Safeguarding Adults At Risk Policy

Transcription

1 Safeguarding Adults At Risk Policy Version: 2.0 Policy Number Policy Lead/Author & position: Veronica Flood Ward / Department: Clinical Care and Practice Ratified by Governance and Risk ManagementCommittee Date Approved/Ratified: June 2010 Previous Reviewed Dates February 2011, September 2011 Date of Current Review: July 2013 Date of Next Review: June 2016 Relevant NHSLA Standard(s): N/A Target Audience All staff

2 EQUALITY STATEMENT Barnet, Enfield and Haringey NHS Trust aims to design and implement services, policies and measures that meet the diverse needs of our service, population and workforce, ensuring that none are placed at a disadvantage over others. It takes into account the Equality Act (2010) including the Human Rights Act 1998 and promotes equal opportunities for all. This document has been assessed to ensure that no employee receives less favourable treatment on the protected characteristics of their age, disability, sex (gender), gender reassignment, sexual orientation, marriage and civil partnership, race, religion or belief, pregnancy and maternity. Members of staff, volunteers or members of the public may request assistance with this policy if they have particular needs. If the member of staff has language difficulties and difficulty in understanding this policy, the use of an interpreter will be considered. Barnet, Enfield and Haringey NHS Trust embraces the four staff pledges in the NHS Constitution and this policy is consistent with these pledges. Version Control Summary Version Date Section Author Comments 1.0 June 2010 All Veronica This is a new policy sections Flood 1.1 September 2011 Veronica Flood Sections 1.1, 2.1, 3.1, 6.1, 7.2, 7.3, 8.3, , 9.3, 9.4, 9.7, 9.8, 9.9, 10.1, 10.6, 11.1, 11.6, , , appendix 2.0 July 2013 Veronica Flood Sections 6., 8.3,8.4, 8.5,9.1,9.2, 12, 13, 14, 15, 16, 17, 18, 22, Appendix 2, 3 and 7 Safeguarding Adults Policy Version 2 2

3 Table of Contents 1. Policy Statement Introduction Aims Purpose and Outcome Scope Definitions What is abuse? Who may be the abuser? Patterns of abuse Safeguarding thresholds Duties Different Agencies: Service Line Managers/ SOVA Trust leads are responsible for: Team/Ward Managers are responsible for Assistant Director, Safeguarding Adults is responsible for: Executive Director of Nursing, Quality and Governance is responsible for Internal Procedures and Structures Serious Incidents- (SI) Physical Assault on Inpatient Units/Safeguarding Adults Children visiting inpatient areas Reporting Pressure Ulcers Referrals to the Multi-agency Risk Assessment Conference (MARAC) Mental Capacity Act Prevent Whistle-Blowing The Pan London Multi-agency policy and procedure Organisational Learning Procedure for Dealing with Observed/Alleged Abuse Involving BEHMHT/ECS Staff Quality Assurance and monitoring Training Strategy Sharing Information People and Organisational Development Department and Safeguarding Process Disemination and Implementation References EQUALITY IMPACT ASSESSMENT AND ANALYSIS FORM Appendices Safeguarding Adults Alert / Referral Form Paid Carer: Other vulnerable adult Appendix 5 Enfield Flow Chart 1 The Procedure Safeguarding Adults Alert Form Appendix 6 - Haringey Safeguarding of Vulnerable Adults (SOVA) workflow as at April 6th Safeguarding Adults Policy Version 2 3

4 1. Policy Statement Barnet Enfield and Haringey Mental Health Trust (BEHMHT), together with its partner agencies, take a zero tolerance approach to abuse of any kind. This policy refers to adults at risk who are over the age of 18 years and who are under the care of staff employed by Barnet Enfield and Haringey Mental Health Trust/ Enfield Community Services (ECS). This policy is to support all staff in their duty to immediately report any concerns about the possible abuse of an adult at risk. It indicates that positive action will be taken where abuse is identified. Barnet, Enfield and Haringey Mental Health Trust/ECS work together with its partner agencies Barnet, Enfield and Haringey Social Services Departments in its commitment to reporting and investigating any allegation of abuse of a an adult at risk. 2. Introduction This Policy sets out the procedures to be undertaken by any employee of the Mental Health Trust/ECS if they suspect that an adult has suffered or is suffering from any form of abuse. This policy document should be read in conjunction with the guidelines issued by: Protecting adults at risk: London multi-agency policy and procedures to safeguard adults from abuse local practice guidance from the Local Authority No Secrets Department of Health Guidance (2000) Safeguarding Adults A National Framework for Standards for Good Practice and Outcomes in Adult Protection Work, (ADSS 2005) Being Open When Patients are Harmed (NPSA Safer Practice Notice, September 2005) Barnet Enfield and Haringey Mental Health Trust SI Policy and Procedures Barnet Enfield and Haringey Mental Health Trust Sexual assaults Policy Barnet Enfield and Haringey Mental Health Trust Whistle blowing Policy Mental Capacity Act 2005 Barnet Enfield and Haringey Mental Health Trust Domestic Violence Protocol 3. Aims The aim of this policy is to ensure that adults at risk are protected from any form of abuse whilst under the care of Barnet Enfield and Haringey Mental Health Trust/ECS. In addition that staff are aware of the special needs of adults at risk and that they receive training and guidance in the recognition of abuse. 4. Purpose and Outcome The purpose of the policy is to provide clear guidance on reporting any concerns or allegations of abuse and to set out the levels of responsibility by: Ensuring that the Mental Health Trust/ECS promotes a culture in which patients, relatives, carers and staff feel that they are able to raise concerns Ensuring that staff are aware of the policy Ensuring that adults at risk adults are not subject to any form of abuse Ensuring that staff receive the appropriate training Ensuring that any allegations of abuse are reported immediately and are thoroughly investigated and appropriate action taken Ensuring partnership working with other agencies Safeguarding Adults Policy Version 2 4

