1. INTRODUCTION

• Shop and Donate CIC was established in April 2020. Our aim is to provide education and inspiration to young people who want to fulfil their potential in the London Boroughs of Hammersmith and Fulham and Westminster.

2. BACKGROUND AND GENERAL PRINCIPLES

• This Policy supports Shop and Donate CIC’s role in safeguarding. It states how the organisation will work in conjunction with other agencies to recognise and manage suspicions, allegations and findings or abuse of adults and children at risk who access the CIC’s services.
• Shop and Donate CIC’s is committed to the following principles in all aspects of its safeguarding work:
• Empowerment – taking person-centred approach, whereby all people feel involved and informed;
• Protection – delivering support to victims to allow them to take action;
• Prevention – responding quickly to suspected cases;
• Proportionality – ensuring outcomes are appropriate for the individual;
• Partnership – information is shared appropriately and the individual is involved;
• Accountability – ensuring that all members of staff and volunteers have a clear role.

3. SAFEGUARDING DEFINED

• Safeguarding is the term that describes the function of protecting adults and children from abuse or neglect. It is an important shared priority of many public services, as well as being a key responsibility of Local Authorities.
• Safeguarding relates to the need to protect certain people who may be in vulnerable circumstances. These are people who may be at risk of abuse or neglect, due to the actions (or lack of action) of another person.  In these cases, it is critical that services work together to identify people at risk, and put in place interventions to help prevent abuse or neglect, and to protect people.

4. INTERPRETATION

• Adults and children at risk who fall under Shop and Donate CIC’s Safeguarding Policy will be referred to within this policy as “customers”.
• The term “adult at risk” has been used in this Policy to replace “vulnerable adult”. This is because the term “vulnerable adult” may wrongly imply that some of the fault for the abuse lies with the adult abused. The term “adult at risk” is used as an exact replacement for “vulnerable adult” (as used throughout existing Government guidance).

5. SCOPE

• The responsibilities of Shop and Donate CIC covers all members of staff, including any volunteers carrying out duties on their behalf.

6. ABUSE

• Abuse is a violation of an individual’s human and civil rights by another person or persons. Abuse may consist of a single act or repeated acts.  It may be physical, financial, verbal or psychological or an act of neglect or omission to act.  It may occur when an adult at risk is persuaded to enter into a financial or sexual transaction to which they have not consented, or cannot consent.  Abuse can occur in any relationship and may result in significant harm to, or exploitation of, the person subjected to it.
• Some types of abuse will constitute a criminal offence, in which case adults at risk are entitled to the protection of the law in the same way as any member of the public. Whenever a criminal offence is suspected Shop and Donate CIC will make a referral to the Police.  It may be necessary to make an urgent referral for the public safety of the adult at risk and/or to protect or preserve evidence.
• Abuse is about the misuse of power and control that one person has over another. Where there is dependency, there is a possibility of abuse or neglect unless adequate safeguards are put in place.
• Abuse can be viewed in terms of the following categories:

• Physical Abuse

Includes hitting, slapping, pushing, kicking, and misuse of medication, restraint or inappropriate sanctions;

• Financial Abuse

Ranging from failure to access benefits, through inadvertent mismanagement and opportunistic exploitation to deliberate and targeted abuse, often accompanied by threats and intimidation.  It can include theft, fraud, exploitation, pressure in connection with wills, property or inheritance or financial transactions, overcharging or carrying out unnecessary work, or the misuse or misappropriation of property, possessions or benefits;

• Sexual Abuse

Includes rape and sexual assault or sexual acts to which the adult at risk has not consented, or could not consent or was pressured into consenting.

• Psychological/ Emotional Abuse

Includes emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, isolation or withdrawal from services or supporting networks.

• Neglect/ Acts of Omission

Includes ignoring medical or physical care needs, failure to provide access to appropriate health, social care or educational services, the withholding of the necessities of life, such as medication, adequate nutrition and heating.  Research has shown that neglect is the most prevalent form of abuse of elders in the UK, with financial abuse a close second.

