CQC Quality Statement

Theme 3 – How the local authority ensures safety in the system: Safeguarding

Royal Borough of Greenwich statement

We work with people to understand what being safe means to them as well as our partners on the best way to achieve this. We concentrate on improving people’s lives while protecting their right to live in safety, free from bullying harassment, abuse, discrimination, avoidable harm and neglect. We make sure we share concerns quickly and appropriately.

What people expect

I feel safe and supported to understand and manage any risks.

1. Introduction

Each local authority must set up a Safeguarding Adults Board (SAB). The main objective of a SAB is to assure itself that local safeguarding arrangements and partners are working well together to help and protect adults in its area who meet the criteria as in Section 2, The Safeguarding Duty, Adult Safeguarding.

The SAB has a strategic role and it oversees and leads adult safeguarding across the locality. It has an interest in a range of matters that contribute to the prevention of abuse and neglect, including:

  • oversees and leads adult safeguarding across the locality and will be interested in a range of matters that contribute to the prevention of abuse and neglect;
  • monitors the safety of patients in its local health services;
  • evaluates the quality of local care and support services;
  • monitors the effectiveness of prisons and approved premises in safeguarding offenders;
  • promotes the awareness and responsiveness of further education services.

The SAB will need intelligence on safeguarding in all providers of health and social care in its locality (not just those with whom its members commission or contract). It is important that SAB partners feel able to challenge each other and other organisations where it believes that their actions or inactions are increasing the risk of abuse or neglect. This will include commissioners, as well as providers of services.

The SAB can be an important source of advice and assistance, for example in helping others improve their safeguarding mechanisms and practice. It is important that the SAB has effective links with other key partnerships in the locality and share relevant information and work plans. They should consciously co-operate to reduce any duplication and maximise efficiency, particularly as objectives and membership is likely to overlap.

An effective SAB will:

  • assure itself that safeguarding approaches in their area support the principles of personalisation;
  • work with partners and citizens to prevent abuse and neglect where possible;
  • ensure agencies and practitioners respond in a timely and proportionate manner when people raise safeguarding concerns;
  • learn from and respond to safeguarding trends within their area;
  • ensure that individuals and organisations are competent in their delivery of safeguarding practice;
  • assure itself that safeguarding practice is continuously reviewed to ensure good quality and responsive practice, enhancing the quality of life for adults in its area. (Revisiting Safeguarding Practice, DHSC)

Under the terms of the Care Act the membership of the SAB must include:

In addition to these organisations, due to the way in which health services are commissioned in RBG Oxleas Foundation Trust and Lewisham and Greenwich Hospitals Trust are also considered to be core members of the Greenwich SAB.

2. Core Duties of the Safeguarding Adults Board

A SAB has three core duties:

  • it must publish a strategic plan for each financial year that sets out how it will meet its main objective and what the members will do to achieve this. The plan must be developed with local community involvement, and the SAB must consult the local Healthwatch organisation. The plan should be evidence-based and make use of all available evidence and intelligence from partners to form and develop its plan;
  • it must publish an annual report detailing what the SAB has done during the preceding year to achieve its main objectives and implement its strategic plan, and what each member has done to implement the strategy as well as detailing the findings of any safeguarding adults reviews and subsequent action;
  • it must conduct any Safeguarding Adult Reviews (see Safeguarding Adult Reviews chapter) in accordance with the Care Act 2014.

Adult safeguarding requires collaboration between partners in order to create a framework of inter-agency arrangements.  Local authorities and their relevant partners must collaborate and work together as set out in the co-operation duties in the Care Act 2014 and in doing so, must where appropriate, also consider the wishes and feelings of the person on whose behalf they are working.

Local authorities may cooperate with any other body they consider appropriate where it is relevant to their care and support functions. The lead agency with responsibility for coordinating adult safeguarding arrangements is the local authority, but all the members of the SAB should designate a lead officer.  Other agencies should also consider the benefits of having a lead for adult safeguarding.