5 5. Scope This policy aplies to all staff. 6. Definitions This policy focuses on the needs of adults at risk in relation to abuse. The term adult at risk has been used to replace Vulnerable Adult (as per the Pan London Procedures) and is defined as: Someone who is 18 years and over ( No Secrets DOH 2000) who: Is or may be in need of community care services by reason of mental or other disability, age or illness; and who Is or may be unable to take care of him or herself or unable to protect him or herself against significant harm or exploitation In real terms the people most likely to be assessed as an adult at risk are those adults who: Are elderly and very frail Suffer from mental illness, including dementia Have a physical or sensory disability Have a learning disability Suffer from a severe and incapacitating physical illness 7. What is abuse? The term abuse can be subject to many interpretations and for the purpose of this document, the definition is: Abuse is a violation of an individual s human and civil rights by any other person or persons. Abuse may consist of a single act or repeated acts and can occur in any relationship, it may be an act of neglect or an omission to act or it may occur when a vulnerable person is persuaded to enter into a financial or sexual transaction to which he or she has not consented or cannot consent. ( No Secrets, DOH 2000). The following is a list of the different forms of abuse: Physical abuse, including hitting, slapping, pushing, kicking, misuse of medication, restraint or inappropriate sanctions; Sexual abuse, including rape and sexual assault or sexual acts that the vulnerable adult has not consented to, or could not consent to or was pressured into consenting; Psychological abuse including emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, verbal abuse or withdrawal from services or supportive networks; Financial or material abuse, including theft, fraud, exploitation, pressure in connection of wills, property or inheritance or financial transactions, or the misuse of property, possessions or benefits Neglect or acts of omission, including ignoring medical or physical care needs, failure to provide access to appropriate health, social care or educational needs, withholding of the necessities of life such as medication, adequate nutrition and heating; Discriminatory abuse including racism, sexism, and abuse based on a person s disability slurs or similar treatment. Safeguarding Adults Policy Version 2 5

6 Institutional abuse refers to poor professional practice or neglect, which may be an isolated incident on one end of the spectrum or pervasive ill treatment or gross misconduct at the other. 7.1 Who may be the abuser? Adults at risk may be abused by a wide range of people including relatives and family members, professional staff, paid care workers, volunteers, neighbours, friends and associates, those who deliberately exploit vulnerable people and strangers. An adult at risk may be abused by their partner or by children in the family. In what circumstances may abuse occur? It can occur in any setting; when the adult at risk lives alone, with a relative, in nursing and residential homes, day care settings, hospitals, custodial situations, in other places previously presumed safe or in public places. 7.2 Patterns of abuse Patterns of abuse and abusing vary and reflect very different dynamics. These include: Sexual or serial abuse where the person is sought out and groomed Long term abuse in the context of family relationships, domestic violence Opportunistic abuse such as theft because money has been left around Situational abuse where pressures have built up and or difficult challenging behaviour. Neglect of needs because those around are not able to be responsible for their care, for example if the carer has mental health problems, alcoholism, or debts Institutional abuse which features poor standards of care, rigid routines inadequate staffing, insufficient knowledge base within the service Unacceptable treatments like sanctions where food, fluid is withheld, unnecessary or unauthorised restraint, keeping equipment out of reach like frames for example Failure to access key services such as health care, dentistry Misappropriation of benefits or use of person s money by others Fraud or intimidation in connection with wills property and other assets. 7.3 Safeguarding thresholds There is no standard precise definition of what should be categorised as a safeguarding issue (e.g. on some occasions a service user assaulting another service user should result in an alert whilst on other occasions it will not be appropriate to institute safeguarding proceedings following such an assault). Because it is not always obvious, staff should be cautious and raise a safeguarding alert if in doubt. However, it should be acknowledged that staff will exercise professional judgement before instigating the safeguarding procedures by asking the question is this a safeguarding issue? Safeguarding Adults Policy Version 2 6

7 8. Duties 8.1 Different Agencies:- The Police lead on criminal investigations Social Services and the Mental Health Trust will work in partnership on investigations relating to allegations of abuse on a service user under the care of the Mental Health Trust. Social services will lead on allegations of abuse of a service user under the care of ECS. Mental Health Trust will lead on internal SI investigations relating to allegations of abuse and serious harm within the trust. This could run pararell to the safeguarding investigation. Independent Service Providers can offer a range of support to service users and carers in protecting people from abuse and helping them recover from it Independent Advocacy Services have a role in ensuring that the voice of the adult at risk is heard, their wishes fully taken into account and their rights protected. Each of these agencies has a responsibility to ensure the protection of the rights and welfare of any adult at risk involved in the process. Consideration needs to be given to the protection of rights and welfare of the perpetrator (if they are another service user) and anyone who witnessed or reported the abuse. In addition all staff (including Managers, Ward Managers and all Clinical staff) are responsible for: Ensuring that they are aware of the Safeguarding Adults Policy Ensuring that they receive the appropriate training Ensuring that adults at risk are protected whilst in the care of the Trust Ensuring that the policy is implemented within their clinical area Reporting and investigating if appropriate any allegations of abuse immediately in line with the Pan London Procedures. 8.2 Service Line Managers/ SOVA Trust leads are responsible for: Attending the Trust-wide Safeguarding Adults Committee Acting in an advisory capacity Keeping a record of all Alerts, investigations etc within their Service Line Ensuring that the Trust is compliant with the CQC regulatory framework on safeguarding adults 8.3 Team/Ward Managers are responsible for Keeping a record of all Alerts, investigations etc within their Ward or Team Sending monthly returns to the local authority Ensuring that the Trust is compliant with the CQC regulatory framework on safeguarding adults 8.4 Assistant Director, Safeguarding Adults is responsible for: Ensuring Quality Assurance across the Mental Health Trust/ECS in relation to Safeguarding Adults Providing Mandatory Level 1 Safeguarding adult Basic Awareness training Co-ordinating the Trust-wide Safeguarding Adults Committee Providing a link with each of the Boroughs Safeguarding Adults structures Safeguarding Adults Policy Version 2 7

