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Safeguarding policy & procedure

Last Updated On: May 2023
Effective Date: May 2023

1. Introduction:
Nouvita Healthcare are committed to safeguarding the welfare of all adults. Adult safeguarding can apply to anyone over the age of 18 years who has needs for care and support, is being abused or is at risk of experiencing abuse or neglect and/or cannot protect themselves from abuse/exploitation and or neglect. By definition all hospital inpatients and residence of care/nursing homes are defined as having care and support needs, as defined by The Care Act 2014.

1.1. What Does Safeguarding Mean?
Safeguarding means protecting an adult’s human right to live in safety, free from abuse, exploitation and neglect. It is about people and organisations working together to prevent and stop both the risks and experience of abuse or neglect, while at the same time making sure that the adult’s wellbeing is promoted including, where appropriate, having regard to their views, wishes, feelings and beliefs in deciding on any actions to ensure their safety and wellbeing.
All residents of care establishments have the right to be safe, to be treated with respect and dignity and to have their voice heard. Everyone can play a part in making this happen.

1.2. What is Adult Abuse?
Abuse is mistreatment by any other person or persons that violates a person’s human and civil rights. The abuse can vary from treating someone with disrespect in a way which significantly affects the person’s quality of life, to causing actual physical suffering.

Abuse can happen anywhere – at home, in a residential or nursing home, a hospital, in the workplace, at a day centre or educational establishment, in supported housing, in the street, or even on line.

Nouvita Healthcare recognises that across our organisation all members of staff have a legal responsibility and duty of care to prevent the abuse of adults at risk of abuse, harm, or neglect (including self-neglect) and to act positively to report abuse and raise safeguarding alerts in a timely manner. The organisation is also accountable for ensuring that there are “reliable systems, processes, and practices in place to keep people safe and to safeguard them from abuse and neglect” (CQC, 2015).

This policy covers all Nouvita and Psycare services and details how adults at risk of harm or abuse will be protected, along with the procedures that must be followed to ensure that concerns are reported immediately. It can be read in conjunction with our Incident Reporting Policy, which also advises how a safeguarding alert should be reported and recorded using the Radar and Nourish systems.

2. QCS Policy:
This policy has been adapted from the current QCS policy and applies to all members of staff, whether paid or unpaid, student, or volunteer. For each individual service’s safeguarding policy, please refer to QCS using your personal log in details. This policy has been reviewed in line with the recent CQC publication on ‘Promoting sexual safety through empowerment’ and an additional procedural point and reference added in relation to this. Further minor content changes have been made and references have been updated to ensure they remain current.

3. Purpose:

The purpose of this policy is:

  • To protect the service user’s right to live in safety, free from abuse/ exploitation and neglect
  • Ensure that all staff working for, or on behalf of Nouvita Healthcare understand their responsibilities in relation to safeguarding adults at risk and know who to escalate concerns within the organisation
  • To ensure our safeguarding policy is regularly reviewed and ‘dovetails’ with our local authorities’ policy and procedures for safeguarding both locally and nationally as safeguarding practice develops.
  • To set out the key arrangements and systems that Nouvita Healthcare has in place for safeguarding and promoting the welfare of adults at risk and to ensure compliance with local policies and procedures
  • To have a clear, well-publicised policy of zero-tolerance of abuse/ neglect across the organisation
  • To support each Nouvita Healthcare service to meet the applicable ‘Key Lines of Enquiry’ as dictated by the CQC
  • To identify lessons to be learned from cases where adults have experienced abuse or neglect, sharing learning and promoting safeguarding practice
  • To support and empower each adult in our care 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
  • To manage the safety and wellbeing of adults in line with the six principles of safeguarding:

Empowerment – People being supported and encouraged to make their own decisions and informed consent:
“I am asked what I want as the outcomes 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 for my best interests, 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. I get help to take part in the safeguarding process to the extent to which I want and to which I am able.”

Partnership – Local solutions through services working with their communities. Communities have a part to play in preventing, detecting and reporting neglect and abuse:
“I know that staff treat any personal and sensitive information in confidence, only sharing what is helpful and necessary. I am confident that professionals will work together to get the best result for me.”

Accountability – Accountability and transparency in delivering safeguarding
“I understand the role of everyone involved in my life.”