Each SAB should:

  • identify the role, responsibility, authority and accountability with regard to the action each agency and professional group should take to ensure the protection of people;
  • establish ways of analysing and interrogating data on safeguarding notifications that increase the SAB’s understanding of prevalence and patterns of abuse and neglect locally that builds up a picture over time;
  • establish how it will hold partners to account and gain assurance of the effectiveness of its arrangements;
  • determine its arrangements for peer review and self-audit;
  • establish mechanisms for developing policies and strategies for protecting people which should be formulated, not only in collaboration and consultation with all relevant agencies but also take account of the views of people who have needs for care and support, their families, advocates and carer representatives;
  • develop preventative strategies that aim to reduce instances of abuse and neglect in its area;
  • identify types of circumstances giving grounds for concern and when they should be considered as a referral to the local authority as an enquiry;
  • formulate guidance about the arrangements for managing adult safeguarding, and dealing with complaints, grievances and professional and administrative malpractice in relation to safeguarding people;
  • develop strategies to deal with the impact of issues of race, ethnicity, religion, gender and gender orientation, sexual orientation, age, disadvantage and disability on abuse and neglect;
  • balance the requirements of confidentiality with the consideration that, to protect people , it may be necessary to share information on a ‘need to know basis’, giving due regard to the Caldicott Principles where applicable;
  • identify mechanisms for monitoring and reviewing the implementation and impact of policy and training;
  • carry out safeguarding adult reviews and determine any publication arrangements;
  • produce a strategic plan and an annual report;
  • evidence how SAB members have challenged one another and held other local boards to account
  • promote multi-agency training and consider any specialist training that may be required. Consider any scope to jointly commission some training with other partnerships, such as the Community Safety Partnership.

See Care and Support Statutory Guidance paragraphs 14.133-14.161 for further information about Safeguarding Adults Boards.

3. Provision of Local Adult Safeguarding Procedures

In order to respond appropriately where abuse or neglect may be taking place, anyone in contact with the person, whether in a voluntary or paid role, must understand their own role and responsibility and have access to practical and legal guidance, advice and support. This will include understanding local inter-agency policies and procedures.

In any organisation, there should be adult safeguarding policies and procedures.  These should reflect the Care and Support statutory guidance and give due regard to the Royal Borough of Greenwich Safeguarding Adults Procedures. The local policy is to be used locally to support reduction or removal of safeguarding risks, as well as to secure any support to protect the person and, where necessary, to help the person recover and develop resilience. Such policies and procedures should assist those working with people how to develop swift and personalised safeguarding responses and how to involve people in this decision making. This, in turn, should encourage proportionate responses and improve outcomes for the people concerned. Procedures may include:

  • a statement of purpose relating to promoting wellbeing, preventing harm and responding effectively if concerns are raised;
  • a statement of roles and responsibility, authority and accountability sufficiently specific to ensure that all staff and volunteers understand their role and limitations
  • a statement of the procedures for dealing with allegations of abuse, including those for dealing with emergencies by ensuring immediate safety, the processes for initially assessing abuse and neglect and deciding when intervention is appropriate, and the arrangements for reporting to the police, urgently when necessary;
  • a full list of points of referral indicating how to access support and advice at all times, whether in normal working hours or outside them, with a comprehensive list of contact addresses and telephone numbers, including relevant national and local voluntary bodies;
  • an indication of how to record allegations of abuse and neglect, any enquiry and all subsequent action;
  • a full description of channels of inter-agency communication and procedures for information sharing and for decision making;
  • how professional disagreements are resolved especially with regard to whether decisions should be made, enquiries undertaken for example.

The SAB should keep policies and procedures under review and report on these in the annual report as necessary. Procedures should be updated to incorporate learning from published research, peer reviews, case law and lessons from recent cases and Safeguarding Adults Reviews. The procedures should also include the provisions of the law – criminal, civil and statutory – relevant to adult safeguarding. This should include local or agency specific information about obtaining legal advice and access to appropriate remedies.

The Care Act requires that each local authority must arrange for an independent advocate to represent and support a person who is the subject of a safeguarding enquiry or Safeguarding Adult Review where the person has ‘substantial difficulty’ in being involved in the process and where there is no other suitable person to represent and support them.

4. Responding to Abuse and Neglect in a Regulated Care Setting

It is important that all partners are clear where responsibility lies when abuse or neglect is carried out by employees or in a regulated setting, such as a care home, hospital, or college.  The first responsibility to act must be with the employing organisation as the provider of the service. However, social workers or counsellors may need to be involved in order to support the person to recover.

When an employer is aware of abuse or neglect in their organisation, they are under a duty to correct this and protect the person from harm as soon as possible and inform Royal Borough of Greenwich, CQC and ICB where the latter is the commissioner.

Where Royal Borough of Greenwich has reasonable cause to suspect that a person may be experiencing or at risk of abuse or neglect, then it has a duty to make (or make arrangements for) whatever enquiries it thinks necessary to decide what, if any, action needs to be taken and by whom.  Royal Borough of Greenwich may be reassured by the employer’s response so that no further action is required. However, Royal Borough of Greenwich would have to satisfy itself that an employer’s response has been sufficient and proportionate to deal with the safeguarding issue and, if not, to undertake any enquiry of its own and any appropriate follow up action (for example referral to CQC, professional regulators).

