Policies
Safeguarding Children & Young People Policy & Procedure

We are Committed to these principles and processes that guide our practice:

• We comply with safeguarding legislation, statutory guidance, multi-agency policies and procedures and keep up to date with changes in practice. We are responsive to the safeguarding requirements of The Charity Commission and our commissioning partners. See legislation at the end of this policy
• We promote a listening and safeguarding ethos across Housing Justice and have a ‘zero tolerance’ approach to harmful practices including bullying
• We act on the understanding that everyone has the right to protection from abuse, whatever their age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, sexual orientation or any other difference
• We act on the understanding that the safety and welfare of our guests and other people that we work with is paramount
• We apply safer recruitment processes so that people who are recruited to work in our organisation and deliver services are suitable to do so
• We take all suspicious allegation of abuse seriously and respond swiftly and appropriately
• We work in partnership with other agencies sharing good practice, information and concerns with other agencies that need to know
• Providing education, advice, and support to the adults we work with so that they can understand and manage their own safety and risks in order to protect themselves from threats of or actual abuse
• Providing accommodation which assists to uphold and ideally improve the well-being of the adults and children we support
• Recognising potential signs and indicators of abuse and taking action to raise these as concerns in the safeguarding reporting process
• Ensuring we have clear policies, training, management support, and guidance so that our staff and volunteers have clear direction and assistance to fulfil their responsibilities
• Ensuring our organisation lives up to its values and fulfils its legal and ethical responsibilities through good governance and leadership.

1:3 Safeguarding means:
• Protecting from abuse and maltreatment
• Preventing harm to children’s health or development
• Ensuring children grow up with the provision of safe and effective care
• Taking action to enable the person to have the best outcomes.

1:4 Child Protection is defined as the process of:
Protecting individual children identified as either suffering, or at risk of suffering, significant harm as a result of abuse or neglect
Responding to circumstances that arise
Safeguarding children and child protection guidance and legislation applies to all children up to the age of 18, at this age parental responsibility for the child ceases.

The law recognises that children and adults are different and should be treated differently. Children, by definition, are dependent on their parents or carers in a way in which adults are not. They are vulnerable by virtue of their lack of understanding and autonomy and their welfare is primarily the responsibility of their parents or carers. They lack the capacity to make decisions about their own lives so rely on adults to make such decisions for them.

1:5 Paramountcy Principle
A key principle of the Children Act 1989 is that the welfare of the child is paramount. This refers to a child-centred approach which is fundamental in safeguarding every child. It means keeping the child’s best interest in focus and at the heart of all decisions.
Where there is a possible child protection issue, priority should be given to ensuring safety and well-being of the child–even if this is at the expense of an adult.

1:6 Context of Abuse and Neglect
Abuse and neglect are types of maltreatment. One may abuse or neglect another person by inflicting harm, or failing to act to prevent harm.

Safeguarding concerns may arise in many contexts and can vary in terms of nature and seriousness.

Abuse may be perpetrated by a child or children, an adult or adults. Neglect may be perpetrated by an adult or adults. Perpetrators may include:
• Family members including spouses, partners and children
• Neighbours, acquaintances
• Local residents, community members
• Paid staff, professional and volunteers
• Carers

Abuse and neglect can happen over a period of time but can also be a one-off event. People may experience more than one type of abuse, as well as other difficulties in their lives. Abuse and neglect can have major long-term impacts upon the development of a child and young person into adulthood.

1:7 Historical or ‘non-recent’ allegations of abuse.
This refers to concerns about abuse or neglect that happened more than a year ago.
In many circumstances, victims of abuse may find it difficult to speak about or report their experiences of abuse and neglect. For many people, childhood experiences of abuse are not disclosed due to them not feeling safe to speak out or having trusted adults to talk to. This trauma has significant impact upon the development of children and young people.
Regardless of time lapse, it is important to take historical or ‘non-recent’ allegations seriously and act in accordance with this procedure, even if the child is no longer at risk of harm. It should be noted that the alleged perpetrator may remain a risk to other children and young people.

1:8 Housing Justice will ensure that:
• Children and young people are listened to, valued and respected
• Staff are aware of the need to be alert to the signs of abuse and know what to do with their concerns
• All paid and unpaid staff are subject to rigorous recruitment procedures
• All paid and unpaid staff are given appropriate support and training.

