The purpose of this document is to specify the policy of LSME for the safeguarding of adults who may be considered susceptible to abuse of any form. LSME aims to take all reasonable steps in relation to the safety and welfare of all vulnerable groups during its operations. The College does not tolerate the abuse, deliberate harm and neglect occurring on its premises. This Policy is based on and incorporates elements of the following legislation and national guidance documents (including but not limited to):
- Safeguarding Vulnerable Groups Act 2006
- Protection of Freedoms Act 2012
- Disclosure and Barring Service Guidance documents and should be read in conjunction with the Fitness to Practice Policy, Confidentiality and Data Protection Act, The Prevent Duty Policy, Misconduct and Disciplinary Policies and Procedures.
This Policy applies to all members of staff, students, visitors, and volunteers during their duties within or outside LSME premises engage in regulated activity relating to adults or may have contact with vulnerable groups.
This includes registered students within or outside the premises (including work-based and placement learning, health and social care settings etc) regardless of their mode of study and irrespective of whether a matter arises during term time or vacation. Students on work based and placement learning (if reporting safeguarding concerns) are encouraged to invoke the Safeguarding Policy and procedures of the organisation in which they are carrying out their placement. However, if this is not appropriate or if no action is taken, students are encouraged (with the support of their Class Tutor or Placement Tutor) to follow this Safeguarding Policy for reporting of safeguarding concerns.
Regulated activity relating to adults: In the context of LSME, this includes regular unsupervised contact with adults over 18 such as supervising; providing advice and guidance on well-being; includes pastoral care in relation to assistance with general and sometimes personal matters and/or in the conduct of the adult’s own affairs. Where health and social care placement learning is implemented, a regulated activity will include unsupervised provision of personal care to disabled people.
Vulnerable adult: An adult who is in receipt of regulated activity is considered vulnerable at the time he or she requires that regulated activity, regardless of the setting or the personal circumstances of the adult receiving the activity. Other factors that contribute to vulnerability of students may include physical and learning disabilities, social exclusion, underachievement, recent religious conversion, rejected by peers, faith, social groups or family, victim or witness to race or religious hate crime, family conflict and identity confusion. Some of these factors may result in a recent change in appearance and or behavior. A vulnerable adult is also prone to being influenced by others to engage in acts of violence or terrorism through radicalization.
Types of Abuse or Harm that may be experienced by a Child or Vulnerable Adult: Types of abuse or harm that vulnerable adults /adults at risk (adults with care and support needs) may encounter may include:
Emotional/ Psychological: Action or inaction by others that causes mental anguish or severe adverse effects on the emotional development of the adult at risk.
Physical: Any intentional physical contact that results in discomfort, pain or injury including fabricating symptoms or deliberately inducing illness to an adult at risk.
Sexual: Including any form of sexual activity with an adult at risk or coercion or force to take part in sexual acts including non-contact abuse or being forced to watch inappropriate images and/ or use of the internet/ technology.
Neglect: Failure to identify and / or meet care needs or adequate supervision; failure to act or omission.
Institutional: Maltreatment of a person from a system of power.
Financial: Usually associated with the misuse of money, valuables, or property
Discriminatory Abuse: Including racist, sexist, ageist abuse based on a person’s disability, and other forms of harassment, slurs, or similar treatment.
Internet/electronic Abuse: The use of modern communication technologies (e.g. internet, text or video messaging, e-mail, chatrooms, social media networking sites or picture sites such as snapchat) to embarrass, humiliate, threaten, intimidate, or bully an individual to gain power and control over them.
The following may indicate that abuse is taking place (this list is not exhaustive):
- Unexplained or suspicious injuries, particularly if such an injury is unlikely to have occurred accidentally;
- An injury for which the adult’s or carer’s explanation appears inconsistent;
- The adult describes an abusive act or situation or allegation of mistreatment;
- Unexplained changes in behaviour;
- Inappropriate sexualised or risky behaviour (sexual or otherwise);
- Apparent mistrust of others;
- The adult appears increasingly unkempt.
How LSME work can acquire contact with vulnerable adults
- Widening participation initiatives taking place in or out of the premises.
- Identifying adult student who may have been abused outside the premises.
- Placements with health and social care institutions as part of professional training.
- Provision of welfare and pastoral care services.
- Social activities.