8 Being a member of each Borough s Safeguarding Adults Boards Completing the Trust Safeguarding Adult Annual Report Ensuring that the Trust is compliant with the CQC regulatory framework on safeguarding adults Providing advice and guidance where needed Keeping a database of all Alerts, investigations and outcomes of safeguarding relating to service users of BEHMHT. 8.5 Executive Director of Nursing, Quality and Governance is responsible for Ensuring that the Trust is adequately resourced to meet its Safeguarding Adults requirementsensuring that the Trust Board receives six monthly updates on the Trust s performance on Safeguarding Adults Ensuring that the Trust is compliant with the CQC regulatory framework on safeguarding adults Chairing the Trust Safeguarding Adult Committee. Attendance at the safeguarding adults Boards 9. Internal Procedures and Structures Each borough uses the Pan London Multi-agency Policy and Procedures to Safeguard adults from abuse. Access to the policies can be found on the Mental Health Trust s intranet.to support the implementation of the Pan London Procedures practice guidance have been developed by the local authorities and can be found on the Trust Intranet. Once a safeguarding issue has been identified an Alert must be raised by completing an Alert form and submitting via the following prcoess as described below as there is slight differences depending on which borough the alert is being raised in. Borough Procedures The procedures differ slightly in each borough: Barnet After discussion with the Line Manager a copy of the Alert form is sent to the CMHT Manager and local authority (please note an Alert form must be completed for all suspected Safeguarding concerns whether it is to be taken forward as such or not as the Safeguarding team needs to record all Alerts). If it is being taken forward to be investigated it is allocated within the team that raised the Alert (appendix 3 and 4) Enfield After discussion with the Team/Ward Manager/Team Leader, the Alert form is sent to the CMHT Manager for the CMHT in which the alleged victim lives. The CMHT manager is then responsible for allocating the case and co-ordinating the investigation. Each Team Manager is required to complete a monthly monitoring form which is sent to the Borough Head of Mental Health Services, who keeps a database of all Alerts and a map of the progress of each (appendix 3 and 5). NB If you work in Enfield Community Services the completed alert form is sent to the Access Team adultsocialcare@enfield.gov.uk (appendix 3 and 5). Safeguarding Adults Policy Version 2 8

9 Haringey the Alert form is sent to the Integrated Access Team (IAT) or the Borough s Safeguarding Adults Team who will carry out an investigation themselves or in discussion with the relevant Team Manager discuss how the investigation would proceed. The relevant Team/Ward Manager to ensure that all copies of the safeguarding adult paper work is uploaded on RIO.(appendix 3 and 7). 9.1 Recording It is a requirement that all paperwork relating to a Safeguarding Adult alert is uploaded on to the service users RIO case notes (appendix 1). If the allegation is in relation to another service user and/or a member of staff the paperwork MUST be annoymised. Every team/ward has access to a scanner to enable staff to upload the relevant documentation. 9.2 Disagreement re Safeguarding Should there be disagreement as to whether or not the issue should be raised as a safeguarding alert the advice of the designated Mental Health Trust lead/ecs for the relevant Service Line should first be sought. If there is still failure to reach agreement the decision should be escalated up to the Mental Health Trust s lead for Safeguarding Adults, the Assistant Director who will make a decision in consultation with the relevant Local Authority lead. 10. Serious Incidents- (SI) A number of events that are reported as an SI are often Safeguarding issues too (for example the alleged sexual assault of a service user by a member of staff). Whilst such incidents should always be reported as SIs they are also a Safeguarding issue and an Alert should also be raised. Safeguarding adults awareness is feature as part of the Mental Health Trust s SI and Root Cause Analysis training to ensure that the relationship between SI reporting and investigating and safeguarding is understood and that both are run in parallel where appropriate. Both processes can and should run in parallel. Therefore whenever a member of staff is reporting an incident as an SI, they must also consider Safeguarding issues. This is also set out in the Mental Health Trusts SI policy. Hence when an incident occurs in practice an incident form on Datix must be completed. If the incident is considered severe and reportable to NHS London (Strategic Health Authority) a 24 hour report is also to be completed. In addition there is also a requirement to consider and determine if the incident requires a referral through the safeguarding adult process. To ensure that there is an integration of the incident reporting process and the Safeguarding Adults procedure, staff must enter in the incident report form on DATIX, under the heading Immediate Action Taken, that a safeguarding adult alert has been raised. This requirement is necessary as the Trust has to report all incdients that meet the criteria listed below to the National Patient Safety Agency (NPSA), who in turn will Safeguarding Adults Policy Version 2 9

10 notify the Care Quality Commission (CQC) that the following types of incidents have occurred: Reporting Criteria for CQC: The abuse happens on Trust premises Alleged abuser is a member of staff Alleged abuser is another service user 11. Physical Assault on Inpatient Units/Safeguarding Adults The Trust has adopted a zero tolerance approach to violence and believes that the management of violence and aggression is the early recognition and prevention of such events. However where there has been an incident of violent behaviour from one Service User to another resulting in a physical assault, staff need to decide and be equipped to take the appropriate action necessary to both manage the situation and to minimise the risk of the incident happening again. Physical assault has been defined as the intentional application of force to a person without lawful justification, resulting in physical injury or personal discomfort. Physical assault could be as a result of angry feelings caused by hurt or ongoing frustration. However when dealing with incidents of aggression or violence on inpatient units staff must be aware that they are dealing with a person acting aggressively or violently and not necessarily a person who is aggressive or violent. Therefore consideration needs to be given to the person who have caused the harm mental state at the time of the assault. Albeit, it is not possible to precisely define thresholds for raising safeguarding alerts following instances of aggression and violence of one Service User to another on inpatient units. Therefore, a Team approach need to be taken when deciding whether to raise an alert or not. Additionally, if there are further concerns from staff as to the appropriateness of raising an alert following a physical assault a discussion should be held with the safeguarding Lead for that service or the AD for Safeguarding Adults. However, Managers and staff should consider raising alerts in the following circumstances: 1. Serious physical assaults 2. Multiple acts of aggression The following are examples of physical assault. Intimidation: making a fist, pushing, stalking, stealing/throwing objects. Brutality: attacks, struggles, fight. Punches and injuries: hitting, slapping, kicking, bites, bruises, injuries, dislocations, fractures Provocation: insults, death threats Prevention and Therapeutic Management of Violence and Aggression Safeguarding Adults Policy Version 2 10