4. Our Policy & Hertfordshire Safeguarding Adults Board:

The safeguarding policies and procedures of Nouvita Healthcare will dovetail with the Hertfordshire Safeguarding Adults Board and other multi-agency policy and procedures, which we understand take precedence over those of Nouvita Healthcare. Nouvita Healthcare services will ensure that the Hertfordshire Safeguarding Adults Board 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.

5. Our Services:

We aim to provide services that will be appropriate and ensure our duty of care towards adult’s at risk and not discriminate because of disability, age, gender, sexual orientation, race, religion, culture, or lifestyle. We will make every effort to enable service users 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 our service users and others involved in their care, 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.

Nouvita Healthcare understands the importance of working collaboratively to ensure that:

  • The needs and interests of adults at risk are always paramount, 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 any form of abuse or neglect
  • 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 and free from any acts of recrimination or retribution
  • Physical abuse
  • Domestic violence
  • Sexual abuse
  • Psychological abuse
  • Financial/material abuse
  • Modern slavery
  • Discriminatory abuse
  • Organisational abuse
  • Neglect and acts of omission
  • Self-neglect

Our governance processes will make sure that staff working for and on behalf of Nouvita Healthcare recognise and respond to the aforementioned 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: Furthermore, we also recognise our duty to prevent adults at risk of being exploited and or radicalised into terrorism or to commit acts of terrorism themselves.

6. Making Safeguarding Personal:

Nouvita Healthcare is committed to the principles of Making Safeguarding Personal, a project developed by the Local Government Association and the Association of Directors of Adults Social Services (ADASS).

The aim of Making Safeguarding Personal is to ensure that safeguarding is person-led and focused on the outcomes that they want to achieve. It engages the person 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, well-being and safety. We recognise the power imbalance between patients and staff and endeavour to work in a way that promotes patients self- determination, choice and control free of coercion.

7. The 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 appropriate Adult Safeguarding Team (Hertfordshire or Cambridgeshire, where appropriate) is contacted to inform them of the concern or harm
  • If a Service User is at immediate risk of harm, the manager will contact the The CQC will also be informed
  • In all cases of alleged harm, there will be early consultation between the Registered Manager, the local Adult Safeguarding Team and the Police to determine whether or not a joint investigation is required. We understand that it may also be necessary to advise the relevant Power of Attorney, if there is one appointed. In dealing with incidents of potential harm, people have rights which must be respected and which may need to be balanced against each other
  • The wishes of the person harmed will be taken into account whenever possible. This may result in no legal action
  • Documentation of any incidents of harm in the Service User’s file and using body maps to record any injuries
  • Follow the local Adult Safeguarding Board’s 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
  • Undertake thematic reviews of safeguarding incidents and benchmark data locally and where available with national benchmarking data.
  • If a safeguarding concerns / alert is raised about a member of staff, these will be promptly investigated, without prejudice and the safety of the service user and patients will be paramount and the worker involved will be supported by being removed from patient contact until a determination is made about the validity of the safeguarding concern, following our HR policies and procedures and working with other agencies such the local authority, police, DBS and professional bodies.

8. Roles & responsibilities across the organisation:

The Chief Executive, Phil Massetti, has ultimate responsibility for all aspects of the safeguarding of vulnerable adults within the organisation.  This responsibility is delegated to the Clinical Director, Victoria Hulstrom for all Nouvita Healthcare services.

Director of Nursing and Clinical Governance
The Clinical Director is responsible for ensuring a strategy for the management of adults at risk of harm/ exploitation or abuse is in place that conforms to legislation, national policy and guidance.

The Safeguarding Lead will be designated at each Nouvita Healthcare service; this is usually the Registered Manager unless this responsibility is delegated to an appointed Safeguarding Lead within the organisation.  This person will be responsible for leading internal investigations and reviewing serious incidents that have resulted in a safeguarding being raised, making recommendations for internal safety changes and supporting organisational learning. They will provide monitoring information and report to the board of directors.  They are responsible for ensuring mandatory training is attended by all staff.  See section 7 for “The Registered Manager’s responsibilities”. The safeguarding leads will work with local authority safeguarding teams to ensure compliance, taking advice and guidance while also carrying out thematic reviews of safeguarding concerns to ensure compliance with our statutory safeguarding duties and responsibilities. Moreover, where available to benchmark internal safeguarding data to ensure it is within acceptable levels of national reporting figures / occurrence of incidents.

The Compliance team will audit compliance in accordance with the Safeguarding Adults policy and Incident Reporting policy.