• Discriminatory Abuse

Includes ageist, racist, sexist, that based on a person’s disability, and other forms of harassment, slurs or similar treatment.

• Institutional Abuse

The mistreatment or abuse or neglect of an adult at risk by a regime or individuals within settings and services that adults at risk live in or use that violate the person’s dignity, resulting in lack of respect for their human rights.  Institutional abuse occurs when the routines, systems and regimes of an institution result in poor or inadequate standards of care and poor practice which affects the whole setting and denies restricts or curtails the dignity, privacy, choice, independence or fulfilment of adults at risk

• Abuse of Trust

A relationship of trust is one in which one person is in a position of power or influence over the other person because of their work or the nature of their activity.  There is a particular concern when abuse is caused by the actions or omissions of someone who is in a position of power or authority and who uses their position to the detriment of the health and well-being of a person at risk, who in many cases could be dependent on their care.  There is always a power imbalance in a relationship of trust.

• Mate Crime

Mate crime a type of hate crime where perpetrators befriend a person with a disability but in fact soon begin to exploit, hurt or harm them.  This can include sexual abuse, forced prostitution, financial exploitation, physical abuse, violence and even murder.

• Abuse can take many forms. It does not have to fit comfortably into any of the above.  Abuse can be perpetuated by one adult at risk towards another.  This is still abuse and should be dealt with accordingly.  The adult at risk may also be neglecting him/herself which could also justify a safeguarding referral.

7. ALERTS TO FORMS OF ABUSE

• There are a number of characteristics that may increase the risk of abuse. These include:
• Records of previous abuse or suspected abuse to the customer;
• Previous abuse to other members of customer’s family;
• The presence of family tensions and conflicts;
• Predisposing factors to abuse have been shown to include: advanced age (75+) female, organic brain injury, cognitive impairment, physical, mental or emotional dysfunction especially depression, recent loss of spouse, social isolation, living alone, estranged from children.

8. POSSIBLE ALLEGED ABUSERS

• Adults at risk may be abused by a wide range of people including relatives and family members, professional staff, paid care workers, other adults at risk, volunteers, other service users, neighbours, friends and associates, people who deliberately exploit vulnerable people, strangers and opportunistic people.
• There is often particular concern when abuse is perpetrated by someone in a position of power or authority who uses his or her position to the detriment of an adult at risk.

9. SHOP AND DONATE CIC’S ROLE

• Shop and Donate CIC will employ a combination of preventative measures, investigative measures and remedial action as part of its commitment to safeguarding children and adults at risk.
• Preventative measures include:
• Promoting and raising awareness of legal safeguards and remedies through training, presentations, publicity and work with its key stakeholders;
• Development and review of strategies and policies regarding protection of its customers, both within the organisation and in partnership with other Government departments and external partners;
• Ensuring systems are in place to prevent/reduce the likelihood of abuse of an adult at risk by Shop and Donate CIC staff and volunteers.
• Investigative measures include:
• Receiving reports of abuse relating to an adult at risk (covered under the organisation’s Whistleblowing Policy);
• Investigating reported concerns about the actions of a member of staff of volunteer;
• Working in partnership with other agencies (such as Adult Social Services and the Police) which may include: referring suspicions and allegations to external agencies where appropriate; participating in meetings/ case conferences with relevant agencies; participating in joint investigations of suspected abuse.
• Remedial actions include:
• Monitoring the situation where abuse is known to have occurred previously, or there is considered to be an ongoing risk of abuse.