11 It is recognised that at times some service users can be violent and agrressive towards others which can result in harm to other service users, staff or themselves. In line with the Prevention and Therapeutic Management of Violence and Aggression policy all patients must be screened for risk to others and where necessary have a care plan that addresses risks identified. During a violent/aggressive incident the intervention should initially be of a non- physical nature involving the extensive use of verbal de-escalation skills such as talking and reasoning with the patient in an effort to reduce levels of aggression and/or violence. However if physical restraint is used staff to ensure the safety of the service user and to record on RIO actions taken to manage the situation. Please refer to the Prevention and Therapeutic Management of Violence and Aggression Policy for further information. 12. Children visiting inpatient areas The separation of children from their parents or other key family members during the course of a parent s hospital admission can be a traumatic and distressing experience for all involved. Many children will be very anxious at such an event, and even brief periods of hospitalisation can seem lengthy in a child s mind. However, inpatient psychiatric wards are not always appropriate environments for children s visiting, and some service users may put children at risk of physical or psychological harm. Service users may also be disturbed or inconvenienced by children visiting. Albeit, it will usually be very helpful both to the child and the service user for children to be able to visit. The Trust is supportive to the continuity of family relationships and to children visiting family members in hospital. Visiting will normally be restricted to children who are close relatives of the service user or have an equivalently significant relationship with them. Hence where the service user has children or is closely involved with the children of friends or family members, it is important for the team to consider how these relationships will be maintained whilst the patient is in hospital. This discussion should include the service user, the child s current carer and any other involved agencies, In formulating a plan for contact with children, the team should take into account risks associated with: The patient's history, family situation and current mental state (Which may differ from an assessment made on admission) The age and overall emotional needs of the child The views of the child, the service user, and of those with parental responsibility The overall nature of the unit and the patient population as a whole (please refer to the Children Visiting Policy for further information) 13. Reporting Pressure Ulcers All new pressure ulcers assessed as being Stage 2 or higher should be recorded as a clinical incident and reported on the Datix System. Stage 3 and 4 pressure ulcers will be investigated to establish if the damage to the skin was avoidable or unavoidable and are reportable to the Strategic Health Authority via the Trust/ ECS quality monitoring pathway Avoidable Pressure Ulcer: Safeguarding Adults Policy Version 2 11

12 Avoidable means that the person receiving care developed a pressure ulcer and the provider of care did not do one of the following: evaluate the person s clinical condition and pressure ulcer risk factors; plan and implement interventions that are consistent with the persons needs and goals, and recognised standards of practice; monitor and evaluate the impact of the interventions; or revise the interventions as appropriate Unavoidable Pressure Ulcer: Unavoidable means that the person receiving care developed a pressure ulcer even though the provider of the care had evaluated the person s clinical condition and pressure ulcer risk factors; planned and implemented interventions that are consistent with the persons needs and goals; and recognised standards of practice; monitored and evaluated the impact of the interventions; and revised the approaches as appropriate; or the individual person refused to adhere to prevention strategies in spite of education of the consequences of non-adherence Safeguarding Concerns If it is suspected that pressure ulcers have resulted either from poor practice, lack of reasonable action to prevent skin damage or deliberate non-compliance with an agreed care plan, a safeguarding alert should be raised. 14. Domestic Violence Domestic violence is defined as any incident of threatening behaviour, violence orabuse (psychological, physical, sexual, financial or emotional) between adults who are or have been intimate partners or family members regardless of gender or sexuality.(family members are defined as mother, father, son, daughter, brother, sister and grandparents, whether directly related, in-laws or step-family; see ACPO, 2004.) Whatever form it takes, domestic abuse is rarely a one-off incident and should instead be seen as a pattern of abusive and controlling behaviour through which the abuser seeks power over the victim. Domestic abuse occurs across society, regardless of age, gender, race, sexuality, wealth and geography. The figures show, however, that it consists mainly of violence by men against women. Children are also affected both directly and indirectly and there is also a strong correlation between domestic violence and child abuse. The victim/ survivor is referred to here as female and the perpetator as male because this reflects the majority of cases where there are child protection concerns. However professionals should apply the guidance to all situations of domestic violence ( i.e. where it is perpetrated by women against men, within same sex relationships, and to or from a child or adult a carer may be caring for.effective safeguarding is achieved when agencies share information to obtain an accurate picture of the risk and then work together to ensure the safety of the adult at risk is prioritised. While the adult at risk should always remain at the centre of the safeguarding Adults process and be involved in their own safety planning, this does not preclude Safeguarding Adults Policy Version 2 12

13 the sharing of information without their consent, particularly where the risks are considered to be high. This approach is supported by legislation including the Data Protection Act 1998 (Schedules 2 and 3), the Crime and Disorder Act 1998 and the Human Rights Act The abusive partner should not be informed of any disclosures. Consideration should be made to contacting relevant agencies who may hold information on the adult at risk in domestic circumstances which might include the police, children s social care, health and provider organisations (this list is not exhaustive) Referrals to the Multi-agency Risk Assessment Conference (MARAC) A MARAC is a meeting where information is shared on the highest risk domestic abuse cases between representatives of local police, probation, health, children and adults safeguarding, housing practitioners, substance misuse services, independent domestic violence advisers (IDVAs) and other specialists from statutory and voluntary sectors. The four aims of a MARAC are as follows: to safeguard adult victims who are at high risk of future domestic iolenc to make links with other public protection arrangements in relation to children, people causing harm and vulnerable adult to safeguard agency staff and to work towards addressing and managing the behaviour of the person causing harm. Hence whilst most domestic violence referral for Safeguarding are managed by the Safeguarding adult process, for complex cases a referral to the Multi Agency Risk Assessment Conference (MARAC) is required. 15. Mental Capacity Act 2005 The primary purpose of the MCA is to promote and safeguard decision-making within a legal framework. It does this in two ways: by empowering people to make decisions for themselves wherever possible, and by protecting people who lack capacity by providing a flexible framework that places individuals at the heart of the decision-making process by allowing people to plan ahead for a time in the future when they might lack the capacity, for any number of reasons, to make decisions for themselves A lack of mental capacity could be due to: a stroke or brain injury a mental health problem dementia a learning disability confusion, drowsiness or unconsciousness because of an illness or the treatment or it substance misuse. (Sections 2 4, MCA) 15.2 What is mental capacity and when might you need to assess capacity? Safeguarding Adults Policy Version 2 13

