Scope: This procedure sets out the safeguarding of children policy at the Wembley Park Medical Centre
Objective: To provide guidelines and information to the staff to ensure a consistent and cohesive approach is taken to safeguarding children
Procedure: The following guidelines should be followed:
The policy statement and procedures have been drawn up in order to enable the practice to:
- promote good practice and work in a way that can prevent harm, abuse and coercion occurring,
- to ensure that any allegations of abuse or suspicions are dealt with appropriately and the person experiencing abuse is supported,
- and to stop that abuse occurring.
In this policy, as in the Children Acts 1989 and 2004 respectively, a child is anyone who has not yet reached their 18th birthday. Safeguarding and promoting the welfare of children is defined for the purposes of this policy as:
- protecting children from maltreatment,
- preventing impairment of children’s health or development,
- and ensuring that children are growing up in circumstances consistent with the provision of safe and effective care; and undertaking that role so as to enable those children to have optimum life chances and to enter adulthood successfully.
Child in Need: Under Section 17 (10) of the Children Act 1989, a child is in need if:
- He/she is unlikely to achieve or maintain, or have the opportunity of achieving or maintaining, a reasonable standard of health or development without the provision for him/her of services by a local authority;
- His/her health or development is likely to be significantly impaired, or further impaired, without the provision for him/her of such services; or
- He/she is disabled
It is acknowledged that significant numbers of children are at risk of being abused and it is important that the Medical Centre has a safeguarding children policy which contain procedures to follow and puts in place preventative measures to try and reduce abuse of children. This guideline addresses the responsibilities of all members of the practice team and those outside the team with whom we work. It is the role of the practice manager and safeguarding children lead to brief the staff and partners on their responsibilities under the policy, including new starters and sessional GPs. For employees, failure to adhere to the policy could lead to dismissal or constitute gross misconduct.
- will work with other agencies within the framework of the local Safeguarding Children Board Policy and Procedures, issued under No Secrets guidance (Department of Health, 2000),
- will act within GMC guidance on confidentiality,
- will make a referral to Child Services as appropriate,
- will endeavour to keep up to date with national developments relating to preventing abuse and welfare of children
This policy should be read in conjunction with the Local Multi Agency Safeguarding Children Policy and information available from the Safeguarding Children Board.
The Medical Centre is committed to putting in place safeguards and measures to reduce the likelihood of abuse taking place within the services it offers and that all those involved with the practice will be treated with respect. Supporting these guidelines are the following practice policies:
- Dignity & Respect
- Whistle Blowing
- Data Protection & Confidentiality
- Information Governance
- Recruitment and Selection
- Retention of Records
The Medical Centre is committed to safer recruitment policies and practices for partners and employees. The minimum safety criteria for safe recruitment of all staff that work at practice name are that they:
- have been interviewed face to face
- have 2 references that have been followed up
- have been DBS checked
The practice will work within the current legal framework for reporting staff or volunteers to the Independent Safeguarding Authority where this is indicated. The complaints policy and safeguarding children policy statement will be available to patients and their carers/families. Information about abuse and safeguarding children will be available within public areas of the practice.
The practice is committed to the prevention of abuse and will highlight the records of patients about whom there is significant concern. All new employees at the Medical Centre undergo in-house training or other basic safeguarding training, organised under local arrangements to enable them to recognise the signs of harm.
- Non-clinical staff Level 1
- Clinical Staff [Practice Nurses and others] Level 2
- Practice Safeguarding Lead and GPs Level 3
Recognising the signs and symptoms of abuse
All who work at the Medical Centre should take part in training and if appropriate significant event discussion regarding safeguarding children.
- physical abuse: including hitting, slapping, punching, burning, misuse of medication, inappropriate restraint,
- sexual abuse: including rape, indecent assault, inappropriate touching, exposure to pornographic material,
- psychological or emotional abuse: including belittling, name calling, threats of harm, intimidation, isolation,
- financial or material abuse: including stealing, selling assets, fraud, misuse or misappropriation of property, possessions or benefits,
- neglect and acts of omission: including withholding the necessities of life such as medication, food or warmth, ignoring medical or physical care needs,
- Discriminatory abuse: including racist, sexist, that based on a person’s disability and other forms of harassment, slurs or similar treatment
- Institutional or organisational: including regimented routines and cultures, unsafe practices, lack of person-centred care or treatment.
Abuse may be carried out deliberately or unknowingly. Abuse may be a single act or repeated acts. Abuse may occur in any setting including private homes, day centres and care homes. Abuse may consist of acts of omission as well as of commission.
People who behave abusively come from all backgrounds and walks of life. They may be doctors, nurses, social workers, advocates, staff members, volunteers or others in a position of trust. They may also be relatives, friends, neighbours or people who use the same services as the person experiencing abuse.