1. All staff, students and volunteers who carry out regulated activity relating to adults or who may have contact with vulnerable groups:
- Should ensure they understand the implications of this Policy before commencing any programme, event, visit or other activity and must ensure there is a risk assessment in place. Where relevant, safeguarding training should be incorporated into relevant programmes of study and/or briefings for students undertaking work based and placement learning;
- are responsible for their own actions and behaviour and should avoid any conduct which would lead any reasonable person to question their motivation and intentions;
- Should work in an open and transparent manner with vulnerable groups;
- Should protect the welfare of people who are vulnerable.
All vulnerable groups, without exception, have the right to protection from abuse regardless of age, disability, gender reassignment, marriage, and civil partnership; pregnancy and maternity, race, religion and belief, sex, or sexual orientation.
2. Student/Employment Vetting
LSME has in place policies that require the vetting of employees, students or volunteers who are carrying out a regulated activity relating to adults, or who are carrying out work, work based and placement learning where it is a legal requirement for such checks to have been satisfactorily completed.
All LSME staff handling DBS disclosure information is committed to storing and handling it securely in accordance with the Data Protection Act and the DBS Code of Practice.
3. Dealing with Suspicions or Allegations of Abuse
Staff, students, and volunteers who have contact with vulnerable groups have a responsibility to be alert to the possibility that an individual may have been abused or be at risk of abuse. Concerns of this nature could arise in a variety of ways and in a range of settings. To identify and respond appropriately to concerns of abuse the following structures have been put in place:
Class tutors are the first point of contact with students. They are required to detect any changes in behaviour that may require further action. Students who wish to discuss personal issues affecting academic progress and have occurred may do so with their class tutors.
Student Welfare Officer
LSME has designated Welfare Officers who are responsible for overseeing the management of safeguarding issues within the College. They respond directly to the students’ needs and if they are not able to, relevant staff members who serve on the Student Welfare and Pastoral Care committee can receive and respond appropriately to reports of abuse within LSME.
Student Welfare Committee
This comprise a group of senior management staff including the Principal, Programme Leaders and Welfare officer who work together to support learners on welfare and safeguarding related issues.
The Welfare Officer and members of the Student Welfare and Pastoral Care Committee will undergo relevant safeguarding training and attend refresher training as appropriate. This will include input from Social Services (Adult Safeguarding) and / or Police, as well as input on the handling of confidential information.
Information Sharing and Confidentiality
A general principle for processing information is that information is only shared with the consent of the subject of the information. In some circumstances, however, it will not be appropriate to seek consent before sharing information with others and / or information can be shared where consent has been refused. The exception to this is where to do so would:
Place an adult or others at increased risk of significant harm; or undermine the prevention, detection or prosecution of a serious crime including where seeking consent might lead to
Interference with any potential investigation.
The Reporting Process
The Class Tutor will act as the points of contact within the LSME for receiving and recording safeguarding concerns and liaising directly with the Welfare Officer. If the student does not want to disclose information to the tutor, he/she may report directly to the Student Welfare Officer who would report directly to the committee. The Student Welfare and Pastoral Care Committee should never leave a concern unreported.
The committee will need to establish facts but will not investigate allegations of abuse. LSME has a duty of care to report any reports of concern, abuse, or harm to Social Services or to the Police. In dealing with allegations of this nature, LSME also recognises that it has a duty of care both to the vulnerable group concerned and (for protecting staff, and students from false or malicious allegations) to the member of staff, student, or volunteer against whom the allegation is made. LSME will liaise with the Local Safeguarding Boards within Social services or with the Police. Depending on the nature of the offence, LSME may withhold the initiation of its procedures for the Fitness for Professional Practice or Student / Staff Disciplinary) until any external processes (including: investigations; court results or legal proceedings) are complete.
Reporting Process for Situations External to LSME
If a student/ staff member becomes aware of an adult safeguarding issue whilst on work based and placement learning, then s/he should report the concern to the safeguarding officer of that organisation.
Referral to the Disclosure and Barring Service (DBS)
LSME has a legal duty to refer individuals (whose role involves regulated activity relating to children and/or adults) to the DBS if:
They have been removed from their regulated activity role (or would have been removed if they had not left, resigned, retired or been made redundant); or have engaged in professional misconduct, or have received a caution or conviction for a ‘relevant offence’. All allegations need to have been substantiated (and / or investigated by a relevant agency including Social Services or Police). The Chair of the Board of Directors will be responsible for all DBS referrals. Further details on DBS referrals are available on DBS website.
Annual review: The Student Welfare and Pastoral Care Committee will liaise with the LSME Board of Directors annually to ensure this policy and supporting procedures remain effective and relevant.
Next Review Date: October 2020