HAVERING Clinical Commissioning Group
SAFEGUARDING
CHILDREN AND ADULTS
AT RISK STRATEGY
Document HistoryLead/Author(s) / Sue Elliott
Reggie Medina-Rios
Sue Nichols
Version and date / 01November 2015
Approved by / BHR CCGs’ Quality & Safety Committee
Approval / Implementation date / Decemeber 2015
Review date / November 2017
Target audience / All CCG staff
Date of equality impact assessment / November 2015
Strategy reference number / SG(R)003
Version History
Date / Version / Author / Status / Description of change/comments
Contents
1.0 Introduction
2.0 Accountability
3.0 General Roles and Responsibilities
4.0 Safeguarding Structure
5.0 Safeguarding arrangements
6.0 Commission safe services
7.0 Safeguarding Children and LAC Training
8.0 Managing Safeguarding Allegations against staff
9.0 Whistleblowing
13.0 Monitor Assurance
14.0 What to do if you have a safeguarding concern about a child, young person or vulnerable adult?
15.0 BHR CCGs Safeguarding Contacts
16.0 Safeguarding Priorities for 2015-16 and 2016-17
Appendix A - Referenced Documents
Appendix B- Catogeries of Abuse
Appendix C - Equality Impact Assessment
1.0Introduction
1.1 BHR CCGs holds the value that living a life that is free from harm and abuse is a fundamental right of a person. It acknowledges its statutory responsibility to promote the welfare of children, young people and to protect adults from abuse and harm.
- This strategy sets out the strategic approach required to ensure that safe and effective safeguarding services are in place. It does not detail procedure and operational policies, as these are developed in partnership with and available through, the multi-operational policies approved by HaveringSafeguarding Childrens and Adult Boards and the Pan London Child Protection Procedures (2015).
- The CCG’s vision is to commission services that protect individual human rights, promote dignity, independence and wellbeing; hear and respond to the needs of children, young people, adults and carers.
1.2 The CCG will evidence that their commissioned services achieve local priorities and demonstrate progress on improved quality and safety outcomes year on year through the use of contractual arrangements and metrics with provider organisations. This will include having in place key performance indicators (KPI’s), CQUIN targets, quality schedules, systems to embed learning from incidents and procedures and a Safeguarding Training Strategy & Framework.
1.3In addition the CCG will support recommendations from public enquires, such as: the Francis Inquiry (2013), Independent Inquiry into Child Sexual Abuse in Rotherham (2014) and the Lampard Enquiry (2015) regarding openness, transparency, duty of candour and leadership being integral to service delivery and outcomes across the health economy.
1.4Any BHR CCG employee, who identifies a safeguarding concern about a child, young person or adult, must discuss their concerns immediately with their line manager and/or the designated nurse to get appropriate advice and support.
- NHS England Safeguarding Vulnerable People in the NHS-Accountability and Assurance Framework (2015) identifies that: robust information sharing practice is at the heart of good safeguarding practice, with legislation (Data Protection Act 1998) and case law to clarify issues of confidentiality and privacy.
- The CCG Caldicott Guardian and designated professionals can advise CCG staff and partner agencies regarding sharing proportionate “health” information so as to protect specific children or adults or if it is in the wider public interest to do so.
2.0 Accountability
2.1Overall accountability for safeguarding within BHR CCGs rests with the Chief Officer. The Nurse Director is responsible for senior clinical leadership.
3.0 General Roles and Responsibilities
3.1 The ultimate accountability for safeguarding sits with the Chief Officer of the CCG. Any failure to have systems and processes in place to protect children and vulnerable adults in the commissioning process, or by providers of healthcare that the CCG commissions would result in failure to meet statutory andnon-statutory constitutional and governance requirements.
3.3 The CCG must demonstrate robust arrangements are in place to demonstrate compliance with safeguarding responsibilities.
3.4The CCG must establish and maintain good constitutional and governance arrangements with capacity and capability to deliver safeguarding duties and responsibilities, as well as effectively commission services ensuring that all service users are protected from abuse and neglect.
