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Safeguarding Children & Young People Policy Policy Number QSE003 Date of Policy September 2016 Next Review Date September 2017 Sponsor Designated Nurse Safeguarding Children & Integrated Quality Reviewed by / on Quality & Patient Safety Committee / 1 st September 2016 Approved by / on Quality & Patient Safety Committee / 1 st September 2016 Version Date Comments By Whom 1.4 22 August 2016 Draft Draft version for initial review by Quality & Patient Safety Committee Final 1 st September 2016 Final Approved

Contents 1. Introduction... 3 2. Scope... 3 3. Definitions... 4 4. Accountability and Assurance... 5 5. Roles and Responsibilities... 6 6. Safe Recruitment... 9 7. Safeguarding Children Training... 9 8. Supervision and Support... 10 9. Information Sharing... 10 10. Mental Capacity Act (2005)... 11 11. Child Protection Protocol... 12 12. Safeguarding Children Escalation Process... 12 13. Allegations against Staff and Volunteers who work with Children... 12 14. Looked After Children (LAC)... 13 15. Private Fostering... 13 16. Children with Disabilities... 14 17. Child Sexual Exploitation (CSE)... 14 18. Domestic Abuse... 15 19. Female Genital Mutilation (FGM)... 16 20. Modern Slavery... 16 21. Extremism and Radicalisation... 17 22. Serious Case Reviews and Serious Incidents... 17 23. Communications... 18 24. Monitoring this Policy... 18 25. Equality and Health inequalities Analysis... 18 26. References... 20 Appendix 1: BaNES CCG Safeguarding Leads... 21 Appendix 2: Definitions of Child Abuse (Working Together to Safeguard Children 2015)... 22 Appendix 3: Safeguarding Children s Mandatory Training... 23 Appendix 4: Seven Golden Rules Information Sharing... 27 Appendix 5: When to Share information... 28 Appendix 6: Child Protection Protocol... 29 Appendix 7: Serious Case Review Process... 30 Safeguarding Children Page 2 of 31

1. Introduction Section 11 of the Children Act 2004 places Clinical Commissioning Groups (CCGs) under a statutory duty to make arrangements to ensure that in discharging their functions they have regard to the need to safeguard and promote the welfare of children. Working Together to Safeguard Children, 2015 defines safeguarding and promoting the welfare of children as: Protecting children from maltreatment Preventing impairment of children s health or development Ensuring that children grow up in circumstances consistent with the provision of safe and effective care; and Taking action to enable all children to have the best outcomes. This policy supports national legislation and guidance, together with local policies and procedures and should be read in conjunction with; Working Together to Safeguard Children (2015) https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/419 595/Working_Together_to_Safeguard_Children.pdf South West Child Protection Procedures at www.swcpp.org.uk Effective safeguarding arrangements in every local areas should be underpinned by three key principles: Safeguarding is everyone s responsibility: For services to be effective each professional and organisation should play their full part. A child-centred approach: For services to be effective they should be based on a clear understanding of the needs and views of children. Think Family agenda. 2. Scope This policy sets out BaNES CCG s arrangements for safeguarding children. Promoting the welfare of children and young people at risk and to demonstrate how the CCG works effectively with partners. This policy is designed to support all staff employed by, volunteering at or contracted to work for BaNES CCG in their safeguarding and child protection duties and to ensure managers take responsibility for the actions of their entire staff. Managers within BaNES CCG are responsible for ensuring that practice reflects the standards laid out within this policy and that staff are given adequate resources and support to comply with them. Safeguarding Children Page 3 of 31

All BaNES CCG employees must be aware of their responsibility to safeguard children. They should be able to recognise indicators of abuse and know how to act upon concerns. Staff should seek advice from their line manager or seek advice and support from the CCG Safeguarding Team. (Appendix 1) BaNES CCG will develop safeguarding children s standards which will be included in providers contracts. Providers must comply with the annual and/or quarterly returns of performance indicators as appropriate to their contract. http://www.bathandnortheastsomersetccg.nhs.uk/membersdocuments/safeguarding/childrens-safeguarding Staff involved in the commissioning of services must consider this policy when they develop and commission services and must include the safeguarding children standards in all contracts for services which have contact with adults or children. 3. Definitions 3.1 Child A child is anyone who has not yet reached his or her 18 th Birthday, Children Act (1989) 3.2 Safeguarding and Promoting the Welfare of Children and Young People Safeguarding and promoting the welfare of children is defined as: Protecting children from maltreatment; Preventing impairment of children s health and development; Ensuring that children grow up in circumstances consistent with the provision of safe and effective care; and Taking action to enable all children to have the best outcomes. 3.3 Child Protection Part of safeguarding and promoting welfare: This refers to the activity that is undertaken to protect specific children who are suffering, or are likely to suffer significant harm. 3.4 Significant Harm It is the threshold that justifies Local Authority compulsory interventions in family life in the best interests of the child. Safeguarding Children Page 4 of 31

