Safeguarding Policy

This policy has been developed with reference to the following national legislation and safeguarding guidance:

A) Safeguarding Children
Working Together to Safeguard Children 2015, updated 2026, is the guide to Inter Agency working to safeguard and promote the welfare of children.

Whilst Local Authorities play a lead role, safeguarding children and protecting children from harm is the responsibility of every agency. Everyone who comes into contact with children and families has a role to play.

Local agencies including police, health, education, voluntary and community services and housing providers also have a duty under section 11 of the Children’s Act 2004 to ensure that they consider that they have arrangements in place to safeguard and promote the welfare of children when carrying out their functions.

Under Section 10 of the same act, Local Authorities are required to make arrangements with their relevant partners; these arrangements are to be made with a view to improving the wellbeing of all children including protection from harm and neglect.

The following definitions for children are taken from ‘Working Together to Safeguard Children’ – A guide to inter-agency working to safeguard and promote the welfare of children 2026

Definition of a ‘child’
The definition of a child is any person who is yet to reach their 18th birthday. The fact that a child has reached 16 years of age, is living independently or is in further education, is a member of the armed forces, is in hospital or in custody in the secure estate, does not change their status or entitlements to services or protection.

Safeguarding and promoting the welfare of children is defined as:

• Protecting children from maltreatment.
• Preventing impairment of children’s health and development.
• Ensuring that children grow up in circumstances consistent with the provision of safe and effective care and taking actions to enable all children to have the best outcomes.

Emphasis is put on ‘Early Help’: local agencies should have in place effective ways to identify emerging problems and unmet needs for children and families.

B) Safeguarding Adults
The Care Act 2014 was passed into law in April 2015. The definition of Adult Safeguarding is to prevent harm and reduce the risk of abuse or neglect to adults with care and support needs.

The Act sets out specific responsibilities for each Local Authority, which must:

• Make enquiries, or ensure others do so, if it believes an adult is subject to, or at risk of abuse or neglect. An enquiry should establish action needed to be taken to stop or prevent abuse and by whom.
• Set up Safeguarding Adults Boards (SAB) with core membership from the Local Authority, the Police and the NHS (specifically Clinical Commissioning Groups).
• Arrange for an Independent Advocate to represent and support an adult who is subject to a safeguarding enquiry.
• Co-operate with each of its relevant partners in order to protect adults experiencing or at risk of abuse or neglect.

Definitions for adults are taken from Care and Support Statutory Guidance updated February 2017 – Issued under the Care Act 2014

Safeguarding adults is defined as:

• Protecting the rights of adults to live in safety, free from abuse and neglect.
• People and organisations working together to prevent and stop both the risks and experience of abuse or neglect.
• People and organisations making sure that the adult’s wellbeing is promoted including, where appropriate, taking fully into account their views, wishes, feelings and beliefs in deciding on any action.
• Recognising that adults sometimes have complex interpersonal relationships and may be ambivalent, unclear or unrealistic about their personal circumstances and therefore potential risks to their safety or wellbeing.
  Safeguarding adults duty applies to an adult who is 18 or over and who:
• Has a care and support need, whether or not this is being met by the local authority.
• Is experiencing, or at risk of abuse or neglect.
• As a result of those care and support needs is unable to protect themselves from either the risk of, or the experience of abuse or neglect.

Six Principles of Safeguarding

The Care Act 2014 is underpinned by the six principles of safeguarding:

1. Empowerment – presumption of person led decisions and informed consent
2. Prevention – it is better to take action before harm occurs
3. Proportionality – proportionate and least intrusive response appropriate to the risk presented
4. Protection – support and representation of those in greatest need
5. Partnerships – local solutions through services working with their communities
6. Accountability – accountability and transparency in delivering safeguarding

C) Legislation and guidance relevant to this policy:

• The Children Act 1989 and 2004
• Working together to Safeguard Children 2015, updated 2026
• The Care Act 2014
• The Care Act Statutory Guidance (updated March 2020)
• Crime and Policing Act 2026
• Safeguarding Vulnerable Groups Act 2006
• Protection of Freedoms Act 2012

• This policy contains information about safeguarding children and adults at risk and the policy context in which we operate.
• This policy recognises the importance of interagency working and that safeguarding is the responsibility of every agency and their colleagues.
• To describe the robust structure for accountability and responsibility for safeguarding at all levels of the organisation.
• The Safeguarding Procedure (Guidance Notes) should be read in conjunction with this policy. The procedure clarifies roles and responsibilities for colleagues when reporting concerns.

