PDSA encourages a culture where people are easily able to speak up if they feel something is wrong. This policy, in conjunction with the associated procedures, enables anyone to easily report worries or concerns relating to a child or adult at risk, whilst making sure that those concerns are dealt with appropriately and in a sensitive manner.
All colleagues are expected to behave with respect and consideration towards other colleagues, clients, customers and supporters at all times, and to uphold PDSA’s values. Colleagues have a moral obligation, as well as a contractual requirement, to adhere to this policy and the related legislation and guidance.
In this policy, and the supporting procedures, the following definitions will apply:
The objectives of this policy and the supporting procedure and guidance are to:
This policy applies to all colleagues and third parties where appropriate.
At PDSA we have a duty to safeguard everyone we come into contact with, especially children and adults at risk. This duty arises from a framework of legislation and guidance, including Guidance from the Charity Commission for England and Wales.2 This policy reflects this framework and PDSA will comply with all relevant legislation and guidance as required. The various measures that support everyone to feel and be safe at PDSA are outlined in the document Feeling and Being Safe at PDSA.
Safeguarding is a key part of feeling and being safe at PDSA. It is vital because the most vulnerable in society – children and adults at risk – require additional measures to keep them safe. Safeguarding is about protecting the health, wellbeing and human rights of children and adults at risk, and enabling everyone to live free from abuse, harm and neglect. These vulnerable groups may include employees, volunteers, clients, customers, supporters and any other people we may come into contact with. We recognise that PDSA may not always have enough information to know whether someone meets the criteria of a child or adult at risk. Therefore, all concerns involving those that may be vulnerable or under the age of 18 should be reported in line with this policy and associated procedures.
PDSA is committed to making safeguarding personal using a person-led approach that enhances involvement, control and choice throughout the safeguarding process. When making decisions about an adult at risk, consideration will be made using the six principles of adult safeguarding set out in the Care Act 2014:
Keeping everyone safe often requires information to be shared with the right agencies in order to piece together a full picture of the circumstances. Single pieces of information can reveal a very different picture when combined together. To make this possible, effective information sharing between PDSA and other agencies is essential. This ensures concerns can be identified, the situation assessed, the right actions taken and the services a person needs provided. If PDSA receives information that someone has been, or is at risk of, harm we may need to inform relevant agencies.
While we will always seek to involve children, adults at risk and their carers as much as possible in decision making, the law allows us to share information without consent in certain circumstances. This is in line with the Data Protection Act 2018, the General Data Protection Regulation (GDPR), the Human Rights Act 1998 and the Crime and Disorder Act 1998,as well as the Mental Capacity Act 2005.How to apply this legislation to determine whether we should share information externally without consent is outlined in the associated procedures (parts two-five), however the basic principle remains that if we have a concern that someone is at risk of abuse, neglect or immediate harm we are likely to need to share this externally, with or without consent.
Please note, we never need consent to share information within PDSA to keep someone safe.
Records will be shared and stored securely, in line with GDPR. This includes the storing of safeguarding information in online personnel, client and supporter files. Safeguarding records will be kept up to date by staff members and audited regularly to ensure that records comply with GDPR.
The Safeguarding Manager will have oversight of all safeguarding concerns and will collate incidents and analyse trends in a quarterly Dashboard report to the Council of Trustees and the Senior Management Team. This information will be used to inform ongoing safeguarding strategy.
We all have a moral responsibility for safeguarding, especially the welfare and safety of children and adults at risk. Colleagues are expected at all times to show respect for, and understanding of, the rights, safety and welfare of everyone they engage with, and will conduct themselves in a way that reflects the values of PDSA and is in line with this policy and the PDSA Code of Conduct.
The Council of Trustees have overall responsibility for Safeguarding within PDSA and includes a Safeguarding Trustee Champion. The Director of People is the overall Director responsible as the Designated Safeguarding Officer.
All colleagues should have an awareness of this policy and understand how to comply with its requirements. As representatives of PDSA, all colleagues must act with honesty and integrity at all times.
Where colleagues have worries about suspected abuse or neglect, either an external threat to PDSA or suspicions about the actions of another PDSA colleague, they must speak up and report this as soon as possible. PDSA and its people have a duty of care to help, protect and safeguard the welfare of children and adults at risk whom they may come into contact with during the course of their activities.
