DRAFT ADULT SAFEGUARDING POLICY

Transcription

1 DRAFT ADULT SAFEGUARDING POLICY Version 2.0 Status Comments from discussion at Quality, Safety and Clinical Risk Committee meeting on 21 November incorporated Author Jude Channon Senior Responsible Officer Sarah Mansuralli Clinical Responsible Officer Dr Amanda Craig Directorate Responsible Chief Operating Officer s Office Ratified By and Date Quality, Safety and Clinical Risk Committee subject to discussed amendments being incorporated (21 st November 2014) Date Effective Date of Next Formal Review 30 th April 2013 Version Control Record Version Description of Change(s) 1.0 First draft of Brent Specific Policy nd draft Incorporating incorporating amendments arising guidance on from discussion of statutory draft policy at QSCR responsibilities and Committee meeting including on 21 st November governance and 2012 accountability framework for NHS Brent CCG Reason for Change Author Date Jude Channon 31/10/12 Sarah Mansuralli 23/11/12 Adult Safeguarding Policy (v rd Nov 12) Page 1 of 15

2 Contents 1. Aim Introduction Policy Framework Scope and Application of Policy Roles and responsibilities Definition of an adult at risk Principles of Safeguarding Adults Deprivation of Liberty (DoLs) Senior and Strategic Health Leads Commissioning Serious Incidents (SIs) and Serious Case Reviews (SCRs) Training NHS Brent CCG Board Assurance Safeguarding Adults Boards (SAB) Dissemination and Implementation Monitoring Review Appendix A Brent Safeguarding Adults Board Adult Safeguarding Policy (v rd Nov 12) Page 2 of 15

3 1. Aim 1.1 The aim of this policy is to make clear the duties, responsibilities and arrangements in place to safeguard and promote the welfare of Vulnerable Adults in the population that NHS Brent CCG is responsible for. 1.2 This policy therefore sets out: a. The systems that NHS Brent CCG has in place to discharge its statutory responsibilities with respect to the safeguarding and promoting the welfare of Vulnerable Adults. b. Provides guidance to NHS Brent CCG employees to support them in fulfilling their adult safeguarding responsibilities. 2. Introduction 2.1 NHS Brent CCG is responsible for commissioning high quality services for all patients registered to member practices of the CCG and those patients who are resident in the London Borough of Brent but are unregistered with any other GP practice. We have a particular duty and commitment to those patients who are less able to protect themselves from harm, neglect or abuse, for example, due to impaired mental capacity. 2.2 The term Safeguarding Adults covers everything that assists an adult at risk to live a life that is free from abuse and neglect and which enables them to retain independence, well-being, dignity and choice. It is about preventing abuse and neglect as well as promoting good practice for responding to concerns on a multi agency basis. 2.3 NHS Brent CCG recognises that safeguarding adults is integral to: Patient care achieving high quality care for patients. Safeguarding is particularly relevant to domains 4 and 5 of the NHS Outcomes Framework patient experience and protecting people from avoidable harm Regulations safeguarding is a fundamental requirement for registration and compliance with the Care Quality Commission, Essential Standards for Quality and Safety Legislation duty to comply with other legislation including the Human Rights Act; Equality Act; Mental Capacity Act, and Safeguarding Vulnerable Groups Act. Cost Effectiveness Quality, Innovation, Productivity and Prevention harm, neglect and abuse cost the NHS millions each year in avoidable admissions and care. 2.4 Through the No Secrets document 2000, the Department of Health placed the responsibility for coordination and development of local procedures for safeguarding adults from abuse with Local Authorities. Adult Safeguarding Policy (v rd Nov 12) Page 3 of 15

