Safeguarding

1. Purpose

1.1) To protect the people we support/members' right to live in safety, free from abuse and neglect.

1.2) To ensure that the relevant Local Safeguarding Policy and Procedure is understood by all relevant staff at Kisharon Langdon and that their safeguarding procedures dovetail with the service's policy and procedure.

1.3) To set out the key arrangements and systems that Kisharon Langdon has in place for safeguarding and promoting the wellbeing of adults at risk and to ensure compliance with local policies and procedures.

1.4) To have a clear, well-publicised policy of zero-tolerance of abuse within Kisharon Langdon.

2. Objectives

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

2.2) To manage the safety and wellbeing of adults in line with the six principles of safeguarding.

2.3) To identify lessons to be learned from cases where adults have experienced abuse or neglect.

2.4) Kisharon Langdon aims to support and empower each adult to make choices, to have control over how they want to live their own lives and to prevent abuse and neglect occurring in the future which is a key underpinning principle of Making Safeguarding Personal (MSP). Kisharon Langdon intends to take this approach with all safeguarding concerns.

3. Policy

3.1 The Care Act 2014

In England, The Care Act 2014, sections 42–46, sets out clear legal frameworks for local authorities and other relevant agencies of how to protect adults at risk of abuse and neglect. The Department of Health and Care and Support Guidance issued under the Care Act outlines the duties these place on all relevant agencies.

3.2 Safeguarding duties apply to an adult who:

• Has needs for care and support (whether or not the local authority is meeting any of those needs)
• Is experiencing, or at risk of, abuse or neglect
• As a result of those care and support needs is unable to protect themselves from either the risk of, or the experience of, abuse and neglect

3.3 What is Safeguarding

Kisharon Langdon recognises the definition of Safeguarding as the actions taken to keep people we support/members safe from harm and neglect whilst making sure that the adult's wellbeing is promoted, including, where appropriate, due regard to their views, wishes, feelings and beliefs in deciding on any action. This must recognise that adults sometimes have complex interpersonal relationships and may be ambivalent, unclear or unrealistic about their personal circumstances.

Kisharon Langdon and its employees understand the importance of working together in partnership to make sure individual people we support/members are safe through our collective and proactive approach to safeguarding.

Organisations should always promote the adult's wellbeing in their safeguarding arrangements. People have complex lives and being safe is only one of the things they want for themselves. Professionals should work with the adult to establish what being safe means to them and how this can best be achieved. Professionals should not be advocating "safety" measures which do not take account of individual wellbeing as defined in chapter 1 of the Care and Support Statutory Guidance issued by the Department of Health.

3.4 What Constitutes Abuse?

Kisharon Langdon employees understand that the people we support/members can be extremely vulnerable to abuse and neglect, especially if they have care and support needs. Abuse is a violation of an individual's human or civil right by any other person. It is where someone does something to another person, or to themselves, which puts them at risk of harm and impacts on their health and wellbeing. Abuse can have a damaging effect on the health and wellbeing of people we support/members. These effects may be experienced in the short and long term and can sometimes be lifelong.

3.5) The signs of abuse are not always obvious, and a victim of abuse may not tell anyone what is happening to them — sometimes they may not even be aware they are being abused. The robust governance processes at Kisharon Langdon will make sure that staff working for and on behalf of them recognise and respond to the main forms of abuse which are set out in the Care Act 2014 Statutory Guidance Chapter 14, which is not an exhaustive list but an illustration as to the sort of behaviour that could give rise to a safeguarding concern:

• Physical abuse — including assault, hitting, slapping, pushing, misuse of medication, restraint or inappropriate physical sanctions.
• Domestic violence — including psychological, physical, sexual, financial, emotional abuse; so called 'honour' based violence.
• Sexual abuse — including rape, indecent exposure, sexual harassment, inappropriate looking or touching, sexual teasing or innuendo, sexual photography, subjection to pornography or witnessing sexual acts, indecent exposure and sexual assault or sexual acts to which the adult has not consented or was pressured into consenting.
• Psychological abuse — including emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, cyber bullying, isolation or unreasonable and unjustified withdrawal of services or supportive networks.
• Financial or material abuse — including theft, fraud, internet scamming, coercion in relation to an adult's financial affairs or arrangements, including in connection with wills, property, inheritance or financial transactions, or the misuse or misappropriation of property, possessions or benefits.
• Modern slavery — encompasses slavery, human trafficking, forced labour and domestic servitude. Traffickers and slave masters use whatever means they have at their disposal to coerce, deceive and force individuals into a life of abuse, servitude and inhumane treatment.
• Discriminatory abuse — including forms of harassment, slurs or similar treatment; because of race, gender and gender identity, age, disability, sexual orientation or religion.
• Organisational abuse — including neglect and poor care practice within an institution or specific care setting such as a hospital or care home, for example, or in relation to care provided in one's own home. This may range from one off incidents to on-going ill-treatment. It can be through neglect or poor professional practice as a result of the structure, policies, processes and practices within an organisation.
• Neglect and acts of omission — including ignoring medical, emotional or physical care needs, failure to provide access to appropriate health, care and support or educational services, the withholding of the necessities of life, such as medication, adequate nutrition and heating.
• Self-neglect — this covers a wide range of behaviour neglecting to care for one's personal hygiene, health or surroundings and includes behaviour such as hoarding.

3.6) Incidents of abuse may be one-off or multiple and affect one person or more. Professionals and others should look beyond single incidents or individuals to identify patterns of harm, just as the Care Quality Commission, as the regulator of service quality, does when it looks at the quality of care in health and care services.

3.7) Repeated instances of poor care may be an indication of more serious problems and of what we now describe as organisational abuse. In order to see these patterns it is important that information is recorded and appropriately shared.

3.8 Patterns of abuse vary and include:

• Serial abusing in which the perpetrator seeks out and 'grooms' individuals. Sexual abuse sometimes falls into this pattern as do some forms of financial abuse.
• Long-term abuse in the context of an ongoing family relationship such as domestic violence between spouses or generations or persistent psychological abuse.
• Opportunistic abuse such as theft occurring because money or jewellery has been left lying around.

3.9) Everybody has the right to live a life that is free from harm and abuse. Kisharon Langdon recognises that safeguarding adults at risk of abuse or neglect is everybody's business. Kisharon Langdon aims to ensure that all adults at risk of abuse or neglect are enabled to live and work, be cared for and supported in an environment free from abuse, harassment, violence or aggression. The safeguarding policies and procedures of Kisharon Langdon will dovetail with the Local Authority's multi-agency policy and procedures, which we understand take precedence over those of Kisharon Langdon. Kisharon Langdon will ensure that the Local Authorities policies and procedures are reflected within its own policy and procedure and that this is shared with all staff and is accessible and available for staff to follow.

3.10) We aim to provide services that will be appropriate to the adult at risk and not discriminate because of disability, age, gender, sexual orientation, race, religion, culture, or lifestyle. We will make every effort to enable people we support/members to express their wishes and make their own decisions to the best of their ability, recognising that such self-determination may well involve risk. We will work with people we support/members and others involved in their support, to ensure they receive the support and protection they may require; that they are listened to and treated with respect (including their property, possessions and personal information) and that they are treated with compassion and dignity.

3.11 The six principles of the Care Act 2014

Kisharon Langdon will follow the six principles as set out in guidance to the Care Act 2014 and this will inform practice with all people we support/members:

• Empowerment — People being supported and encouraged to make their own decisions and informed consent. "I am asked what I want from the safeguarding process, and these directly inform what happens."
• Prevention — It is better to take action before harm occurs. "I receive clear and simple information about what abuse is, how to recognise the signs and what I can do to seek help."
• Proportionality — The least intrusive response appropriate to the risk presented. "I am sure that the professionals will work in my interest, as I see them, and they will only get involved as much as needed."
• Protection — Support and representation for those in greatest need. "I get help and support to report abuse and neglect. I get help so that I can take part in the safeguarding process to the extent to which I want."
• Partnership — Local solutions through services working with their communities. "I know that staff treat any personal or sensitive information in confidence, only sharing what is helpful and necessary. I am confident that professionals will work together and with me to get the best result for me."
• Accountability — Accountability and transparency in delivering safeguarding. "I understand the role of everyone involved in my life and so do they."