3.6 Children in Need Children in need are children defined under Section 17 of the Children Act 1989, as those whose vulnerability is such that they are unlikely to reach or maintain a satisfactory level of health or development or their health or development will be significantly impaired, without the provision of services. It includes children who are disabled. 3.7 Looked After Child (LAC) Looked After Child is the term used to describe a child who is in the care of the local authority. Different circumstances will apply to each child regarding their care order which will be relevant when obtaining consent for treatment, as the local authority will have an element of parental responsibility for the child. 3.8 Child Abuse A form of maltreatment of a child: Somebody may abuse or neglect a child by inflicting harm, or by failing to act to prevent harm. Children may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others (e.g. via the internet). They may be abused by an adult or adults, or another child or children. Child abuse is any action by another person adult or child that causes significant harm to a child there are four categories of abuse (Appendix 2): Physical Sexual Emotional Neglect An abused child will often experience more than one type of abuse, as well as other difficulties in their lives. It often happens over a period of time, rather than being a one-off event. It can increasingly happen online. 4. Accountability and Assurance Safeguarding vulnerable people in the NHS Accountability and Assurance Framework (2015) sets out clearly the safeguarding roles, duties and responsibilities of all organisations in the NHS. BaNES CCG is monitored in fulfilling its functions by NHS England, the Care Quality Commission (CQC), the NHS Litigation Authority and BaNES Safeguarding Children s Board. Safeguarding Children Page 5 of 31

BaNES CCG has a clear line of accountability within the organisation for work on promoting the welfare of children and safeguarding children and young people. Quarterly reports are submitted to the CCG Quality Committee. The Safeguarding Children and Young People Annual Report is submitted to the Quality Committee and CCG Board annually. BaNES CCG is responsible for ensuring that safeguarding is integral to service development, quality improvement, clinical governance and risk management arrangements. BaNES CCG will work with stakeholders including Foundation Trusts, NHS Trusts, Independent contractors, Third Sector and Social Enterprises to ensure they have comprehensive safeguarding policies and procedures which are in line with statutory requirements and are informed by BaNES Safeguarding Children s Board and South West Child Protection Procedures. Safeguarding forms part of the NHS standard contract (service condition 32) and in addition local safeguarding children standards against which all providers are expected to comply are included in all contracts commissioned by BaNES CCG. Providers performance in relation to safeguarding children should be managed primarily through the usual contract/quality monitoring arrangements. The expertise of the Designated Nurse will assist Commissioners to achieve robust scrutiny of provider safeguarding children arrangements. Reports against the standards (and relevant performance indicators) should be provided on a quarterly basis as detailed in the standards. All safeguarding children significant incidents will be reported to the CCG by the provider in line with the NHSE Serious Incident Reporting and Learning Framework (2015) and reported onto the Strategic Executive Information System (STEIS). 5. Roles and Responsibilities 5.1 Executive Lead for Safeguarding Children and Young People The Executive Lead for Safeguarding is the Director of Nursing and Quality responsible, for ensuring the CCG discharges its duties in relation to Safeguarding; they ensure that the CCG has management and accountability structures that deliver safe and effective services in accordance with statutory, national and local guidance for safeguarding children and young people. 5.2 Designated Doctor and Nurse for Safeguarding Children The Designated Doctor and Designated Nurses take a strategic and professional lead on safeguarding children across the health economy. The Designated Safeguarding Children Page 6 of 31

professionals work closely with provider Trusts Named professionals and Named GP to develop and improve safeguarding practice within and between organisations. The designated professionals will provide safeguarding advice on policy and procedure as well as on day to day safeguarding management of children and families concerns. The designated professionals are a source of professional advice on safeguarding children matters to health professionals to ensure the range of services commissioned and contracted by BaNES CCG take account of the need to safeguard and promote the welfare of children and young people. The designated professionals should plan an integral role in all parts of the commissioning cycle, from procurement to quality assurance to ensure that commissioned services have effective safeguard children arrangements in place. The designated professionals will access training and supervision commensurate with their roles and maintain competencies as laid out in the Royal College of Child Health and Paediatrics Intercollegiate Document, March 2014. 5.3 Named GP The Named GP works closely with the Designated Professionals. The Named GP provides a professional lead to support and advice to the CCG about safeguarding in general practice and incorporating new models of practice. As part of the Safeguarding Team the Named GP contributes to the setting, monitoring and maintenance of robust safeguarding children arrangement and training programmes. 5.4 Designated Nurse, Looked After Children The role of the Designated Nurse Looked After Children is to provide expert health advice and clinical leadership to the CCG, and local health providers by having a strategic overview of services to ensure robust clinical governance of NHS health services for LAC is in place. In addition, to be able to assure the Governing Body of the CCG and other partners that clear commissioning of services are in place and fit for purpose. 5.5 Managers Need to ensure that staff are aware of and can access this policy. Need to ensure that staff are aware of and can access the BaNES LSCB policies and South West Child Protection Procedures. Safeguarding Children Page 7 of 31

