerns or allegations of abuse and/or neglect in a way that:

  • respects and empowers the individual.
  • is supportive of Switchback staff.

It is not the responsibility of staff to determine if a safeguarding concern or allegation is founded; rather, they are responsible for reporting them in accordance with this policy.

Safeguarding concerns or allegations that are anonymous or historical (e.g. relating to unnamed people or an incident that allegedly happened some time ago) should not be ignored.

All incidents, concerns or allegations must be immediately reported as stated above and appropriate referrals to adult protection agencies may be made.

If you are in any doubt whether a safeguarding incident has taken place always complete a Safeguarding Incident form and follow the procedures above. It is always better to report than to not if you are not sure.

Switchback Leads (procedures)

The Safeguarding leads within Switchback are:

  • Head of Delivery
  • Director of Finance and Operation

The Board Safeguarding leads are:

  • Nicola Hurley
  • Jasmine Ashely-Tagoe

Local Safeguarding Board:

The local adult safeguarding board for Switchback is Tower Hamlets however there are local safeguarding boards for each London borough.

Code of Conduct (your responsibility)

It is anticipated that staff – even when new to Switchback – would have a clear concept of acceptable standards of professional behaviour. This section is primarily to help clarify understanding; it is not exhaustive.

It is important that Switchback staff must:

  • ensure everyone is treated equally and with respect and dignity
  • not accept or condone bullying or any inappropriate verbal or physical behaviour (taking immediate action to stop it and/or reporting it to a member of the Leadership Team)
  • provide a positive example for dealing with other people
  • bring to attention any concerns for an individual’s wellbeing at the earliest opportunity.
  • use words and actions that focus on positive personal development.
  • react calmly and in a considered manner to all situations.
  • be aware of your position as a role model and demonstrate best professional behaviour, remembering that someone else might misinterpret your actions, no matter how well intentioned.
  • maintain records about any Safeguarding concerns.
  • ask a more experienced member of staff if you do not understand something or want to know something and remember to give guidance and support to more inexperienced staff.
  • consider what clothing is appropriate to wear when representing Switchback particularly Switchback Mentors working closely with Trainees, see Working with Trainees Policy.

Switchback staff must not:

  • engage in inappropriate, intimate or sexual relationships with any Trainee. This constitutes serious misconduct and would be dealt with under Disciplinary, grievance, complaints and redundancy Policy.
  • promise any Trainee money or give them money (including loans) without permission from your line manager.
  • take money or gifts from any Trainee without permission from your line manager.
  • tell Trainees your home address or personal phone number or the address or personal phone number of any other member of staff or Trainee (including mobile phone numbers)
  • communicate with a Trainee through social media, including but not limited to twitter, Facebook, LinkedIn, or add a Trainee as a ‘friend’, ‘contact’ or similar, or accept an equivalent invitation over social media from a Trainee. We recommend that staff ensure social media accounts are made ‘private’.
  • give a Trainee permission to take something away from Switchback without first checking with your line manager.
  • make suggestive, offensive, inappropriate or derogatory remarks or gestures.
  • leave dealing with a concern to someone else. If you are concerned, report it.