Safeguarding Policy [HTML]

1.1      This policy statement outlines the commitment of CCHA (Cardiff Community Housing Association) in relation to the Safeguarding of Adults and Children.

2.1      CCHA are committed to co-creating, with our tenants and communities, neighbourhoods that people want to live in. We want to provide quality services for our tenants, and to dedicate ourselves to continuous improvement. We recognise that our staffing team often work with households that include children and adults at risk.

2.2      CCHA are committed to ensure our residents, communities and staff are safe and protected and that our statutory responsibilities to safeguard and protect children, young people and adults are effectively met.

2.3      CCHA recognise our duty to safeguard collaboratively and in partnership with external agencies particularly local authorities and statutory services and we will support the multi-agency protocols and procedures that are in place including MARAC (Multi-Agency Risk Assessments Conference – information sharing on high risk domestic abuse cases) and MAPPA (Multi-Agency Public Protection Arrangements – to manage risks posed by sexual and violent offenders).

3.1      This policy applies to all staff, volunteers and anyone working for or on behalf of CCHA. Whilst employees, volunteers and contractors are likely to have varied levels of contact with children and adults everyone must be aware of the potential indicators of abuse and neglect and be clear about what to do if they have concerns.

3.2      This policy is developed to meet the requirements of the following legislation and guidance:

Social Services and Well-being (Wales) Act 2014 (legislation.gov.uk);

All Wales Safeguarding Procedures 2019;

Mental Capacity Act 2005 (legislation.gov.uk);

The Children Act 1989 & 2004 Children Act 1989 (legislation.gov.uk);

UN Convention on the Rights of the Child (UNCRC) – UNICEF UK;

National Strategy on Violence against Women, Domestic Abuse and Sexual Violence 2016-2021;

and, Safe recruitment practices.

4.1      The strategic lead for Safeguarding is Corporate Director of People and Places, responsible for providing support, check and challenge to the Safeguarding Lead. The Corporate Director of People and Places acts as the link between the safeguarding operational leads and the Corporate Leadership Team.

4.2      The Board Safeguarding Champion will act as a link between the Safeguarding Lead and the Board, ensure safeguarding is embedded with the work of the Board, ensure the Board acts in accordance with legislation, guidance and CCHA Safeguarding Policy and Procedures.

4.3      The operational leads for safeguarding are and Safeguarding and Partnerships Lead. The Safeguarding and Partnerships Lead is responsible for providing advice, guidance, and support to CCHA Staff and to partner organisations and contractors; case management of complex cases with other agencies, overseeing of case management and ensuring CCHA is meeting its duty to report; sharing of case studies, lessons learned and best practise; analysing safeguarding data. The Head of Housing & Communities is responsible for supporting and monitoring the work of the Safeguarding and Partnerships Lead.

4.4      Safeguarding Champions will be identified across the business and will provide advice, help and support to colleagues with lower-level matters relating to safeguarding. They will provide cover when the Safeguarding Lead is absent.

4.5      All managers should contribute to developing a culture that does not tolerate abuse and takes a safeguarding first’ approach. Managers will encourage people to raise concerns and provide practical and wellbeing support to staff when concerns are identified.

4.6      All staff have a responsibility to be aware of the policy and procedures and to report any concerns in line with the Safeguarding procedure. All members of staff have a duty of care which requires them to report any safeguarding concerns. CCHA expects all staff to take seriously their duty of care and report concerns at the earliest possible time. All staff will act professionally when dealing with a safeguarding concern and will recognise the responsibility to report concerns, not to investigate potential abuse or neglect.

4.7      All contractors are required to undertake safeguarding training and have a duty of care to recognise and report concerns picked up during work in CCHA homes and communities. CCHA works orders include a ‘Report your concern’ page to prompt consideration and reporting.

4.6     This policy will be reviewed every 2 years by the Corporate Director of People & Places.

5.1     The following definitions are from the All Wales Safeguarding Procedures, 2019.

5.2      Adult at risk:               ‘Describes anyone over 18 years of age who is experiencing or is at risk of abuse or neglect and has needs for care and support (whether or not the authority is meeting any of those needs), and as a result of those needs is unable to protect himself or herself against the abuse or neglect or the risk of it.(S 126 of the Social Services and Well-being Act 2014)’

5.3     Child at risk:                ‘This describes an individual under the age of 18 years who is experiencing or is at risk of abuse, neglect, or other kinds of harm; and who has needs for care and support (whether or not the authority is meeting any of those needs). When a child has been reported under section 130 of the Social Services and Well-being Act 2014, the local authority shall make, or cause to be made, such enquiries as they consider necessary to enable them to decide whether they should take any action to safeguard or promote the child’s welfare under section 47 of the Children Act (1989).

