The SAGE Safeguarding Policy may change so please remember to check back from time to time. Where we have made any changes to this Safeguarding Policy, we will make this clear on our website.

SAFEGUARDING ADULTS POLICY AND PROCEDURES

SECTION 1: POLICY AND STATUTORY FRAMEWORK

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Aim of this policy
1.1.1 The aim of this policy is to outline the practice and procedures for paid staff,
volunteers, trustees and students in SAGE to contribute to the safeguarding of adults
at risk of harm through raising awareness and providing a clear framework for action
when a potential or actual safeguarding issue is suspected.
1.1.2 The policy is aimed at protecting adults at risk of harm, workers, volunteers,
trustees and students.
1.1.3 This policy should be read in conjunction with SAGE’s Confidentiality policy and
SAGE’s Learning and Development policy

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1.2 Policy statement
1.2.1 SAGE holds as one of its highest priorities the health, safety and welfare of all
adults at risk of harm involved in activities which come under the responsibility of SAGE.
SAGE has a duty to ensure that staff members, volunteers, trustees and students fulfil
their responsibilities to prevent abuse of adults at risk of harm and that proper procedures
are followed if any abuse is discovered or suspected.
1.2.2 SAGE will work with appropriate local agencies and, in particular, Sheffield
Safeguarding Adults Office, to ensure that adults at risk of harm are safeguarded through
the effective operation of SAGE’s Safeguarding adults policy and procedures.
1.2.3 SAGE recognises that any adults at risk of harm can be subject to abuse and all
allegations of abuse will be taken seriously and treated in accordance with the
organisation’s policy and procedures. It is the responsibility of all staff, volunteers,
trustees and students to act upon any concern brought to their attention no matter how
small or trivial it may seem.
1.2.4 SAGE is committed to supporting, resourcing and providing appropriate training to
those members of staff, volunteers and students who work with, or who come into contact
with, adults at risk of harm and to providing appropriate supervision, and to ensuring that
trustees can fulfil their responsibilities in respect to this policy.

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1.3 Statutory framework and definitions
1.3.1 The law underpinning safeguarding adults at risk of harm is the Care Act 2014,
section 42 - 47. Policy and guidance for South Yorkshire is available in the ‘Safeguarding
Adults’ procedures. Also of relevance is Schedule 4 Part 2 of the Safeguarding
Vulnerable Groups Act 2006, in relation to DBS checks.
1.3.2 Section 2 (8) of the Care Act 2014 defines adult as a person aged 18 or over.
1.3.3 Section 42 of the Care Act 2014 suggests that an adult at risk of harm is one who
has needs for care and support (whether or not the authority is meeting any of those
needs) and, as a result of those needs, would be unable to protect himself or herself
against abuse or neglect or the risk of it.
1.3.4 A person in one of the following categories (not exhaustive) may have care and
support needs:

• Older people (no definition in the Care Act),
• An adult with physical or learning disability or a sensory impairment,
• An adult with a long term health condition
• An adult who misuses substances or alcohol to the extent that it affects their ability to
  manage day-to-day living,
• A carer, providing unpaid care to a family member or friend.
• An adult with short to medium term mental health issues, or
• Any other person with care and support needs who is unable to protect themselves
  against abuse or neglect or the risk of it.

1.3.5 Schedule 4 Part 2 of the Safeguarding Vulnerable Groups Act 2006 requires
employers to implement DBS checks before allowing employees or volunteers to work
unsupervised, either face to face or remotely, with adults at risk of harm. SAGE is
required under this legislation to apply for an enhanced disclosure from the Disclosure
and Barring Service (DBS) for staff, volunteers and students who may be working
unsupervised with adults at risk of harm in any regulated activity whether in-person or
remotely (telephone or video).
1.3.6. Regulated activity is defined in Schedule 4 Part 2, paragraph 7:
“Each of the following is a regulated activity relating to vulnerable adults if it is carried out
frequently by the same person or the period condition is satisfied [e.g. face-to-face or
remotely with the service user for any length of time] —
(a) any form of training, teaching or instruction provided wholly or mainly for vulnerable
adults;
(b) any form of care for or supervision of vulnerable adults;
(c) any form of assistance, advice or guidance provided wholly or mainly for vulnerable
adults;
(d) any form of treatment or therapy provided for a vulnerable adult;
(e) moderating a public electronic interactive communication service which is likely to be
used wholly or mainly by vulnerable adults;
(f) driving a vehicle which is being used only for the purpose of conveying vulnerable
adults and any person caring for the vulnerable adults pursuant to arrangements made in
prescribed circumstances;
(g) anything done on behalf of a vulnerable adult in such circumstances as are
prescribed.”
Regulated activity includes the supervision of any person carrying out regulated activity.
1.3.7 SAGE aims to work with a wide range of individuals, not all of whom will be adults at
risk of harm as defined above.
1.3.8 Types of abuse: abuse can be physical, verbal, domestic, sexual, psychological or
emotional, neglect or acts of omission, financial or material, discriminatory, modern
slavery, self-neglect, organisational abuse, female genital mutilation, honour based
violence, forced marriages, hate incidents or it could be a combination of these and also
includes the criminal offence of wilful neglect or ill treatment.

