Introduction
Studee recognize that we have a duty of care towards young service users and vulnerable adults and that they have a fundamental right to be protected from harm. It is the duty of all employees of Studee to prevent the physical, sexual, psychological/emotional, financial, discriminatory, or institutional abuse and neglect of all service users with whom they come into contact.
Definitions
Young service users (under 18 year olds) Team Members and Customers Vulnerable adults - Exclusion that negatively affects their quality of life, well-being and future life opportunities such as lack of education, knowledge, understanding, language and disabilities
Purpose
This Safeguarding Policy seeks to put into practice the principles of the Children Act 1989, the Online Safety Act 2023, the Protection of Children Act 1999, the Safeguarding Vulnerable Groups Act 2006, The Care Act 2014 and the Protection of Freedoms Act 2012 and support the development of all service users, including young service users and vulnerable adults, in ways which will foster security, confidence and independence. This approach is regarded as central to the wellbeing of the individual and is therefore seen to be an intrinsic part of all aspects of our learning programmes. The principles of the Counter Terrorism and Security Act 2015 and the Equality Act 2010 inform the implementation of our Prevent duty to Safeguarding children. Studee is committed to following these principles in all aspects of our safeguarding work:
- Empowerment - Putting people first and helping those who lack mental capacity feel involved and informed.
- Protection - Supporting victims so they can take action.
- Prevention - Responding quickly to suspected cases of abuse.
- Proportionality - Making sure what we do is appropriate to the situation and the individual.
- Partnership - Sharing the right information in the right way.
- Accountability - Making sure all stakeholders have a clear role.
Scope
This policy covers all full-time and part-time staff, including agency, partnership or subcontracted staff and volunteers.
Aims
- To enhance the self-esteem, self-confidence, communication skills, and personal safety of service users by developing appropriate skills enabling them to make reasoned, informed choices, judgements, and decisions.
- To ensure that staff are well informed about Safeguarding and Prevent issues.
- To ensure that staff are aware of their duty of care and their responsibility to report Safeguarding and Prevent concerns.
- To promote full cooperation with our partners and statutory agencies in our response to Safeguarding and the Prevent duty.
- To protect all service users, specifically those who are young and/or vulnerable, and staff members.
Procedures
Our aims will be put into effect by the following procedures:
- Provide a work environment in which service users and staff members are valued, listened to, and taken seriously.
- Allow opportunities for discussion of thoughts and feelings in an atmosphere of trust, acceptance, and tolerance.
- Promote values.
- Require all staff to exemplify values at all times.
- Give service users and staff time to share concerns and discuss problems.
- Integrate personal safety issues into learning programmes and staff training.
- Ensure we observe and monitor the welfare and physical, emotional, intellectual, and behavioral development of young service users and vulnerable adults whilst they are under our care.
- Promote staff awareness of types and indicators of abuse and neglect, the appropriate response to the service user, knowledge of procedures for reporting concerns, and our statutory responsibilities.
- Ensure appropriate record keeping and report writing.
- Establish regular contact with other appropriate agencies in order to promote cooperation, protect young service users and vulnerable adults, and develop an understanding of and appreciation for other professional roles and responsibilities.
Code of Conduct
All staff maintain entirely proper and professional relationships with service users and behave responsible at all times. Appendix 1: ‘Code of Conduct’ has been drawn up to assist staff in this area and to make clear the boundaries of their roles and the use of power and authority. To accompany this policy, including the Code of Conduct, all staff in regular contact with young service users and vulnerable adults will be provided with this policy for training and guidance.
Prevention
Recruitment and Selection
Through rigorous recruitment and selection procedures we will attempt to ensure that the staff we recruit to work with young service users and vulnerable adults are suitable candidates and have the necessary skills, experience and qualities to perform their duties effectively and responsibly.
Training and Induction
All staff will be provided with guidance and training in Safeguarding and Prevent duty appropriate to their role. Staff will be made fully aware of the company’s guidelines, procedures, and code of conduct. They will be briefed fully on their responsibilities and accountability within their roles.
Supervision
All staff will be required to adhere to the company’s code of conduct, which provides practical guidance on how to work effectively with service users whilst protecting their interests and welfare. In order to ensure that the company’s policy and code of conduct are being adhered to and to prevent and/or detect abuse, the activities and conduct of staff will be regularly monitored and supervised. Annually Heads of Studee will be made aware of the Safeguarding Policy where any team member is either directly or indirectly working with young service users and vulnerable adults staff to review and plan their work in line with the company’s Safeguarding and Prevent policies and procedures. In addition, line managers will ensure that they create opportunities to observe staff whilst they are working with service users. All visitors will be chaperoned by a member of staff during their visit. All resources that are to be used will be screened prior to being presented.