4 2.5 NHS Brent CCG and all commissioned healthcare services have a responsibility for: a. identifying safeguarding incidents b. alerting Adults Social Services of alleged abuse c. contributing towards investigations involving clinical neglect / abuse 2.6 All NHS Brent CCG managers and their staff and contracted agencies are responsible for raising awareness of the vulnerable adult s agenda to its own staff. Managers are responsible for ensuring their staff have attended relevant training provided by the London Borough of Brent. 3. Policy Framework 3.1 NHS Brent CCG is committed to the principles and definitions set out in the Pan- London multi-agency policy and procedures to safeguard adults from abuse. 3.2 This policy should be read ion conjunction with NHS Brent CCG s Quality Strategy and the Brent, Ealing, Harrow and Hillingdon Integrated Risk Management Framework. 3.3 This policy draws on the guidance within the Department of Health guidance No Secrets and the Pan-London multi-agency policy and procedures, as well as other national and local guidance, which includes: a. Protecting adults at risk: London multi-agency policy and procedures to safeguard adults from abuse. SCIE b. No Secrets: guidance on developing and implementing multi-agency policies and procedures to protect vulnerable adults from abuse. Department of Health. 2000, AndGuidance/DH c. Safeguarding Adults. The role of commissioners. Department of Health. 2001, AndGuidance/DH d. Mental Capacity Act 2005 (including 2011 amendments), CapcityAct2005/index.htm e. Deprivation of Liberty Safeguards: A guide for Primary Care Trusts and Local Authorities. DH 2009, AndGuidance/DH f. Clinical Governance and adult safeguarding: an integrated process. Department of Health AndGuidance/DH Adult Safeguarding Policy (v rd Nov 12) Page 4 of 15

5 4. Scope and Application of Policy 4.1 In order to comply with Department of Health guidance, NHS Litigation Authority standards and general public expectations, NHS Brent CCG is required to have a Vulnerable Adults policy that respects patients rights, is understood by all staff, and is accessible to all those who need it. 4.2 The focus of this policy is not only to highlight the responsibilities for all NHS Brent CCG staff and contracted staff but to recognise that Safeguarding Vulnerable Adults is everyone s business and can only be overcome by using a multi agency approach where communication is a key theme. 4.3 This policy applies to all staff employed by NHS Brent CCG, directly or indirectly. 4.4 Independently contracted staff have an individual responsibility to read and comply with this policy and to notify their manager if they have training needs in this area. 5. Roles and responsibilities 5.1 Whilst the primary responsibility for co-ordinating Safeguarding Adults arrangements lies with Borough Councils with social care responsibilities, effective safeguarding is based on a multi-agency approach. This policy sets out the range of CCG responsibilities and how it will meet these. 5.2 NHS Brent CCG is responsible for: a. Having clear lines of accountability, robust governance and leadership for safeguarding within the CCG, including regular board reports. b. Taking an active membership role of the Safeguarding Adults Boards and resources to support this group. c. Having in place plans to train staff in recognising and reporting safeguarding issues. d. Providing assurance that commissioned health services have appropriate arrangements in place to safeguard adults (e.g. policies, governance, leadership, training, partnership working, senior membership of the Safeguarding Adult Board). e. Providing assurance that commissioned services comply with Care Quality Commission requirements on safeguarding. f. Ensuring information is shared with partner agencies (e.g. social services, police). g. Ensuring commissioned health services participate in LA-led case reviews should a safeguarding incident occur, disseminate learning and monitor implementation of improvement actions. h. Leading a local NHS investigation process if a safeguarding incident falls outside the remit of the safeguarding board, but there is potential learning for health services. Adult Safeguarding Policy (v rd Nov 12) Page 5 of 15

6 i. Ensuring a designated safeguarding adults clinical lead for commissioning and a lead for the Mental Capacity Act, supported by relevant policies and training. 6. Definition of an adult at risk 6.1 An adult at risk is a person over 18 who may be eligible for community care services whose independence and wellbeing would be at risk if they do not receive appropriate health and social care support. 6.2 An adult at risk s vulnerability is determined by a range of interconnected factors, including personal characteristics, factors associated with their situation or environment and social factors. 6.3 The Pan London Policy for Safeguarding Adults advises that the vulnerability of the adult at risk is related to how they are able to make informed choices and protect themselves from harm, free from duress, pressure or undue influence of any sort, and to protect themselves from abuse, neglect and exploitation. An adult at risk may therefore be a person who for example: is elderly and frail due to ill health, physical disability or cognitive impairment has a learning disability has a physical disability and/or sensory impairment has mental health needs including dementia or a personality disorder has long term illness / condition misuses substances or alcohol is a carer such as a family member/ friend who provides personal assistance and care to adults and is subject to abuse is unable to demonstrate the capacity to make a decision and is in need of care and support 6.4 Abuse is a violation of an individual s human and civil rights by any other person or persons and takes many forms. It can occur in any relationship and any setting and can be caused intentionally or unintentionally. 6.5 Abuse may be a single event or repeated events or, as in the case of neglect, it may be a process going on over time. Abuse may occur as a result of deliberate intent, negligence or ignorance or as a result of a developed poor practice. 6.6 Abuse is recognised in seven categories: Physical Sexual Financial or material Neglect, both self and acts of omission Psychological Institutional Discriminatory Adult Safeguarding Policy (v rd Nov 12) Page 6 of 15