Clinical Service Manager/Service Leads/Safeguarding Leads (dependent on the service) are responsible for:

  • Ensuring the appropriate referrals have been sent to the police in cases of criminal adult abuse
  • Ensuring clinical staff are following the Safeguarding Adults policy and procedures
  • Provide advice and support for staff involved in the adult at risk safeguarding process
  • Informing Clinical Governance of all cases
  • Will support staff to identify and complete timely safeguarding alerts
  • Will participate in the thematic review of safeguarding incidents

Service Leads/Deputy Manager/Team Leaders/ Charge Nurses and Night Service Managers (dependent on the service) are responsible for:

  • Ensuring they have a working knowledge of the Safeguarding Adults policy and procedures
  • Informing the on-call manager out of hours of alleged abuse to a vulnerable adult at the earliest opportunity
  • Ensuring evidence is recorded correctly and preserved for Police investigation
  • Will promote and share lessons learnt with staff to provide a safe and effective care, treatment and protection of all service users

The on-call manager is responsible for:

  • Deciding if police involvement is immediately required as a criminal offence has taken place
  • For establishing in non-criminal abuse, the best interests of the vulnerable adult, if they lack capacity to decide for themselves
  • In the event of the Safeguarding Lead or Registered Manager being unavailable out of hours, to take urgent Safeguarding referrals and ensure these are actioned without delay

The responsibilities of all staff:

  • All staff have a responsibility to report concerns of abuse/ neglect and exploitation following the procedures set out in this policy
  • 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 training and participate in lessons learnt, supervision and reflective practice
  • To know how and when to use the Whistleblowing procedures
  • To understand the Mental Capacity Act 2005 and how to apply it in practice
  • To understand their duty of care as health workers

9.General Principles:

We will have robust recruiting and safer staffing policies 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.

At Baldock Manor, this person is Adam Trickett (Compliance and Safeguarding Lead),  Ambrose Nyaley (Hospital Director)
At Eltisley Manor, this person is Fiona Joyner (Registered Manager)
At Howe Dell Manor, this person is Fredah Kamau (Registered Manager)

Any staff member who knows or believes that harm is occurring will report it to their line manager as quickly as possible, or if they feel they cannot follow the regular reporting procedure, they must use the Whistleblowing process. Furthermore, all staff have a duty of candour and should notify their line manager without delay should they subject to any criminal investigation, in turn both the named safeguarding lead and registered manager should be notified.

Nouvita Healthcare is committed to working collaboratively with other agencies, including liaison in relation to any investigation of allegations and will ensure its procedures dovetail with the local authorities’ multi-agency procedures.  Furthermore, 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.  Whilst we recognise our responsibilities in relation to confidentiality, we will share information where necessary and as appropriate on a need to know basis to ensure we provide effective and a safe care environment for all patients and residence using our service.

Across our organisation we use incident reporting, root cause analysis, lessons learned, thematic reviews, benchmarking data and auditing to determine themes to improve care practice.  We have a learning and development strategy which specifically addresses adult safeguarding and 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.  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 and will adhere to the Code of Conduct for Care Workers

There is a clear, well-publicised Whistleblowing Policy and Procedure in place that staff know how to use.  Our Incident Reporting Policy also outlines how to report and record incidents that may require a safeguarding alert to be raised.

10. All Staff – Prevention – Providing information to support our service users:
Across each of our services, we are committed to supporting service users by providing accessible, easy to understand information on what abuse is and what signs to look out for. This will include Service Users’ 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 Service Users will receive a copy of the Service User Guide, 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 the individual Nouvita Healthcare service.

10.1. All Staff – Prevention – Raising awareness through training:
Staff will need to be trained and understand the different patterns and behaviours of abuse and neglect as detailed in The Care Act 2015 Chapter 14 and Nouvita Healthcare will ensure that it is able to respond appropriately.  Furthermore, all staff must be trained on the Whistleblowing Policy and Procedure.  During induction training, all employees will complete the safeguarding statutory training, as part of the Care Certificate.