1:9 An Effective Safeguarding Culture requires all workers to:
• Monitor their own work and be insightful and reflective about their practice
• Work openly and transparently and inform their manager when they believe that their acts or omissions have fallen short of professional expectations
• Monitor the work of others: colleagues, managers, external professionals, friends and families of the adults they work with and raise concerns with their manager or their manager’s manager immediately as they arise
• Provide well-led services where managers are open, supportive, and inspire trust and confidence to their teams
• Refrain from promoting/evangelising religious beliefs to guest and hosts and proselytising membership or active involvement within a religious, political, or organisational activity and/or membership.

Senior management are fully committed to good practice and are willing to reflect and make changes to policies, protocols etc. which do not meet service needs or the needs of the adults/children at risk.

If you have concerns about reporting a matter, regardless of the status of the alleged person, please discuss it with your manager. If you make a professional disclosure, you will be protected by the organisation, provided that your report is made in good faith.

1:10 Responding to a Child about Safeguarding Concerns:
Children and young people who have safeguarding needs can expect staff working at Housing Justice to respond and support with:
• Vigilance: to have staff notice and ask when things are troubling them
• Understanding and action: to understand what is happening and to respond
• Stability: to have stable and consistent relationships of trust with people helping them
• Respect: to be treated with respect
• Information and engagement: to be involved in decisions and plans
• Explanation: to be told about outcomes and reasons
• Advocacy: to have assistance to put forward views

When a child or young person shares that they have suffered or are experiencing harm, this is called making a ‘disclosure’. This information may need to be reported to another agency and there may be criminal or safeguarding inquiries that follow.

A member of staff/volunteer who first hears a disclosure may not be the person who decides whether abuse has occurred. Such concerns must be reported to the safeguarding lead and the reporting flow chart should be adhered to. This will indicate who will make the decision as to whether a referral to another agency is required. The Police and Children’s Social Care are responsible for undertaking such inquiries and for making decisions following a referral being made.

Section 2: Responsibilities

2:1 All workers: paid staff, locum workers, agency workers, sessional workers, students on placement, will:
• Ensure that their own practice is in line with the principles of effective service provision
• Be alert to signs and indicators that a child may be at risk of, or experiencing abuse
• Work with guests, hosts and other partners to prevent or minimise circumstances which can increase the risk of abuse e.g. isolation, unhealthy relationships, poverty
• Empower guests hosts and other partners to have open conversations about safeguarding, equality or radicalisation
• Appropriately challenge unacceptable views, attitudes, or behaviours in line with the Equality Act 2010 and EDI Policy frameworks
• Offer guests, hosts and other partners opportunities to provide feedback on our services e.g. email, phone, face to face, written surveys, internal/external quality audit reviews
• Maintain clear and comprehensive records in client files as required by the job role
• Keep risk management plans and support plans up to date as required by the job role
• Communicate any safeguarding concerns to your Manager or Safeguarding LeadContribute towards whatever actions are needed to safeguard and promote the well-being of the child and young person, including completing incident forms and attending/contributing at meetings
• Promote awareness of abuse and provide support and guidance to the adults/children they work with including discussing safeguarding in guest liaison meetings
• Engage openly and fully in training and supervision.

2:2 The London Catalyst Team Leader will:
• Identify and report safeguarding risks in their individual projects
• Ensure this procedure is implemented and that reporting structures are used and followed within the project they co-ordinate
• Ensure they are aware of the service’s local contact for the following Prevent and know how to refer concerns about radicalisation to the appropriate Prevent Channel
• Ensure they are aware of the local community support for young people aged 16 years and over in relation to Domestic Abuse and how to refer concerns and complete the Domestic Abuse, Stalking and Honour Based Violence (DASH 2009) risk identification and assessment.
• Support staff with the completion of the DASH risk identification and assessment form
• Ensure they are aware of how to refer any concerns about modern slavery to the National Referral Mechanism (NRM).

2:3 Managers (Hosting Project Manager / Best Practice and Innovation Team Manager) will additionally:
• Induct all workers in the safeguarding policy
• Ensure that all workers receive relevant training, including refresher training
• Monitor the reporting and recording of safeguarding internally/externally, ensuring it is accurate, timely and centred around the individual concerned, liaising with the Safeguarding Lead as appropriate
• Support and advise their team regarding safeguarding matters, ensuring safeguarding is discussed in team meetings and during supervision
• Be familiar with the Local Safeguarding Children’s Board (LSCB) procedures for reporting
• Ensure other requests from the LSCB, and the process for challenging lack of action or disagreement with the local authority (often called the escalation or dissent procedure) is actioned in a timely manner
• Liaise with external professionals as appropriate
• Participate fully and with candour during safeguarding enquiries/investigations
• Ensure all cases are managed in accordance with good practice and this policy
• Create an open and supportive culture for their team.