Need to ensure that staff involved in commissioning of services considers this policy when they develop and commission services and include the safeguarding children standards in all contracts for services. Need to ensure that on recruitment of staff working with children or handling information on children, that references are always verified, a full employment history is always available with satisfactory explanations for any gaps in employment history, that qualifications are check and that Disclosure and Barring Service (DBS) checks are undertaken in line with national and local guidance. Need to ensure safeguarding responsibilities are reflected in all job descriptions. Need to undertake safeguarding children training as described in Appendix 2, and that staff safeguarding children competencies are reviewed appropriately within their annual appraisal. 5.6 Allegations Officer 5.7 Staff The Allegations Officer is responsible for managing and overseeing individual allegations against staff and volunteers who work with children. The Designated Nurse for Safeguarding Children is BaNES CCG Allegations Officer. In the absence of the Designated Nurse, the Adult Safeguarding Lead Nurse acts as the Allegations Officer. To be responsible for ensuring that they are aware of the requirements to safeguard children. To be alert to the potential indicators of abuse or neglect for children and vulnerable adults and know how to act on those concerns in line with local guidance. To be aware of and know how to access the organisations policies and procedures for safeguarding children and vulnerable adults To take part in training, including attending regular updates, commensurate with their role. Understand the principles of confidentiality and information sharing in line with local and government guidance. Staff are required to contribute as appropriate when requested, to multi-agency meetings established to safeguarding children. Must always act in accordance with this policy and inform their senior manager or designated professional of any concerns they identify, or become aware of, which Safeguarding Children Page 8 of 31

indicate a child may need extra support or services to safeguard / protect a child s welfare. 6. Safe Recruitment BaNES CCG undertakes its recruitment procedures and practices in accordance with current employment legislation and guidance which includes the Safeguarding Vulnerable Groups Act (2006) and Safeguarding Children Safer Recruitment Guidance (2006). BaNES CCG s recruitment policies and procedures adhere to the principles of safer recruitment including enhanced Disclosure and Barring Service checks (DBS), inclusive of agency staff, students and volunteers working with children. Link to LSCB safer recruitment principles. http://www.bathnes.gov.uk/sites/default/files/sitedocuments/children-and-young- People/ChildProtection/lscb_safer_recruitment_principles_aug_2013.pdf BaNES CCG will require assurance that all commissioned services have safe recruitment processes in place as required by the safeguarding children standards attached to all contracts. 7. Safeguarding Children Training The training requirements for all staff are set out in the Royal College of Paediatrics and Child Health Intercollegiate Document Guidance Safeguarding Children and Young People: Roles and Competencies for Health Care Staff (2014). (http://www.apagbi.org.uk/news/2014/safeguarding-intercollegiate-document-2014- released). This guidance outlines that different groups of staff will have different training needs to fulfil their duties, depending on their degree of contact with children and young people and their level of responsibility Safeguarding Children Training is mandatory for all BaNES CCG employees (Appendix 3). Through training staff must: Be aware of the risk factors for child abuse this includes situations where adults may pose a risk to children. Know how to recognise the different forms of abuse. Know what to do if a child s welfare or safety may be at risk. Be aware of local procedures in child protection. Know the names and contact details of the Designated Professionals, Safeguarding Children Lead Professionals. Safeguarding Children Page 9 of 31

Staff are required to complete: Level 1 Safeguarding level 1 is included in the mandatory induction programme, includes: National Skills Academy Safeguarding Guarding Children training can be accessed via the BaNES CCG in-house raining link. https://elearning.nsahealth.org.uk/local/sfhadmin/login/index.php In house Level 1 training provided by the Designated Nurse Safeguarding Children and Young People within 3 months of employment. Level 3 Staff required to complete Level 3 training can access training via BaNES LSCB. There is no cost BaNES CCG staff and GPs. http://www.bathnes.gov.uk/services/children-young-people-and-families/childrensworkforce-training/child-protection-training If staff undertake bespoke Level 3 training the named GP or Designated Professionals can ratify the quality of the training. Compliance with safeguarding children training at BaNES CCG will be monitored by the designated nurse and reported to the Quality Committee. The safeguarding team will advise any member of staff on the best training option to meet their needs. All staff must have a child protection/safeguarding children update every three years as a minimum. 8. Supervision and Support BaNES CCG is responsible for ensuring that all provider services make provision for their staff to receive Safeguarding Children supervision and access to advice and support from qualified safeguarding professionals within the organisation. BaNES CCG will commit to the external safeguarding supervision or peer support for the designated professionals and named GP. 9. Information Sharing BaNES CCG are committed to sharing information with other agencies, in a safe and timely manner, where necessary for the purposes of safeguarding children in accordance with the law. The Data Protection Act 1988 states that professionals can share confidential information without consent if one of the 3 conditions applies: There is a statutory obligation A court orders it The child s or public interest overrides that of the individual Safeguarding Children Page 10 of 31