11. All Staff – Responding to Disclosure, Suspicion or Witnessing Abuse:

Where an adult at risk discloses or discusses potential abuse or harm, the staff member 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

11.1. All Staff – Responding to a Disclosure:

  • 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 a good/the right thing in telling you, you are treating the information seriously and it was not their fault
  • Explain that you must tell your line manager and, with their consent, your manager will contact the local authority’s Safeguarding Adults Team and/or the Police. The appropriate Registered Manager must be informed
  • Please note: in specific circumstances, it may be appropriate to contact the Adult Safeguarding Team without an individual’s consent but their wishes will be made clear throughout If a referral is made but the adult at risk is reluctant to continue with an investigation, record this and bring this to the attention of Safeguarding Adults Team. This will enable a discussion on how best to support and protect the adult at risk. However, a professional case discussion will still need to take place and must be recorded appropriately.

11.2. All Staff – Responding to Abuse or Neglect – What to do:

  • 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. Where a crime is suspected of being committed, leave things as they are wherever possible
  • 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. Team members can call the NHS 111 service for medical help or advice when the situation is not life-threatening or is out of hours
  • The adult may feel frightened, so the care team must ask whether they want them to arrange for someone they feel comfortable with to stay with them
  • The registered manager and the appropriate team will need to 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
  • The team should support and encourage the adult to contact the Police if a crime has been or may have been committed
  • The team will contact the relevant line manager as soon as possible to inform them of the incident or concern
  • Where a service user / patient makes an allegation of historical sexual abuse, this should be raised with the local authority safeguarding teams where the alleged incident took place.


11.3. Registered Managers & Safeguarding Leads – Decision Making Pre-referral to the Local Authorities’ Adult Safeguarding Team:

The Registered Manager and/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, including managers on call over weekends and out of hours

In the event that these are unavailable, advice must be taken from the relevant 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 manager and they have not taken appropriate action (whistleblowing)

Nouvita Healthcare (and the applicable Registered Manager) will ensure that staff are aware of the appropriate local authority’s reporting procedures and timescales for raising adult safeguarding concerns.

11.4. Registered Managers & Safeguarding Leads – Referrals to the Local Authority Adult Safeguarding Team:

Each Nouvita service must ensure that the appropriate local authority’s safeguarding adults referral process is followed and must collect the following information to assist with the referral. The referral process must be clearly visible with contact numbers, including out-of-hours, where staff can access the information.

The referral information will also be required for some of the CQC ‘notification of abuse’ documentation.
Care Plan information should be used to complete the required referral information and have the following information available where possible:

  • Demographic and contact details for the adult at risk, the person who raised the concern and for any other relevant individual, specifically key workers and next of kin
  • Basic facts, focussing 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,
  • 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

In most instances, an incident form on Radar will have been completed and will include the above information. 

11.5. Documenting a Disclosure:

The Registered Manager and/or the appointed Safeguarding Lead must ensure that staff:

  • Make a note of what the person actually said, using his or her 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 and where possible (with consent) photographic evidence to indicate their location, noting the colour of any bruising
  • Make sure the information the individual member of staff records is clear and factual
  • Use a pen with black ink so that the report can be photocopied where written out or sign printed accounts
  • 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

11.6. Information the Relevant Inspectorate:

  • By law, each Nouvita Healthcare service must notify the Care Quality Commission without delay of incidents of abuse and allegations of abuse, as well as any incident which is reported to, or investigated by, the Police
  • Each service 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 Each service must also alert the relevant local safeguarding authority when notification is made to the CQC about abuse or alleged abuse.  The correct forms are available on the CQC website and on the Nouvita intranet. 
  • If a concern is received via the whistleblowing procedure, the Registered Manager/Safeguarding Lead must inform the local authority Safeguarding Team and the

11.7. Strategy Meeting/case Conferences:

  • 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 individua
  • 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 relevant Local Authority’s Safeguarding Adults Team Manager
  • The Registered Manager must ensure that they attend 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

11.8. Involving the Service User Concerned Throughout the Process:

  • The process of the enquiry must be explained to the Service User 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 Service User so desires. 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 Service User’s Care Plan must be undertaken to ensure individualised support following the incident
  • The Service User 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
  • If the service user is unable to express their views, then an advocate or other suitable person should be engaged to promote the service users’ views

11.9. Desired Outcomes:

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 change their views
  • The Service User 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
  • Nouvita health care recognises their duty of care, and how there maybe some incidents whereby the service user/ patient may not wish the police or other statutory authorities to be notified of safeguarding incidents, but will work with the service user to promote their understanding, ultimately recognising our organisational responsibility to be open and transparent, and in the report concerns and raising alerts of safeguarding incidents.

12. Disclosure and Barring Service (DBS) Referral:

There is a statutory requirement for providers of care 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.