The employer should investigate any concern (and provide any additional support that the person may need) unless there is compelling reason why it is inappropriate or unsafe to do this. For example, this could be a serious conflict of interest on the part of the employer, concerns having been raised about non-effective past enquiries or serious, multiple concerns, or a matter that requires investigation by the police.

An example of a conflict of interest where it is better for an external person to be appointed to investigate may be the case of a family-run business where institutional abuse is alleged, or where the manager or owner of the service is implicated. The circumstances where an external person would be required should be agreed locally. All those carrying out such enquiries should have received appropriate training.

There should be a clear understanding between partners at a local level when other agencies such as Royal Borough of Greenwich, CQC or ICB need to be notified or involved and what role they have. The Association of Directors of Adult Social Services (ADASS)Care Quality CommissionLocal Government AssociationNational Police Chiefs Council and NHS England have jointly produced a guide on these roles and responsibilities: Safeguarding Adults: Roles and Responsibilities in Health and Care Services. The focus should be on promoting the wellbeing of those people at risk.

Commissioners should encourage an open culture around safeguarding, working in partnership with providers to ensure the best outcome for the person. A disciplinary investigation, and potentially a hearing, may result in the employer taking informal or formal measures which may include dismissal and possibly referral to the Disclosure and Barring Service.

If someone is removed by being either dismissed or redeployed to a nonregulated activity, from their role providing regulated activity following a safeguarding incident, or a person leaves their role (resignation, retirement) to avoid a disciplinary hearing following a safeguarding incident and the employer/volunteer organisation feels they would have dismissed the person based on the information they hold, the regulated activity provider has a legal duty to refer to the Disclosure and Barring Service.  If an agency or personnel supplier has provided the person, the legal duty sits with that agency. In circumstances where these actions are not undertaken then Royal Borough of Greenwich can make such a referral.

5. Safeguarding Adult Reviews

See also Safeguarding Adult Reviews chapter 

There are different types of Safeguarding Adult Review:

  • SABs must arrange a Safeguarding Adult Reviews (SAR) when a person in its area dies as a result of abuse or neglect, whether known or suspected, and there is concern that partner agencies could have worked more effectively to protect the person;
  • SABs must also arrange a SAR if a person in its area has not died, but the SAB knows or suspects that the person has experienced serious abuse or neglect. In the context of SARs, something can be considered serious abuse or neglect where:
    • the individual would have been likely to have died but for an intervention;
    • has suffered permanent harm;
    • has reduced capacity or quality of life (whether because of physical or psychological effects) as a result of the abuse or neglect;
  • SABs have the discretion to arrange for a SAR in any other situations involving a person in its area with needs for care and support;
  • SARs may also be used to explore examples of good practice where this is likely to identify lessons that can be applied to future cases.

The SAB should be primarily concerned with weighing up what type of ‘review’ process will promote effective learning and improvement action to prevent future deaths or serious harm occurring again. This may be where a case can provide useful insights into the way organisations are working together to prevent and reduce abuse and neglect of people.

Early discussions need to take place with the person, family and friends to agree how they wish to be involved. the person who is the subject of any SAR need not have been in receipt of care and support services for the SAB to arrange a review in relation to them.

6. Providing and Disseminating Information

See also Information Sharing and Confidentiality

6.1 People with care and support needs and their carers

Information should be produced in a range of different ways, user-friendly formats for people with care and support needs and their carers.  Information should explain clearly:

  • what abuse is;
  • how to share any concerns;
  • how to make a complaint;
  • that their concerns or complaints will be taken seriously;
  • that concerns will be dealt with independently;
  • that they will be kept involved in the process to the degree that they wish to be;
  • that they will receive help and support in taking action on their own behalf;
  • that they can nominate an advocate or representative to speak and act on their behalf if they wish.

If a person has no appropriate person to support them and has substantial difficulty in being involved in Royal Borough of Greenwich processes, they must be informed of their right to an independent advocate. Where appropriate, local authorities should provide information on access to appropriate services such as how to obtain independent legal advice or counselling services for example.

6.2 Commissioners, providers and other staff

All commissioners or providers of services in the public, voluntary or private sectors should disseminate information about the multi-agency policy and procedures.

Staff should be made aware through internal guidelines of what to do when they suspect or encounter abuse of people in vulnerable situations.

This should be incorporated in staff manuals or handbooks detailing terms and conditions of appointment and other employment procedures so that individual staff members will be aware of their responsibilities in relation to safeguarding people.