7 6.7 Domestic abuse is a term that is used to describe a wide range of violent and abusive behaviours. These include many forms of physical violence, but also include many forms of sexual abuse (including rape), emotional and psychological abuse and other varieties of abuse such as financial control and deprivation. 6.8 Joint working with professional in the field of domestic abuse during safeguarding adults investigations is crucial to the investigative process and to the outcome of investigation itself. 7. Principles of Safeguarding Adults 7.1 The CCG must make a commitment that adults at risk are listened to and what they have to say is taken seriously and acted upon in an appropriate manner. Individuals have a right to privacy; to be treated with dignity and to be enabled to live an independent life. 7.2 Individuals should be able to exercise choice about how they lead their lives and have their rights upheld, regardless of ethnic origins, gender, sexuality, disability, age, religious or cultural background and beliefs. 7.3 In accordance with the Mental Capacity Act 2005 there is a presumption of mental capacity unless an assessment of capacity shows otherwise. It is the right of adults who have capacity to make their own choices irrespective of how unwise their decision is construed. 7.4 However, where a crime is suspected; or allegations involve a member of staff, parent, carer or volunteer; there is a risk of serious harm to that person or any other adult at risk, then relevant agencies should be informed and allegations must be investigated whether the alleged victim is willing to take an active part in the process or not. 7.5 Where adults lack the capacity to safeguard themselves, other people will need to make those decisions. In doing so, they will act as decision maker and will make best interest decisions on their behalf as described in the Mental Capacity Act Code of Practice. 8. Deprivation of Liberty (DoLs) 8.1 The Mental Capacity Act 2005 provides a framework for making decisions on behalf of people who don t have the mental capacity to do so for themselves. Deprivation of Liberty safeguards the protection of vulnerable adults who can t make decisions about treatment or care, who need to be cared for in a restrictive way. For example, some people who have dementia, a mental health problem (not detained under the Mental Health Act 2007) or a severe learning disability. 8.2 The aim of the safeguards is to: Adult Safeguarding Policy (v rd Nov 12) Page 7 of 15

8 make sure people can be given the care they need in the least restrictive way. This means following good practice in care homes and hospitals prevent decisions being made to suit the home or hospital rather than the needs of the vulnerable person Provide safeguards for vulnerable people Provide the rights to challenge unlawful detention against the person s will. 8.3 Mental Health Capacity decisions are managed by the Head of Commissioning and Procurement for Continuing Care and Complex Patients. This service is responsible to the BEHH Director of Quality and Safety. 9. Senior and Strategic Health Leads 9.1 NHS Brent CCG s Accountable Officer (AO) has the overarching responsibility for ensuring that the contribution by health services to safeguarding and promoting the welfare of adults is discharged effectively across the whole local health economy through its commissioning arrangements. 9.2 The Director of Quality and Safety for Brent, Ealing, Harrow and Hillingdon (BEHH) CCG s is responsible for providing assurance that the monitoring of safeguarding across NHS Brent CCG takes place through Brent s Quality, Safety and Clinical Risk Committee and that there is a constructive relationship with the Brent Safeguarding Adults Board. 9.3 The Director of Quality and Safety is further responsible for reporting any safeguarding/deprivation of liberty risks and achievements to the Accountable Officer and Chief Operating Officer for NHS Brent CCG and to draft corporate media responses where required. 9.4 NHS Brent CCG has a public health responsibility to actively promote the health and well-being of all adults in the area and this function is executed by the Director of Public Health. 9.5 NHS Brent CCG s designated senior clinical commissioning lead for safeguarding adults is the Clinical Responsible Officer for Mental Health, Learning Disability and Carers and the Co-Chair of the Quality, Safety and Clinical Risk Committee of NHS Brent CCG s Governing Body. 9.6 The management of serious incidents reporting rests with the Head of Governance for BEHH. Safeguarding Adults arrangements will interface with the management of SI s through the BEHH Integrated Risk Management Framework. 10 Commissioning 10.1 Safeguarding is integral to commissioning activity and should be incorporated into commissioning decision making by: Adult Safeguarding Policy (v rd Nov 12) Page 8 of 15