Staff should ensure they are familiar with BaNES CCG Information Governance policy and have undertaken mandatory information governance training. BaNES LSCB have multi-agency information sharing protocols in place and staff should ensure they understand and adhere to these. http://www.bathnes.gov.uk/sites/default/files/sitedocuments/children-and-young- People/ChildProtection/information_sharing_protocol_v8_3.pdf Staff must always seek advice if they are in any doubt as to whether information needs to be shared. Fears about sharing information cannot be allowed to stand in the way of the need to promote and protect the safety of children. No member of staff should assume someone else will pass on information which they think may be important in keeping a child safe, this includes third party information. Information Sharing: Advice for practitioners providing safeguarding services to children, young people, parents and carers (2015) supports staff working in both child and adults services make decisions about sharing personal information. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/41962 8/Information_sharing_advice_safeguarding_practitioners.pdf The guidance includes the seven golden rules for sharing information effectively (Appendix 5) and flow chart of when and how to share information (Appendix 6). 10. Mental Capacity Act (2005) The Mental Capacity Act (2005) is intended to assist and support people who may lack capacity; it aims to balance an individual s right to make decisions for themselves with their right to be protected from harm if they lack capacity to make decisions to protect themselves. The Act is built on five principles that guide and inform decision making for people who may lack capacity for decision making in some aspects of their life including their health care. The Act applies to 16 to 17 year olds with the exception of the following provisions: They cannot make a Lasting Power of Attorney (LPA) They cannot make an advance decision to refuse medical treatment The court of Protection cannot make a statutory will. There may be occasions when a 16-17 year old, who would usually be presumed to be competent to make decisions, may lack capacity or may become incapacitated. In these circumstances professionals are advised to look at more detailed guidance on mental capacity and may need to seek expert advice. Government guidance can be found by following this link: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/49725 3/Mental-capacity-act-code-of-practice.pdf Safeguarding Children Page 11 of 31

11. Child Protection Protocol (Appendix 7) All CCG employees and volunteers must be aware of their responsibility to safeguarding children. They should be able to recognise indicators of abuse and know how to act upon concerns. Advice about what to do if you are worried a child is being abused can be found by following this link: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/41960 4/What_to_do_if_you_re_worried_a_child_is_being_abused.pdf Staff should seek advice from their line manager when they have a safeguarding concern or they can seek advice and support from the safeguarding team. Following discussions if there are still concerns about the welfare of a child, a referral should be made to the children and young people s social care team in the area the child lives. If the referral is urgent a verbal referral should be made by telephone. All verbal referrals should be followed up in writing within 48 hours. 12. Safeguarding Children Escalation Process Occasionally situations arise when a practitioner in one agency may feel that the decision made by a worker from another agency on a child protection or child in need case is not a safe decision. Disagreements could arise in a number of areas, but are most likely to arise around: Levels of need Roles and responsibilities The need for action Communication The safety of the child is the paramount consideration in any professional disagreement and any unresolved issues should be addressed with due consideration to the risks that might exist for the child. Staff should feel able to challenge decision-making and to see this as their right and responsibility. Link to BaNES LSCB Safeguarding Children Escalation Policy: http://www.bathnes.gov.uk/sites/default/files/sitedocuments/children-and-young- People/ChildProtection/lscb_escalation_policy_for_resolving_professional_disagree ment_4.pdf The Designated Nurse should be informed if concerns about a child are being escalated. 13. Allegations against Staff and Volunteers who work with Children Children and young people can be subjected to abuse by those who work with them. All allegations of abuse of young children and young people by someone who works Safeguarding Children Page 12 of 31

with children and young people are taken seriously and managed in accordance with BaNES LSCB Managing Allegations against Staff or Volunteers who work with Children policy. http://www.bathnes.gov.uk/sites/default/files/sitedocuments/children-and-young- People/ChildProtection/managing_allegations_against_staff_or_volunteers_who_wor k_with_children.pdf These procedures may also be used if there are concerns about the professional s behaviour towards their own children unrelated to their employment or voluntary work, or when an allegation is made about abuse that took place some time ago and the accused person may still be working or having contact with children. If staff are concerned about a colleague s conduct/behaviour towards a child, staff should discuss their concern with the CCGs Allegations Officer; the Allegations Officer is the Designated Nurse for Safeguarding Children the Deputy Allegations Officer in the absence of the Designated Nurse is the Adult Safeguarding Lead Nurse. It is the role of the Allegations Officer to inform the Local Authority Designated Officer (LADO) within one working day of the allegation being made. The LADO should be informed of all allegations that come to the Allegations Officer. The LADO and the Allegations Officer will then discuss and agree the next steps. The LADO is also responsible for chairing Strategy meetings with the police and the Allegations Officer and with other staff where necessary to agree and plan any further investigation or action relating to the allegation. 14. Looked After Children (LAC) BaNES CCG has a statutory role in ensuring that arrangements are in place to meet the health needs of Looked After Children. BaNES CCG has arrangements in place for a Designated Doctor and Nurse for Looked After Children who take a strategic lead in the health aspects of children in care including advising commissioners regarding the needs of this population. 15. Private Fostering Private fostering is when a child under the age of 16 (under 18 if disabled) is cared for by someone who is not their parent or a close relative. This is a private arrangement made between a parent and a carer, for 28 days or more. Close relatives are defined as step-parents, grandparents, brothers, sisters, uncles or aunts (whether of full blood, half blood or marriage/affinity). There is a requirement on the part of parents and prospective carers entering into private fostering arrangements to notify their local authority. This is in order to safeguard and protect the child s welfare as well as ensuring the child; carer and parent are receiving appropriate support and help. Safeguarding Children Page 13 of 31

