Safeguarding is an ongoing issue for providers in the third sector, but with strict regulatory frameworks and potentially big fallouts for those that fall foul of the law, it's something that providers need to get right. While establishing a robust risk management process is challenging, breaking down the task into seven key steps can help organisations stay on top of their responsibilities, says Markel's care consultancy director, Jerry Oliver.
Step 1: Develop your reporting procedures
As a first step, develop procedures that define what needs to be reported under your safeguarding actions, but make sure you do this in co-operation with your local authority safeguarding team so that the reporting thresholds are understood by both parties. And be clear when a notifiable safeguarding incident needs to be reported to The Care Quality Commission (CQC) or OFSTED.
Step 2: Get your internal structures right
Larger organisations might consider a safeguarding lead on their board or leadership team, whereas smaller organisations might look to allocate the task to a senior manager.
Consider whether safeguarding should be included within job descriptions, and appoint an individual to update trustees and senior managers on the latest safeguarding guidance and practice issues.
Overall, aim to provide appropriate and responsive safeguarding governance in relation to your organisation’s size and practice area.
Step 3: Ensure your safeguarding training is fit for purpose
Training ensures the whole organisation is up to speed with safeguarding requirements and responsibilities.
There are a number of measures to consider, including:
-
Include safeguarding in your induction process
-
Regularly reinforce key messages and information as part of core training competency for all staff
-
Focus on safeguarding in regular supervision or one-to-one sessions with staff members
-
Train senior staff in liability defence or handling of safeguarding investigations
-
Ensure HR and others who are involved in the recruitment of staff are up to date with current ID and DBS checking practices for non-UK nationals
-
Build mental capacity and DoLS into safeguarding training and practice guidance
Step 4: Make sure you log all incidents
Keeping an accurate and written account of all safeguarding incidents is vitally important. Make sure to link your incident reporting with your safeguarding notifications, and ensure that any safeguarding investigations involve the appropriate authorities. It can also help to keep your broker/insurer informed of events, while always respecting the confidentiality of those involved.
Step 5: Supporting service users and carers
Establish policies and procedures that guide staff when supporting service users and carers involved in safeguarding allegations or concerns. Link your policies and procedures with Duty of Candour, whistleblowing and complaint-handling guidelines.
Discuss with the local authority safeguarding team their expectations for reporting suspected abuse between service users where there are no mental capacity concerns.
Step 6: Employment actions to consider
Cover safeguarding in your disciplinary considerations and grounds for terminating employment. And make sure any job roles that are eligible for, or require, DBS checks are kept up to date.
Also, take the time to fully understand vetting procedures in relation to application processes. Specifically, those relating to obtaining overseas criminality information that must be provided to UK employers, or meeting the provision of overseas criminal record certificate immigration rules in support of overseas visitor visa applications.
Finally, audit your agencies thoroughly:
-
To verify their convictions policy is fit for purpose
-
To ensure their checks are being undertaken properly
-
To understand the frequency of their DBS refresh
-
To confirm ID checks have been undertaken on first-time agency staff
Step 7: Understand incident patterns and trends
Analyse your incident and accident reports for safeguarding patterns or trends that might need consideration. Ideally, this issue should be formally considered by senior managers and trustees. Be aware of wider safeguarding trends in the sector, and challenge your organisation on how your systems would have responded to these.
Managing risk is challenging in many ways, but there are a number of key steps organisations can take to ensure they are on the right path. While Markel’s seven-point guide provides solid guidance, each organisation will have its own unique challenges that need to be considered in their own right to ensure appropriate legislative compliance.
Jerry Oliver is the Director of Markel’s specialist care consultancy, Janjer. He leads a 30-strong team that supports Third Sector providers through all aspects of managing safeguarding risk. For more information, contact Jerry on jerry.oliver@markel.com