3.12) Kisharon Langdon understands the importance of working collaboratively to ensure that:

• The needs and interests of adults at risk are always respected and upheld
• The human rights of adults at risk are respected and upheld
• A proportionate, timely, professional and ethical response is made to any adult at risk who may be experiencing abuse
• All decisions and actions are taken in line with the Mental Capacity Act 2005

Each adult at risk maintains:

• Choice and control
• Safety
• Health
• Quality of life
• Dignity and respect

3.13) Kisharon Langdon is committed to the principles of 'Making Safeguarding Personal' and aims to ensure that safeguarding is person-led and focused on the outcomes that people we support/members want to achieve. We will engage people we support/members in a conversation about how best to respond to their safeguarding situation in a timely way that enhances involvement, choice and control as well as improving quality of life, wellbeing and safety.

3.14 Service/Registered Manager's Responsibilities

• To establish the facts about the circumstances giving rise for concern
• To identify sources and level of risk
• To ensure that information is recorded and that the Local Authority's Adult Safeguarding Team is contacted to inform them of the concern or harm
• If a person we support/member is at immediate risk of harm: where appropriate, the Registered Manager in Supported Living (or for other services the Service Manager after consultation with the Director of Operations), will contact the Police and/or other emergency services, and CQC will be notified if it is a safeguarding concern in Supported Living
• In all cases of alleged harm to people we support/members, there will be early consultation between the Director of Operations and either The Registered Manager for Supported Living, or with the Manager for Day Opportunities, and with the Local Authority, and with the Police if appropriate, to determine whether or not a joint investigation is required
• The wishes of the person harmed will be considered whenever possible. This may result in no legal action
• Documentation of any incidents of harm in the people we support/members' file and using body maps to record any injuries
• Follow the Local Authority policy guidelines where applicable
• Report any incidents of abuse to the relevant parties
• Work with multi-agencies
• Advise and support staff
• Ensure staff are trained to enhance knowledge
• Actively promote the Whistleblowing policies

3.15 Staff Responsibilities

• To be able to recognise and report incidences of harm
• To report concerns of harm or poor practice that may lead to harm
• To remain up to date with relevant training — as appropriate for their role
• To follow the policy and procedures
• To know how and when to use the Whistleblowing procedures
• Support staff only: to understand the Mental Capacity Act and how to apply it in practice

3.16 General Principles

• We will have a robust safer recruitment policy in place to make sure that our staff are fit to work with adults at risk and are compliant with national, safe recruitment and employment practices, including the requirements of the Disclosure and Barring Service
• A named safeguarding lead will be in place who is responsible for embedding safeguarding practices and improving practice in line with national and local developments
• Any staff member who knows or believes that harm is occurring will report it to their line manager as quickly as possible, or the service manager. If they feel they cannot follow the regular reporting procedure, they must use the Whistleblowing process
• Kisharon Langdon will work collaboratively with other agencies, including liaison in relation to the investigation of allegations and will ensure its procedures dovetail with the Local Authority multi-agency procedures
• Kisharon Langdon will use incident reporting, root cause analysis, lessons learned and auditing to determine themes to improve support practice
• We will have a learning and development strategy which specifically addresses adult safeguarding. We will provide training on the identification and reporting of harm, as well as training on the required standards in relation to procedures and processes should something need to be reported
• Kisharon Langdon recognises its responsibilities in relation to confidentiality and will share information appropriately
• We will have zero tolerance to harm
• We will work in partnership with other agencies to ensure that concerns or allegations of abuse are appropriately referred for investigation to the most appropriate agency
• We will ensure that any action that is taken is assessed, proportionate and reflective of the risk presented to the people who use the services
• We will report any incidents in line with our regulatory requirements
• Kisharon Langdon will adhere to the Code of Conduct for Support Workers
• There is a clear, well-publicised Whistleblowing Policy and Procedure in place that has been shared with staff

3.17 Prevention — Providing information to support people we support/members

Kisharon Langdon will support people we support/members by providing accessible, easy to understand information on what abuse is and what signs to look out for. This will include people we support/members' rights and how to get help and support if they need it through the Care Plan process. We will comply with the Accessible Information Standards.

All people we support/members will receive a copy of the Guide for People we support/members, have access to the Complaints, Suggestions and Compliments Policy and Procedure and be given information on how to escalate any concerns to the Commissioner, CQC, advocacy or Local Government and Social Care Ombudsman should they not be satisfied with the approach taken by Kisharon Langdon.

3.18 Prevention — Raising awareness

Support staff will need to be trained and understand the different patterns and behaviours of abuse as detailed in the Care Act Chapter 14 and Kisharon Langdon will ensure that it is able to respond appropriately.