2:4 The Volunteer Services Manager will additionally:
• Produce a safeguarding policy and procedure for all volunteers, updated every 3 years, as a minimum
• Produce a volunteer handbook which includes guidance on safeguarding and professional boundaries
• Produce training and written guidance for workers who manage volunteers on local volunteer induction and volunteer supervision, to include reference to safeguarding
• Deliver volunteer safeguarding training
• Ensure all workers and volunteers are kept updated on safeguarding issues as required.

2:5 The Safeguarding Leads will additionally:
• Review safeguarding incident reports
• Provide advice and support through the line management structure when safeguarding matters occur
• Support staff to make referrals to appropriate agencies, including the Local Authority
• Support staff to work constructively with partners, including Local Authorities, Police, NHS and other providers
• Monitor the quality of responses from services
• Conduct a six-monthly review of all medium-high rated safeguarding incidents and provide a summary report to the Board of Trustees’ safeguarding lead. This will include analyses of numbers, serious cases and lessons learned, recommendations, and planned action.
• Produce an annual safeguarding report for the Board of Trustees
• Represent the organisation at external reviews.

NB The Safeguarding Lead for England is Jacob Quagliozzi, Director for England.
The Safeguarding Lead Designate for Wales is Bonnie Navara, Director for Wales.
Each will act as the Deputy for the other (annual leave, absence etc.)

2:6 The Chief Executive Officer (CEO) will:
• Be responsible for ensuring the organisation is well-led
• Line manage the Safeguarding Lead for Children
• Ensure good governance, highlight incidents reportable to the Charity Commission to the Board of Trustees and, where directed by them, to make the report.
• Investigate safeguarding allegations made against staff and be the contact for The Local Authority Designated Office (LADO).

2:7 The Board of Trustees will:
• Fulfil the Charity Commission’s expectations around duty of care to take necessary steps to safeguard and take responsibility for children at risk, acting in their best interests and ensuring all reasonable steps are taken to prevent harm
• Assess the risks that arise from the charity’s activities and operations involving children
• Ensure that appropriate safeguarding policies and procedures are in place
• Monitor to ensure that these safeguards are being effectively implemented in practice e.g. reviewing the annual safeguarding report and challenge as appropriate
• Ensure reportable incidents are made to the Charity Commission
• Appoint a safeguarding lead
• Investigate safeguarding allegations against the CEO and work in partnership with The Local Authority Designated officer (LADO)
• Monitor the role of the CEO in carrying out their responsibilities.

NB The Trustee Safeguarding Lead is Brian O’Doherty, Vice Chair of the Board of Trustees

The Safeguarding Leads for Children are: Jacob Quagliozzi Director for England & Bonnie Navara, Director for Wales.

Follow the reporting flow chart – Call the Children’s Safeguarding Lead If not available, speak to another senior member of staff as a matter of urgency

Police: non-emergency Tel 101 / Emergency Tel 999 Police

Anti-terrorism Hotline Tel 0800 789 321

In an emergency situation, contact either: Children & Families Social Services Duty Desk or, out of office hours: The Emergency Duty Team, – Your Local Authority can give you this information

Use following website England: https://www.gov.uk/report-child-abuse-to-local-council

Safeguarding boards across London: https://www.londonscb.gov.uk/london-scb-contacts

NSPCC Helpline – 0808 800 500

Section 3: Forms of Abuse

3:1 Working Together to Safeguard Children 2018 sets out four categories of abuse and neglect that children may experience. It recognises that children may be vulnerable to neglect and abuse or exploitation from within their family and from individuals they come across in their day-to-day lives. These threats can take a variety of different forms, including: sexual, physical and emotional abuse; neglect; domestic abuse, including controlling or coercive behaviour; exploitation by criminal gangs and organised crime groups; trafficking; online abuse; sexual exploitation and the influences of extremism leading to radicalisation. This is not an exhaustive list and abuse and neglect can take place in many forms and in many circumstances. It is important when we are engaging with families, children and young people that we are alert to any concerns about their well-being and safety.