This information should emphasise that all those who express concern will be treated seriously and will receive a positive response from managers.

Roles and responsibilities should be clear and collaboration should take place at all the following levels:

  • operational;
  • supervisory line management;
  • practice leadership;
  • strategic leadership within the senior management team;
  • corporate/cross authority;
  • chief officers/chief executives;
  • local authority members and local police and crime commissioners;
  • commissioners;
  • providers of services;
  • voluntary organisations;
  • regulated professionals.

6.2.1 Front line staff

Operational front line staff are responsible for identifying and responding to allegations of abuse and poor practice. Staff at an operational level need to share a common view of what types of behaviour may be abuse or neglect and what to do as an initial response to a suspicion or allegation that it is, or has occurred. This includes GPs. It is employers’ and commissioners’ duty to set these out clearly and reinforce regularly.

It is not for front line staff to second guess the outcome of an enquiry in deciding whether or not to share their concerns. There should be effective and well publicised ways of escalating concerns if immediate line managers do not take action in response to the concern being raised.

Concerns about abuse or neglect must be reported whatever the source of harm is.  It is imperative that poor or neglectful care is brought to the immediate attention of managers and responded to swiftly, including ensuring immediate safety and wellbeing of the person. Where the source of abuse or neglect is a member of staff it is for the employer to take immediate action and record what they have done and why (similarly for volunteers and or students).

There should be clear arrangements in place covering what each agency should contribute at this level. These will include approaches to enquiries and subsequent courses of action. Royal Borough of Greenwich is responsible for ensuring effective coordination at this level.

6.2.2  Supervision

Skilful and knowledgeable supervision focused on outcomes for people is critically important in safeguarding work. Managers have a central role in ensuring high standards of practice and that practitioners are properly equipped and supported. It is important to recognise that dealing with situations involving abuse and neglect can be stressful and distressing for staff and workplace support should be available.

Managers need to develop good working relationships with their counterparts in other agencies to improve cooperation locally and swiftly address any differences or difficulties that arise between front line staff or managers.

They should have access to legal advice when proposed interventions, such as the proposed stopping of contact between family members, or if it is unclear whether proposed serious and/or invasive medical treatment is likely to be in the best interests of the person who lacks capacity to consent, require applications to the Court of Protection.

7. Senior Strategic Response

7.1 Practice leadership

All social workers undertaking work with people should have access to a source of additional advice and guidance particularly in complex and contentious situations. The Principal Social Worker is often well placed to perform this role or to ensure that appropriate practice supervision is available.

The Principal Social Worker in Royal Borough of Greenwich is responsible for providing professional leadership for social work practice in their organisation. Practice leaders, safeguarding adults managers and Principal Social Workers should ensure that practice is in line with the Care and Support Statutory Guidance.

Making Safeguarding Personal underpins all social and healthcare delivery in relation to safeguarding, with a focus on the person not the process (see Making Safeguarding Personal chapter). As the professional lead for social work, the Principal Social Worker and senior healthcare safeguarding professionals should have a broad knowledge base on safeguarding and Making Safeguarding Personal and be confident in its application in their own and others’ work.

All providers of healthcare should have in place named professionals, who are a source of additional advice and support in complex and contentious cases within their organisation.  There should be a designated professional lead in the ICB, who is a source of advice and support to the governing body in relation to the safeguarding of individuals and is able to act as the lead in the management of complex cases.

All commissioners and providers of healthcare should ensure that staff have the necessary competences and that training is in place to ensure that staff are able to deliver the service in relation to the safeguarding of individuals. This is strengthened by the development of the Safeguarding Adults: Roles and Competences for Health Care Staff (Royal College of Nursing), which details the levels of training and competencies required for the different groups of staff in the organisations.

Many of the police investigators involved in safeguarding investigations are specially trained for that role and work in specialist units. Each of those units has a set of arrangements to help provide advice and guidance to ensure that a thorough investigation takes place in order to achieve successful outcomes for the individual.

The police service itself has identified ways that enable non-specialist officers to seek advice from supervisors at every stage of the safeguarding process, even when specialist departments are unavailable.

7.2 Strategic leadership within the senior management team

Each SAB member agency should identify a senior manager to take a lead role in the organisational and in inter-agency arrangements, including the SAB. In order for the Board to be an effective decision-making body providing leadership and accountability, members need to be sufficiently senior within their organisation and have the authority to commit the required resources and be able to make strategic decisions. To achieve effective working relationships, based on trust and transparency, the members will need to understand the contexts and restraints within which their counterparts work.