10. INVOLVING EXTERNAL AGENCIES

• Local authority Adult Social Services have the lead role in coordinating the multi-agency approach to safeguard adults at risk. Initial investigations can be undertaken by any agency; the agency most involved with the customer may be the most appropriate to lead this investigation in the first instance, with the involvement (whether in the form of action, information sharing or advice) of Adult Social Services at all stages.
• After discussion with a line manager or senior colleague any suspected abuse can be referred by Shop and Donate CIC staff to the appropriate Adult Social Services. They will have a process in place to arrange strategy meetings and strategy discussions.  The local authority will agree any investigation through its strategy meeting and discussion process so that initial enquiries do not jeopardise any subsequent police investigation.
• The role of Acknowledging Youths CIC will be determined in each case as it arises. It may:
• Take responsibility for investigating. If this course of action is taken, Adult Social Services and/or the police can still be informed of the allegation or suspicion.  It is not necessary to establish that abuse has occurred before a referral to Adult Care Social Services or the Police;
• Refer straight to Adult Social Services and/or the Police if Shop and Donate CIC has no authority to investigate;
• Work in partnership with other agencies (in particular Adult Social Services) to investigate and deal with an allegation or suspicion relating to an Shop and Donate CIC customer.
• Shop and Donate CIC will discuss and agree the need to involve other agencies with the Local Authority or the lead agency in any investigation.

11. REPORTING TO THE POLICE

• If an incident of abuse is considered to be a criminal offence then Shop and Donate CIC will refer to the Police. Examples of when action may be considered a criminal offence include: assault (whether physical or psychological); sexual assault and rape; theft, fraud or other forms of financial exploitation; and certain forms of discrimination, whether on racial or gender grounds.
• Whether to involve the police will be a matter for the Chief Executive Officer or, in urgent situations, a member of the Executive Team, if necessary in consultation with the Shop and Donate CIC’s legal representatives, as it will not always be clear-cut.

12. SHARING OF INFORMATION

• Shop and Donate CIC will manage its customers’ information in line with statutory requirements and in accordance with the organisation’s own values of being straightforward, accessible, and professional.
• As Shop and Donate CIC handles sensitive personal information about people, including personal identity information and information about health and financial issues, it must ensure that there is no unauthorised access, loss, misuse, modification or disclosure of this information.
• When safeguarding adults at risk, there may be a need to disclose personal or sensitive information to someone from another organisation. Shop and Donate CIC will only do this where the law permits, and where disclosure is considered to be in its customer’s best interests (safeguarding) including the prevention of a crime.
• Wherever abuse is alleged or suspected, Shop and Donate CIC will seek to share information between relevant professionals in exploring how to protect the individual concerned or others. People who are subject to abuse or allegations of abuse and their families and carers have a right to expect that confidences will be respected and their privacy protected.  But where their “vital interests” (that is questions of life or death), “best interests”, or the public interest are involved, establishing the facts through information sharing takes precedence.
• Information can be shared in certain circumstances with other people or agencies in compliance with the General Data Protection Regulation 2019. Data can be shared with third parties “in the vital interest of the data subject” or “in the public interest” (e.g. in the interest of the customer or others in the same care setting).  Examples of when this may be appropriate will be if there is a need to seek information from another agency, or there is a potential risk to others from the alleged abuser.  Any information relating to the accusation/suspicion of abuse should and can be shared with the Social Services department or Police investigating the case.
• Shop and Donate CIC will share information with professional and regulatory bodies where it considers it is in the public interest. This includes the Solicitors Regulation Authority, the Disclosure and Barring Service, the Care Quality Commission (England) and the Care and Social Services Inspectorate (Wales).
• If personal or sensitive information is to be shared, this will be done (where possible) with the person’s agreement. In the absence of such, assessment of their best interests may still justify further enquiries, while questions involving the public interest may justify overriding their views.  Where adults lack capacity to safeguard themselves, others will need to make decisions for them in the person’s best interests.  The rights of “whistleblowers” and of alleged perpetrators of abuse will also be respected.
• Information shared will always be on a “need to know” basis (i.e. such which is necessary to achieve the objective of safeguarding adults and children at risk). Care will be taken to ensure the quality of the information shared (e.g. names, addresses and dates) of birth are accurately recorded.