Housing Justice’s engagement with children and young people is peripheral to the core work undertaken. However, we ensure we will be vigilant and proactive in the protection of children and young people. The four categories are defined below with generalised signs and indicators of abuse also listed. The signs are not exhaustive and may vary from child to child, depending on their experiences, age and development stage, their resilience and degree of vulnerability. There may be limited or no signs for some children who are being abused and children whose English is a second/foreign language, children with speech, language and communication needs or children whose behaviour may be correlated to their disability instead of a possible sign of abuse. The behaviour of parents can also indicate if a child is being harmed or at risk, therefore parent-child interactions should be observed and recorded. Additionally, parents struggling with addictions and/or emotional mental health difficulties may struggle with parenting and this may have a negative impact upon the child and young person.

3:2 Category of Harm- Physical Abuse:
Deliberately hurting a child, causing injuries such as bruises, broken bones, burns or cuts. Physical abuse isn’t accidental – children who are physically abused suffer violence such as being hit, kicked, poisoned, burned, slapped or having objects thrown at them. Shaking or hitting babies can cause non-accidental head injuries (NAHI). Sometimes parents or carers will make up or cause the symptoms of illness in their child, perhaps giving them medicine they don’t need and making the child unwell–this is known as fabricated or induced illness (FII).

Possible Signs and Indicators: Bruising caused by finger mark or grasp marks on the limbs or chest of a small child, bites, burn and scald marks; small round burns that could be caused by a cigarette, fractures to arms, legs or ribs in a small child, large numbers of scars of different sizes or ages.

3:3 Category of Harm- Emotional Abuse:
The ongoing emotional maltreatment of a child. It’s sometimes called psychological abuse and can seriously damage a child’s emotional health and development. Emotional abuse can involve deliberately trying to scare or humiliate a child or isolating or ignoring them. Children who are emotionally abused are often suffering another type of abuse or neglect at the same time–but this isn’t always the case.

Possible Signs and Indicators: Excessively clingy, attention-seeking behaviour, very low self-esteem, excessive self-criticism, excessively withdrawn behaviour, fearfulness; a ‘frozen watchfulness’, despondency, lack of appropriate boundaries with strangers (e.g. too eager to please), eating disorders.

3:4 Category of Harm-Sexual Abuse:
A child is sexually abused when they are forced or persuaded to take part in sexual activities. This doesn’t have to be physical contact and it can happen online. Sometimes the child won’t understand that what’s happening to them is abuse. They may not even understand that it’s wrong. They may be afraid to speak out. The Sexual Offences Act 2003 protects children up to the age of 18 years.

Possible Signs and Indicators: Allegations or disclosure, Older children and young people may additionally exhibit: depression, drug and/or alcohol abuse, eating disorders; obsessive behaviours, self-mutilation; suicide attempts; school/peer/relationship problems.

Child Sexual Exploitation: Child sexual exploitation (CSE) is a type of sexual abuse. Children in exploitative situations and relationships receive something such as gifts, money or affection as a result of performing sexual activities or others performing sexual activities on them. Children or young people may be tricked into believing they’re in a loving, consensual relationship. They might be invited to parties and given drugs and alcohol. They may also be groomed and exploited online. Some children and young people are trafficked into or within the UK for the purpose of sexual exploitation. Sexual exploitation can also happen to young people in gangs.

Domestic Abuse: Witnessing domestic abuse is really distressing and scary for a child, and causes serious harm. Children living in a home where domestic abuse is happening are at risk of other types of abuse too. Children can experience domestic abuse or violence in lots of different ways. They might: see the abuse, hear the abuse from another room; see a parent’s injuries or distress afterwards; be hurt by being nearby or trying to stop the abuse. Domestic Abuse also includes:
• Forced Marriages: No faith supports the idea of forcing someone to marry without their consent. This should not be confused with arranged marriages between consenting adults. A young person cannot legally marry or have a sexual relationship until they are 16 years old or more in the UK
• Honour based violence: (HBV) can be described as a collection of practices, which are used to control behaviour within families or other social groups to protect perceived cultural and religious beliefs and/or honour. Such violence can occur when perpetrators perceive that a relative has shamed the family and/or community by breaking their honour code. It is not just physical violence; the harm can also be emotional
• Female Genital Mutilation (please refer to section below)
Possible Signs and Indicators: Aggression, anti-social behaviour, depression, anxiety, stress, nervousness, poor performance at school, low self esteem

Female Genital Mutilation (FGM): The partial or total removal of external female genitalia for non-medical reasons. It’s also known as female circumcision or cutting. Religious, social or cultural reasons are sometimes given for FGM. However, FGM is child abuse. It’s dangerous and a criminal offence. There are no medical reasons to carry out FGM. It doesn’t enhance fertility and it doesn’t make childbirth safer. It is used to control female sexuality and can cause severe and long-lasting damage to physical and emotional health.

