Scope: This procedure sets out the safeguarding of adults policy at the Medical Centre

Objective:  To provide guidelines to all employees that ensures a consistent and cohesive approach is taken to safeguarding adults.

Procedure: The following guidelines should be followed:

This 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.

This policy and procedure relate to the safeguarding of adults at risk. Adults at risk are defined as people:

• aged 18 or over, and
• who are receiving or may need community care services because of learning, physical or mental disability, age, or illness, or
• Who are or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation.

It is acknowledged that significant numbers of adults at risk are abused and the Medical Centre is committed to having a safeguarding adult’s policy which are procedures to follow and puts in place preventative measures to try and reduce abuse of adults. 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 adults 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. 

The Practice:

• will work with other agencies within the framework of the local Safeguarding Adults Board Policy and Procedures, issued under No Secrets guidance (Department of Health, 2000),
• will act within GMC guidance on confidentiality and will gain permission, as required, from patients before sharing information about them with another agency,
• Will pass information to adult services when more than one person is at risk. (i.e. patients within a care home) or as appropriate,
• will inform patients that where a person is in danger, a child is at risk or a crime has been committed then a decision may be taken to pass information to another agency without the service user’s consent,
• will endeavour to keep up to date with national developments relating to preventing abuse and welfare of adults

The Medical Centre recognises that it is the role of the practice to be aware of maltreatment and share concerns but not to investigate or to decide whether or not an adult at risk has been abused. This policy should be read in conjunction with the local Multi Agency Safeguarding Adults Policy. 

Guidelines:

Preventing abuse

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:

• Complaints 
• Dignity & Respect 
• Whistle Blowing 
• Data Protection & Confidentiality 
• Information Governance
• Recruitment and Selection 
• Retention of Records 

The Medical Centre is committed to safe recruitment policies and practices for partners and employees. The minimum safety criteria for safe recruitment of all staff 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 adult’s policy statement will be available to patients and their carers/families. Information about abuse and safeguarding adults 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. The practice will be alert for warning signs such as failure to attend an appointment and will review/follow up.

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 adults. This should take note of Safeguarding Vulnerable Adults – a toolkit for General Practitioners published by the British Medical Association which identified that is essential that

• Health professionals should be able to identify adults whose physical, psychological or social conditions are likely to render them vulnerable, 
• Health professionals should be able to recognise signs of abuse and neglect, including institutional neglect,
• Health professionals need to familiarise themselves with local procedures and protocols for supporting and protecting vulnerable adults

“Abuse is a violation of an individual’s human and civil rights by any other person or persons” (No Secrets: Department of Health, 2000)

Abuse includes:   

• 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 Adults

The practice has a named Safeguarding lead and deputy. The practice lead will:

• implement the safeguarding adults policy,
• ensure that the practice meets contractual guidance, 
• ensure safe recruitment procedures, 
• support reporting and complaints procedures,
• advise 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, 
• Have regular meetings with others in the primary healthcare team to discuss particular concerns. 

Responding to people who have experienced or are experiencing abuse

How to respond if you receive an allegation:

• Reassure the person concerned,
• Listen to what they are saying,
• Record what you have been told/witnessed as soon as possible,
• Remain calm and do not show shock or disbelief,
• Tell them that the information will be treated seriously,
• Don’t start to investigate or ask detailed or probing questions,
• Don’t promise to keep it a secret,

If you witness abuse or abuse has just taken place the priorities will be:

• To call an ambulance if required,
• To call the police if a crime has been committed,
• To preserve evidence,
• To keep yourself, staff, volunteers and service users safe,
• To inform the patient’s GP or the Practice Adult Safeguarding Lead
• To record what happened in the medical records.

• If immediate action is needed this requires a referral to the police or immediately to Adult Social Care depending on the situation,
• Patients should normally be informed of a referral being made. This stage is known as an alert,
• If a referral is not made a plan should still be put in place to reduce the risk of abuse in the future and this should be reviewed at agreed intervals,
• A referral will normally be made by the most appropriate senior clinician available but any member of the clinical or non-clinical staff may take action if the situation justifies this,
• If there is uncertainty whether a patient has capacity to safeguard themselves then an assessment of capacity should be undertaken,
• If the patient does not have capacity then a referral can be made in their best interests,
• Referrals can be made without consent if there is a good reason to do so e.g. a risk to others, or immediate risk to self,
• If a member of staff feels unable to raise a concern with the patient’s GP or the practice adult safeguarding lead then concerns can be raised directly with adult social care,
• Advice may be taken from adult social care and/or other advice giving organisations such as the police.