14 Having mental capacity means that a person is able to make their own decisions. You should always start from the assumption that the person has the capacity to make the decision in question (principle 1). You should also be able to show that you have made every effort to encourage and support the person to make the decision themselves (principle 2). You must also remember that if a person makes a decision which you consider eccentric or unwise, this does not necessarily mean that the person lacks the capacity to make the decision (principle 3). Under the MCA, you are required to make an assessment of capacity before carrying out any care or treatment the more serious the decision, the more formal the assessment of capacity needs to be When should capacity be assessed? You might need to assess capacity where a person is unable to make a particular decision at a particular time because their mind or brain is affected by illness of disability. Lack of capacity may not be a permanent condition. Assessments of capacity should be time- and decision-specific. You cannot decide that someone lacks capacity based upon age, appearance, condition or behaviour alone. Hence 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 at risk. (please refer to the MCA Code of Practice and BEHMHT policy on Mental Capacity for further information) Mental Capacity Act 2005 The test to assess capacity Two-stage functional test of capacity In order to decide whether an individual has the capacity to make a particular decision you must answer two questions: Stage 1. Is there an impairment of or disturbance in the functioning of a person s mind or brain? If so, Stage 2. Is the impairment or disturbance sufficient that the person lacks the capacity to make a particular decision? The MCA says that a person is unable to make their own decision if they cannot do one or more of the following four things: understand information given to them retain that information long enough to be able to make the decision weigh up the information available to make the decision communicate their decision this could be by talking, using sign language or even simple muscle movements such as blinking an eye or squeezing a hand. 16. Prevent The purpose of the Prevent strategy ( is to stop people becoming terrorists or supporting violent extremism. Prevent is one of the four main workstreams of the overall UK strategy for countering international terrorism, known as CONTEST ( Prevent is included in the performance framework for local authorities, the police and other partners through National Indicator 35 (NI 35) and the Analysis of Policing And Community Safety (APACS) framework. NI 35, which applies to all local areas in England, requires authorities to develop a risk-based action plan to tackle violent extremism. The Prevent strategy has five objectives. One of these is to support Safeguarding Adults Policy Version 2 14

15 individuals who are vulnerable to recruitment or have already been recruited by violent extremists The Channel group provides a mechanism for supporting individuals who may be vulnerable to terroristrelated activity by assessing the nature and the extent of the potential risk, agreeing and providing an appropriate support package tailored to the individual s needs. Channel is part of the PREVENT strand of the Government s Counter Terrorism Strategy CONTEST. Channel is a multi-agency partnership that works with existing safeguarding partnerships and crime reduction panels in order to assess referrals of vulnerable individuals that are at risk of being drawn into terrorism. Channel is administered and coordinated by police, but chaired by the local authority. If you have concerns about a service user who might be at risk of being exploited by being involved Terrorism you should raise these with the Trustl Prevent lead or Safeguarding adult lead. The key challenge for the health sector is to ensure that, where there are signs that someone has been or is being drawn into terrorism, healthcare workers can interpret those signs correctly, are aware of the support that is available and are confident in referring the person for further support. If you have concerns about a service user who might be at risk of being exploited by being involved in Terrorism you should raise these with the Trust Prevent lead or Safeguarding adult lead What happens with the referral to Channel? Each referral is screened for suitability. If the referral is not appropriate for Channel an exit strategy will be planned. Appropriate referrals will go through a preliminary assessment coordinated by the police Channel coordinator. Partners will be asked to check and report back to the police Channel coordinator if the vulnerable individual is known to their service and a case profile will be created for the Channel meeting. The multi-agency panel will convene and be chaired by the local authority, support needs will be identified and action plan will be drafted. Each case will be reviewed a minimum of every six weeks. There will be a six-monthly and 12-monthly review for each case Will the vulnerable person be informed that they have been referred for Channel intervention? This will depend on individual circumstances. If there is genuine concern that informing individuals of the referral will jeopardise their engagement and increase vulnerability, partners may agree not to inform them, this should be judged on a case by case basis. 17. Whistle-Blowing The aim of the Whistle-blowing policy is to support a working environment and culture for individuals in which areas of concern raised will be reported and treated as extremely serious when it is about a possible danger, professional misconduct or financial malpractice that might affect patients, colleagues or Barnet, Enfield Safeguarding Adults Policy Version 2 15

16 &Haringey Mental Health NHS Trust itself in order to provide our staff with a safe, secure and honest environment to work. Always act whenever abuse is suspected including when your legitimate concern is not acted upon.whistle blowers are given protection under the Public Interest Disclosure Act (Please refer to the BEHMHT Staff Concerns and the Disclosure Of Information - Whistleblowing Policy). 18. The Pan London Multi-agency policy and procedure His document describes seven key stages (appendix 7) of the Safeguarding Adults process which are as follows: Stage One: Raising an alert Stage Two: Making a referral Stage Three: Strategy discussion or meeting Stage Four: Investigation Stage Five: Case conference and protection plan Stage Six: Review of the protection plan Stage Seven: Closing the Safeguarding Adults process 19. Reporting and Investigation Procedure All staff have a duty of care to share any concerns they have about the welfare of an adult at risk and must report any allegations or concerns immediately. If the alleged abuse occurred outside the Trust: Report to Ward Manager/Operational Manager (or equivalent) who will notify the relevant Trust Safeguarding Adult s lead for their Service Line and relevant Borough Safeguarding Adults lead. If the alleged abuse occurred inside the Trust: Take immediate steps to protect the adult at risk from further harm and ensure they receive medical attention as necessary Report to Ward Manager/Operational manager (or equivalent) who will notify the relevant Trust Safeguarding Adult s lead and relevant Borough Safeguarding Adults lead. Complete and submit an Alert form (please refer to relevant Borough s Procedures as to where Alert form should be submitted) Complete report on Datix If incident is severe a 24-hour report should also be completed and submitted (please refer to the Mental Health Trust s SI Policy and Procedures) All Alert forms, Investigators reports, minutes of Strategy meetings etc must be uploaded on to the service user s case notes in clinical documentation on RIO. 20. Organisational Learning A requirement of the Pan London Procedures is to take the learning from safeguarding adult cases back to the refering team, across the organisation and the partnership. Hence learning lessons from safeguarding adult cases should Safeguarding Adults Policy Version 2 16