Possible Signs and Indicators: Communities traditionally affected by FGM and who are less integrated into the UK may be at greater risk of carrying out FGM, if a child’s mother or her older sister has undergone FGM, then the risk increases. A child may be withdrawn from personal, social and health education or personal and social education so that she remains uninformed about the procedure and her rights. The child may talk of having a long holiday to their country of origin where the practice is prevalent or refer to a “special procedure” or having a ceremony to “become a woman”. They may be taken out of the country for an extended visit or make reference to FGM or they may tell you that a senior female family member is in the country, particularly if she is visiting from their country of origin. Indicators that FGM may have already taken place include: bladder and menstrual problems and reluctance to receive medical attention or participate in physical activities.

3:5 Category of Harm- Neglect: The ongoing failure to meet a child’s basic needs and is the most common form of child abuse. A child may be left hungry or dirty, without adequate clothing, shelter, supervision, medical or health care. A child may be put in danger or not protected from physical or emotional harm. They may not get the love, care and attention they need from their parents. A child experiencing neglect will often suffer from other forms of abuse too. Neglect is dangerous and can cause serious, long-term damage–even death.

Possible Signs and Indicators: Inadequate supervision; being left alone for long periods of time, lack of stimulation, social contact or education, inadequate nutrition, leading to ill-health, constant hunger; stealing or gorging food, failure to seek or to follow medical advice such that a child’s life or development is endangered or wear inappropriate clothing for the conditions.

3:6 Additional Types and indicators for Abuse and Neglect
Abuse and neglect are complex issues and can occur in additional ways, such as those listed below with signs and indicators that accompany them.

Online Abuse: Online abuse is any type of abuse that happens on the web, whether through social networks, playing online games or using mobile phones. Children and young people may experience cyberbullying, grooming, sexual abuse, sexual exploitation or emotional abuse. Children can be at risk of online abuse from people they know as well as from strangers. Online abuse may be part of abuse that is taking place in the real world (for example bullying or grooming) or only happen online (for example, persuading children to take part in sexual activity online).Children can feel like there is no escape from online abuse–abusers can contact them at any time of the day or night, the abuse can come into safe places like their bedrooms. Images and videos can be stored by the abuser and shared with other people.

Possible Signs and Indicators: appears nervous when receiving a text, instant message, or email, seems uneasy about going to school or pretends to be ill, unwillingness to share information about online activity, unexplained anger or depression, especially after going online, abruptly shutting off or walking away from the computer mid-use, withdrawing from friends and family in real life, unexplained stomach aches or headaches, trouble sleeping at night, unexplained weight loss or gain, suicidal thoughts or suicide attempts.

Exploitation by Radicalisation: Comparable to other forms of exploitation, such as grooming and Child Sexual Exploitation. The aim of radicalisation is to attract people to their reasoning, inspire new recruits and embed their extreme views and persuade vulnerable individuals of the legitimacy of their cause. This may be direct through a relationship, or through social media.

Possible Signs and Indicators: Radicalisation can be really difficult to spot. Signs that may indicate a child is being radicalised include: isolating themselves from family and friends, talking as if from a scripted speech, unwillingness or inability to discuss their views, a sudden disrespectful attitude towards others, increased levels of anger, increased secretiveness, especially around internet use. Children who are at risk of radicalisation may have low self-esteem or be victims of bullying or discrimination. Extremists might target them and tell them they can be part of something special, later brainwashing them into cutting themselves off from their friends and family. These signs don’t necessarily mean a child is being radicalised–it may be normal teenage behaviour or a sign that something else is wrong. If these indicators are noted they must be recorded and escalated to the Safeguarding Children Lead.

Criminal Exploitation:
When a child or young person is manipulated and coerced into committing crimes. Through the use of violence or grooming and pressure, they may be forced into activities such as stealing or carrying drugs or weapons and be put into dangerous situations. This may involve being part of a gang which is linked to illegal activity.

‘County Lines’ is a term the police use for urban gangs that exploit children and vulnerable adults into moving drugs from a hub–normally a large city–into areas such as suburbs, markets and coastal towns using mobile phone lines or ‘deal lines’. This can involve victims being trafficked away from home.

Possible Signs and Indicators: Going missing, unexplained absence from school or college, excessive travelling, being found out of their home area, unexplained access to money, clothes or mobile phone, excessive use of the internet, social media, texts, phone calls, relationships with controlling individuals or groups; gang association and/or isolation from peers/social networks, using slang words, suspicion of physical assault, unexplained injuries, carrying a weapon such as knives, self-harm or significant changes in emotional well-being, committing petty crimes like shop lifting or vandalism.

