1.0 Policy Statement

United St Saviour’s Charity (UStSC) is committed to protecting the welfare of beneficiaries, staff and others who directly or indirectly engage with the charity’s services and/or activities.  It aims to take all necessary steps to stop abuse happening, whether that abuse is perpetrated by staff, trustees, volunteers, family members, members of the public or other service users.

This policy outlines the charity’s approach to safeguarding across its full a range of activities and those who engage with them.  This includes almshouse residents, employees and volunteers, and Community Investment partners.

As predominantly a housing provider for older people, UStSC has a very specific set of responsibilities for safeguarding adults.  As such, this policy and the associated procedures includes significantly more detail on the safeguarding of vulnerable adults than of children and young people. For this reason, One Southwark, a project provided by UStSC, offering community-based support to children and young adults, has a separate Safeguarding Procedure. (See One Southwark Safeguarding Children and Vulnerable Adults Procedure)

 

2. Purpose and Scope of the policy

The purpose of this policy is to provide a framework for all staff, trustees and volunteers within United St Saviour’s Charity.  The scope of the policy is broad and covers:

  • Almshouses
  • One Southwark
  • Community investment grantees and partners
  • Employees and volunteers

This policy aims to ensure that staff, volunteers, researchers and trustees are aware of what “safeguarding” means and to understand the actions that should be taken if they have cause to suspect a person engaging with the charity (directly, or indirectly) is at risk of abuse or neglect.

In respect of the almshouses, this policy should be used in conjunction with the Adults at Risk Safeguarding Procedure to prevent and reduce the risk of abuse to all adults. The One Southwark Safeguarding Procedure should be used for children who may be at risk. The principles and procedures covering grant applicants and partners, and employees and volunteers, are included as part of this policy.

The charity is not directly responsible for safeguarding the beneficiaries of its partner organisations but recognises the important role it can play in contributing to the enhancement of safeguarding. As such, we will be rigorous and diligent in our Community Investment and grant-making, and play a supportive role with to develop or improve our partners’ approach to safeguarding as necessary.

The Head of Housing is the Designated Safeguarding Lead for the charity and as such has lead responsibility for responding to concerns.

 

3. Commitments

The charity is committed to promoting the welfare of adults and children at risk and recognises that everyone has the right to protection from abuse regardless of protected characteristics including age, gender, marriage or civil partnership, racial heritage, disability, sexual orientation and identity, religious belief and gender re-assignment.

The charity is committed to ensuring that people with care and support needs who live in our almshouses live free from abuse, harm, exploitation and neglect and that working practices minimise the risk of such abuse.

The charity also recognises the responsibility it has towards our own staff, volunteers and trustees and will put appropriate mechanisms in place to make sure that a safe environment is created for them. It is committed to ensuring all staff and volunteers, including those with designated responsibilities, have received appropriate levels of up-to-date safeguarding and related training.

 

4. Legislation, associated guidance and policies

For UStSC to meet its statutory responsibilities, the following legislation, associated guidance and policies are of significance (N.B. This is not an exhaustive list).

  • Care Act 2014
  • Mental Capacity Act 2005
  • Modern Slavery Act 2015 and Modern Slavery and Human Trafficking: National Referral Mechanism
  • Public Interest Disclosure Act 1998
  • London Multi-Agency Adult Safeguarding Policy & Procedures
  • Working Together To Safeguard Children 2023
  • Charity Commission guidance on Safeguarding and Reporting of Serious Incidents
  • Local Adult Safeguarding Board policies in LB Southwark and LB Croydon
  • Association of Charitable Foundations guidance
  • National Almshouse Association guidance
  • Disclosure and barring Service guidance
  • Data Protection Act and General Data Protection Regulations and UStSC Policy
  • UStSC Whistleblowing Policy
  • The Children Acts 1989 and 2004, which provide a framework for the care and protection of children
  • Section 5B(11) of the Female Genital Mutilation Act 2003, as inserted by section 74 of the Serious Crime Act 2015, which places a statutory duty on teachers and other professionals to report to the police where they discover that female genital mutilation (FGM) appears to have been carried out on a girl under 18
  • Prevent duty guidance: England and Wales (2023)
  • Statutory guidance on FGM, which sets out responsibilities with regards to safeguarding and supporting girls affected by or at risk of FGM
  • Sexual Offences Act 2003, Serious Crime Act 2015 and Voyeurism Act 2019
  • The Rehabilitation of Offenders Act 1974 (exceptions order 1975), which outlines when people with criminal convictions should disclose these to prospective employers.
  • Schedule 4 of the Safeguarding Vulnerable Groups Act 2006 and the Protection of Freedoms Act 2012, which define what ‘regulated activity’ is in relation to children and vulnerable adults
  • Statutory guidance on the Prevent duty, which explains organisations’ duties under the Counter Terrorism and Security Act 2015 with respect to protecting people from the risk of radicalisation and extremism
  • The Disqualification under the Childcare Act (DUCA) Regulation 2018 , which sets out who is disqualified from working in early years or later years childcare
  • Mental Capacity Act 2005 and the Mental Capacity Act Code of Practice 2007 (both to be updated when the Mental Capacity (Amendment) Act 2019 come into force in 2020/21)
  • Human Rights Act 1998