5.4     Safeguarding:              ‘preventing and protecting children and adults at risk from abuse or neglect and educating those around them to recognise the signs and dangers.’

5.5     Mental Capacity:         The ability of an individual to understand and retain information and make informed decisions in areas of day-to-day life. The Mental Capacity Act is designed to protect and empower individuals such as adults at risk who may lack the mental capacity to make their own decisions about their care and protection. The Act recognises that an individual may lack capacity to make some decisions but still have the capacity to make other. Moreover, a person may lack capacity to make specific decisions at one point in time but may be able to make the same decision at a later time. The Act assume a person has the capacity to make a decision themselves unless it is proved otherwise. It applies to people aged 16 years and over. Although CCHA staff may give a professional opinion in safeguarding referral where they suspect a lack of capacity; formal mental capacity assessments are carried out by health and social care professionals.

5.6     Concerns:                    ‘Suspicion of abuse or neglect may take the form of ‘concerns’ rather than ‘known facts’ because evidence of harm may not always be present. Rather, practitioners may suspect abuse or neglect of a child or adult at risk. Alternatively, concerns may be based on information derived from a variety of sources and accumulated over time. Practitioners should also remember that their concerns may, in isolation, not be significant. However, alongside those from other agencies and sources they may build up a picture which suggests that a child or adult at risk may be suffering harm, abuse, or neglect.

6.1      CCHA will ensure that all staff, Board Safeguarding Champion, volunteers, and contractors are trained in Safeguarding at a level appropriate to their responsibilities.

6.2      Training will be reviewed regularly and updated every 2 years, training will be role specific.

7.1      Information sharing and collaborative working are critical to effective safeguarding and public safety. CCHA recognises our duty to share information to protect the vital interests and safety of individuals and the public and to fulfil our statutory obligations.

Information will be shared in accordance with legislative frameworks (i.e., GDPR and Data Protection Act 2018) and information sharing protocols to which CCHA is signed up (i.e., Wales Accord on the sharing of personal information – WASPI).

CCHA will seek to be included in multi-agency fora for the discussion of risk, where individuals living in CCHA properties may be discussed, for the purpose of contributing to a multi-agency approach and to enable us to be proactive and effective in safeguarding people in our homes. Such for a include Domestic Abuse Conferences.

The sharing of personal information, including the processing of special category data, is required on matters of safeguarding. CCHA will ensure due regard is given to data protection principles as outlined in the Data Protection Act i.e.,

• We will only share what is necessary for the purpose at hand.
• We will document what we share and the reasons for doing so.
• Any information we receive will be treated in strict confidence and retained securely.
• We will only use information that we receive for the purpose it was shared with us.
• We will not store confidential information longer than necessary.

8.1      Staff Wellbeing – CCHA acknowledges the emotional impact on staff working in roles where they come into contact, directly or indirectly, with homes and situations in which children or adults may be at risk of, or experiencing, abuse or neglect.

CCHA will always support staff reporting concerns in good faith and will encourage staff to challenge and report where they are not satisfied that a concern is being treated appropriately.

Staff are encouraged to share their experiences, and any associated feelings or wellbeing issues in the way they find most comfortable. This may be in the following ways:

• Informal discussion and debriefing with colleagues within the team or colleagues with whom you have a good relationship;
• Debriefing and discussion with line manager;
• Debriefing and discussion with Safeguarding and Partnerships Lead;
• Discussion with People team;
• Utilising Simply Health Employee Assistance Programme to access the 24-hour support line or to access counselling where needed.

8.2      Risk to staff – There may be instances where the reporting of a concern might lead to fear of threats, verbal abuse or violence from an individual or family that is the subject of a report. As professionals cannot report anonymously, CCHA recognises that some staff are more at risk of repercussions than others. These include staff that live nearby to the property where the concern had been raised or those who are well-known in the local area and staff that are likely to visit a property often as part of their role where their ability to do this may be compromised if they make a report (e.g. M-Team/Contractors).

In most circumstances staff identifying concerns would be expected to discuss these with the family or individual involved and work with them in a collaborative and supportive way where it is safe to do so. Where this is not possible, CCHA will put measures in place to remove the staff member from the referral process by:

• Arranging for another member of staff to visit that can make the report;
• Arrange a call to the person by the Safeguarding and Partnerships Lead to explain our duty to report and the possible benefits to the family of a referral;
• Request that safeguarding teams refer to the Safeguarding and Partnerships Lead in any communication to the individual rather than to the member of staff that may be vulnerable.

9.1      CCHA has an obligation to ensure we only recruit and employ staff working with children, young people and adults at risk who are competent and safe to do so. We will undertake the necessary DBS (Disclosure & Barring Service) checks. We will ensure via our procurement processes that our contractors and sub-contractors also comply with these requirements