If a member of staff identifies a child that is being privately fostered then a referral should be made to Children and Young People s Social Care in the area the child lives. Local authorities have a legal duty to safeguard the well-being of privately fostered children. Once notified Children and Young People s Social Care will visit the child and carer, and undertake an assessment of the placement and offer support as appropriate. 16. Children with Disabilities Research studies into prevalence and risk of violence against disabled children found that disabled children are 3 to 4 times more likely to be victims of violence than their non-disabled peers. There are a number of factors which make disabled children more vulnerable to abuse: Many disabled are at an increased likelihood of being socially isolated with fewer outside contacts than non-disabled children; Their dependency on parents and carers for practical assistance in daily living, including intimate personal care, increases their risk of exposure to abusive behaviour. They may have an impaired capacity to resist or avoid abuse; They may have speech, language and communications needs which may make it difficult to tell others what is happening; Looked after disabled children are not only vulnerable to the same factors that exist for all children living away from home, but are particularly susceptible to possible abuse because of their additional dependency. It is essential that assessments of the needs of disabled children are child focused, and identify and include needs relating to safeguarding and protection. 17. Child Sexual Exploitation (CSE) As a result of recent nationwide cases of Child Sexual Exploitation (CSE) has become a national priority for health professionals and organisations. Health Services and staff have a significant contribution to make in identifying children and young people at risk of sexual exploitation and supporting the treatment and recovery of those harmed. Health professionals are in a key position to recognise and assist children and young people and have several roles including identifying the warning signs of risk or indicators of exploitation, engaging with children and young people so they are encouraged to share information with partner agencies as appropriate. How healthcare staff and agencies work together to promote effective early intervention is Safeguarding Children Page 14 of 31

also of critical importance in supporting children and young people who are sexually exploited. BaNES LSCB guidance for assessing risk factors for young people at risk of CSE can be found via the link: http://www.bathnes.gov.uk/sites/default/files/sitedocuments/children-and-young- People/ChildProtection/cse_protocol_3may_2016_final.pdf 18. Domestic Abuse Domestic abuse is a serious public health issue and has been recognised as a major social problem which is not diminishing in frequency or intensity. Overwhelmingly, it is women who experience domestic abuse, and almost always at the hands of their male partners or former partners. However, it is recognised that domestic abuse also takes place within same sex relationships, that men can be abused by women, and that family members can be abused by siblings, children, grandchildren and other family members. Violence against women and girls can include, but is not restricted to, domestic abuse, sexual assault, stalking, forced marriage, so-called honour based violence, and female genital mutilation. Domestic abuse can occur regardless of age; however age may affect a victim s ability to seek help and access services, and individuals may face stereotyping because of age. Children and young people can experience abuse within intimate relationships The term 'domestic violence and abuse' is used to mean: any incident or pattern of incidents of controlling, coercive or threatening behaviour, violence or abuse between those aged 16 or over who are, or have been, intimate partners or are family members. This includes: psychological, physical, sexual, financial and emotional abuse. It also includes honour -based violence and forced marriage, NICE DA Guidance (2014). If you have any concerns about the welfare or safety of a child because of the risk of domestic abuse, it is your responsibility to discuss your concerns with your line manager or the designated nurse, ensuring that this does not unduly delay safeguarding the child and/or make a referral to Social Care. Ideally referral to Social Care should be discussed with the non-abusing parent and consent sought. Evidence shows that working openly and honestly wherever possible promotes more effective working partnerships with parents. However, this may not always be possible and the health professional s duty to act in the best interests of the child means that parental consent can be dispensed with if seeking consent could result in further harm to the child. Safeguarding Children Page 15 of 31