Kisharon Langdon will ensure that all staff are aware of the Whistleblowing Policy and Procedure.

During induction training, support staff will complete the "Understanding Abuse" workbook as part of the Care Certificate where applicable.

4. Procedures

4.1) It is important to understand the circumstances of abuse, including the wider context such as whether others may be at risk of abuse, whether there is any emerging pattern of abuse, whether others have witnessed abuse and the role of family members and paid staff or professionals.

4.2 Responding to Disclosure, Suspicion or Witnessing of Abuse

Where an adult at risk discloses or discusses potential abuse or harm, support staff must be able to:

• Recognise: Identify that the adult at risk 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
• Report in a timely manner to the appropriate people and organisations

Responding to a Disclosure — Remember you are not investigating. Do:

• Stay calm and try not to show shock
• Listen very carefully
• Be sympathetic
• Be aware of the possibility that medical evidence might be needed
• Tell the person that they did the right thing in telling you, that you are treating the information seriously, and that it was not their fault

Explain that you must tell your line manager, and, with their consent, your manager will contact the Local Authority Safeguarding Adults Team and/or the Police where appropriate. For Supported Living — the Registered Manager must be informed; for all other adult services — the Director of Operations must be informed. Kisharon Langdon will, in specific circumstances, need to contact the Local Authority Adult Safeguarding Team without their consent but their wishes will be made clear throughout.

4.3 Responding to Abuse or Neglect — What to do

Kisharon Langdon must ensure that staff:

• Address any immediate safety and protection needs
• Assess any risks and take steps to ensure that the adult is in no immediate danger
• Where appropriate, call 999 for the emergency services if there is a medical emergency, other danger to life or risk of imminent injury, or if a crime is in progress
• Call for medical assistance from the GP or other primary healthcare service if there is a concern about the adult's need for medical assistance or advice. Support Workers can call NHS 111 for medical help or advice when the situation is not life-threatening or is out of hours
• Ask whether the adult wants the Support Worker to arrange for someone they feel comfortable with to stay with them
• Consider if there are other adults or children with care and support needs who are at risk of harm and take appropriate steps to protect them
• Where appropriate, a senior manager will support the adult to contact the Police if a crime has been or may have been committed
• The Support Worker will contact their line manager as soon as possible to inform them of the incident or concern
• Supported Living — the Registered Manager will be informed and contacted as soon as possible. Other adult services — the Director of Operations will be informed as soon as possible

4.4) Decision-Making pre-referral to the Local Authority Adult Safeguarding Team. The Registered Manager or the Safeguarding Lead will usually lead on decision-making. Where such support is unavailable, consultation with another more senior member of staff will take place. In the event that these are unavailable, advice must be taken from the Local Authority. Staff must also take action without the immediate authority of a line manager:

• If discussion with the manager would involve delay in an apparently high-risk situation
• If the person has raised concerns with their line manager and service manager and they have not taken appropriate action (whistleblowing)

Kisharon Langdon will ensure that support staff are aware of the Local Authority reporting procedures and timescales for raising adult safeguarding concerns.

4.5 Referral to the Local Authority Adult Safeguarding Team

Kisharon Langdon must ensure that the Local Authority Safeguarding Adult referral process is followed and must collect the following information to assist with the referral:

• Demographic and contact details for the adult at risk, the person who raised the concern and for any other relevant individual, specifically Support Workers and next of kin
• Basic facts, focusing on whether or not the person has care and support needs including communication and ongoing health needs
• Factual details of what the concern is about; what, when, who, where?
• Immediate risks and action taken to address risk
• Preferred method of communication
• If reported as a crime, details of which police station/officer, crime reference number, etc.
• Whether the adult at risk has any cognitive impairment which may impede their ability to protect themselves
• Any information on the person alleged to have caused harm
• Wishes and views of the adult at risk, in particular consent
• Advocacy involvement (includes family/friends)
• Information from other relevant organisations, for example, the CQC
• Any recent history (if known) about previous concerns of a similar nature or concerns raised about the same person, or someone within the same household
• Names of any staff involved

4.6 Documenting a Disclosure

Kisharon Langdon must ensure that staff:

• Make a note of what the person actually said, using their own words and phrases
• Describe the circumstance in which the disclosure came about
• Note the setting and anyone else who was there at the time
• When there are cuts, bruises or other marks on the skin, use a body map to indicate their location, noting the colour of any bruising
• Make sure the information written is factual
• Use a pen with black ink so that the report can be photocopied; try to keep writing clear
• Sign and date the report, noting the time and location
• Be aware that the report may be needed later as part of a legal action or disciplinary procedure

4.7 Informing the Relevant Inspectorate

• By law, Kisharon Langdon must notify the Care Quality Commission without unnecessary delay of incidents of abuse, as well as any incident which is reported to, or investigated by, the Police
• Kisharon Langdon must notify the CQC about abuse or alleged abuse involving a person(s) using the service, whether the person(s) is/are the victim(s), the abuser(s), or both
• Kisharon Langdon must also alert the relevant local safeguarding authority when notification is made to the CQC about abuse or alleged abuse
• The forms are available on the CQC website
• If a concern is received via the whistleblowing procedure, Kisharon Langdon must inform the Local Authority Safeguarding Team and the CQC

4.8 Strategy Meeting / Case Conference

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

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

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

4.9 Involve the people we support/members Concerned Throughout the Process

The process of the enquiry must be explained to the people we support/members in a way they will understand and their consent to proceed with the enquiry obtained, if possible.

Arrangements will be made to have a relative, friend or independent advocate present if the people we support/members so desire. The relative, friend or independent advocate must not be a person suspected of being in any way involved or implicated in the abuse.

A review of the people we support/member's Care Plan must be undertaken to ensure individualised support following the incident.

The people we support/members will be supported by the service to take part in the safeguarding process to the extent to which they wish, or are able to, having regard for their decisions and opinions. They must be kept informed of progress.

4.10 Desired Outcomes Identified by the Adult

The desired outcome by the adult at risk must be clarified and confirmed at the end of the conversation(s), to:

• Ensure that the outcome is achievable
• Manage any expectations that the adult at risk may have
• Give focus to the enquiry
• Staff will support adults at risk to think in terms of realistic outcomes but must not restrict or unduly influence the outcome that the adult would like. Outcomes must make a difference to risk and, at the same time, satisfy the person's desire for justice and enhance their wellbeing
• The adult's views, wishes and desired outcomes may change throughout the course of the enquiry process
• There must be an ongoing dialogue and conversation with the adult to ensure that their views and wishes are gained as the process continues and enquiries re-planned if the adult changes their views
• The people we support/members will be informed of the outcome of any investigation, but guidance will be sought from the Local Authority Adult Safeguarding Team before any outcome is shared

4.11 Disclosure and Barring Service (DBS) Referral

There is a statutory requirement for providers of support to refer workers to the DBS for inclusion on the DBS Vetting and Barring scheme list if they consider that the person is guilty of misconduct such that a vulnerable adult was harmed or placed at risk of harm. This requirement covers both existing employees and those who leave their employment, and whose conduct comes to light at a later date. Please see the DBS/Disclosure Policy and Procedure for further procedures regarding initial employment and referral.

4.12 Consent

When reporting information that directly concerns the safety of an adult at risk of harm, consent from the people we support/members is not required. However, informing the people we support/members of your concerns and your referral is good practice unless it would put you or your colleagues at risk or it would put the adult at further risk. When reporting to a local authority allegations or concerns about an adult at risk of harm, the Local Authority must be informed whether the person we support/member is aware of the report. In reporting all suspected or confirmed cases of harm, an employee has a responsibility to act in the best interest of the people we support/members but still operate within the relevant legislation and the parameters of the codes and standards of their practice.

4.13 Confidentiality and Information Sharing

In seeking to share information for the purposes of protecting adults at risk, Kisharon Langdon is committed to the following principles:

• Personal information will be shared in a manner that is compliant with the statutory responsibilities of Kisharon Langdon
• Adults at risk will be fully informed about information that is recorded about them and as a general rule, be asked for their permission before information about them is shared with colleagues or another agency. However, there may be justifications to override this principle if the adult or others are at risk
• Staff will receive appropriate training on people we support/member's confidentiality and secure data sharing
• The principles of confidentiality designed to protect the management interests of Kisharon Langdon must never be allowed to conflict with those designed to promote the interests of the adult at risk
• Staff will follow Kisharon Langdon policies on UK GDPR, Data Protection, Confidentiality and comply with the Caldicott principles

4.14 Pressure Ulcers

This is not currently a high risk in our client group, but if/where there are individual exceptions to this they will be managed on a case-by-case basis, following local safeguarding reporting requirements with regards to pressure areas. Pressure ulcers are costly in terms of both people we support/members suffering and the use of resources. If the pressure ulcer is believed to have been caused by neglect, it must be reported as an adult safeguarding concern whether the pressure ulcer was acquired in a hospital, care setting or the people we support/member's own home. Where people we support/members are new to the service, any pressure ulcers must be documented on a body map and reported in line with safeguarding procedures. Treatment must also be sought from the GP.