1. Colleagues in contact with customers understand how to recognise and respond to suspected child or adult abuse and are supported in raising a concern.
2. Colleagues receive training appropriate to their role and management support to reflect on their practice and the impact of their handling of a concern.
3. Colleagues make an appropriate, timely, professional and ethical response to any concerns of abuse.
4. When raising a safeguarding concern, colleagues assume that the adult has capacity to decide whether they wish a safeguarding alert to be raised on their behalf, and their informed consent is always sought; if there is a decision to make a concern without consent it is because there is a greater risk to the adult or child.

Recognise – Respond – Report – Record – Review

Responsibilities

Colleagues

Colleagues have a responsibility to:

1. Act in line with Great Places’ Safeguarding Policy and Procedure, and be able to recognise signs of abuse, neglect, or exploitation.
2. Act in a timely manner where they have a concern of abuse and ensure that concerns are responded to and reported.
3. Where they suspect that a crime has been committed, or that there is immediate risk of harm or the need for medical treatment, they should make an immediate report to the police or emergency services by calling 999.
4. Know how to report abuse, including how to make a direct referral to the relevant Safeguarding Authority (Child or Adult).
5. Make a clear and factual record of their concern and the action taken.
6. Challenge/escalate concerns if a response is not received or the response does not manage the risk identified, ensuring records are reviewed and updated.
7. Remain compliant with all mandatory safeguarding training identified for their role.

Managers

Managers have a responsibility to:

1. Ensure that all colleagues are compliant with the appropriate safeguarding training associated with their job role.
2. Ensure that the child or adult at risk is made safe if appropriate and possible.
3. Ensure any colleague who may be alleged to have caused harm is not in contact with the child or adult who may be at risk and ensure concerns are raised with the People Team and dealt with appropriately.
4. Ensure information is provided to the Safeguarding Authority in a timely way.
5. Provide support to colleagues who seek advice regarding safeguarding concerns, including assessing any information flagged to them and make an informed decision regarding the case/concern.
6. Review all cases with colleagues monthly and ensure that all relevant actions are clearly recorded.
7. Managers are not responsible for carrying out a safeguarding investigation into alleged abuse. This duty lies with the local authority, although Great Places colleagues may be required to be involved.

Cultural Competence

Cultural competence is required in safeguarding practice to protect individuals from harm while understanding, respecting, and responding to their unique cultural backgrounds. It is essential to ensure that colleagues provide equitable, non-discriminatory safeguarding practice, valuing diversity while maintaining that cultural practices can never be used to justify abuse or neglect, ignoring or excusing practices that are against UK law, or that cause or risk causing significant harm to children, young people or vulnerable adults.

Monitoring and Review

A report of safeguarding data, including case data, training compliance, Enhanced and Basic DBS compliance, Local Authority enquiries and Formal Safeguarding Review findings is reported monthly to the Safeguarding Service Excellence Group (SEG), quarterly to Strategic Safeguarding Group and annually to Board.

Formal Safeguarding Review

Formal Safeguarding Reviews may be commissioned by Strategic Safeguarding Group and carried out by a colleague appointed by the Director of I&W to identify any learning and recommendations to address any areas of practice and reduce risks in the future.

Training and recruitment

Safer Recruitment
We apply a fair and consistent approach to recruitment to draw our workforce from the widest pool and select the best people on merit. As an organisation committed to safeguarding children and adults at risk, we have robust recruitment policies in place, including requiring references and appropriate use of Basic and Enhanced DBS to minimise the risk of recruiting colleagues who may pose a risk to customers, children or vulnerable adults. (See Recruitment and Selection Policy and DBS Policy).

Competent and confident workforce
We provide mandatory safeguarding induction and refresher training and role-specific training. This includes the training and development of our workforce within professional regulatory requirements. We ensure that our frontline and specialist colleagues have the skills they require, and we support all colleagues to trust their judgement and act on safeguarding concerns.

Safeguarding training is of the highest importance to the organisation and there is an expectation that colleagues remain compliant with the relevant training requirements for their role at all times. Noncompliance will be managed by the line manager and the People Team.

Partnership Working and Contract Management
We work in partnership with contractors to ensure that DBS and Safeguarding Training requirements are managed effectively. The Safeguarding in Procurement and Contract Management Procedure details the requirements for all contracts held by Great Places and how these are to be managed.

Safeguarding Accountability

Safeguarding is everyone’s responsibility and Great Places ensures that all colleagues are aware of how to identify safeguarding concerns and our duty to report and protect children and vulnerable adults from suspected harm and abuse.

Director of Independence and Wellbeing

The Director of Independence and Wellbeing is the Safeguarding Lead for the organisation. Their roles and responsibilities include strategic oversight to:

1. Ensure Safeguarding Policy and Procedure support all colleagues to be aware of their duty to recognise, respond, report and record allegations and suspected abuse internally, and the Local Authority where necessary, and ensure management, supervision and support structures are in place to identify and respond to possible abuse and neglect and review safeguarding records in line with guidance.
2. Ensure Safer Recruitment practices are in place, including appropriate use of relevant Disclosure and Barring Services (DBS) for all employees who are in direct contact customers, children or vulnerable adults.
3. Ensure that relevant training is in place and delivered to colleagues according to their role and responsibilities.
4. Liaise with the People Team to ensure that an adequate Whistleblowing Policy is in place to support Safeguarding best practice (Great Places’ Speak Up Policy).