3.5Establish clear lines of accountability for safeguarding, reflected in governance arrangements.
3.5To co-operate with the local authority in the operation of the Local Safeguarding Children Board (LSCB) / Local Safeguarding Adult Board (LSAB).
3.6Ensure that all providers with whom there are commissioning arrangements have in place comprehensive and effective policies and procedures to safeguard children and vulnerable adults in line with those of the LSCB / LSAB.
3.7 Ensure that staff directly or indirectly employed by the CCG are aware of their roles and responsibilities for safeguarding and know how to act on concerns in accordance with local LSCB / LSAB policies and procedures.
3.8 To participate in Domestic Homicide Reviews and Serious Case Reviews.
3.9Secure the expertise of a Designated Doctor and Nurse for Safeguarding Children; a Designated Doctor and Nurse and for Looked After Children (LAC); a Designated Paediatrician for Child Deaths; a Safeguarding Adult Lead and a Mental Capacity Act Lead.
3.10 Ensure that plans are in place to train all staff in contact with children, adults who are parents/carers and vulnerable adults in the course of their normal duties so that they are trained and competent to be alert to the potentialindicators of abuse or neglect for children and vulnerable adults, know how to act on those concerns in line with local guidance.
3.11 Ensure that appropriate systems and processes are in place to fulfil specific duties of cooperation and partnership and the ability to demonstrate that the CCG meets best practice in respect of safeguarding children and adults at risk and looked after children.
3.12Ensure that safeguarding is at the forefront of service planning and a regular agenda item of the CCG’s Board business.
3.13 Ensure that all decisions in respect of adult care placements are based on knowledge of standards of care and safeguarding concerns.
Nurse Director
3.14Ensures that the health contribution to safeguarding and promoting the welfare of children and vulnerable adults is discharged effectively across the whole local health economy through the organisation’s commissioning arrangements.
3.15Ensures that the organisation not only commissions specific clinical services but exercises a public health responsibility in ensuring that all services users are safeguarded from abuse or the risk of abuse.
3.16Ensures that safeguarding children and vulnerable adults is identified as a key priority area in all strategic planning processes.
3.17 Ensures that safeguarding children and vulnerable adults is integral to clinical governance and audit arrangements.
3.18Ensures that all providers from whom services are commissioned have comprehensive single and multi-agency policies and procedures for safeguarding which are in line with the LSCB / LSAB policies and procedures, and are easily accessible for staff at all levels.
3.19 Ensures that all contracts for the delivery of healthcare include clear service standards for safeguarding children and vulnerable adults; these service standards are monitored thereby providing assurance that service users areeffectively safeguarded.
3.20 Ensures that all staff in contact with children, adults who are parents/carers and vulnerable adults in the course of their normal duties are trained and competent to be alert to the potential indicators of abuse or neglect for children and vulnerable adults, know how to act on those concerns in line with local guidance.
3.21 Ensures the CCG co-operates with the Local Authority in the operation of the LSCB and LSAB.
3.22Ensures that all health organisations with whom the CCG has commissioning arrangements have links with their LSCB and LSAB; that there is appropriate representation at an appropriate level of seniority; and that health workers contribute to multi-agency working.
3.23Ensures that any system and processes that include decision making about an individual patient (e.g. funding panels) takes account of the requirements of the Mental Capacity Act 2005; this includes ensuring that actions and decisions are documented in a way that demonstrates compliance with the Act.
CCG Board Lead with responsibility for safeguarding
3.25 Ensures that the CCG has management and accountability structures thatdeliver safe and effective services in accordance with statutory, national andlocal guidance for safeguarding and looked after children.
3.26Ensures that service plans/specifications/contracts/invitations to tender etc. include reference to the standards expected for safeguarding children and vulnerable adults.
3.27 Ensures that safe recruitment practices are adhered to in line with national and local guidance and that safeguarding responsibilities are reflected in all job descriptions.