 

5. Key terms and definitions

Safeguarding means protecting a persons’ right to live in safety, free from abuse or neglect, while at the same time making sure that their wellbeing is promoted. This includes having regard to their views, wishes, feelings and beliefs in deciding on any action, as appropriate.

Examples of abuse and neglect include, but are not limited to: physical, sexual, psychological or emotional, financial or material, discriminatory, and organisational abuse; neglect (including acts of omission); self-neglect; radicalisation and enforced gang membership. Other examples of abuse many include domestic violence; sexual offences; stalking; female genital mutilation (FGM); crimes said to be committed in the name of ‘honour’; forced marriage; prostitution; and human trafficking for sexual exploitation.

 

6. Policy Principles

All allegations, concerns or suspicions of abuse or neglect are taken seriously and responded to within the steps laid out in the corresponding procedure.

All staff have a responsibility to ensure they are informed, trained and understand their duty to operate within this policy and procedure.  All staff, trustees and volunteers have a shared responsibility to take appropriate steps to protect adults and children at risk.

All UStSC employees have a duty to act upon and report actual, suspected or allegations of abuse in line with the Code of Conduct.

We will develop and foster a culture of openness, dialogue and trust in our approach to safeguarding; ensuring that staff, partners and residents feel comfortable and able to report concerns and issues to us and to relevant authorities.

  • We will record and refer all concerns, suspicions or allegations of abuse or neglect to the lead agencies or team responsible for carrying out safeguarding assessments and enquiries, specifically the Local Authority in line with section 42 of the Care Act 2014 and The Children Acts 1989 and 2004, which provide a framework for the care and protection of children.

We will do this only with consent from the adult at risk, unless they lack capacity or there is an overriding public interest consideration. Referrals of children will be in line with the Pan London Safeguarding Children Procedures.

We will work in partnership with lead agencies and relevant partners, to respond to suspicions or incidents of abuse or make safeguarding enquiries in accordance with statutory procedures.

We will report any incidents of abuse that we suspect are a criminal offence to the Police. We will treat any disclosures of actual historical abuse in the same way as an allegation, disclosure or suspicion of current abuse.

We will share information for the purposes of safeguarding, and will comply with the statutory duty to provide information where requested. We will adhere to principles for sharing information.

We will handle data in accordance with the Data Protection Act, General Data Protection Regulation and the UStSC Data Protection Policy.

We will involve adults at risk of abuse in any safeguarding decisions. However, where someone is judged as not having capacity to make an informed decision about their own wellbeing, these will be made in their best interest on their behalf. This decision will be made in accordance with the requirements of the Mental Capacity Act 2005, and in liaison with the necessary statutory services and agencies, involving carers and family members as appropriate.

We will provide employees with role appropriate training so that they understand their roles and responsibilities in relation to safeguarding and are enabled to identify, and report the signs of abuse in accordance with safeguarding procedures.

We will meet our responsibilities in the safe recruitment, selection and vetting of employees and volunteers by using the Disclosure and Barring Service and undertake any other pre-employment screening checks as appropriate.

We will provide support and supervision for employees, creating a safe environment in which they feel able to report safeguarding issues, including where they have concerns about the behaviour of another UStSC in line with our Whistleblowing Policy.

We will address any allegations or suspected abuse by UStSC employees through formal statutory investigative procedures and our own internal disciplinary procedures.

We recognise the emotional impact on staff of recognising and reporting safeguarding concerns. Employee support will be available through line managers.