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SECTION 2: PROCEDURES

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2.1 Responsibilities
2.1.1 It is the responsibility of all employees, volunteers, trustees and students working
within SAGE to report to the Director of SAGE (or Chair in the Service Manager’s and
Director’s absence, or other member of the board of trustees in the Chair’s absence) any
concerns that they have about adults at risk of harm that they encounter through the
course of their work with SAGE, i.e. where they believe an adult at risk of harm has been
or is at risk of abuse, or significant harm. This responsibility extends to all staff,
volunteers, trustees and students and not just those specifically working with adults at risk
of harm.

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2.2 Internal nominated referrer
2.2.1 SAGE has a designated member of staff, the internal nominated referrer, who is
assigned to act upon adults at risk of harm protection concerns. At SAGE the internal
nominated referrer is the Director and he/she is responsible for co-ordinating action within
the organisation and liaising with other agencies.
2.2.2 In the absence of the internal nominated referrer, the Chair of the board of trustees
shall take on this role. In absence of the Chair of the board of trustees, another member
of the board of trustees shall take on this role.

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2.3 Procedure for taking action when there are safeguarding concerns
2.3.1 Once you suspect abuse of an adult at risk of harm, you should immediately inform
SAGE’s internal nominated referrer in person or by telephone. If the internal nominated
referrer is not available you should contact the Chair. In the absence of the Chair you
should contact another member of the board of trustees. You should make a brief written
record of your conversation. See paragraphs 2.5.8 and 2.5.9 regarding storage.
2.3.2 Even if you have only heard rumours of abuse, or you have a suspicion but do not
have firm evidence, you should still contact the internal nominated referrer to discuss your
concerns. If the internal nominated referrer is not available you should contact the Chair.
In the absence of the Chair you should contact another member of the board of trustees.
Abuse may be in-person, by telephone, video contact or via social media.
on
2.3.4 You must not try to investigate the matter, conduct interviews or collect
evidence on your own If SAGE’s internal nominated referrer (or Director, Chair or other
member of the board of trustees covering his or her absence) does decide to pass
concerns onto a statutory agency it will be that agency’s responsibility to decide what
further information should be gathered from the service user or witnesses etc. and by
whom. By supporting the adult at risk of harm and carefully logging any information given
to you at this stage, you will lay the foundations for an effective formal section 42 enquiry,
should it be required.
2.3.5 Therefore, if one of SAGE’s service users discloses abuse to you, you should
respond in the following way:

• Issues of confidentiality must be clarified early on; explain that you cannot keep the
  information private, that it must be reported to the internal nominated referrer (or Chair
  or other member of the board of trustees covering his or her absence), in the first
  instance,
• Let the person speak, do not interrupt or make comments,
• Do not let your own feelings distract you,
• Watch for non-verbal clues,
• Remember as much as you can,
• Feel comfortable with silences,
• Clarify the bare facts
• Do not ask questions (only to clarify) i.e.
  - Do not probe as this could be construed as ‘leading’ but do ask for clarification
  of the bare facts, enough for you to be able to establish whether or not there is
  a safeguarding issue, but no more than that.
• Assume that the adult is telling the truth,

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2.4 Procedure for taking action when a safeguarding incident has occurred
2.4.1 Follow the procedure described in 2.3 above.
2.4.2 Ensure the adult’s safety, seek immediate or emergency assistance, if needed,

• If in immediate danger ring 999
• If there are concerns about the adult returning home, seek advice from the
  internal nominated referrer or the Chair. In the absence of the Chair you should
  contact another member of the board of trustees, in their absence, you should
  contact the adult access team (0114 273 4908)
• Do not arrange for medical examination if medical treatment is not immediately
  required,
• Consider wider risks to other people or in other places,
• Preserve evidence, e.g,
  - Seal off areas, if applicable
  - Do not remove the victim’s clothing
  - Discourage washing or bathing
  - Do not handle items that may contain DNA evidence
  - Put any significant items given to you (e.g. clothing, weapons) in a safe and dry
  place
  - Do not interview the victim or potential witness
  - Do not alert the alleged source of harm.