Working Environment
The provision of a safe learning environment is vital to protect both service users and staff.
Definitions
We use the following definitions for abuse:
- 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.
- Physical abuse - including assault, hitting, slapping, pushing, misuse of medication, restraint, or inappropriate physical sanctions.
- 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.
- 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.
- Organizational abuse - including neglect or poor care practice within an organization or specific care setting, such as a hospital or care home. It can also be in relation to care provided in your own home. This may range from one-off incidents to ongoing ill-treatment. It can be through neglect or poor professional practice as a result of the structure, policies, processes, and practices within an organization.
- Discriminatory abuse - including forms of harassment, slurs or similar treatment because of race, gender and gender identity, age, disability, sexual orientation, or religion.
- Self-neglect - this covers a wide range of behavior such as neglecting to care for personal hygiene, health or surroundings and includes behavior such as hoarding.
- Domestic abuse - including psychological, physical, sexual, financial, emotional, or so-called 'honor' based violence.
- Modern slavery - encompasses slavery, human trafficking, forced labor and domestic servitude. Trafficking 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.
Response
In the event of an allegation of abuse, the member of staff will:
- Listen to the service user and accept what is said.
- Establish what happened, when, where, and who did it involve.
- Record statements.
- Explain what they have to do next and whom they have to talk to.
- Reassure the service user that they have done the right thing in talking about the incident.
- Refer information to the designated staff outlined in Appendix 2.
Referral
In the event that a member of staff suspects abuse or neglect of a service user, or a service user discloses abuse or neglect, the matter must be reported immediately. Please email our Safeguarding Office, Ellie Robertson, using [email protected]. If you would prefer to speak directly with Ellie, email her and ask for her direct contact number.
Please include the following information:
- Date the incident occurred (if known).
- Details of the incident (as much detail as possible).
- Allegations against Name.
- Allegations against Position.
Where allegations of abuse relate to a child or young person, Studee will raise the issue with the police and/or the local authority.
Any areas of concern and allegations about people who are not covered by our policy will be reported to the relevant police force, local authority, and/or children’s services.
Appendix 2 ‘Reporting Procedure’ which accompanies this policy sets out the steps a member of staff should follow in every case. All staff who have regular contact with service users will receive guidance on the use of this procedure.
Confidentiality and Record Keeping
Only designated personnel should be informed in cases of suspected or disclosed abuse and have access to written records.
- Nominated Safeguarding Officers
- CEO
It is of the utmost importance that any notes and records made in such cases are treated as sensitive data and, as such, will be held securely with access restricted to designated personnel. Staff will share Safeguarding and Prevent duty information about vulnerable individuals within the organization and externally as required in accordance with provider information sharing agreements and data protection legislation.
Monitoring and Compliance
It is the responsibility of the Safeguarding Officer to continually monitor and evaluate to ensure the effectiveness of this policy is maintained.
Policy Review
This policy was last updated on 14.6.2024 and will be reviewed annually; however, unscheduled reviews will take place in the event of any significant change.
Send form to [email protected]
Appendix 1: Code of Conduct
Introduction
This code has been drawn up to assist staff in maintaining entirely proper and professional relationships with service users and provides a clear and unambiguous picture of the boundaries associated with staff roles and the use of power and authority.
It is stressed that this code is not a legal document but is intended to provide guidance to employees in carrying out their responsibilities. The code covers all full-time and part-time staff, including agency or subcontracted staff and volunteers.
As employees of Studee, all staff must exemplify values such as tolerance and respect for different faiths, cultures, and beliefs, demonstrate professional behavior at all times, and avoid any behavior that could bring the company into disrepute. Staff are required to demonstrate high standards in their exercise of authority, their management of risk, in the proper use of resources, and in the active protection of service users from discrimination and avoidable harm. This document is designed to be both useful for staff and others in avoiding situations that might lead to allegations against them and to reassure other parties (e.g., parents/carers, employers, and funding bodies) that Studee takes its responsibilities for safeguarding and the Prevent duty seriously.
Staff are required to be prudent about their own conduct and vigilant about the conduct of others, so that their relationships with service users remain, and are seen to remain, entirely proper and professional. It is recognised that staff are vulnerable to the possible consequences of their close professional relationships with service users and to the potential for malicious and misplaced allegations being made, either deliberately or innocently, arising from the normal and proper associations that staff may have with them.
Principles
The duty of our staff is to:
- Train service users assigned to them according to the learning needs of those service users.
- Promote the general progress and wellbeing of individual service users and of any group of service users assigned to them.
- Ensure the health & safety and wellbeing of service users while they are within their responsibility/jurisdiction.
- Provide advice and guidance to service users on educational, personal, and social matters if appropriate and provide information about sources of expert advice on specific questions.