All police forces in England and Wales have a head of public protection that has strategic management responsibility for all aspects of protecting people in vulnerable situations, including people at risk. The role of the head of public protection is to build an effective working team and develop a multi-agency approach into alleged offences involving people in vulnerable circumstances. They will also have responsibility for managing and developing policy that ensures standardised processes of investigation and working practice throughout each force.  The police and ICBs are now represented at a strategic level on the RBG SAB and contact details for the individuals concerned are available to the Board and its members.

7.3 Corporate / cross authority roles

To ensure effective partnership working, each organisation must recognise and accept its role and functions in relation to adult safeguarding. They should also have protocols for mediation and family group conferences and for various forms of dispute resolution.

7.4 Chief officers and chief executives

As chief officer for the leading adult safeguarding agency, the Director of Health and Adult Services (DASS) has a particularly important leadership and challenge role to play in adult safeguarding.

Responsible for promoting prevention, early intervention and partnership working is a key part of the DASS’s role and also critical in the development of effective safeguarding. Taking a personalised approach to adult safeguarding requires the DASS to promote a culture that is person-centred, supports choice and control and aims to tackle inequalities.

However, all officers, including the Chief Executive of Royal Borough of Greenwich, NHS and police chief officers and executives should lead and promote the development of initiatives to improve the prevention, identification and response to abuse and neglect. They need to be aware of and able to respond to national developments and ask searching questions within their own organisations to assure themselves that their systems and practices are effective in recognising and preventing abuse and neglect. The chief officers must sign off their organisation’s contributions to the strategic plan.

7.5 Annual reports

Chief officers should receive regular briefings of case law from the Court of Protection and the High Courts.

7.6 Local authority elected members

Local authority elected members need to have a good understanding of the range of abuse and neglect issues that can affect people and of the importance of balancing safeguarding with empowerment. Local authority members need to understand prevention, proportionality, and the dangers of risk adverse practice and the importance of upholding human rights. The RBG SAB may invite elected members to attend when appropriate and this is one way of increasing awareness of members and ownership at a political level. Managers must ensure that members are aware of any critical local issues, whether of an individual nature, matters affecting a service or a particular part of the community.

In addition, local authority health scrutiny functions, such as the Council’s Health Overview and Scrutiny Committee, Health and Wellbeing Boards (HWBs) and Community Safety Partnerships can play a valuable role in assuring local safeguarding measures, and ensuring that SABs are accountable to local communities.  Similarly, local Health and Wellbeing Boards provide leadership to the local health and wellbeing system; ensure strong partnership working between local government and the local NHS; and ensure that the needs and views of local communities are represented

7.7 Commissioners

Commissioners from Royal Borough of Greenwich and the Integrated Care Boards are vital to promoting adult safeguarding. Commissioners have a responsibility to assure themselves of the quality and safety of the organisations they place contracts with and ensure that those contracts have explicit clauses that hold the providers to account for preventing and dealing promptly and appropriately with any example of abuse and neglect.

7.8 Providers of services

All service providers, including housing and housing support providers, should have clear operational policies and procedures that reflect the framework set by the SABs in consultation with them. This should include what circumstances would lead to the need to report outside their own chain of line management, including outside their organisation to Royal Borough of Greenwich. They need to share information with relevant partners such as Royal Borough of Greenwich even where they are taking action themselves. Providers should be informed of any allegation against them or their staff and treated with courtesy and openness at all times.  It is of critical importance that allegations are handled sensitively and in a timely way both to stop any abuse and neglect but also to ensure a fair and transparent process. It is in no one’s interests to unnecessarily prolong enquiries. However some complex issues may take time to resolve.

7.9 Voluntary organisations

Voluntary organisations need to work with commissioners and the SAB to agree how their role fits alongside the statutory agencies and how they should work together. This will be of particular importance where they are offering information and advice, independent advocacy, and support or counselling services in safeguarding situations. This will include telephone or online services. Additionally, many voluntary organisations also provide care and support services, including personal care.  All voluntary organisations that work with people need to have safeguarding procedures and lead officers.

7.10 Regulated professionals

Staff governed by professional regulation (for example, social workers, doctors, allied health professionals and nurses) should understand how their professional standards and requirements underpin their organisational roles to prevent, recognise and respond to abuse and neglect.

8. Further Reading

8.1 Relevant chapters

Adult Safeguarding

Safeguarding Adults Procedures

Information Sharing and Confidentiality

8.2 Relevant information

Chapter 14, Safeguarding, Care and Support Statutory Guidance (Department of Health and Social Care)

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