4.15 Medication Errors

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

4.16 Abuse of Trust

• A relationship of trust is one in which one person is in a position of power or influence over the other person because of their work or the nature of their activity
• Where the person who is alleged to have caused the abuse or neglect has a relationship of trust with the adult at risk because they are a member of staff, a paid employee, a paid carer, a volunteer or a manager, Kisharon Langdon must invoke disciplinary procedures for employed staff as well as taking action in line with this policy
• Kisharon Langdon must ensure that a referral is made to the Disclosure and Barring Service if an employee is found to have caused harm to an individual
• If the person who is alleged to have caused the harm is a member of a recognised professional group, Kisharon Langdon must act under the relevant code of conduct for the profession as well as taking action under this policy
• Where the person alleged to have caused the harm or neglect is a volunteer or a member of a community group, Kisharon Langdon must work with adult social services to support any action under this policy
• Where the person alleged to have caused the harm is a neighbour, a member of the public, a stranger or a person who deliberately targets vulnerable people, the policy and procedures will be used to ensure that the adult at risk receives the services and support that they may need
• In all cases, issues of consent, confidentiality and information sharing must be considered

4.17 Allegations Against People who are Relatives or Friends

There is a clear difference between unintentional harm caused inadvertently by a relative or friend and a deliberate act of either harm or omission, in which case the same principles and responsibilities for reporting to the police apply. In cases where unintentional harm has occurred, this may be due to lack of knowledge or due to the fact that the relative's own physical or mental needs make them unable to care adequately for the adult at risk. The relative may also be an adult at risk. In this situation, the aim is to protect the adult from harm, work to support the relative to provide support and to help make changes in their behaviour in order to decrease the risk of further harm to the person they are caring for. A carer's assessment will consider several factors and a referral to the Local Authority will be made as part of the safeguarding process.

4.18 Whistleblowing

Whistleblowing is an important aspect of the support and protection of adults at risk of harm where staff are encouraged to share genuine concerns about a colleague's behaviour. Their behaviour may not be related to an adult at risk, but they may not be following the code of conduct or could be pushing boundaries beyond normal limits or displaying conduct which is a breach of the law, conduct which compromises health and safety or conduct which falls below established standards of practice with adults at risk. Kisharon Langdon has clear whistleblowing policies and procedures in place which staff are frequently reminded about and with which they must be familiar. They must also understand how to escalate and report concerns.

4.19 Abuse by Another Adult at Risk

We recognise that we may also have responsibilities towards the person causing the harm, and certainly will have if they are both in a care setting or have contact because they attend the same place, e.g. Supported Living, Day Opportunities, social enterprises, etc. The person causing the harm may themselves be eligible to receive an assessment. In this situation, it is important that the needs of the adult at risk who is the alleged victim are addressed separately from the needs of the person causing the harm. It will be necessary to reassess the adult allegedly causing the harm.

4.20 Exploitation by Radicalisers who Promote Violence

Individuals may be susceptible to exploitation into violent extremism by radicalisers. Staff will be expected to be alert to overt signs and if they have any concerns to report them to their service manager who will take necessary advice and action.

4.21 Self-Neglect and Refusal of Care

Kisharon Langdon must ensure that staff understand the importance of delivering care as detailed in the Care Plan. Where a people we support/member refuses support, this must always be documented. Where refusal occurs repeatedly, it must be escalated by Kisharon Langdon as a safeguarding concern and a request for a review of the people we support/member's support will be instigated.

4.22 Abuse and Sexual Safety

We recognise that culture, environment and processes support a people we support/member's sexuality and keep them and staff safe from sexual harm. As such, Kisharon Langdon will ensure that sexuality is discussed as part of the Care Plan process and is addressed positively to support people to raise concerns where necessary. The CQC publication on sexuality and sexual safety can be referred to for further guidance in this area.