- Maintain good order and discipline among service users and promote their development.
- Promote at all times democracy, the rule of law, individual liberty, and mutual respect and tolerance for those with different faiths and beliefs.
These principles are intended to guide staff members and ensure that they give paramount consideration to the wellbeing of service users by respecting and attempting to understand the following:
- The ascertainable wishes and feelings service users are concerned about (considered in the light of service user age and understanding).
- The physical, emotional, and learning needs of service users.
- The likely effect on the service user of any change in his/her circumstances.
- The age, gender, religion, ethnicity, background, and any other relevant characteristics of the service user.
- Any harm that service user has suffered or is at risk of suffering.
Staff members are in a position of trust, and they owe a duty of care to service users for whom they are responsible. Staff should never seek gratification of their own emotional or physical needs in their relationships with service users, and all affiliations must always be professional, appropriate, and justifiable.
The company’s Safeguarding and Prevent procedures have primacy over other requirements, and this document attempts to be supportive and complimentary to those procedures. These principles and subsequent guidelines provide the basis for the company to identify inappropriate behavior by our staff and should therefore be accessible to all members of staff.
Guidelines for all staff
Physical Contact
- There may be occasions when a service user or staff needs comfort or reassurance, which may include physical comforting such as a caring parent would give. Staff should use their discretion in such cases to ensure that what is normal and natural does not become unnecessary and unjustified contact, particularly with the same service user over a period of time.
- Physical contact may be misconstrued by a service user, parent/carer, or observer. Such contact can include well-intentioned informal and formal gestures such as putting a hand on the shoulder or arm which, if repeated with an individual service user, could lead to serious questions being raised. Any such comforting gestures must always be acceptable to the service user concerned; i.e., there should be no unwanted physical contact, however well-intentioned. Therefore, as a general principle, staff should not have unnecessary physical contact with their service users or colleagues.
- There may be occasions where it is necessary for a member of staff to physically restrain a service user or colleague to prevent him/her from inflicting injury to himself/herself or others. In such cases, only the minimum force necessary must be used, and any action taken must be to restrain an individual. Where the member of staff has taken action to restrain a person, he/she should report the matter as advised below.
- Any form of physical punishment is unlawful, as is any form of physical response to misbehavior unless it is by way of restraint. It is particularly important that employees understand this both to protect their own position and that of the company and the educational establishment.
The practice of physical restraint
- Restraint can be defined as ‘the reasonable application of the minimum necessary force to overpower a person with the intention of preventing them from harming themselves or others, or from causing serious damage to property.’
- Restraint should only be used exceptionally, when unavoidable and in keeping with the incident leading to it, and should be primarily for the benefit of the person.
- Restraint should not be used as a form of punishment or, in normal circumstances, to enforce compliance with instructions. It should not be attempted where the member of staff is put at undue risk.
- Incidents of restraint should, in appropriate circumstances, be subject to debriefing for staff involved and lead to a review of strategies for managing the behavior between relevant parties.
- Where staff themselves are the subject of physical attack, they should refer to the guidance provided by the company and report the incident as advised below.
Sexual Contact
- There is NO acceptable behavior that has either explicit sexual connotations or innuendo. Any such behavior will always be treated as extremely serious and must be reported immediately.
Meetings with Young Service User / Vulnerable Adults
- Staff should be aware of the potential risks, which may arise from interviewing individuals in private. It is recognized that there will be occasions when confidential interviews must take place, but where possible, such interviews should be conducted in a room with visual access or with the door open, or in a room or area which is likely to be frequented by other people.
- Where such conditions cannot apply, staff are advised to ensure that another adult knows that the interview is taking place.
- If necessary to detain a person for any length of time after the end of normal hours, prior warning must be given to them.
Caring / First Aid
- If an individual reports that they have suffered an injury or sickness, a judgment should be made as to whether he/she should be referred to a First Aider or advised to see his/her own doctor. The individual's next of kin may also be informed, if appropriate.
- Staff needing to administer first aid should ensure wherever possible that another adult is present, if they are in any doubt as to whether necessary physical contact could be misconstrued.
- Another adult should accompany employees who have to help someone with personal care and should, wherever possible, be encouraged to deal with such matters themselves.
- Male staff should not, as a general rule, enter female toilets nor should female staff enter male toilets, except in extreme situations such as fire.
Provision of Advice and Guidance
- Staff may from time to time be approached for advice and where they may appear to be distressed, and staff may feel the need to ask if all is well. In such cases, staff must judge whether it is appropriate for them to offer counseling and advice or whether to refer them to a member of staff of another gender, one with acknowledged expertise, experience, or responsibility for that service user, or to an external specialist agency. Staff must, in these circumstances, use their discretion to ensure that, for example, any probing for details cannot be constructed as unjustified intrusion.