19. Female Genital Mutilation (FGM) Female Genital Mutilation (FGM) is an illegal practice which affects a girl s genital area which can have a significant impact on their emotional and physical wellbeing. FGM has been a specific criminal offence since 1985, under the Prohibition Female Circumcision Act (1985), which was replaced by Female Genital Mutilation Act (2003) in England, Wales and Northern Ireland. If staff become aware of any parent who has had FGM or any female children at risk of FGM they must discuss with their manager or the Designated Nurse. A referral to Social Care should always be made if the child is at risk. Staff should follow LSCB guidance for FGM which can be found via this link: http://www.bathnes.gov.uk/sites/default/files/sitedocuments/children-and-young- People/ChildProtection/female_genital_mutilation_multi_agency_guidance.pdf Mandatory recording From September 2014, it became mandatory for acute trusts to collate and submit basic anonymised details about the number of patients treated who have had FGM to the Department of Health every month. This requirement was expanded to include GP practices and Mental Health Trusts in October 2015. An amendment to the Serious Crime Bill in October 2015 introduced a mandatory duty on frontline professionals to report cases of FGM in under 18s, and require reports made to the police within one month of initial disclosure/identification. The police will then work with the relevant agencies to ensure an appropriate safeguarding response is put in place. The new duty applies to all regulated healthcare professionals. Link to NHSE FGM mandatory reporting flowchart: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/52540 5/FGM_mandatory_reporting_map_A.pdf 20. Modern Slavery Modern Slavery encompasses slavery, human trafficking and forced labour and domestic servitude. Traffickers and slave masters use whatever means they have at their disposal to coerce, deceive and force individuals into a life of abuse, servitude and inhumane treatment. United Nations Office on Drugs and Crime describes Trafficking in Persons (Human Trafficking) as the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation. Exploitation shall include, at a minimum, the exploitation of the prostitution of others or other forms of sexual exploitation, forced labour or services, slavery or practices similar to slavery, servitude or the removal of organs. Safeguarding Children Page 16 of 31

21. Extremism and Radicalisation The current threat from Terrorism and Extremism in the United Kingdom is real and severe and can involve the exploitation of vulnerable people, including children, to involve them extremist activity. A number of young girls and boys have been persuaded to leave the country against the wishes of their families, or GP, in secret, putting themselves in extreme danger. The Department of Health is a key strategic partner in the PREVENT Strategy as health care professionals may meet and treat people who are vulnerable to radicalisation of CCGs are required to ensure that provider organisations adhere to the requirements of the national PREVENT strategy. The aim of PREVENT is to stop people becoming terrorists or supporting terrorism. This includes the training of all relevant front line staff in the responsibilities of PREVENT as well as introducing and embedding processes to identify and protect those who may be at risk of radicalisation as well as escalating concerns regarding potential terrorist events to the Police. All staff involved in the care and / or commissioning of healthcare should ensure they are aware of the PREVENT Strategy and the referral process. CCGs should: Ensure that best practice around PREVENT is promoted, implemented and monitored both within the CCG and within commissioned provider services. Ensure that safeguarding and PREVENT leads work within the local health and social care economies to influence local thinking and practice by working with partner agencies to provide joint strategic leadership on the PREVENT agenda. Ensure that provider contracts specify compliance with the PREVENT Strategy and that commissioned services are supported and contract monitored for compliance. The key challenge for the healthcare sector is to ensure that were there are signs that someone has been or is being drawn into terrorism, the healthcare worker can interpret those signs correctly, is aware of the support which is available and is confident in referring the person for further support. Additional information can be found by following this link: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/97976/ prevent-strategy-review.pdf 22. Serious Case Reviews and Serious Incidents The designated professionals take a lead role in conducting the health component of Serious Case Reviews as well as other forms of significant case reviews which do not reach the threshold for a SCR (Working Together to Safeguard Children, 2015) Safeguarding Children Page 17 of 31

and for ensuring that a culture of learning and improvement is embedded across organisations and that practice is evaluated as a result of any review. All Serious Incidents related to children where there are safeguarding concerns must be reported through the Serious Incident reporting process of provider organisations and the Designated Nurse informed. In BaNES CCG the Director of Nursing and Quality is responsible for approving and closing incidents. Child deaths should be reported to the Designated Nurse in line with the Serious Incident process and the child death review process. Appendix 7 23. Communications The Director of Nursing and Quality should be informed of any safeguarding issue that may attract media interest who will then share with BaNES CCG communication team as appropriate. 24. Monitoring this Policy The Designated Nurse is responsible for the monitoring, revision and updating of this policy. The Designated Nurse will act on behalf of the Director of Nursing and Quality in this respect, and will update the Director of Nursing and Quality on its implementation. 23.1 Breaches of Policy This policy is mandatory. Where it is not possible to comply with the policy or a decision is taken to depart from it, this must be notified to the Designated Nurse Safeguarding Children &/or the Director of Nursing and Quality as the Executive Lead for Safeguarding Children so that the level of risk can be assessed and an action plan can be formulated. 23.2 Contact Details Director of Nursing and Quality Executive Lead Safeguarding Children Tel: 01225 831445 Designated Nurse Safeguarding Children Tel: 01225 831691 25. Equality and Health inequalities Analysis Promoting equality and addressing health inequalities are at the heart of BaNES CCG s values. Throughout the development of the policies and processes cited in this document, we have: Safeguarding Children Page 18 of 31