13. Consent:

When reporting information that directly concerns the safety of an adult at risk of harm, consent from the Service User is not required. However, informing the Service User 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 Service User 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 Service User but still operate within the relevant legislation and the parameters of the codes and standards of their practice.

14. Confidentiality & Information Sharing:

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

  • Personal information will be shared in a manner that is compliant with the statutory responsibilities of Nouvita Healthcare
  • 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 Service User confidentiality and secure data sharing
  • The principles of confidentiality designed to protect the management interests of Nouvita Healthcare must never be allowed to conflict with those designed to promote the interests of the adult at risk
  • Staff must follow the policy on Data Protection and Confidentiality and comply with the Caldicott principle


15. Pressure Ulcers:

Pressure ulcers are costly in terms of both Service User 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 Service User’s own home. Each service must ensure that staff read and follow Safeguarding Adults Protocol Pressure Ulcers and the interface with a Safeguarding Enquiry (, seeking advice and further guidance where required.

Where Service Users 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.

16. Medication Errors:

Each Nouvita service must follow local safeguarding reporting procedures for medication errors and ensure that notifications are made to the CQC in line with statutory requirements. Each service should have an open and transparent approach to medication incidents and ensure that staff follow the appropriate Medication Errors Policy and Procedure and understand their Duty of Candour responsibilities.

17. Abuse of Trust and acts of Omission

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, Nouvita Healthcare must invoke disciplinary procedures for employed staff as well as taking action in line with this policy. 

Nouvita Healthcare 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.  Furthermore, if the person who is alleged to have caused the harm is a member of a recognised professional group, Nouvita Healthcare must act under the relevant code of conduct for the profession as well as taking action under this policy, being open and transparent.

Where the person alleged to have caused the harm or neglect is a volunteer or a member of a community group, Nouvita Healthcare 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, in many cases 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.

18. 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 take into account a number of factors and a referral to the appropriate local authority will be made as part of the safeguarding process.

19. 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.

Nouvita Healthcare 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.

20. 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 (for example, a day centre). 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.

21. Exploitation by Radicalisers who Promote Violence:

Individuals may be susceptible to exploitation into violent extremism by radicalisers. Staff will be expected to follow the Protecting Vulnerable People from Radicalisation Policy and Procedure that is in place.

22. Self-Neglect and Refusal of Care:

Each service must ensure that staff understand the importance of delivering care as detailed in the Care Plan. Where a Service User refuses care, this must always be documented. Where refusal occurs repeatedly, it must be escalated by the relevant Nouvita Healthcare service as a safeguarding concern and a request for a review of the Service User’s care will be instigated

23. Abuse and Sexual Safety:

We recognise that culture, environment and processes support a Service User’s sexuality and keep them and staff safe from sexual harm. As such, each Nouvita service should ensure that sexuality is discussed as part of the Care Planning process and is addressed positively to support people to raise concerns where necessary.

The recent CQC publication on sexuality and sexual safety can be referred to for further guidance in this area.

24. Self-Funding Service Users:

People who fund their own care 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.

25. Risk Assessment and Management:

Achieving a balance between the right of the individual to control their care 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 Service Users 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.

26. Audit and Compliance:

It is essential that the implementation of this policy and associated procedures is audited to ensure that each Nouvita Healthcare service 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 the specific service
  • Look in detail at specific cases to determine learning or organisational learning
  • Use the ‘Safety Alert’ to notify others across the organisation


Ensure implementation of the Safeguarding Policy and Procedure


27. Training and Competencies:

Nouvita Healthcare 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.


Relevant Legislation:

  • Serious Crime Act 2015 Section 76
  • Domestic Violence, Crime and Victims Act 2004
  • The Counter Terrorism and Security Act 2015
  • The Modern Slavery Act 2015
  • Anti-social Behaviour, Crime and Policing Act 2014
  • The Criminal Justice and Courts Act 2015 Section 20-25
  • Public Interest Disclosure Act 1998
  • Protection of Freedoms Act 2012 (Disclosure and Barring Service Transfer of Functions) Order 2012
  • The Care Act 2014
  • Care Quality Commission (Registration) Regulations 2009
  • Equality Act 2010
  • Human Rights Act 1998
  • Mental Capacity Act 2005
  • Safeguarding Vulnerable Groups Act 2006
  • The Health and Social Care Act 2008 (Regulated Activities) (Amendment) Regulations 2012