- In dealing with an individual, staff must inform them at the start of the discussion that the member of staff may have to disclose the information to another person e.g. the Department Manager/Health professional/Police.
Freedom of Speech
- Studee promotes freedom of speech for all and encourages people to share thoughts/opinions and be involved in democratic debates, whilst mutually respecting others. All staff have a responsibility to supervise open debates and vet the content of communications.
IT Security
- Firewalls/filters are in place to protect staff and service users from accessing inappropriate materials and from viruses. All staff must monitor the use of computers and report any concerns following normal safeguarding procedures.
- The Information Security team can vet the firewalls and filters to ensure that no inappropriate content can be accessed.
- Staff are responsible for embedding awareness of online safety within our IT Security, including Prevent and cyber-bullying during interactions with young service users.
General Relationships with Young Service Users
- Staff should ensure that their relationships with service users are appropriate to the age and gender of the service user, taking care that their conduct does not give rise to comment or speculation. Attitudes, demeanor, and language all require care and thought.
- Comments by staff to service users, either individually or collectively, can be misconstrued. As a general principle, staff must not make unnecessary comments to and/or about service users that could be construed to have a sexual connotation. It is also unacceptable for staff to introduce or encourage debate among service users in a class, training situation, or elsewhere, which could be construed as having a sexual connotation that is unnecessary given the context of the training session or the circumstances. However, it is recognized that a topic raised by a service user is best addressed rather than ignored.
- Staff should be careful in their use of language/terminology that may be misconstrued.
- The systematic use of insensitive, disparaging, or sarcastic comments is unacceptable.
- If a member of staff at any time feels that their relationship with a service user is developing into one that would be inappropriate between a member of staff and a service user, it is their responsibility to discuss the situation with their Manager.
Reporting of Incidents which may lead to complaints
- Following any incident where a member of staff feels that his/her actions have been, or may be, misconstrued, both the company’s designated Safeguarding Officer and the Department Manager/CEO should be informed immediately, and the incident confirmed in writing by the member of staff involved. (See appendix 2 ‘Procedures for Reporting Suspected or Disclosed Abuse’.)
- Such reporting is especially important in any case where a member of staff has been obliged to restrain a person to prevent him/her from inflicting injury to others or themselves, or where he/she has been personally attacked by another individual.
Appendix 2: Procedures for Reporting Suspected or Disclosed Abuse
Studee Safeguarding Officer has responsibility for safeguarding issues within the company relating to service users and staff members. In the event of the Safeguarding Officer’s absence or non-availability, the CEO will assume responsibility for safeguarding individuals.
If a service user makes a disclosure to a member of staff, which gives rise to concerns about possible abuse, or if a member of staff has concerns about a service user in respect of the Prevent duty, the member of staff MUST ACT PROMPTLY.
HE/SHE SHOULD NOT INVESTIGATE - This is a matter for the relevant agency. They should, however, report these concerns immediately to the designated Safeguarding Officer, discuss the matter with him/her, and make full notes.
The company’s Safeguarding Officer will then plan a suitable course of action and ensure that a written record is made.
The Safeguarding Officer will decide whether, in the best interests of the person, the matter needs to be referred to the relevant agency, e.g. Social Services or the Police. If there are concerns that the service user may be at risk, the Safeguarding Officer/CEO is obliged to make a referral, taking into account who may be the possible abuser.
The Safeguarding Officer will, in accordance with the establishment’s own procedures, seek clarification or advice from appropriate bodies e.g. Local Education Authority (LEA), funding body, or police. No decision to refer a case to Social Services will be made without the fullest consideration and on receipt of appropriate advice. THE SAFETY OF THE YOUNG SERVICE USER / VULNERABLE ADULT WILL ALWAYS BE THE FIRST PRIORITY.
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Allegations against a member of staff:
If a complaint about possible abuse is made against a member of staff, the designated Safeguarding Officer must be informed immediately. The above procedures will apply unless the complaint is about the designated Safeguarding Officer.
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Allegations against a Senior Manager or Safeguarding Officer:
If a complaint is made against a member of the senior management staff, the designated Safeguarding Officer must be informed immediately. He/she will inform the CEO and together they will ensure that upon raising a complaint using the Safeguarding complaint form, the appropriate action is taken within 48 hours, and acknowledgment of your complaint resulting in an investigation started. If a complaint is made against the Safeguarding Officer, the CEO must be informed immediately, and appropriate action will be taken.
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Suspension from Duties:
Where a matter is referred to Social Services, the member of staff will be removed from duties involving direct contact with service users and may be suspended from duty as a precautionary measure pending investigation by Social Services.