Safeguarding Adults Policy
1. Purpose
This Safeguarding Adults Policy sets out the organisation’s commitment to protecting adults at risk from abuse, neglect, and exploitation. As a healthcare recruitment agency supplying staff to CQC-regulated services, the organisation recognises its responsibility to ensure safeguarding is embedded across recruitment, placement, and ongoing management of healthcare professionals.
This policy is aligned with the Care Quality Commission (CQC) Fundamental Standards, the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, and relevant safeguarding legislation and guidance.
2. Scope
This policy applies to all directors, employees, recruiters, compliance staff, temporary workers, and contractors engaged by the organisation. It covers all safeguarding concerns arising during recruitment, placement, or employment of healthcare professionals supplied by the agency.
3. Regulatory and Legal Framework
This policy is informed by:
- Care Quality Commission (CQC) Fundamental Standards
- Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (Regulations 12, 13, and 17)
- Care Act 2014
- Mental Capacity Act 2005 and Code of Practice
- Working Together to Safeguard Adults
- Local Safeguarding Adults Board (LSAB) procedures
- UK GDPR and Data Protection Act 2018
4. Definitions
4.1 Adult at Risk
An adult aged 18 or over who:
- Has care and support needs
- Is experiencing, or at risk of, abuse or neglect
- Is unable to protect themselves because of those needs
4.2 Safeguarding
Safeguarding means protecting an adult’s right to live in safety, free from abuse and neglect.
4.3 Abuse and Neglect
Abuse and neglect may take many forms, including but not limited to:
- Physical abuse
- Sexual abuse
- Emotional or psychological abuse
- Financial or material abuse
- Neglect and acts of omission
- Discriminatory abuse
- Organisational abuse
- Domestic abuse
- Modern slavery
- Self-neglect
5. Principles of Safeguarding (Care Act 2014)
The organisation adopts the six safeguarding principles:
- Empowerment
- Prevention
- Proportionality
- Protection
- Partnership
- Accountability
6. Roles and Responsibilities
6.1 Directors / Board
The Board is accountable for ensuring effective safeguarding systems and a culture of safety. Responsibilities include:
- Ensuring safeguarding policies and procedures are in place
- Providing sufficient resources for safeguarding training and oversight
- Reviewing safeguarding reports and risks
6.2 Registered Manager / Nominated Individual
(where applicable)
The Registered Manager or Nominated Individual is responsible for:
- Overall safeguarding oversight and CQC compliance
- Acting as the main point of contact with safeguarding authorities and the CQC
- Ensuring safeguarding concerns are escalated and managed appropriately
6.3 Safeguarding Lead
The organisation appoints a Safeguarding Lead who is responsible for:
- Providing advice and guidance on safeguarding matters
- Receiving and managing safeguarding concerns and referrals
- Liaising with Local Authorities, clients, and external agencies
- Maintaining safeguarding records and logs
6.4 All Staff and Agency Workers
All staff and agency workers are responsible for:
- Understanding and adhering to this policy
- Completing safeguarding training appropriate to their role
- Being alert to signs of abuse or neglect
- Reporting safeguarding concerns immediately
7. Safer Recruitment and Safeguarding
The organisation supports safeguarding through robust safer recruitment practices, including:
- Enhanced DBS checks (including barred list checks where required)
- Verification of identity, right to work, and qualifications
- Employment history and reference checks
- Assessment of suitability to work with adults at risk
8. Training and Awareness
The organisation ensures that:
- All staff complete safeguarding adults training at induction
- Refresher training is completed at least every 12 months
- Role-specific safeguarding training is provided where required
9. Recognising and Responding to Safeguarding Concerns
9.1 Recognising Abuse
Staff must remain vigilant to signs of abuse or neglect, including changes in behaviour, unexplained injuries, poor care standards, or concerning disclosures.
9.2 Reporting Safeguarding Concerns
Safeguarding concerns must be reported immediately to the Safeguarding Lead or senior manager. In an emergency, staff must contact emergency services first.
9.3 Escalation and Referral
The organisation will:
- Refer safeguarding concerns to the relevant Local Authority Safeguarding Adults Team
- Inform the client organisation promptly
- Notify the CQC where required
- Cooperate fully with safeguarding enquiries and investigations
10. Whistleblowing
The organisation encourages staff to raise concerns without fear of reprisal. Whistleblowing concerns relating to safeguarding may be raised internally or directly with external bodies such as the CQC or Local Authority.
11. Confidentiality and Information Sharing
Information will be shared on a need-to-know basis in line with safeguarding requirements, UK GDPR, and data protection legislation. Confidentiality will not be maintained if doing so places an adult at risk of harm.
12. Allegations Against Agency Workers
Where an allegation is made against an agency worker, the organisation will:
- Take immediate steps to protect adults at risk
- Remove the worker from placement if necessary
- Investigate concerns in line with internal procedures
- Refer to the DBS, professional regulator, or Local Authority where required
13. Monitoring, Audit, and Assurance
Safeguarding effectiveness is monitored through:
- Safeguarding logs and incident reviews
- Compliance and training audits
- Governance and quality meetings
14. Review
This policy will be reviewed annually or sooner if there are changes to legislation, CQC guidance, or safeguarding best practice.
15. Safeguarding Procedure (Operational Guidance)
This procedure outlines the steps that must be followed when a safeguarding adults concern is identified. It sits under and supports this Safeguarding Adults Policy and must be followed by all staff and agency workers.
Step 1: Immediate Safety
- If an adult is in immediate danger or requires urgent medical attention, call 999 immediately.
- Take reasonable steps to ensure the adult is safe.
- Do not put yourself or others at risk.
Step 2: Recognise and Respond
- Listen carefully to the adult and take any disclosure seriously.
- Remain calm, supportive, and non-judgemental.
- Do not promise confidentiality.
- Do not investigate or ask leading questions.
Step 3: Report the Concern Internally
- Report the concern immediately to the Safeguarding Lead or senior manager.
- If the concern involves the Safeguarding Lead, escalate to a Director or Nominated Individual.
- Record the concern accurately, including dates, times, observations, and actions taken.
Step 4: Initial Risk Assessment
The Safeguarding Lead will:
- Assess the level of risk and seriousness of the concern
- Determine whether the concern meets the threshold for a safeguarding referral
- Decide on immediate protective actions (e.g. removal from placement)
Step 5: External Referral and Escalation
Where required, the organisation will:
- Make a referral to the relevant Local Authority Safeguarding Adults Team (Section 42 enquiry)
- Inform the client organisation promptly
- Notify the CQC where the concern meets notification requirements
- Refer to the DBS, professional regulator (e.g. NMC, GMC, HCPC), or other bodies where appropriate
Step 6: Support and Cooperation
- Cooperate fully with safeguarding enquiries and investigations
- Provide information requested by the Local Authority, CQC, or client
- Support the adult at risk and relevant staff throughout the process
Step 7: Outcome, Learning, and Improvement
- Record outcomes and actions taken
- Review whether policies, training, or recruitment processes require improvement
- Implement learning and share themes through governance meetings
Date written: 27/2/2026
To be reviewed: 27/02/2027