3:7 Particular Vulnerabilities:
Some children and young people may be more vulnerable to abuse and neglect due to impairment and/or their life experiences. Childhood adversity and trauma such as abuse, neglect, family breakdown, entering the care system, seeking asylum, no recourse to public funds can impact upon every area of a person’s life. Below is a list of circumstances that may make children and young people more vulnerable to abuse, neglect and exploitation.

Looked After Children and Care Leavers
Many children and young people who have experienced being in care may have poor outcomes in terms of education, employment, or health care needs–both physical and psychological–being met.

Asylum Seekers, Refugees and Unaccompanied Asylum-Seeking Children (UASC).
Children and young people residing in the UK without any national status, ability to work or recourse to public funds are significantly at risk to abuse and exploitation.

Disability & Additional Health Needs.
Disabled children and young people or those with additional health needs, including mental health difficulties may be additionally vulnerable to:
• Signs of abuse and neglect masked or thought to be due to disability
• Isolation and limited access outside contacts
• Increased risk of exposure to numerous carers who provide personal care
• Impaired capacity to resist abuse
• Communication difficulties that make it difficult to disclose
• Finding it difficult to raise concern or complain.

Unborn or Newly-Born Babies.
Unborn babies can be vulnerable to situations outlined below:
• Unwanted or unplanned pregnancy; ambivalence about pregnancy; emotional detachment from pregnancy; concealed pregnancy
• Inability to prioritise baby’s needs; poor preparation; lack of awareness of the baby’s needs; inappropriate parenting plans. Poor antenatal care
• Premature birth; foetal abnormality.
Factors related to the capacity of the Parent/s:
• Young age or immaturity (pregnancy for a female under the age of 16 must be addressed as a safeguarding concern)
• Experience of being in care
• Abuse in childhood or adverse childhood experiences (ACE)
• Mental health concerns
• Drug/alcohol misuse
• Learning and communicating difficulties
• Mother or another adult in the house/facility or a regular visitor is identified as a risk: abuse/neglect of previous children if known; known offender against children; previous care proceedings; current risk to related children (sibling)
• Homelessness/asylum seekers: no recourse to public funds
• Non-cooperation with services, non-compliance with treatment for the unborn baby.

Young Carers
Young Carers are those under the age of 18 who provide care for someone else. Doing so may limit life opportunities for young carers, including education, relationships and social interactions that other children and young people experience. Some young carers may be in need of protection for example if the person they care for is abusive.

Contextual Safeguarding
This refers to harm that people can experience from outside of their families. The environment and relationships that people form in neighbourhoods, schools or online can feature violence and abuse and so may make them vulnerable to harm in social contexts. Adolescents may be particularly affected as they spend more time independently of their families and outside their home. Examples such as street robbery; sexual violence in parks and public places; gang-related violence; online bullying; harassment from peers and abuse in their intimate relationships show that children and young people can be exposed to significant harm in settings outside their families.

Section 4: Confidentiality, Information Sharing and Consent

There is no such thing as complete confidentiality, only conditional confidentiality

Information given to a Housing Justice worker belongs to Housing Justice NOT to the individual worker; guests must be advised of this in advance

Our Whistle-Blowing Policy underlines our responsibility to report any concerns in relation to a colleague’s actions that might be considered abusive, unethical or out of bounds

(Please contact Kathy Mohan CEO–all concerns will be treated in confidence)

4:1 There are a number of principles that guide our response in this area:
• When a child discloses that they may be at risk or are experiencing abuse they must be made aware that you cannot keep this to yourself
• Anything the child tells you must be disclosed to your Manager (Caveat: if the disclosure is regarding the manager then only the Safeguarding Lead must be made aware)
• You have a duty to record any and all conversations: safeguarding incident report form, case notes, updating of the support and risk management plans as appropriate

If the alleged person of concern (perpetrator) is a guest, host or worker then advice must be sought from the Safeguarding Lead regarding what can be shared, with whom and why. No information may be shared until this discussion has taken place.