 

7. Policy Commitments – Almshouses and One Southwark

A detailed ‘Adults at Risk’ Safeguarding Policy and Procedure applies to UStSC’s almshouse residents and is attached to this document. This follows definitions laid down in The Care Act 2014 and follows that safeguarding duties will apply to an adult (someone over the age of 18) who:

  • has needs for care and support (whether or not the Local Authority is meeting any of those needs);
  • is experiencing, or at risk of, abuse or neglect; and
  • as a result of those care and support needs is unable to protect themselves from either the risk, or experience, of abuse or neglect.

A detailed Children’s Safeguarding Procedure applies to children who engage with One Southwark and is attached to this document. This follows definitions laid down in The Children Acts 1989 and 2004 and follows that safeguarding duties will apply to children (someone under the age of 18)

UStSC will apply the Department of Health’s six key safeguarding principles when working with Adults and Children at Risk of abuse: empowerment, protection, prevention, proportionality, partnership and accountability.

 

8. Policy Commitments – Employees and Volunteers

The charity’s approach to safeguarding the welfare of employees and volunteers is underpinned by the suite of human resource, and health and safety policies and procedures, including Health and Safety, Volunteering and Interns, Whistleblowing, and Performance Management.

The Employee Code of Conduct and the organisational values (and expected behaviours) support the safeguarding principles outlined in this policy.  The 6 core values are woven into the way that the charity supports its staff and volunteers, and these particularly encourage openness, trust and honesty – something that underpins safeguarding principles.

To safeguard the welfare of almshouse residents, Enhanced DBS checks will be carried out on all staff (carrying out a regulated activity) working with older residents prior to their appointment. Trustees may also be required to undertake a DBS check if undertaking a regulated activity.

 

9. Policy Commitments – Community Investment and Grant-making

As a grant-maker, UStSC is not directly responsible for safeguarding the beneficiaries of its partner organisations but recognises that it can play an important role in contributing to the enhancement of safeguarding by being rigorous and diligent.  In line with our objective of strengthening local groups, the charity will also support and assist its partners to develop or improve their safeguarding approach.

At all stages of grant-making/management UStSC will adopt a principle of relevance and proportionality; this means applying more rigour where beneficiaries are potentially more vulnerable and proportionate in terms of the size of the partner organisation and level of grant.

All groups receiving grants will be expected to have a safeguarding policy and procedure in place.  It will apply a principle of proportionality and so the level of policy and procedure detail will depend on the nature of the organisation’s activities. Any partner working with vulnerable adults or children will be expected to have policies and procedures appropriate to the higher level of risk.

9.1        Community Investment Procedures and Requirements

Assessing applicants for funding

Large Grants (all applicants)

  • Online application form (full application) will ask for Safeguarding Policy as basic check
  • Full application due diligence: upload and check Safeguarding Policy
  • Due diligence (prior to approval of grant), assessments of safeguarding competence carried out (include question such as: have you had any safeguarding concerns recently? If so, please explain the process that you followed

Small Grants

  • Online application form asks for Safeguarding Policy or Approach as basic check
  • For those groups working with vulnerable adults or children, due diligence assessments will be carried out by staff as above.

Monitoring

Large Grants (all applicants and grants partners)

  • Grant conditions document includes expectation of partners to apply and update Safeguarding policy and approach. Provision for withdrawal of grant if proper procedures are not followed is included.
  • Monitoring visits (normally 6 monthly) to include question on safeguarding as per the assessment stage above

Strengthening and Supporting

UStSC’s ‘Funding Plus’ programme is designed to build the knowledge, capacity and impact of partners.  Developing knowledge and capacity around safeguarding is an integral part of this.  This will include:

  • Resources and signposting to the ‘Resources’ section of the USS website
  • Delivering Safeguarding training for partners (through specialists)
  • Connecting organisations who can share good practice and support each other

Community Investment Staff Training

To ensure that grant-making staff have sufficient knowledge to assess whether a partner’s approach to safeguarding is adequate, training will be provided.

If a member of UStSC staff believed that a CI partner was not dealing adequately with allegations or incidents of abuse which had to our attention, they will report the matter to the charity’s Designated Safeguarding Lead. The charity may then decide to report the matter to the Charity Commission or Local Authority Social Services directly.

 

10. Monitoring, continuous improvement and dissemination

This policy will be reviewed every two years – unless legislation, business or sector developments require otherwise – to ensure that it continues to meet the stated objectives and take account of good practice developments.

Almshouse residents will be informed each time this policy is reviewed and copies will be made available to them at their almshouses and on the website.