4.23 Self-Funding people we support/members

People who fund their own support arrangements are legally entitled to receive support if subject to abuse or neglect in exactly the same way as those supported or funded by the Local Authority. They are also entitled to the protections of the Deprivation of Liberty Safeguards process.

4.24 Risk Assessment and Management

Achieving a balance between the right of the individual to control their support package and ensuring that adequate protections are in place to safeguard wellbeing is a very challenging task. The assessment of the risk of abuse, neglect and exploitation of people we support/members will be integral in all assessment and planning processes. Assessment of risk is dynamic and ongoing, especially during the adult safeguarding process, and must be reviewed throughout so that adjustments can be made in response to changes in the levels and nature of risk.

4.25 Audit and Compliance

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

• Recruitment procedures and Disclosure and Barring Checks
• Audit of incident reporting, frequency and severity
• Audit of training processes, including reviews of uptake of training and evaluations

Safeguarding concerns and incidents will be reviewed by the Senior Management Team as part of a root cause analysis with the following terms of reference:

• Review incident themes
• Reports from the lead responsible for Safeguarding within Kisharon Langdon
• Look in detail at specific cases to determine learning or organisational learning
• Ensure implementation of the Safeguarding Policy and Procedure

4.26 Training and Competencies

Kisharon Langdon will ensure that staff receive training in recognising and responding to incidents, allegations or concerns of abuse or harm as part of their induction programme.

5. Definitions

5.1 People in a Position of Trust (PiPoT)

• People who work with, or care for, adults with care and support needs, including anyone who is an employee, volunteer, or student, paid or unpaid

5.2 Independent Mental Capacity Advocate (IMCA)

• An advocate appointed to act on a person's behalf if they lack capacity to make certain decisions
• Refer to the Mental Capacity Act (MCA) 2005 Policy and Procedure

5.3 Forced Marriage

• The Anti-Social Behaviour, Crime and Policing Act 2014 protects people from being forced to marry without their free and full consent as well as people who have already been forced to do so
• We will ensure that staff are reminded of the one chance rule: our employees may only have one chance to speak to a potential victim of forced marriage and, therefore, only one chance to save a life
• Forced marriage can involve physical, psychological, emotional, financial and sexual abuse including being held unlawfully captive, assaulted and raped
• Law enforcement agencies will also be able to pursue perpetrators in other countries where a UK national is involved under powers defined in legislation

5.4 Hate Crime

A disability hate crime is: 'Any criminal offence which is perceived by the victim or any other person, to be motivated by a hostility or prejudice based on a person's disability or perceived disability.'

Incidents can include:

• Physical attacks such as physical assault, damage to property, offensive graffiti and arson
• Threat of attack including offensive letters, abusive or obscene telephone calls, groups hanging around to intimidate and unfounded, malicious complaints
• Verbal abuse, insults or harassment — taunting, offensive leaflets and posters, abusive gestures, dumping of rubbish outside homes or through letterboxes and bullying at school or in the workplace

5.5 Honour-Based Violence

• The terms 'honour crime', 'honour-based violence', and 'izzat' embrace a variety of crimes of violence (mainly but not exclusively against women), including physical abuse, sexual violence, abduction, forced marriage, imprisonment and murder where the person is being punished by their family or their community
• They are punished for actually, or allegedly, 'undermining' what the family or community believes to be the correct code of behaviour
• In transgressing this, the person shows that they have not been properly controlled to conform by their family and this is to the 'shame' or 'dishonour' of the family
• 'Honour crime' may be considered by the perpetrator(s) as justified to protect or restore the 'honour' of a family

5.6 Enquiry Planning / Strategy Meeting

• Enquiry planning/strategy meeting or discussion is a multi-agency discussion between relevant organisations involved with the adult at risk to agree how to proceed with the referral
• It can be face to face, by telephone or by email

5.7 Significant Harm

• Significant harm is not only ill treatment (including sexual abuse and forms of ill treatment which are not physical), but also the impairment of, or an avoidable deterioration in, physical or mental health, and the impairment of physical, intellectual, emotional, social or behavioural development

5.8 Modern Slavery

• Traffickers and slave masters use whatever means they have at their disposal to coerce, deceive and force individuals into a life of abuse, servitude and inhumane treatment
• Modern slavery encompasses slavery, human trafficking, forced labour and domestic servitude