17 feedback into practice and monitored through clinical governance meetings, Safeguarding Adult Committee, Ward and Team meetings and the partnership as appropriate.ensure the action plans from safeguarding cases are reviewed and acted upon. 21. Procedure for Dealing with Observed/Alleged Abuse Involving BEHMHT/ECS Staff Report the incident to your line manager immediately or as soon as possible, if your line manager is not available or it is outside normal working hours report the incident to the on call manager and inform the Assistant Director for your service the next working day. The Director of Nursing and the Assistant Director Safeguarding Adults need to be informed. Any immediate action with respect to the member of staff as the person who have caused the harm will be taken by the appropriate Assistant Director for the Service Line or if out of hours the on call Director. Immediately complete an incident report form (DATIX) and an alerter form to the relevant Team Manager or in the case of ECS the relevant social work team. (Note wherever the abuse takes place or is discovered, that borough (host authority) leads on the safeguarding procedure, which is where the alert form needs to go) If allegations of abuse involve the line manager the incident can be reported to a manager of your choice or through the Trusts Whistle blowing policy. The DATIX form will be processed under the Trusts incident reporting policy, the alerter form sent to the relevant team manager or social work team of the relevant Borough. The line manager will inform the Assistant Director for the Service Line who will then inform the Director of Nursing and Assistant Director for Safeguarding Adults (or another director if not present) to decide whether the Trusts SI policy should be implemented. The investigation into safeguarding will be coordinated through the agreed Trust arrangements with the local authority and it will be the strategy meeting that decides the course of action if a safeguarding investigation takes place. The line manager will participate in the strategy meeting and may be tasked through that group Investigative meetings with the alleged person who caused the harm or alerter may be carried out jointly with social services (as lead agency for safeguarding adults) to ensure the information is ascertained at the earliest opportunity and that staff are not subjected to numerous meetings to go over the same ground Safeguarding Adults Policy Version 2 17

18 The member of staff will be dealt with in accordance with the Trusts disciplinary policy, which will be implemented by the line manager The investigating Trust Manager will be the same as that involved in the strategy meeting and will have the responsibility to carry out the Trusts internal disciplinary policy. It is important that the safeguarding procedure and Trusts internal policy do not conflict and how this is managed in should be discussed and agreed at the strategy meeting. 22. Quality Assurance and monitoring 22.1 Barnet Enfield and Haringey Mental Health Trust have a number of internal governance arrangements in place to monitor and maintain quality assurance with regards to safeguarding Adults procedures There is a multi-agency Trust wide Safeguarding Adults committee that meets on bi-monthly basis and maintains an overview of the Mental Health Trust s/ecs performance in relation to Safeguarding Adults and quality assurance There are service line leads and a lead officer within each Ward/Team (usually the Ward or Team Manager) who have the responsibility for linking in with each Borough s governance structures and ensuing that the Mental Health Trust/ECS is complying with the policies and procedures as expected The People and Organisational Development Department will provide quarterly compliance reports to the Senior Management Group on each service s compliance with the Trust s mandatory training requirements for level 1 Safeguarding Adults training. In addition the Head of Workforce Development will provide the Trust s Safegaurding Adults committee with bi monthly reports on the uptake of multi agency level 2 and level 3 training All paperwork related to Safeguarding adult must be uploaded onto the patient s case notes in clinical documentation on the Mental Health Trust s/ecs internal database, RiO. Spot check case note audits by the AD for Safeguarding Adults on compliance with the above requirements will be carried out on a bi monthly basis. A report on the findings will be provided to each Trust Safeguarding Adults Committee The AD for Safeguarding Adults will ensure that collated analyses from the data bases from each borough specifying how many SOVA alerts have been raised by Trust staff (and the current status of these alerts), are considered at every Trust Safeguarding Adults Committee 22.7 Team managers to complete one case file audit per month on a closed safeguarding adult case. The case file audit data to be presented within a balanced scorecard which will presented at the Safeguarding Adults Committee three times per year by the AD for Safeguarding Adults A safeguarding annual report and workplan will be developed and presented at the Trust Board on a annual basis. Safeguarding Adults Policy Version 2 18

19 22.9 The Trust Safeguarding Adults Policy will be reviewed as a minimum, every three years by the Assistant Director for Safeguarding Adults taking into account the views of staff across the Trust. The policy will further be discussed at the Trust Safeguarding adult committee. Any amendmnets will be ratified by the Policy development Group. 23. Training Strategy The training strategy for Safeguarding adults is that all existing and new staff will receive training appropriate to their job role. Three levels of training are available: Level Training of Safeguarding adults raising awareness (level 1) Safeguarding adults raising awareness (refresher) (level 1) Safeguarding Investigations (level 2) Staff Group Staff groups A,B,C and D. this level of training is provided in the Trust and has been mapped against the Learn to Care Bournemouth Competencies and the Core Skills Framework Staff groups A,B,C and D. this level of training is provided in the Trust has been mapped against the Learn to Care Bournemouth Competencies and the Core Skills Framework Staff group B and C Training Package/ or provider This training is provided inhouse as outlined in the Trust Mandatory Training Matrix. This training is provided inhouse as outlined in the Trust Mandatory Training Matrix. Required for staff who lead on safeguarding adult Frequency Once in employment Every three years. This is to provided via e-learning however currently is offered as a taught session. Once (unless major changes to procedures then an update is required). However safeguarding adult refresher training is Safeguarding Adults Policy Version 2 19

20 Chairing Strategy Meetings/Case Conference (level 3) Investigations. This includes staff at band 6 and above. The training is multi agency and is offered by the local authority in Barnet, Enfield and Haringey Staff group C Required for staff who chair Strategy meetings/ Case Conferences. This training is for Team Mangers, Senior Practitioners and other senior staff who are required to take the role of a Safeguarding Adult Manager (SAM). The training is multi agency and is offered by the local authority in Barnet, Enfield and Haringey required every three years. Once (unless major changes to procedures then an update is required). However safeguarding adult refresher training is required every three years 24. Sharing Information The question of sharing or disclosing information with the view to protecting adults at risk presents a number of professional, ethical, practical and legal dilemmas. It is necessary to identify the circumstances in which the usual practice of respecting Safeguarding Adults Policy Version 2 20

21 confidentiality should be overridden in order to protect the adult at risk (eg is the adult being intimidated or if there is concern about another adult at risk.) The principles of information sharing are summarised below: Information will only be shared on a need to know basis when it is in the best interest of the service user. Confidentiality must not be confused with secrecy. Informed consent should be obtained but, if this is not possible and other adults at risk it may be necessary to override the requirement. It is inappropriate for agencies to give assurances of absolute confidentiality in cases where there are concerns about abuse, particularly in those situations when other vulnerable people may be at risk. For patients where there is concern that they may not be able to give consent to information sharing or investigation, for example in the case of a person with dementia or learning disabilities, an assessment of mental capacity and any subsequent best interests decisions should be made in accordance with the Mental Capacity Act 2005 and the associated Code of Practice, and with reference to the Mental Health Trusts consent policy. Decisions about who needs to know and what needs to be known should be taken on a case by case basis, within agency policies and constraints of the legal framework. If there is any doubt around sharing information, advice should be sought from the Trust s legal department. If it is essential that confidential information is to be sent via it may only be done so as encrypted and password protected files. 25. People and Organisational Development Department and Safeguarding Process If a member of staff has been dismissed as a result of a disciplinary investigation following an allegation of abuse, the Trust is duty bound to inform the Independent Safeguarding Authority Disemination and Implementation This document will be made available to all Trust staff on the Trust through line management cascade. Intranet and Safeguarding Adults Policy Version 2 21