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2.5.1 Recording the safeguarding concern/incident
2.5.2 Write up your record as soon as possible. Use the same language as the adult
used, noting how they appeared (upset, angry). The report should be factual and should
not include opinions or personal interpretations of the facts presented. Sign, date, and
print your name on the record. Retain any handwritten notes you make as potential
evidence. If you are unsure about what to write or where to file the report, you can get
advice from the internal nominated referrer (or Director, Chair or other member of the
board of trustees covering his or her absence). See paragraphs 2.5.8 and 2.5.9 regarding
storage.
2.5.3 Do not share information about the incident without agreeing this first with the
internal nominated referrer (or the Director, Chair or other member of the board of
trustees if the internal nominated referrer is absent).
2.5.3 The internal nominated referrer (or Chair or other member of the board of trustees
covering his or her absence) will be responsible for recording essential information about
each case and for collecting reports and notes as appropriate.
2.5.4 Any detailed information about a case will be confined to the internal nominated
referrer, the Chair (or other member of the board of trustees standing in for the Chair in
his or her absence) and (if not involved in the allegations), any other person that the
subject of the concern has asked to be notified, if deemed appropriate.
2.5.5 The internal nominated referrer (or person covering absence – see list in previous
paragraphs) will advise the Chair of SAGE of the safeguarding concern or incident. Staff,
volunteers, trustees or students reporting the concern or incident will be kept informed of
the progress of the case on a 'need to know' basis.
2.5.6 The internal nominated referrer (or Chair or other member of the board of trustees
covering his or her absence) is also responsible for ensuring that the adult at risk of harm
is kept informed of decisions and progress as appropriate.
2.5.7 The paper record of the safeguarding concern or incident will be kept in a separate
Safeguarding folder, stored separately from case record in a locked filing cabinet.

2.6 What happens next
2.6.1 Taking into account all the information available, the internal nominated referrer (or
Chair of SAGE in his or her absence) will decide on the next steps, which may include
taking no further action.
To determine the appropriate action it is important to consider:

• Risk – to the individual, staff member, volunteer, trustee or student,
• Self-determination – is the adult at risk of harm able to make their own decisions
  and choices, and do they wish to do so
• Seriousness:
  - perception by the individual
  - extent of the abuse
  - length of time it has been going on
  - risk of repetition or escalation
  - is a criminal offence being committed?

2.6.2 The internal nominated referrer (or Chair of SAGE in his or her absence) will also
use guidance from Sheffield’s Safeguarding Adults Office or Adult Access team in making their decision. This is available from the Sheffield City Council website or by telephoning the Adult access team.
2.6.3 Where the internal nominated referrer (or Chair of SAGE in his or her absence)
decides that further action is necessary, this may be to:

• Seek further advice from the Sheffield Safeguarding Adults Office or Adult Access
  team
• Make a referral to the Sheffield Adult Access team by phone (0114 273 4908) or
  using the Safeguarding Alert form, see Appendix 1; available to download from:
  www.sheffield.gov.uk/caresupport/adult/adult-abuse/professionals.html
• Report the incident to a designated Social Worker
• Report the matter to the police if a crime is suspected
• In circumstances where the action does not meet the threshold of abuse, e.g. it is
  poor practice but not abuse,
  - Invoke SAGE’s Complaints/ Disciplinary Procedures

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2.6.4 Once a referral is made, the internal nominated referrer (or Chair of SAGE in his or
her absence) will co-operate with the statutory investigation and provide further
information as required.
2.6.5 Where there is no further action to be taken
In cases where the internal nominated referrer (or Chair of SAGE in his or her absence)
decides that no further action is necessary, the reasons for this will be recorded and
shared with the Chair and member of staff, volunteer, trustee or student reporting the
concern. The record will be stored safely in the designated place. See paragraphs 2.5.8
and 2.5.9 regarding storage.

• If a member of staff, volunteer, trustee or student does not agree with a decision
  of SAGE’s internal nominated referrer (or Chair of SAGE in his or her absence)
  that no further action is necessary, the member of staff, volunteer, trustee or
  student should refer these concerns in the first instance to the Director.
• If the Director does not recommend further action and the member of staff,
  volunteer, trustee or student still has concerns, then he or she can refer to the
  Chair or other member of the board of trustees in the Chair’s absence.
• If s/he still has concerns s/he has the right and duty to refer the case directly to the
  Sheffield, Adult Access team (0114 273 4908) in line with the Public Interest
  Disclosure Act 1998. In this instance, the member of staff, volunteer, trustee or
  student should inform the Chair (other member of the board of trustees in the
  Chair’s absence) of the action they have taken.