Practice Lead for Safeguarding Children
The practice has a named Safeguarding lead and deputy. The practice lead will:
- implement the safeguarding children policy,
- ensure that the practice meets contractual guidance,
- ensures safe recruitment procedures,
- support reporting and complaints procedures,
- advises practice members about any concerns that they have,
- ensure that practice members receive adequate support when dealing with safeguarding adults concerns,
- lead on analysis of relevant significant events,
- determine training needs and ensures they are met,
- makes recommendations for change or improvements in practice procedural policy,
- act as a focus for external contacts
- has regular meetings with others in the primary healthcare team to discuss particular concerns
Responding to people who have experienced or are experiencing abuse
Disclosure of an allegation of abuse: If a child discloses information about abuse, whether concerning themselves or a third party, practice staff and the nursing team must immediately pass this information on to the safeguarding lead. GPs should follow the safeguarding referrals procedures below.
Responding to a child making an allegation of abuse:
- Stay calm,
- Listen carefully to what is being said,
- Find an appropriate early opportunity to explain that it is likely the information will need to be shared with others – do not promise to keep secrets,
- Allow the child to continue at his/her own pace,
- Ask questions for clarification only, and at all times avoid asking questions that are leading or suggest a particular answer,
- Reassure the child that they have done the right thing by telling you,
- Tell them what you will do next and with whom the information will be shared,
- Record in writing what has been said using the child’s own words as much as possible – note date, time, any names mentioned, to whom the information was given and ensure that paper records are signed and dated, and electronic subject to audit trails,
- Do not delay in passing this information on.
During any contact with parents and children, in addition to any physical examination clinicians need to ensure they listen to what parents say, document the content of the discussion and any concerns, and take appropriate action to ensure that the children are safeguarded.
Where there are concerns of significant harm or a child is considered to be a possible child in need, GPs at the Medical Centre should contact the local children’s team. All telephone referrals should be followed up in writing within 48 hours. If the referring GP has not received an acknowledgement within three working days they should contact the social care referral and assessment team again.
In the event that a referring GP does not agree with the response and decisions about the referral by the children’s social care referral and assessment team, they should discuss their concerns directly with the line manager of the social worker, in the first instance to seek resolution. They should also follow procedures from the local safeguarding children board where applicable. In addition, any non mobile baby with head, facial or other marking/bruising must be referred for a same day paediatric assessment.
While GPs should seek, in general, to discuss any concerns with the child and family and where possible, seek their agreement to making referrals to local authority children’s social care, this should only be done where such discussion and agreement-seeking will not place a child at increased risk of suffering significant harm.
In circumstances where a GP is unsure how to respond they should immediately consult with the designated lead for safeguarding at the Medical Centre.
The Medical Centre will adhere to the local inter-agency safeguarding procedures and those of the local Safeguarding Children Board to ensure that the child receives the services and support that they need.
Incidents must be notified to the CQC for any abuse or alleged abuse concerning a person who uses the services. https://www.cqc.org.uk/service-providers/gps-and-primary-medical-services/information-gps-and-other-primary-medical-servi-1
Any staff implicated in abuse must be referred to the Disclosure and Barring Service (DBS). Further information and guidance is available at https://www.gov.uk/government/publications/dbs-referrals-factsheets
Practitioner has concerns about Child’s Welfare
- Practitioner discusses with manager, child protection, administrator or senior colleagues as appropriate
- Practitioner refers to local authority childrens’ social care and follows up in writing within 48 hours
- No further child protection action although may need to act to ensure that services are provided
- Social worker or manager acknowledges receipt of referral and decides on a course of action within 1 working day
- Feedback given to referrer on next course of action
Children and other patients who may lack competence to give consent:
“If you believe a patient to be a victim of neglect or physical, sexual or emotional abuse and that the patient cannot give or withhold consent to disclosure, you should give information promptly to an appropriate responsible person or statutory agency, where you believe that the disclosure is in the patient’s best interests. You should usually inform the patient that you intend to disclose the information before doing so. Such circumstances may arise in relation to children, where concerns about possible abuse need to be shared with other agencies such as social services. Where appropriate you should inform those with parental responsibility about the disclosure. If, for any reason, you believe that disclosure of information if not in the best interests of an abused or neglected person, you must still be prepared to justify your decision.”
- GPs can disclose information without consent if they are making a safeguarding referral (subject to the guidance above),
- Consent must always be sought for a referral as a child in need,
- If in doubt about whether to refer a child as a ‘safeguarding referral’ versus a ‘child in need’ referral, GPs should ask advice from the practice safeguarding lead.
- Clear and comprehensive records relating to all events and decisions must be maintained.
Child Protection Register:
A list of children judged to be at continuing risk for which there is a child protection plan in place is maintained by social services. Social services, police and health care professionals have 24 hour access to this. A child on a protection plan has a “key worker” to whom reference can be made.
Ringing the Child Protection Register can tell you:
- Whether the child or siblings are already registered or have been on the register in the past,
- Whether anyone else has made enquiries about this child,
- It records your enquiry, so if someone else subsequently enquires about the child, they will know that they are not the first to be concerned,
- If there are several enquiries about an individual child, social services can look into the case,
- Whether either parent is a schedule 1 offender (has been convicted of offences against children)
Ringing the child protection register does not constitute a formal referral to social services, and will not set a child protection investigation in motion.