9 a. putting patients first in how services are commissioned b. leading a culture that safeguards patients c. using systems and processes that support safeguarding and connect aligned areas d. developing partnerships with patients, public and multi agency partners 10.2 Service specifications drawn up by NHS Brent CCG will therefore include clear service standards for safeguarding and promoting the welfare of all adults, which are consistent with the Pan London Policy for Safeguarding Adults NHS Brent CCG will ensure, through established processes (Clinical Quality Groups, Service Alerts and the Quality, Safety and Risk Committee), the quality standards of commissioned providers. This will include ensuring that commissioned providers have comprehensive and effective management arrangements in place to safeguard and promote the welfare of vulnerable adults, which include: a. training programme for all staff with direct or indirect access to adults at risk b. quality assurance programme, including the regular review of alerts raised and whether these were raised in line with procedure c. internal procedure for safeguarding adults 10.4 NHS Brent CCG commissioners will ensure that managers of commissioned services are clear about their leadership role in safeguarding adults, the supervision and support of staff including induction and training, and responding to and investigation a concern about an adult at risk NHS Brent CCG Commissioners will liaise with Brent Safeguarding Adults Board and regulatory bodies with a view to making regular assessments of the ability of service providers to effectively safeguard service users, ensuring Safeguarding Adults are always included in the monitoring arrangements for contracts and service level agreements When considering commissioning services for the health and well-being of adults in need in their area, NHS Brent CCG will ensure the consideration of temporary residents in the CCG area that are not registered with a GP NHS Brent CCG will ensure that safeguarding and promoting the welfare of adults at risk is integral to the quality and safety of all services with evidence of robust audit arrangements that are reported to the Brent Adult Safeguarding Board the CCG s Quality, Safety and Clinical Risk Committee NHS Brent CCG will monitor the service standards of contracted service providers to ensure providers meet the required safeguarding adults standards. This will involve regular announced and unannounced visits and analysis of monthly performance reports from providers with necessary action plans developed and monitored. 11. Serious Incidents (SIs) and Serious Case Reviews (SCRs) 11.1 NHS Brent CCG is responsible for co-ordinating the health component of serious case reviews in accordance with the Pan London Policy for Safeguarding Adults via the borough based designated leads for Safeguarding. Adult Safeguarding Policy (v rd Nov 12) Page 9 of 15

10 11.2 NHS Brent CCG will ensure that the NHS Commissioning Board and the Care Quality Commission (CQC) are notified of all serious case reviews via the borough based designated leads for Safeguarding Serious Incidents, reported through STEIS and DATEX, will be escalated to the Adult Safeguarding Board on the basis of risk assessment. The management of Serious Incidents rests with the BEHH Head of Governance Risk assessment to determine whether escalation is appropriate will be through the processes and risk appetite framework contained in the BEHH Integrated Risk Management Framework In accordance with current practice, all Serious Incidents scoring a grade 4 (moderate) risk score will be escalated to the Brent Adult Safeguarding Board for a decision about initiating a Serious Case Review. 12. Training 12.1 Competencies are a combination of skills, knowledge, attitudes and values that are required for safe and effective practice. The Association of Directors of Social Services (ADSS) standards for good practice recommend that organisations ensure staff at all levels have appropriate knowledge of and competencies in relation to the: a. potential for occurrence of abuse or neglect b. identification of abuse and neglect c. Safeguarding Adults policy and procedures d. requirement to report any concerns of abuse or neglect e. internal reporting structure for such concerns 12.2 NHS Brent CCG will ensure staff receive appropriate training at an appropriate level in both safeguarding adults and deprivation of liberties. All board members will be required to undertake this training as part of the Governing Body member induction programme. 13. NHS Brent CCG Board Assurance 13.1 NHS Brent CCG has identified a board member with lead responsibility for Safeguarding Adults who will ensure strategic ownership of Safeguarding Adults at a board level. Their role (in conjunction with chairing the Quality, Safety and Clinical Risk Committee) will be to: a. evidence compliance with safeguarding requirements b. ensure quarterly updates are provided to the Quality, Safety and Clinical Risk committee with more frequent papers being presented as required 13.2 The Quality, Safety and Clinical Risk Committee of NHS Brent CCG s Governing Body is responsible for providing assurance that there are effective arrangements for monitoring and improving the safety and quality of care that is commissioned on behalf of patients, including clinical governance and clinical risk management of commissioned services The governance structure demonstrating the clear lines of accountability for safeguarding adults within NHS Brent CCG and its links to the Brent Adult Adult Safeguarding Policy (v rd Nov 12) Page 10 of 15