3.28 Ensures that staff in contact with children and or adults in the course of their normal dutiesare trained and competent to be alert to the potential indicators of abuse or neglect and know how to act on those concerns in line with local guidance.
3.29 Ensures CCG have Designated and Professional Leads for Safeguarding MCA.
3.30 To ensure that the CCG fulfils its statutory functions for safeguarding as detailed in statutory and national guidance, providing assurance to the executive lead for safeguarding.
3.31Ensure that there is a CCG Safeguarding Strategy, which includes clear standards for delivery across the adults and children agendas.
3.32 Ensure the CCGs meet the requirements of the MCA, including Deprivation of Liberty Safeguards.
3.33 Ensure that safeguarding children and adults at risk is an integral part of the CCG’s clinical governance framework.
3.34 Promote, influence and develop safeguarding training – on a single and inter-agency basis - to meet the training needs of staff.
3.35 Provide clinical advice on the development and monitoring of the safeguarding aspects of CCG contracts.
3.36 To review and evaluate the practice and learning from all health professionals as part of the serious case review processes and DHR’s.
3.37 To provide advanced expert knowledge and advice on safeguarding children and adults to a wide range of professional groups and organisations/agencies.
3.38 To undertake statutory designated safeguarding functions as outlined in statutory guidance (HM 2015) and detailed in the Intercollegiate Document (RCPCH 2014)
3.39 To provide an annual report on safeguarding which will be considered by the Governing Body.
CCG Individual Staff Members
3.40 To be alert to the potential indicators of abuse or neglect for children and adults and know how to act on those concerns in line with local guidance.
3.41To undertake training in accordance with their roles and responsibilities as outlined by the training frameworks of the LSCB and LSAB and Intercollegiate Competencies so that they maintain their skills and are familiar with procedures aimed at safeguarding children and adults at risk.
3.42Understand the principles of confidentiality and information sharing in line with local and government guidance.
3.43 All staff contributes, when requested to do so, to the multi-agency meetings established to safeguard children and adults at risk.
4.0 Safeguarding Structure
5.0 Safeguarding arrangements
5.1Integrate safeguarding within other CCG functions and contractual arrangements, such as quality and safety, patient experience, healthcare acquired infections management of serious incidents as per the incident reporting policy.
5.2Secure the expertise of designated professionals. Including the expertise of a designated doctor for children and also for Looked After Children (LAC) and a designated paediatrician for unexpected deaths in childhood.
5.3 Safeguarding professionals have appropriate amount of time and support to complete both individual management reviews and health management reports.
5.4 To fulfil the statutory requirement to participate in multiagency case reviews, Serious Case Reviews and Serious Adult Case Reviews as identified by the respective safeguarding boards and also to Domestic Homicide Reviews (DHR) as identified by Home Office/Community Safety Partnerships.
5.5There is a safeguarding adult lead and a lead for Mental Capacity Act 2005 and Deprivation of Liberty Safeguards 2009.
5.6CCG staff, including the Governing Body, are trained to embed safeguarding within the commissioning process and are able to recognise and report safeguarding concerns.
5.7 The CCG, through its designated professionals, will actively work to raise awareness of, and ensure robust arrangements are developed and in place, to address the risk and harm associated with both national and local issues such as; human trafficking, child sexual exploitation, missing children, radicalisation of vulnerable individuals and female genital mutilation.
5.8 The CCG will disseminate national and local publications, alerts, information and data relating to safeguarding adults at risk and children.
5.9The CCG will publicise on its website contact details for staff with specific safeguarding responsibilities, disseminate key learning and themes from local and national enquires and provide links to signpost CCG staff and members of the public to organisations and support to safeguard adults and children at risk of or who have suffered significant harm.
5.10The CCG has incorporated key elements of the PREVENT Strategy within its safeguarding procedures. The CCG is required to ensure that each provider includes the principles contained in the Government Prevent Strategy and has programmes in place to raise awareness.
6.0 Commission safe services
6.1 Have a clear strategy for Children Looked After and the commissioning of appropriate services.
6.2 Ensure that all aspects of safeguarding work and practice are considered and incorporated in all existing provider contracts and Service Level Agreements.