22 27. References Barnet Enfield and Haringey Mental Health Trust Sexual assaults Policy Barnet Enfield and Haringey Mental Health Trust Serious Untoward Incident Policy Barnet Enfield and Haringey Mental Health Trust Domestic Violence Protocol Barnet Enfield and Haringey Mental Health Trust Mandatory Training Policy Barnet Enfield and Haringey Mental Health Trust Complaints Procedure Barnet Enfield and Haringey Mental Health Trust Children Visiting Polocy Barnet Enfield and Haringey Mental Health Trust Pressure Ulcer Prevention & Management Policy Version 2 December 2010 Barnet Enfield and Haringey Mental Health Trust revention and Therapeutic Management of Violence and Aggression Barnet Enfield and Haringey Mental Health Trust whistleblowing policy Being Open When Patients are Harmed (NPSA Safer Practice Notice, September 2005) Department of Health (2000) No Secrets :guidance on developing multi-agency policies and procedures to Protect vulnerable adults from abuse. Department of health- health and social care bill Safeguarding Adults A National Framework for Standards for Good Practice and Outcomes in Adult Protection Work, (ADSS 2005) Social care Institute for Excellence (2011) Protecting adults at risk: London multi-agency policy and procedures to safeguard adults from abuse Safeguarding Adults Policy Version 2 22

23 EQUALITY IMPACT ASSESSMENT AND ANALYSIS FORM Name of the policy/service development, strategy or plan being analysed: Safeguarding Adults at Risk Policy Name and job title of the manager responsible for carrying out this analysis: Veronica Flood-Assistant Director Safeguarding Adults Please summarise your policy/service development, strategy or plan The aim of this policy is to ensure that adults at risk are protected from any form of abuse whilst under the care of Barnet Enfield and Haringey Mental Health Trust/ECS. In addition that staff are aware of the special needs of adults at risk and that they receive training and guidance in the recognition of abuse. It sets out the responsibilities of Trust staff in the recognition and prevention of abuse and the actions to take when abuse is suspected or identified What are the main objectives or intended outcomes of the policy/service development, strategy or plan? Objective: 1. To ensure that staff within Barnet Enfield and Haringey Mental Health NHS Trust are aware of their responsibilities with regards to the protection of adults at risk from significant harm and abuse. 2. To ensure staff awareness in taking action to protect adults at risk from abuse Intended outcomes: Any reported cases of abuse will be dealt with according to the Protecting adults at risk: London Multi-agency policy and Procedures to safeguard adults from abuse 1. Please indicate the expected impact of your proposal on people with protected characteristics Characteristics Significant +ve Some +ve Neutral Some -ve Significant -ve Age: Disability: Ethnicity: Gender re-assignment: Religion/Belief: Sex (male or female) Sexual Orientation: Marriage and civil partnership Pregnancy and maternity 2. Consideration of available data, research and information Monitoring data and other information should be used to help you analyse whether you are delivering a fair and equal service. Social factor are significant in health and wellbeing outcomes. Please consider the availability of the following as potential sources: Demographic data and other statistics, including census findings Recent research findings (local and national) Results from consultation or engagement you have undertaken Service user monitoring data (including age, disability, ethnicity, gender, religion/belief, sexual orientation and) Safeguarding Adults Policy Version 2 23

24 Information from relevant groups or agencies, for example trade unions and voluntary/community organisations Analysis of records of enquiries about your service, or complaints or compliments about them Recommendations of external inspections or audit reports Key questions 2.1 How does this change/development/plan relate to the Trust s corporate equality objectives and the public sector duty? 2.2 What are the relevant equalities characteristics of the staff involved or affected? 2.3 What are the relevant equalities characteristics of the service users and carers involved or affected? 2.4 What other relevant data do you have in terms of service users or staff? (e.g results of customer satisfaction surveys, consultation findings, census data, health needs assessments etc). Reference data, research and information that you have reviewed which you have used to form your response Safeguarding adults from abuse is applicable to all service users irrespective of race, gender or religious belief. 3. It is Trust policy that you explain your proposed development or change to people who might be affected by it, or their representatives. Please outline how you plan to do this. Group Methods of engagement Staff Policy Development Group Safeguarding Adult Committee Communication Via regarding reviewed policy 4. Does the proposal incorporate or promote all or some of the nine principles of mental health recovery? Personal responsibility and self Strengths approach Spirituality determination Hope and Optimism Support networks Community integration/social inclusion Collaboration Service user involvement Positive risk taking If yes, please give evidence. Personal responsibility and self determination Strengths approach Spirituality Hope and optimism have been taken into account in that if a service user becomes a victim of abuse that they are supported to report it and at best staff will take action to minimise harm or distress caused by the incident. if a service user becomes a victim of abuse that they are supported to report it and at best staff will take action to minimise harm or distress caused by the Safeguarding Adults Policy Version 2 24

25 incident. Support Networks Community integration/social inclusion Collaboration Staff to work in collaboration with service users and relatives/carers. Service user involvement The service user or their representative to be involved in the safeguarding case. Positive risk taking Positive approach to reporting abuse.. 5. Equality Impact Analysis Improvement Plan If your analysis indicates some negative impacts, please list actions that you plan to take as a result of this analysis to reduce those impacts, or rebalance opportunities.. These actions should be based upon the analysis of data and engagement, any gaps in the data you have identified, and any steps you will be taking to address any negative impacts or remove barriers. The actions need to be built into your service planning framework. Actions/targets should be measurable, achievable, realistic and time framed. Issues identified Actions required By who 6. Sign off and publishing Once you have completed this form, it needs to be approved by Service Director or an Executive Director or their nominated officer. If this Equality Impact Analysis relates to a policy, procedure or protocol, please attach it to the policy and process it through the normal approval process. Following this sign off by the Policy Review and Monitoring Committee your policy and the associated EqIAn will be published by If your EqIAn related to a service development or business /financial plan or strategy, once your Director or the relevant committee has approved it please send a copy to the Equalities Team (equalities@beh-mht.nhs.uk), who will publish it on the Trust s website. Keep a copy for your own records. I have conducted this equality Impact analysis in line with Trust guidance Name: Veronica Flood Position Assistant Director Safeguarding Adults Signed: Date: 18 th September 2013 Approved by: Name: Sign: Date Position Safeguarding Adults Policy Version 2 25