Section 5 Responding to a Concern

When you have a safeguarding concern and the situation requires immediate action and/or you need advice or guidance, then you must telephone your Manager or the Safeguarding Lead straight away

Every time you have a concern or are informed of abuse/risk of abuse you must complete a safeguarding incident report form (see Appendix A), even if you have made a telephone report . This must be sent immediately to your manager and/or the Safeguarding Lead no later than 4 hours after the disclosure was made

This report may be used in court and must therefore be an accurate and unbiased record of questions and statements. The record must be factual, and if it does contain the worker’s opinion or assessment, this should be backed up with factual evidence.

Opinion should be stated as such, and facts differentiated from hearsay.

5:1 Concern generated through discussion
If you receive a report either directly from the child or from anyone else, please follow these guidelines:
Do
• Thank the person for talking with you and listen carefully
• Reassure them that they have done the right thing and that they will be taken seriously
• Remain calm
• Ensure that the child is not in immediate danger and, if they are, take steps to protect them
• Seek immediate medical assistance if required
• Immediately inform your Manager or in their absence the Safeguarding Lead
• Call the Police immediately in cases of serious assault, indecent assault or rape
• Listen carefully: summarise and reflect back to ensure understanding of the facts they have provided
• Ask if there is anything else that they would like to tell you
• Take action to protect any evidence that might assist the Police e.g. clothing, the environment within which the abuse occurred
• Explain that you will write up notes of the conversation
• Explain that you will share what they have said in line with this policy and explain what will happen next.
Do Not
• Ignore the child/adult
• Give promises that you will not share the information
• Respond by looking horrified or giving your opinions of what has been said
• Jump to conclusions–stick to the facts as they are given to you
• Ask detailed questions about what you are told
• Share this information with other workers or anyone other than your Manager/the Safeguarding Lead unless you have been given express permission to do so
• Confront the alleged person of concern (perpetrator)
• If the matter relates to an employee/volunteer, do not record in the case records or anywhere else that could be read by the person concerned
• Disturb the evidence e.g. suggest that the person may want to have a shower, put their clothes in the washing, clean up their room, clean their wounds.

Follow the Incident Management Flow Chart located below.

5:2 INCIDENT MANAGEMENT FOLLOWING ALLEGATION OF ABUSE

Inform your Manager by telephone immediately you have a concern
(do not investigate or wait until you have evidence)
Complete & email the Safeguarding Incident Report Form within 4 hours to your
Manager (in the absence of your Manager contact the Safeguarding Lead)

Agree with your Manager any immediate steps to be taken to safeguard the individual that have not already been taken (see Managers’ Responsibilities listed below)

Manager immediately to inform the Safeguarding Lead and review the Safeguarding Incident Form with them to agree immediate actions

Safeguarding Lead to inform:
• Local Authority via telephone, followed up with LA Safeguarding Concern Form
• The police: if the matter is criminal
• HR Partner, Compose HR (if the matter relates to a worker–to discuss possible options e.g. redeployment, suspension etc)

Manager and Safeguarding Lead to consider who else is aware of the incident e.g. staff/other guests etc and put in place action plan to reassure (with due regard to information sharing)
Alternative accommodation for a guest may be considered in order to keep either the guest or the host safe

All workers to participate in on-going enquiry, meetings etc with the Local Authority, Police etc to ensure that the needs of the individual are met and best practice followed.

5:3 Manager’s Responsibilities
• Deal with any immediate needs, ensuring that the child is safe
• Ensure that emergency medical treatment has been arranged as appropriate
• Ensure that appropriate steps have been taken so that no evidence is lost
• Ensure, if the alleged person of concern is another service user, that their needs are met and that their social worker is informed
• Ensure no-one else is at risk
• Review the safeguarding concern report form and where necessary ensure it is updated
• Report the matter to the Safeguarding Lead
• Ensure any contract requirements are fulfilled
• Ensure that all documentation is protected so that the enquiry process/investigation has integrity
• Consider immediate risk and ensure that the risk management plan is updated as appropriate
• Take account of the child’s wishes and feelings regarding the matter (their desired outcomes)
• Work openly and collaboratively with the organisation and local authority throughout the safeguarding process.

5:4 Alerting Outside of Housing Justice
Where the concern is deemed serious enough, the Local Authority’s Safeguarding Concern Form should be completed and sent to the local Safeguarding Team within 24 hours of the incident/disclosure. Usually it will be the Safeguarding Lead who makes this decision in liaison with the Manager. The Local Authority’s referral procedures should be used and a referral form may need to be completed following an initial telephone call or discussion.

5:5 Further Action
It is the Local Authority’s Child Protection Lead who decides how to investigate the alert/take further action. Once a decision has been made, Housing Justice will be informed of their role in the process. Every worker is required to participate fully and transparently in this process.