13. ASSESSING AND RESPONDING TO THE LEVEL OF RISK

• All suspicions or allegations of abuse will be taken seriously.
• Shop and Donate CIC staff acknowledge that the needs of the adult or child at risk are paramount. Shop and Donate CIC will always attempt to act in the best interests of the adult or child at risk.  Where an individual has capacity and is not acting under duress, threat, fear or intimidation, that person has the right to make an unwise decision.
• All allegations of abuse or risk of abuse will be responded to promptly. Shop and Donate CIC’s business plan sets out timescales for responding to allegations of abuse.

14. ROLES AND RESPONSIBILITIES OF SHOP AND DONATE CIC PERSONNEL

• The Chief Executive Officer has a responsibility to do whatever he can to ensure the safety and protection of adults and children at risk who access Shop and Donate CIC’s services. This policy is therefore adopted by the Board of Directors.  Together, they will promote the messages within it and ensure that all staff adhere to it at all times.
• The Chief Executive Officer has the following responsibilities:
• To ensure that staff are fully aware of the Safeguarding policy;
• To promote the importance of the policy;
• To ensure that staff can attend training and can access guidance to enable them to identify and deal appropriately with abuse and potential abuse situations;
• To ensure that staff are aware of reporting systems and that these are followed;
• To ensure, through the organisation’s performance management systems that staff whose role involves safeguarding will document objectives that positively support and contribute to the Acknowledging Youth CIC’s Safeguarding Policy.
• The Chief Executive Officer also has the following responsibilities:
• Ensuring that Shop and Donate CIC adheres to this policy and that appropriate operational systems and processes are in place;
• Holding key relationships with external agencies and stakeholders in relation to safeguarding issues and will have responsibility for staff, customer and stakeholder communications on safeguarding issues;
• Responsibility for the management of finance policies and practices including but not limited to the provision of a robust fees policy to support Safeguarding matters; adequate cash handling guidance; and an appropriate framework of internal controls to support managers across the business in the proportionate management of their risks.
• The Chief Executive Officer will also have responsibility for the management of information assurance policies and practices, including the provision of appropriate records management guidance in relation to safeguarding records.
• Each manager responsible for a team of staff is responsible for ensuring that all staff understand, are skilled enough and adhere to this policy.
• All staff will have access to a copy of this policy. All staff will take responsibility for ensuring that they have read and understood this policy and the guidelines provided within it.  If individuals are unsure of anything either upon reading it or when dealing with a customer’s case then they will seek advice or information from their line manager.
• All staff will participate in briefings and training provided for them on safeguarding issues.
• Where appropriate within their role, staff will agree objectives with their manager that contribute to the Shop and Donate CIC’s role in safeguarding, and will document positive contributions they have made to that role.
• All staff, but especially those having contact with customers will use this policy and any other information provided to them for the purposes of identifying risk or incidences of abuse, and for acting appropriately in order to deal with such circumstances.

• All staff will refer to guidance on information assurance and security when managing personal information about customers. References to staff throughout this policy should be taken to include permanent, temporary and agency staff and contractors.

15. TRAINING & BRIEFINGS

• All Shop and Donate CIC Senior Managers, Managers and Team Leaders will be expected to attend training or briefings on the responsibilities of Acknowledging Youths, how to recognise abuse or the risk of abuse and Acknowledging Youths CIC’s procedures.
• All Shop and Donate CIC staff who have contact with customers (and their files, where appropriate) will be expected to attend training on this policy and guidelines.
• Mandatory training and briefing sessions will be provided in order to keep all staff updated, and more often for senior managers with a lead responsibility.

16. POLICY REVIEW

• This policy is part of an ongoing process to strengthen Shop and Donate CIC’s approach to safeguarding. It will be constantly reviewed and revised in line with national policy and legislative changes.
• The Chief Executive Officer, in conjunction with the Board of Directors, has responsibility for ensuring this.