Given due regard to the need to eliminate discrimination, harassment and victimisation, to advance equality of opportunity, and to foster good relations between people who share a relevant protected characteristic (as cited under the Equality Act 2010) and who do not share it; Given regard to the need to reduce inequalities between patients in access to, and outcomes from, healthcare services and in securing that services are provided in an integrated way where this might reduce health inequalities. Safeguarding Children Page 19 of 31

26. References Children Act (1989) Female Genital Mutilation Act 2003 Information Sharing: Advice for practitioners providing safeguarding services to children, young people, parents and carers (2015) NICE Domestic Abuse (PH50) Guidance (2014) RCPCH Intercollegiate Document Guidance Safeguarding Children and Young People: Roles and Competencies for Health Care Staff (2014) Safeguarding Vulnerable People in the NHS. Accountability and Assurance Framework (2015) Safeguarding Children Safer Recruitment (2006) Mental Capacity Act (2005) Serious Crime Act 2015 Working together to Safeguard Children, London, DfE, (2015) Safeguarding Children Page 20 of 31

Appendix 1: BaNES CCG Safeguarding Leads Name Role Contact Details Dawn Clarke Jenny Daly Fiona Finlay Executive Lead Safeguarding Designated Nurse Safeguarding Children & Young People Designated Doctor Phone : 01225 831445 Email: dawn.clarke6@nhs.net Phone : 01225 831691 Mobile: 07917067761 Email: jenniferdaly@nhs.net Phone : 01225 731575 Email: Email: Fiona.Finlay@sirona-cic.org.uk ffinlay@nhs.net Donna Redman Named GP Phone : 01225 427403 Email: dredman@nhs.net Anne Hodgkins Jacquie Wrench Jacquie Bell Jenny Daly Sarah Jeeves Louise Leach Safeguarding Administrator Designated Nurse Looked After Children Designated Doctor Looked After Children Designated Officer for Allegations Management Safeguarding Adults Lead Nurse Safeguarding Adults lead GP Phone : 01225 831853 Email: anne.hodgkins@nhs.net Phone : 01225 731567 or 731575 Email: Jackie.Wrench@sirona-cic.org.uk Phone : 01225 731575 Email: Jacquelyn.Bell@sirona-cic.org.uk Email: jacquelyn.bell@nhs.net Phone : 01225 831691 Mobile: 07917067761 Email: jenniferdaly@nhs.net Phone : 01225 831857 Email: sarahjeeves@nhs.net Phone : 01225 831853 Email: louise.leach1@nhs.net Safeguarding Children Page 21 of 31

Appendix 2: Definitions of Child Abuse (Working Together to Safeguard Children 2015) Physical Abuse Physical abuse may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating, or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child. Emotional Abuse Emotional abuse is the persistent emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child s emotional development. It may involve conveying to children that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person Sexual Abuse Sexual abuse involves forcing or enticing a child or young person to take part in sexual activities, including prostitution, whether or not the child is aware of what is happening. The activities may involve physical contact, including penetrative (e.g. rape, buggery or oral sex) or non-penetrative acts. They may include non-contact activities, such as involving children in the looking at, or in the production of, sexual online images, watching sexual activities or encouraging children to behave in sexually inappropriate ways. Neglect Neglect is the persistent failure to meet a child s basic physical and/or psychological needs, likely to result in serious impairment of the child s health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to: Provide adequate food, clothing and shelter (including exclusion from home or abandonment); Protect a child from physical and emotional harm or danger; Ensure adequate supervision (including the use of inadequate care-givers); or Ensure access to appropriate medical care or treatment Safeguarding Children Page 22 of 31

Appendix 3: Safeguarding Children s Mandatory Training Matrix for BaNES CCG Employed Staff and Volunteers This training matrix is a guide for BaNES CCG staff and volunteers to identify their mandatory requirements to undertake safeguarding children training. The matrix takes into account the training recommendations laid out in Royal College of Paediatrics and Child Health Intercollegiate Document 2014 The safeguarding children training matrix is identified in six levels; Level 1 and 2 is provided BaNES CCG, level 3 training will be provided by BaNES LSCB. Some Level 3 update sessions will be provided by BaNES CCG.. Levels 4-6 are for specialist staff such as named, designated professionals, and doctors providing expert advice. The Intercollegiate Document 2014 indicates the specific amount of time and knowledge the training must include and the competencies the staff member must acquire. http://www.rcpch.ac.uk/sites/default/files/page/safeguarding%20children%20- %20Roles%20and%20Competences%20for%20Healthcare%20Staff%20%2002%200%20 %20%20%20(3)_0.pdf The matrix below indicates how staff can achieve and evidence their training. Level 1 All Staff employed by BaNES CCG are required to complete the National Skills Academy Safeguarding Children E learning package within one month of employment, Staff are also required to attend a Level 1 safeguarding children in house training session provided by the designated nurse within 6 months of employment. Staff need to complete a minimum of 2 hours Level 1 training every 3 years as a minimum. Level 2 Clinical and non-clinical staff who have regular contact with parents, children and young people Staff employed by the CCG are required to complete Level 2 training provided by the Designated Nurse within 3 months of employment. Staff need to evidence a minimum of 3 hours Level 2 training every 3 years. Safeguarding Children Page 23 of 31