5:6 Where the concern involves an employee/volunteer
In addition to ensuring that the safeguarding concern form is completed, a Manager must always inform the Safeguarding Lead where a worker is alleged to have carried out the abuse. The safeguarding Lead will then ensure that the local borough’s LADO is contacted for advice. If it is decided by the Safeguarding Lead that the person must be suspended, this will be carried out in accordance with Housing Justice’s disciplinary policy with advice from Compose HR.

5:7 What happens once an enquiry is made?
The relevant Safeguarding Manager at the local authority may decide to hold a strategy discussion or meeting involving all agencies which are supporting the guest. The purpose will be to agree a multi-agency plan to investigate the allegations and assess the concerns to the safety of the child who is being harmed, and address any immediate needs to coordinate the collection of information about the abuse or neglect. This may involve continuing the enquiry, or triggering a referral to other processes, such as a criminal enquiry. A continuing enquiry may result in a case conference and a protection plan which will be regularly reviewed.

5: 8 Closing a concern
A concern is closed when relevant action has been taken to address the abuse, even if the abuse is ongoing. It will typically be closed after the processes of reporting, external referral, case conferences and creating an action plan have taken place.

If the allegation is unfounded, then the issue should be recorded in the guest’s records. It may be that the guest made the allegation because they didn’t like the member of staff, volunteer or host or was unhappy with something the worker did. They may need support around expressing their needs and/or dissatisfaction in more appropriate ways. If the allegation was made about their host, it may be appropriate to discontinue the hosting placement.

5:9 Supporting a child who makes repeated allegations
A child who makes repeated allegations that have been investigated and are unfounded should be treated without prejudice. Each allegation must be responded to under these procedures. A Safety and Well-being Plan must be completed in full and measures have to be taken to protect staff and others and a case conference convened, where appropriate. Each incident must be recorded.

5:10 What to do if a safeguarding enquiry is closed with no further action
• Ask for full explanation, in writing, on why the safeguarding enquiry has been closed with no further action being taken
• Review the information in the enquiry for completeness and clarity. Was there something important which was omitted and were concerns about the child’s safety explicitly stated?
• Did the Safeguarding Team have a full and proper understanding of the safety concerns involved?
• Pass any further relevant information to the team such as information missing from the original enquiry or additional information which is now available
• Review the Safeguarding Team’s practice and decision against relevant local procedures (often called threshold and/or criteria documents). These are usually published online with the rest of the local authority’s procedures or staff should request a copy. Are they working in accordance with these procedures or is there is a gap between what their procedures require and what they have done?
• Challenge the decision on the above basis and, if the disagreement remains unresolved, make a complaint to the relevant local authority’s complaints officer

5:11 Staff Training and Support
All workers will receive safeguarding and boundaries induction training within 3 months of joining the organisation and refresher training every 2 years as a minimum. Persistent failure to attend such training will be treated as a conduct issue and addressed through the disciplinary procedure.

Managers must attend appropriate training in relation to their safeguarding role and safe recruitment practice. Managers will also ensure that Safeguarding is addressed during supervision and at team meetings and will operate an open door policy so that staff can discuss concerns and receive ongoing support. Additional support is provided via the Safeguarding Lead.

5:12 Relevant Legislation and Guidelines
• The Children’s Acts, 1989 and 2004
• Public Interest Disclosure Act 1998
• Sexual Offences Act 2003
• Female Genital Mutilation Act 2003
• Safeguarding Vulnerable Groups Act 2006
• Borders, Citizenship and Immigration Act 2009
• Equality Act, 2010
• Counter Terrorism and Security Act, 2015
• Criminal Justice and Courts Act, 2015
• Children and Social Work Act 2017
• Working Together to Safeguard Children, 2018
• Data Protection 2018, incorporating the General Data Protection Regulations 2016
• Modern Slavery
• Information Sharing Guidance 2018
5:13 Associated Policies and Procedures
• Preventing Radicalisation and Extremism Policy
• Whistleblowing Policy
• Data Protection and Confidentiality Policy and Procedure
• Equality and Diversity Policy and Procedure
• Recruitment and Selection Policy and Procedure
• Criminal Records Disclosure Policy and Procedure
• Harassment Policy and Procedure

Appendix A

Click here to download the full policy and procedure document. Please use the ‘Safeguarding Incident Report Form‘ located at the bottom of the document in ‘Appendix A‘ to record and report an incident or disclosure. Please send it to your Manager within 4 hours of the incident.