Whistle Blowing and Complaints
The Medical Practice has a whistle-blowing policy that recognises the importance of building a culture that allows all practice staff to feel comfortable about sharing information, in confidence and with a lead person, regarding concerns they have about a colleague’s behaviour. This will also include behaviour that is not linked to safeguarding adults but that has pushed the boundaries beyond acceptable limits. Open honest working cultures where people feel they can challenge unacceptable colleague behaviour and be supported in doing so, help keep everyone safe. Where allegations have been made against staff, the standard disciplinary procedure and the early involvement of the local authority safeguarding team may be required.
The Medical Centre has a clear procedure that deals with complaints from all patients.
Case conferences, strategy meetings etc.
The contribution of GPs to safeguarding children is invaluable and priority should be given to attendance and sending a report to meetings wherever possible. Consider liaising with your district nurse or other relevant professionals in addition about your attendance.
- Concerns and information about children at risk should be recorded in the medical records. These should be recorded using recognised computer codes, agreed at the practice.
De – Registration:
- When a child whose record contains a child protection alert, moves to a new surgery, the child protection co-ordinator should be notified, normally by the health visitor. The admin team will ensure that the health visitor is made aware that the child is moving out of the area.
- The child protection co-ordinator will contact the child’s new GP or health visitor and will arrange for the transfer of any necessary records.
Child Protection files should not normally be retained in the practice after a patient has left.
- Concerns and information from other agencies such as social care, or the police or from other members of the primary health care team, including district nurses should be recorded in the notes under a computer code.
- Email should only be used when secure, [e.g. nhs.net to nhs.net] and the email and any response(s) should be copied into the record,
- Conversations with and referrals to outside agencies should be recorded under appropriate computer code,
- Case Conference notes may be scanned in to electronic patient records as described below. This will usually involve the summary/actions, appropriately annotated by the patient’s usual doctor or practice child safeguarding lead,
- Records, storage and disposal must follow national guidance for example, Records Management, NHS Code of Practice 2009,
- If information is about a member of staff this will be recorded securely in the staff personnel file and in line with your own jurisdiction guidance.
Case Conference Summaries & Minutes
Case conference minutes frequently raise concerns – much of it about information concerning third parties. See also the Good Practice Guidance to GP electronic records
Case conference minutes should be stored in the patient’s records.
Conference minutes should not be stored separately from the medical records because:
- they are unlikely to be accessed unless part of the record,
- they are unlikely to be sent on to the new GP should the patient register elsewhere,
- they may possibly become mislaid and lead to a potentially serious breach in patient confidentiality.
Whilst GPs may have concerns about third party information contained in case conference minutes, part of the solution is to remove this information if copies of medical records are released for any reason, rather than not permitting its entry into the medical record in the first place.
Sharing Information and Confidentiality
General Principles of Information Sharing
The ‘Seven Golden Rules’ of information sharing are set out in the government guidance, Information Sharing: Pocket Guide. This guidance is applicable to all professionals charged with the responsibility of sharing information, including in safeguarding adults scenarios.
- The Data Protection Act is not a barrier to sharing information but provides a framework to ensure personal information about living persons is shared appropriately.
- Be open and honest with the person/family from the outset about why, what, how and with whom information will be shared and seek their agreement, unless it is unsafe or inappropriate to do so.
- Seek advice if you have any doubt, without disclosing the identity of the person if possible.
- Share with consent where appropriate and where possible, respect the wishes of those who do not consent to share confidential information. You may still share information without consent, if, in your judgment, that lack of consent can be overridden by the public interest. You will need to base your judgment on the facts of the case.
- Consider safety and well-being: base your information sharing decisions on considerations of the safety and well-being of the person and others who may be affected by their actions.
- Necessary, proportionate, relevant, accurate, timely and secure, ensure that the information you share is necessary for the purpose for which you are sharing it, is shared only with those people who need to have it, is accurate and up to date, is shared in a timely fashion and is shared securely.
- Keep a record of your concerns, the reasons for them and decisions whether it is to share information or not. If you decide to share, then record what you have shared, with whom and for what purpose
Safeguarding of Children Policy
Safeguarding Children Policy Statement
This policy will enable the Medical Centre to demonstrate its commitment to keeping safe children at risk with whom it comes into contact with as patients or in other ways. The Medical Centre acknowledges its duty to respond appropriately to any allegations, reports or suspicions of abuse.
In law, the responsibility for ensuring that this policy is reviewed and implemented belongs to the partners of the practice.
We have reviewed and accepted this policy
Signed by: Dr Juliette Ross & Dr Sachin Patel
The practice team has been consulted on how we implement this policy
Signed by: Dr Juliette Ross & Dr Sachin Patel
GMC – Protecting children and young people the responsibility of all doctors – July 2012
The Children Act (DoH 1989),
Working Together to Safeguard Children (DoH 2006),
The Human Rights Act (DoH 1999),
RCGP – Safeguarding Children and Young People: A toolkit for General Practice (2011) http://www.rcgp.org.uk/clinical/clinical-resources/~/media/Files/CIRC/Safeguarding%20Children%20Module%20One/Safeguarding-Children-and-Young-People-Toolkit.ashx