6.3 Service developments take account of the need to safeguard all patients, and are informed where appropriate, by the views of service users and by a Quality Impact Assessment.
6.4 Processes in place to ensure that adult care placements (such as care homes, nursing homes or independent hospitals) are based on knowledge of standards of care and safeguarding concerns by utilising intelligence from monitoring partners, such as the local authority, Care Quality Commission (CQC).
6.5 Strengthen contractual arrangements for children and adults in “out of area” provision for LAC, Unaccompanied Asylum Seeking Children (UASC) and or/residential care for adults with some elements of specialist health need.
6.6 Processes in place to disseminate, monitor and evaluate outcomes of all multiagency case reviews, serious case reviews (SCR) serious adult reviews (SAR) and Domestic Homicide Reviews (DHR) recommendations and actions plan within the CCG and with providers.
6.7 Demonstrate compliance with the Mental Capacity Act and the Deprivation of Liberty Safeguards through systems, processes and outcomes.
6.8 Ensure that there are effective arrangements for sharing information between designated professionals, health partners and also within the multiagency area to ensure the prevention of and protection from harm and abuse for children, young people and adults.
6.9Designated professionals will monitor commissioned NHS provider organisations, safeguarding training compliance and safeguarding systems.
6.10Seek assurance that commissioned providers are meeting their statutory safeguarding responsibilities, and in particular that staff are following approved NICE guidance and that young people are supported in transition from Childrens services to Adult services.
7.0 Safeguarding Children and LAC Training
7.1 A safeguarding training strategy details what is expected of all CCG employees.
8.0 Managing Safeguarding Allegations against staff
8.1The CCG adheres to the Local Authority Designated Officer (LADO) process for dealing with allegations relating to staff conduct towards children or other behaviour which indicates they pose a risk to children. A BHR CCG procedure details the process for dealing with safeguarding allegations against staff.
9.0 Whistleblowing
9.1 A culture of open practice underpins effective safeguarding within an organisation. BHR CCG’s whistleblowing policy contributes to the CCG’s safeguarding children and adult arrangements by supporting a culture where issues can be raised safely and addressed by the organisation.
10.0 Professional Boundaries
10.1 Maintaining professional boundaries is central to providing safe and quality care for patients. It ensures personal and organisational reputation is maintained, professional standards are upheld and statutory requirements are met. Staff should be aware that this responsibility extends to conduct on the internet and in the use of communication devices such as mobile phones and tablets.
10.2 See BHR CCGs Standards of Employment Practice.
11.0 Supervision and Support
11.1 Safeguarding Children supervision is described as an accountable process which supports assures and develops the knowledge, skills and values of an individual, group or team.
11.2 See BHR CCGs supervision policy
12.0 LSCB Escalation and Resolution Policy
12.1 If the referrer remains unclear regarding the outcome of their referral or if there is a difference of opinion regarding the outcome, the referrer should contact the designated professionals for further discussion. Professionals should work to the LSCB Escalation and Resolution Policy if differences cannot be resolved.
13.0 Monitor Assurance
13.1 The strategy will be monitored through the BHR CCGs CQRM and the development of specific action plans to manage progress of assurance reporting, which will be monitored through the Safeguarding Assurance Committee.
13.2 Comprehensive service specifications for children and adults’ services, of which child & adult protection/ safeguarding is a key component, is evident in all contracts with provider organisations. Service specifications include clear service standards and KPIs (key performance indicators) for safeguarding Children & Adults and promoting their welfare, is consistent with LSCB/ LSAB procedures.
13.3 Service specifications and service level agreements are reviewed annually to ensure safeguarding and quality elements of care are monitored within provider contracts.
13.4 Contract monitoring through regular contract management meetings with providers.
13.5 Quality assurance visits to commissioned services and independent providers and the collation of quality and patient safety data and ‘soft’ intelligence will facilitate the identification, monitoring and analysis of safeguarding concerns in relation to vulnerable groups.