Level 3 All staff working predominately with children, young people and parents This is specialist training for senior managers/ clinicians who support staff and for staff who manage safeguarding cases. To achieve this level you must attend BaNES LSCB multiagency training. Staff need to evidence a minimum of 8 hours training every 3 years. http://www.bathnes.gov.uk/services/children-young-people-and-families/childrensworkforce-training/child-protection-training Level 3 (Specialist ) This training is also multi-agency and staff who meet these criteria must complete multiagency training at both core and specialist levels. In addition they should access some form of safeguarding supervision or reflection on practice and an annual update of their safeguarding children training. This training must be multi-agency. BaNES LSCB training is offered free to staff employed by BaNES CCG. Staff need to evidence a minimum of 16 hours training every 3 years which can include some e-learning training but must include multi-agency face to face training as well. Safeguarding Children Page 24 of 31

Staff Group Level 1 Level 2 Level 3 ( Core ) Level 3 (Specialist ) Within 1 month Within 3 months Within 6 months Within 6 months All BaNES CCG employed X staff, independent contractors Training and volunteers requirement National Skills Academy e- learning package in house training session delivered by Designated Nurse Clinical and non-clinical staff who have contact with parents, children and young people eg practice nurses, Opticians, Dentists All clinical staff working with children/ young people/ parents and carers who could contribute to the assessing, planning and evaluation of the needs of children and their carers parenting abilities to X Training requirement National Skills Academy e- learning package in house training session delivered by Designated Nurse X Training requirement National Skills Academy e- learning package in house training session delivered X Training requirement 3 hours. In house session delivered by Designated Nurse X BaNES LSCB Standard Child Protection training within 3 months of employment. Minimum 3 yearly update. Level 4-6 Safeguarding Children Page 25 of 31

safeguard and protect children CCG GP leads, designated professionals, Named GP Level 3 Specialist Link GPs, Named GP, Designated professionals. by Designated Nurse X Annual Multiagency training Level 4-6 Specialist roles eg named and designated professionals for safeguarding children X X X Any staff members who wish to clarify their safeguarding children training needs should discuss this with their line manager or Designated Nurse. Safeguarding Children Page 26 of 31

Appendix 4: Seven Golden Rules Information Sharing 1. Remember that the Data Protection Act 1998 and human rights law are not barriers to justified information sharing, but provide a framework to ensure that personal information about living individuals is shared appropriately. 2. Be open and honest with the individual (and/or their family where appropriate) from the outset about why, what, how and with whom information will, or could be shared, and seek their agreement, unless it is unsafe or inappropriate to do so. 3. Seek advice from other practitioners if you are in any doubt about sharing the information concerned, without disclosing the identity of the individual where possible. 4. Share with informed consent where appropriate and, where possible, respect the wishes of those who do not consent to share confidential information. You may still share information without consent if, in your judgement, there is good reason to do so, such as where safety may be at risk. You will need to base your judgement on the facts of the case. When you are sharing or requesting personal information from someone, be certain of the basis upon which you are doing so. Where you have consent, be mindful that an individual might not expect information to be shared. 5. Consider safety and well-being: Base your information sharing decisions on considerations of the safety and well-being of the individual and others who may be affected by their actions. 6. Necessary, proportionate, relevant, adequate, accurate, timely and secure: Ensure that the information you share is necessary for the purpose for which you are sharing it, is shared only with those individuals who need to have it, is accurate and up-to-date, is shared in a timely fashion, and is shared securely (see principles). 7. Keep a record of your decision and the reasons for it whether it is to share information or not. If you decide to share, then record what you have shared, with whom and for what purpose. Reference: HM Government Information Sharing Advice for Safeguarding Practitioners. Safeguarding Children Page 27 of 31

Appendix 5: When to Share information Reference: HM Government Information Sharing Advice for Safeguarding Practitioners. Safeguarding Children Page 28 of 31

Appendix 6: Child Protection Protocol Reference: LSCB Child Protection Protocol Safeguarding Children Page 29 of 31

Appendix 7: Serious Case Review Process Safeguarding Children Page 30 of 31

Reference: BaNES Local Safeguarding Children s Board Safeguarding Children Page 31 of 31