11 Safeguarding Board is shown below. The terms of reference and membership of the Brent Adult Safeguarding Board is available in appendix A to this policy. 14. Safeguarding Adults Boards (SAB) 14.1 Each local authority with responsibility for adult social care must establish a Safeguarding Adults Board. The role and remit of the SAB is to help and protect vulnerable adults in its area through coordinating and ensuring the effectiveness of what each of its members does. The Brent SAB provides this strategic multi agency leadership to ensure that adults are appropriately safeguarded by: a. preventing abuse and neglect from happening b. promoting wellbeing and safety and c. responding effectively to instances of abuse and neglect 14.2 NHS Brent CCG has put in place arrangements to actively participate, in cooperation with the local authority, to effectively discharge its statutory functions with regard to safeguarding and promoting the welfare of vulnerable adults In line with policy guidance on representation at the SAB, NHS Brent is represented on Brent SAB by a Clinical Responsible Officer and Senior Responsible Officer for Safeguarding, ensuring an appropriate level of seniority which further serve as an effective interface with the CCG s governance and accountability mechanisms NHS Brent CCG is responsible for providing and/or ensuring the availability of appropriate expertise and advice and support to the SAB with regard to a range of Adult Safeguarding Policy (v rd Nov 12) Page 11 of 15

12 specialist health functions e.g. primary care, mental health and sexual health and for co-ordinating the health component of serious case reviews NHS Brent CCG, through is processes for quality assurance of providers, will ensure that all health organisations with which it has commissioning arrangements, have links with a specific SAB, and that health agencies work in accordance with their agreed SAB plan. 15. Dissemination and Implementation 15.1 This policy will be disseminated through the CCG via the CCG website as well as through the Governing Body member induction programme. Hard copies will be made available from the corporate offices to those who request it Implementation of this policy will be the responsibility of the BEHH Director of Quality and Safety who will be supported by CCG specific designated leads for safeguarding (as shown in the structure chart below), which are part of the Chief Operating Officers Office. Deputy COO Designated Nurse Adult Safeguarding (Band 8b) Designated Nurse Children s Safeguarding (Band 8b) Designated Doctor Children s Safeguarding Primary Care Named Nurse (Band 7) Administrator (Band 4) CDOP Co-ordinator (Band 6) 15.3 Changes to training programmes, existing materials or guidelines will be approved by the BEHH Director of Quality and Safety in the first instance and then cascaded appropriately. 16. Monitoring 16.1 NHS Brent CCG will use the Pan-London safeguarding Adults Assessment tool with review and benchmarking of services for seeking assurance on its arrangements for the protection and safeguarding of vulnerable adults. This will be presented annually to the Quality, Safety and Clinical Risk Committee with an action plan for any remedial measures required. The Committee will Adult Safeguarding Policy (v rd Nov 12) Page 12 of 15

13 monitor and keep under review the progress towards achieving the actions contained therein NHS Brent CCG will monitor the service standards of contracted service providers to ensure providers meet the required safeguarding adults standards through quarterly exception reports provided to the CCG s Quality, Safety and Clinical Risk Committee, which is responsible for assurance and oversight of this function NHS Brent CCG will ensure, through its designated safeguarding leads, the maintenance of records of staff that have completed appropriate safeguarding training, ensuring that this is updated every 3 years. This will be the responsibility of every individual line manager and collated through the Chief Operating Officer s Office NHS Brent CCG will ensure that there is a system in place to evidence that all NHS Brent CCG staff and contracted staff have the relevant CRB checks for their current roles. Human resources will be responsible for monitoring this and reporting to managers should they identify gaps. 17. Review 17.1 This policy will be reviewed on an annual basis. The next review will ensure that this policy aligns to national guidance on CCG s responsibilities for safeguarding by 30 th April Adult Safeguarding Policy (v rd Nov 12) Page 13 of 15