Colleagues are responsible for declaring any convictions in line with the Rehabilitation of Offenders Act 1974 on application to PDSA. They are also responsible for declaring any subsequent convictions of any nature during the course of their employment/volunteering experience at PDSA. Failure to do this may result in disciplinary action.
Line Managers have an additional responsibility to embed good safeguarding practice, encouraging a culture of openness and understanding within their teams. Line Managers must:
PDSA will always take safeguarding allegations against, or concerns about the the behaviour of staff and volunteers seriously, and will response in a way that places the protection and needs of children and adults at risk fist. The procedures for managing such concerns are outlined in Safeguarding at PDSA – part four: procedures for managing concerns about staff and volunteers.
PDSA will work with relevant agencies with openness and transparency and share information in line with the relevant legislation and statutory processes. PDSA will always inform the police if information is received that suggests that a law has been broken.
The Director of People, who is the Designated Safeguarding Officer, will be informed at each stage of the concern or allegation.
In order to ensure that our people feel and are safe we adopt the following practices throughout our recruitment activity.
Our colleagues are recruited knowing what behaviours are expected of them. These behaviours underpin everything we do.
Additional safer recruitment measures are in place for certain posts as appropriate for the duties and responsibilities of the role. a wider review of safer recruitment practices is currently in progress, in the interim period please contact HR Shared services should you have any queries or concerns regarding our recruitment practices.
PDSA will ensure it regularly assesses the requirement for roles, both new and existing, to be DBS checked in every department. Where a DBS check is considered essential, for a role, activity and/or project.
For the roles identified as requiring a DBS check, periodic rechecks will be undertaken at a frequency appropriate for the role; in any case, this will be as a minimum requirement every three years. However, it is expected that colleagues will make us aware immediately of any changes that may affect them with regards to this.
PDSA employees should also participate in regular training and departmental meetings which include consideration of safeguarding.
Awareness of this policy, including an online training course, is part of the induction process for all new colleagues.
All colleagues will complete biennial refresher training at a level appropriate to their role, on how to implement and adhere to this policy. Further role specific training is provided where required.
The Director of People will chair the Safeguarding Committee and coordinate a quarterly review of any concerns raised, which will be presented to the Senior Management Team. No specific personal details with regards to the concerns will be included in the summary. Safeguarding is a standard agenda item at the full Council meeting.
The Director General will provide an update of any concerns or allegations against PDSA staff or volunteers to the Chair of PDSA’s Council and the Trustees. The Director of People will also proactively monitor the overall implementation of this policy and its effectiveness to ensure it continues to accomplish the policy statement. The suitability, adequacy and effectiveness of the policy and procedure will be considered and any improvements identified will be made as soon as possible.
To ensure its effectiveness and that it remains fit for purpose, this policy suite will be reviewed annually by the Safeguarding Manager, any significant changes to the documents will be reviewed and agreed by Council. PDSA will also audit and monitor compliance with the policy and procedure on a periodic basis, through theme audits or as part of wider departmental or site audits.
It is important to recognise that there are occasions when national or international emergencies(for example, financial crisis, pandemic disease, natural disasters or international conflicts) may impact the frequency and presentation of safeguarding risks. During such times, vulnerable members of society often face additional pressures alongside decreased services and support, resulting in an increased risk of abuse, harm and exploitation. Added to this, any disruption to our usual ways of operating could reduce colleague’s ability to recognise and respond to the signs of safeguarding concerns.
No matter what the external pressure is, PDSA will continue to be committed to protecting and safeguarding everyone we come into contact with. The need for additional safeguarding measures, resources and protections required during times of difficulty will be identified, developed, implemented and kept under regular review.
1 In Scotland, the definition of a ‘child’ varies according to the legal circumstances: usually, in child protection law, a child is defined as someone under the age of 18. In some child protection contexts, however, a child is someone under the age of 16. Colleagues at PDSA have a responsibility to protect anyone under theage of 18, wherever they live.
2 The Charity Commission for Northern Ireland and the Office of the Scottish Charity Regulator similarly emphasise the importance of safeguarding.