Following an alert, a safeguarding adult’s manager from adult social care will normally decide if the safeguarding process should be instigated or if other support/services are appropriate. Feedback will be given to the person who raised the safeguarding adults alert.

If the safeguarding adults manager decides the safeguarding process needs to be instigated this will then lead to the implementation of the next stages of the multi-agency policy and procedures. 

Referrals should be made by telephone to the appropriate adults social care service. You should ask to make a safeguarding adults alert.

The telephone call should be followed up in writing to the adult social care service outlining concerns using the local safeguarding adult’s multi-agency alert form. All verbal referral to social services must be followed up in writing by the referrer, giving full details, within 48 hours. 

Mental Capacity Act

The presumption is that adults have mental capacity to make informed choices about their own safety and how they live their lives. Issues of mental capacity and the ability to give informed consent are central to decisions and actions in Safeguarding Adults. Mental capacity is time and decision specific. The practice will work within the principles of the Mental Capacity Act 2005.

• An adult at risk has the right to make their own decisions and must be assumed to have capacity to make decisions about their own safety unless it is proved (on a balance of probabilities) otherwise.
• Adults at risk must receive all appropriate help and support to make decisions before anyone concludes that they cannot make their own decisions.
• Adults at risk have the right to make decisions that others might regard as being unwise or eccentric and a person cannot be treated as lacking capacity for these reasons.
• Decisions made on behalf of a person who lacks mental capacity must be done in their best interests and should be the least restrictive of their basic rights and freedoms.

Deprivation of Liberty Safeguards (DoLS) provide protection to people in hospitals and care homes who lack mental capacity for decisions about their care and treatment. Advice will be sought if there is concern that a person may be being deprived of their liberty.

Independent Mental Capacity Advocates (IMCAs) have a statutory role in proving safeguards for people who lack capacity to make important decisions and who do not have family or friends who can represent them to do so. Referrals will be made in these circumstances during safeguarding procedures or if it is necessary to make a decision about serious medical treatment in a non-emergency situation.

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 Adults 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 adults 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. If attendance is not possible, the provision of a report is essential.

Recording Information

• Concerns and information about adults at risk should be recorded in the medical records. These should be recorded using recognised computer codes
• Concerns and information from other agencies such as social care, e 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 adults 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

www.dh.gov.uk/en/Publicationsandstatistics/Publications/PublicationsPolicyAndGuidance/DH_125310

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

The practice will follow GMC guidance on patient confidentiality.

In most situations patient consent must be obtained prior to release of information including making a safeguarding adults alert. If the patient is suspected of lacking in capacity an assessment of mental capacity should be undertaken. If this assessment indicates that the patient lacks capacity then an alert may be made and information shared under best interest’s guidance.

In some circumstances disclosure of confidential information should be made without patient’s consent in the public interest. This is most commonly if there is a risk to a third party. An example would be if children or other adults at risk were potentially in danger. The patient should normally be informed that the information will be shared but this should not be done if it will place the patient, you or others at increased risk.

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.

1. 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.
2. 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.
3. Seek advice if you have any doubt, without disclosing the identity of the person if possible.
4. 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.
5. 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.
6. 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.
7. 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

Reference Documents:

RCPCH

Adult safeguarding

General Medical Council. Confidentiality: Protecting and Providing Information (September 2000) 

Department of Health Adult Safeguarding Statement https://www.gov.uk/government/publications/adult-safeguarding-statement-of-government-policy-10-may-2013

SAFEGUARDING OF VULNERABLE ADULTS POLICY

Practice Name: WEMBLEY PARK DRIVE MEDICAL CENTRE

Practice Safeguarding Vulnerable Adults Lead: DR JULIETTE ROSS & SACHIN PATEL

Safeguarding Adults Policy Statement

This policy will enable the Medical Centre to demonstrate its commitment to protecting adults 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.

Declaration

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         

Date: 16/2/16

The practice team has been consulted on how we implement this policy

Signed by: Dr Juliette Ross & Dr Sachin Patel            

Date: 16/2/16

ALL SAFEGURADING CONTACTS ARE AVAILABLE IN ALL CLINICAL ROOMS & RECEPTION