14 Appendix A Brent Safeguarding Adults Board Terms of Reference Brent SAB supports and works according to the principle that everyone has the right to live their life free from harm and abuse. In other words, Brent s SAB reflects the full breadth of the safeguarding adults agenda, encompassing (to use the Law Commission s definitions) both adult protection (responding to abuse of vulnerable adults) and the much broader challenge of prevention and reduction of risk of harm. The Board understands that safeguarding adults is not just about responding to allegations of abuse, it is also about promoting independence while ensuring people have the support they need to make their own decisions and manage the associated risks to achieve the outcomes they want to achieve. However, the Board is also very clear about its overarching and primary objective: to ensure the protection of adults at significant risk of harm and in order to deliver this it must ensure that safeguarding is everyone s business. The Board recognises that robust partnership working, underpinned by clear and well understood multi-agency policies and procedures, is the key to effective safeguarding at both strategic and operational levels. Therefore, in , the Board agreed in principle to implement the Pan London Safeguarding Policy and Procedures in Brent, replacing Brent s multi-agency procedures. The Board acts as the key strategic driver of safeguarding adults work within Brent by overseeing a strategic delivery framework and via the development and implementation of a multi-agency business plan. The Safeguarding Adults Board strives to have an ethos of openness and continuous learning and improvement of practice by regular scrutiny and feedback from safeguarding practice. More specifically, the responsibility of the Safeguarding Adults Board is to ensure: partners are held to account for their role in the safeguarding arena appropriate multi-agency safeguarding policies and procedures are in place and adhered to agreed operational definitions and thresholds of safeguarding interventions system development to audit inter-agency relationships preventative strategies are developed/in place information sharing protocols are in place and their effectiveness reviewed the Board receives assurances of safeguarding practice across the partnership, via regular reports/data (quantitative and qualitative) oversee the implementation of a workforce development plan and training plan/competency framework, so staff recognise and appropriately respond to safeguarding alerts consider national enquiries, Serious Case Reviews and good practice developments/safeguarding standards links with regional and national safeguarding networks are established Adult Safeguarding Policy (v rd Nov 12) Page 14 of 15

15 In order to deliver this there are clear expectations for all partners: All partner agencies are expected to sign a statement, outlining key commitments, which include: continuous improvement of their agencies safeguarding practice (AE) senior representation at the Safeguarding Adults Board active input into other agreed structures of the Board (such as Exec Group, sub-groups) attendance at Board meetings, including via a nominated deputy where appropriate contributing to agenda planning contributing resources to the Safeguarding Adults Board partnership, if deemed appropriate (eg statutory agencies) report to Board significant individual safeguarding cases, and themes arising from safeguarding investigations, Serious Case Reviews and Serious Untoward Incidents partner annual statement to the Safeguarding Adults Board, reporting on safeguarding activity, self-assessments and auditing contribute to the Board s annual report developing and reporting from QA mechanisms to capture the qualitative aspects of safeguarding work, including at the interface with partners formal reporting of safeguarding both to the Board and to executive bodies via partners own governance structures (statutory agencies). Membership Alison Elliott Phil Porter Steven Forbes Anna Dias Fiona Bateman Genny Renard Laurence Coaker Sue Matthews Ann O Neill John Sclocco Fiona Hill Amanda Craig Sarah Mansuralli Yvonne Leese Bridget Jansen Natalie Fox Mike West Terry Harrington Rebecca Bauers Hannah Storer Dierdre Bryant Chair, Director of Adult Social Care, Brent Head of Reablement and Safeguarding, Brent Council Head of Adult Social Care Commissioning, Brent Council Learning and Organisational Development Manager, Brent Council Senior Lawyer, Brent Council Head of Community Safety, Brent Council Head of Housing Solutions, Brent Council Safeguarding Children Co-ordinator Mencap Brent Carers Centre Brent Mental Health User Group Brent Clinical Commissioning Group Director, Lead for Safeguarding Adults Deputy Borough Director, Brent PCT Director of Community Service, Ealing Hospital Trust Deputy Director of Nursing, North West London Hospital Trust Borough Director, Central and North West London Trust Detective Inspector, Metropolitan police Borough Commander, London Fire Brigade Care Quality Commission Brent Safeguarding Lead, London Ambulance Service Probation Service Adult Safeguarding Policy (v rd Nov 12) Page 15 of 15