Head of Independent Living

The Head of Independent Living has strategic and operational responsibility, through line management of the Safeguarding Partner and partnership working with relevant departments, to ensure all policy, procedure and processes are in place to safeguard children and vulnerable adults. Their roles and responsibilities include strategic and operational oversight to:

1. Ensure Safeguarding Policy and Procedure support all colleagues to be aware of their duty to recognise, respond, report and record allegations and suspected abuse internally, and the Local Authority where necessary, and ensure management, supervision and support structures are in place to identify and respond to possible abuse and neglect and review safeguarding records in line with guidance.
2. Ensure Safer Recruitment practices are in place, including appropriate use of relevant Disclosure and Barring Services (DBS) for all employees who are in direct contact customers, children or vulnerable adults.
3. Ensure that relevant training is in place and delivered to colleagues according to their role and responsibilities.

Safeguarding Partner

Reporting to the Head of Independent Living, the Safeguarding Partner acts as an expert advisor to the business by:

1. Ensuring that the business is compliant with all requirements within safeguarding legislation and best practice
2. Embedding a safeguarding culture across the business.
3. Delivering high-quality training, policy and guidance.
4. Reviewing data to monitor and maintain compliance of Case Management, Training and DBS practices.
5. Advising senior leaders and Strategic Safeguarding Group of obligations under safeguarding best practice, in particular safeguarding legislation, DBS legislation and best practice
6. Liaising with Local Authority Safeguarding Boards and coordinating Great Places’ response to Serious Case Reviews and Safeguarding Adult Reviews
7. Providing advice and guidance to case managers and line managers regarding safeguarding concerns.

SSG

There is a Strategic Safeguarding group (SSG) that meets quarterly. The SSG is led by the Director of Independence and Wellbeing with support from senior managers from across the business.

The role of the SSG is to provide strategic oversight of safeguarding at Great Places to ensure that adequate policy, procedure, training, case management and safer recruitment resource is in place to maintain compliance with legal requirements and the Great Places Safeguarding Policy.

Safeguarding SEG

The Safeguarding Service Excellence Group (SEG) meets monthly. The Safeguarding SEG is chaired by the Head of Support Services and attended by the Safeguarding Partner, with representation of colleagues from across the business. The role of the Safeguarding SEG is to maintain oversight of the performance and effectiveness of Great Places’ safeguarding framework, including Case Management, Training and Safer Recruitment.

Operational Responsibilities

Colleague and Line Manager responsibilities for Safeguarding, including providing support and guidance to colleagues, are detailed within the Safeguarding Procedure (Guidance Notes).

Information Sharing and Partnership working

In line with Government legislation, we will work in partnership with other relevant agencies in order to protect children and vulnerable adults at risk from harm. This will mean attending and contributing to meetings, raising concerns and issues where we feel relevant. The Data Protection Act 1998 and UK GDPR 2018 is not a barrier to sharing information but provides a framework to ensure that personal information about people is shared appropriately.

Prevent

Great Places Housing Group is committed to safeguarding customers, colleagues and communities from harm. This includes protecting individuals from being drawn into terrorism or extremist activity. We support the aims of the Government’s Prevent strategy and recognise that radicalisation is a safeguarding concern. Where needed, we will work in partnership with local authorities, the police and other organisations to report potential risks.

The Director of Assurance is responsible for ensuring that Great Places appropriately supports the Government’s Prevent Strategy.

Great Places will:

• Provide Prevent training to relevant colleagues, and monitor compliance.
• Report concerns, relating to customers, communities and colleagues in line with Great Places’ safeguarding process and the Government’s Prevent Strategy.
• Take proportionate action to safeguard individuals who may be vulnerable, by engaging with other relevant organisations.
• Monitor referrals to other relevant organisations.
• Share information appropriately where there is a safeguarding or public safety concern.

We respect our customers’ human rights and any decisions taken will be done so fairly and without discrimination.

Review arrangements

Great Places will review this policy every three years. In cases of relevant legal or local procedure changes, we will review this policy accordingly.

• Domestic Abuse Policy
• Modern Slavery
• Anti-Social Behaviour (ASB) Policy
• Hoarding Policy
• Recruitment and Selection Policy
• Acceptable Use of Business Systems Policy
• Speak Up Policy (Whistleblowing)
• Safeguarding in Procurement and Contract Management Procedure
• DBS Policy