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‍2.7 Confidentiality and consent
2.7.1 See also SAGE’s confidentiality policy
2.7.2 The consent of the adult at risk of harm to pass on information to external agencies
should be obtained.
2.7.3 Circumstances in which the internal nominated referrer (or Chair, in his or her
absence) can reasonably pass on information without the individual’s explicit consent
include:

• the person lacks the mental capacity to make that decision – this must be properly
  explored and recorded in line with the Mental Capacity Act
• other people are, or may be, at risk, including children
• sharing the information could prevent a crime
• the alleged abuser has care and support needs and may also be at risk
• a serious crime has been committed
• staff are implicated
• the person has the mental capacity to make that decision but they may be under
  duress or being coerced
• the risk of immediate harm is unreasonably high
• a court order or other legal authority has requested the information.
• The individual cannot be contacted

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2.7.4 Where the decision is taken not to share information because the adult at risk of
harm has refused consent.
If the circumstances in 2.7.3 do not apply and the internal nominated referrer (or Chair, in
his or her absence) makes the decision not to share safeguarding information or not to
intervene to safeguard the person, the internal nominated referrer (Chair, in his or her
absence) will, where deemed appropriate,

• support the person to weigh up the risks and benefits of different options
• ensure they are aware of the level of risk and possible outcomes
• offer to arrange for them to have an advocate or peer supporter
• offer support for them to build confidence and self-esteem, if necessary
• agree on and record the level of risk the person is taking
• record the reasons for not intervening or sharing information
• regularly review the situation
• try to build trust and use gentle persuasion to enable the person to better protect
  themselves.

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Where the decision is made not to intervene or share information, the reasons for the
decision will be recorded and shared with the Chair and, if appropriate, with the member
of staff, volunteer, trustee or student reporting the concern.
2.7.5 Where the decision is taken to share information despite the adult at risk of harm
refusing consent (see also 2.7.3)
If it is necessary to share information outside the organisation without the adult at risk of
harm’s consent, efforts should first be made to obtain consent by taking the following
actions:

• explore the reasons for the person’s objections – what are they worried about?
• explain the concern and why you think it is important to share the information
• tell the person who you would like to share the information with and why
• explain the benefits, to them or others, of sharing information – could they access
  better help and support?
• discuss the consequences of not sharing the information – could someone come to
  harm?
• reassure them that the information is still confidential and should not be shared with
  anyone who does not need to know
• provide them with information about support that may be available to them.

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2.7.6 If, after having taken the above actions, the person cannot be persuaded to give
their consent then, unless it is considered dangerous to do so, it should be explained to
them that the information will be shared without consent.
2.7.7. Where the decision is made to pass on information without the individual’s explicit
consent, the reasons for the decision will be recorded and shared with the Director and
Chair and, if appropriate, with the member of staff, volunteer, trustee or student reporting
the concern.
2.7.8 If it is not clear that information should be shared outside the organisation, a
conversation can be had with safeguarding partners in the police or local authority without
disclosing the identity of the person in the first instance. They can then advise on whether
full disclosure is necessary without the consent of the person concerned.
2.7.9 It is very important that the risk of sharing information is also considered. In some
cases, such as domestic violence or hate crime, it is possible that sharing information
could increase the risk to the individual. Safeguarding partners need to work jointly to
provide advice, support and protection to the individual in order to minimise the possibility
of worsening the relationship or triggering retribution from the abuser.
2.7.10 The safeguarding principle of proportionality should underpin decisions about
sharing information without consent, and decisions to do so should be on a case-by-case
basis. The following guidance, from Section 5.6. of ‘No secrets: Guidance on developing
and implementing multi-agency policies and procedures to protect vulnerable adults from
abuse’ should be followed:

• information will only be shared on a ‘need to know’ basis when it is in the best
  interests of the service user;
• confidentiality must not be confused with secrecy;
• informed consent should be obtained but, if this is not possible and other
  vulnerable adults are at risk, it may be necessary to override the requirement; and
• 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.