26 28. Appendices Appendix 1- Process for Data Recording on RiO Introduction BEHMHT is working on Safeguarding Adults with the Boroughs of Barnet, Enfield, and Haringey the actual processes vary slightly from Borough to Borough. The process below will ensure data is collected in a standardised and consistent format. Requirements & Proposed Process The process below fulfils the following criteria: standardized access to all Safeguarding Adults documentation in one place: all available as uploaded letters in patient record a simple and obvious way of identifying Patient Files which are subject to Safeguarding Adults: flagged on front page of record ability to easily identify Progress Notes relating to Safeguarding Adults Process: visible as Significant Events and as Risk Incidents ability to report on number of active patients subject to Safeguarding Adults: Report from RiO backend Caveats and Comments RiO still displays as 'Adult Protection' instead of Safeguarding Adults. This change has been initiated, but is not expected to be present in the application prior to rolling out the new process. Patients may need to be notified when a SoVA is entered on their record. Standard RiO confidentiality as well as Policies concerning Confidentiality, Audit, and Pseudonomization fully apply Safeguarding Adults Policy Version 2 26

27 Proposed Process for Safeguarding Adults Data Recording Safeguarding Adults Adults Process Process RiO RiO Upload SoVA Alerts form Enter Note, flag as Risk: Vulnerability From Others Notify Client that SoVA has been entered onto system SoVA raised by MHT or other Agency Initial Enquiries Strategy Meeting Enter Note, flag as Risk: Vulnerability From Others Upload minutes from Strategy Meeting Yes Closed? No Investigation Enter Note, flag as Risk: Vulnerability From Others Mark Patient Record as Subject to Safeguarding Adults Upload documents (Minutes, Investigation Report, Protection/ Action Plan) Reconvened Strategy Meeting / Case Conference Protection Plan Enter Note, flag as Risk: Vulnerability From Others Upload Reviewed Plan Review of Plan Enter Note, flag as Risk: Vulnerability From Others Remove Subject to Safeguarding Adults Closed Safeguarding Adults Policy Version 2 27

28 Progress Notes The following needs to be selected for all SoVA related Progress Notes: Document Upload The following needs to be selected for all SoVA related document uploads: Flagging as Subject to Safeguarding Adults The flag to make this visible on the Case Record Screen can be set/removed here: Safeguarding Adults Policy and Version 1 28 October 2011

29 Appendix 2 Safeguarding Adults Safeguarding Adults is everyone s business. The Trust in partnership with the three local authorities are committed to providing high quality training both inhouse and multi-agency that supports staff in carrying out their duties and to ensure compliance against Skills for Care CQC requirements - Essential Standards of Quality and Safety, Outcome 7 safeguarding people who use services from abuse. We are committed to the National Learn (Bournemouth) to Care Competency Framework for safeguarding Adults which is designed to provide a baseline of standards of competence required of those who work to safeguard adults across the range of sectors. Therefore courses are now mapped in staff groups A D against the Framework. All newly appointed staff should be assessed as competent against their relevant competencies within the first 6 months of entering their post. To maintain skills and knowledge in Safeguarding Adults staff in groups A, B, C and D should undertake a refresher a minimum of every three years. Staff Group A Group A staff have a responsibility to contribute to safeguarding Adults, but do not have specific organisational responsibility or statutory authority to intervene. Examples include, but not limited to Care/ support staff Drivers, transport staff Day services staff All support staff in health and social care settings Health and Social care professionals HR staff Admin staff Domestic and ancillary staff Health and Safety officers Elected members Volunteer Befrienders Charity trustees Trades people Staff Group B Group B staff have considerable professional and organisation responsibility for safeguarding Adults and has to be able to act on concerns and contribute appropriately to safeguarding procedures. They need to work within an inter- or multiagency context. Examples include, but not limited to Social workers, Health and Social Care professionals Nurses Frontline Managers Integrated team Managers Head of Drivers, transport staff Health and Social care Provider service managers ABE Trained investigating officers Safeguarding Adults Policy 29

30 Staff Group C Group C staff ensure the management and delivery of Safeguarding Adult services is effective and efficient. They will have oversight of the development of systems and policies to facilitate good working partnership with allied agencies to ensure consistency in approach and quality of service Examples include, but not limited to Operational Managers Heads of Assessment & Care management Service Managers Senior Practitioners Staff Group D Group D staff are responsible to ensuring that the organisation is committed to Safeguarding Adults and have in place appropriate systems and resources Examples include, but not limited to Heads of Support Services Heads of Assessment & Care management services Heads of directly Provided Services Safeguarding Adults Policy 30

31 Level 1 Basic Awareness in Safegurding Adults Competencies Target Group Anyone in the statutory, voluntary and private sectors that comes into contact withadults at risk including paid and volunteer workers, managers, senior officers and elected members (Enfield Council). Aim This course will provide an introduction to safeguarding adults and the Pan London Procedures Competency Having attended a course, participants will be able to: Understand the definition of an adult who may be at risk of abuse; and understand the definition of abuse and its different types, as defined by No Secrets (DH 2000) Understand their role as an alerter and reporter of abuse as defined by the local policy and procedures-pan London Procedures Recognise the signs and symptoms of abuse Describe how to access and use the local multi-agency Safeguarding Adults Procedures Recognise the importance of whistle-blowing procedures and the common barriers to reporting Recognise the importance of creating a safe environment in order to minimise the immediate risk of abuse Understand how to preserve evidence Understand in broad terms relevant national policy and legislation Course content Types and signs of abuse Definitions of adult at risk Confidentiality and capacity Legislation Pan London Procedures Multi Agency Risk Assessment Conference (MARAC) Mental Capacity Act 2005 Whistle Blowing Domestic Violence Safeguarding Adults Policy 31

32 Appendix 3 Safeguarding Adults Policy 32

33 Safeguarding Adults Policy 33

34 Safeguarding Adults Policy 34

35 Appendix 4: Barnet Safeguarding Adults Flowchart &Alert Form 1 Safeguarding Adults Policy 35

36 Safeguarding Adults Alert / Referral Form 1 To be completed by the worker receiving the alert Safeguarding Adults Policy 36