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2.7.11 SAGE complies with the requirements of the Data Protection Act 1998, which
allows for disclosure of personal data where this is necessary to protect the vital interests
of an adult at risk of harm.
2.7.12 Staff, volunteers, trustees and/or students must not discuss the case with anyone
other than those immediately involved in the case and must not share information with
other bodies. If you have any concerns about the progress of the case or have any other
concerns these must be discussed with the internal nominated referrer or Chair in his or
her absence.
2. Allegations against staff, volunteers and/or trustees
2.8.1 The primary concern of SAGE is to ensure the safety of the adult at risk of harm. It
is essential in all cases of suspected abuse by a member of staff, volunteer, trustee of
student that action is taken quickly and professionally whatever the validity.
2.8.2 There may be occasions where an adult at risk of harm will accuse a member of
staff/volunteer/trustee/student of abusing them. In some cases this may be false or
unfounded. However, in some cases the allegations may be true.
2.8.3 Any instance of an adult at risk of harm being abused by a member of
staff/volunteer/trustee/student is particularly serious. On the other hand, for an innocent
person to be accused of such an act is a serious ordeal which can result in long-term
damage to their health and career.
2.8.4 In the event that any member of staff/volunteer/trustee/student suspects any other
member of staff/volunteer/trustee/student of abusing a SAGE user, it is their responsibility
to bring these concerns to the Chair and the internal nominated referrer except where the
suspect is one of these people.
2.8.5 If the allegation concerns a member of the board of trustees, the matter should be
discussed with the internal nominated referrer who will discuss it with the Chair (unless
they are the subject of the allegation, in which case another member of the board of
trustees will be chosen), in addition to following the normal procedures for safeguarding
adults.
2.8.6 If the allegation concerns the internal nominated referrer, the matter should be
discussed with the Chair, in addition to following the normal procedure for safeguarding
adults.
2.8.7 The member of staff, volunteer, trustee or student will be advised to contact their
union representative or to seek independent advice and keep records of all conversation,
meetings attended, letters received and telephone calls relating to the allegation.
2.8.8 The procedure outlined in SAGE’s disciplinary procedure will be followed to
investigate an allegation of abuse against a member of staff.
2.8.9 The procedure outlined in SAGE’s complaints procedure will be followed to
investigate an allegation of abuse against a member of the board of trustees, volunteer
team or a student.
2.8.10 Neither of the circumstances described in 2.8.8 & 2.8.9. preclude formal reporting
of the alleged abuse.

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SECTION 3: CODE OF BEHAVIOUR FOR SAFEGUARDING ADULTS FOR SAGE

STAFF, VOLUNTEERS, TRUSTEES AND STUDENTS

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3.1.1 SAGE recognises that it is not practical to provide definitive instructions that would
apply to all situations at all times whereby staff, volunteers, trustees or students come into
contact with adults at risk of harm and to guarantee the protection of adults at risk of harm
and staff, volunteers, trustees and students. However, below are the standards of
behaviour required of staff/volunteers/trustees/students in order to fulfil their roles within
SAGE. This code should assist in the protection of both adults at risk of harm and
members of staff, volunteers, trustees and students
3.1.2 Staff, volunteers, trustees and students must adhere to SAGE’s Safeguarding
Adults policy at all times.
3.1.3 Staff, volunteers, trustees and students must follow SAGE code of conduct
3.1.4 Implications for staff, volunteers, trustees and students:

Staff members who breach any of the above may be subject to the disciplinary procedure;
volunteers, trustees or students who breach any of the above may be subject to the
complaints procedure.

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4 Safeguarding training

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4.1 Safeguarding training, including updates, is mandatory for staff and will be
recorded in staff files
4.2 Staff, volunteers, students and members of the board of trustees must be made
aware of SAGE’s safeguarding policy as part of their induction into SAGE.

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5 Keeping the Trustee Board informed

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5.1 In addition to references elsewhere in this document with regard to the Trustee
Board, the Director will provide the board of trustees with information about
safeguarding concerns, under the heading of Risk Management within the Service
Manager (or Director’s) report to the board of trustees meetings.
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6 POLICY REVIEW

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6.2.1 The policy will be reviewed every year.

Signed: W. Carlile 7.9.22

On behalf of the board of trustees

Date of implementation: 6/12/05
Date of last amendment: 7/9/22

(to incorporate recommendations following the last review)

Date of last review: 7th September 2022
Date of next review: September 2023

At Support Arts Gardening Education  (SAGE) we want everyone who contacts us, or who comes to us for support, to feel confident and comfortable. The Safeguarding policy is aimed at protecting adults at risk of harm, workers, volunteers, trustees and students.