SAFEGUARDING ADULTS AT RISK POLICY & PROCEDURE
1. Purpose
This policy sets out SSG Sustainable Living's approach to safeguarding adults at risk within its homeless supported accommodation services. It outlines the responsibilities, standards and procedures designed to protect adults from abuse, neglect, exploitation, or harm and ensures that all staff and volunteers understand their roles in promoting safety, wellbeing, and dignity. The Government's 'Ending Rough Sleeping for Good' Strategy recognises that severe disadvantage and multiple, and complex needs are often experienced by individuals with lived experience of rough sleeping, and that this significantly heightens vulnerability to abuse, neglect, exploitation, or harm. SSG is committed to minimising these risks through proactive person-centred safeguarding practice.
2. Scope
This policy applies to all individuals engaged in SSG's work, including:
- The Board of Trustees
- Senior Management Team
- Employees
- Volunteers
- Contractors
- Residents
All those covered by this policy share responsibility for creating and maintaining a safe, respectful, and protective environment for adults at risk.
3. Statement of Commitment
3.1. Organisational Commitment
SSG is committed to safeguarding and promoting the welfare of adults at risk by:
- Maintaining a safe and secure environment
- Embedding a strong organisational safeguarding culture
- Responding to concerns effectively, promptly, proportionately and compassionately
- Ensuring policies and procedures reflect current legislation, statutory guidance and best practice
- Promoting openness, transparency, accountability and continuous learning
3.2. Zero Tolerance of Abuse
SSG believes that abuse, neglect, or exploitation is never acceptable. Adults at risk will be listened to, taken seriously, and supported to express their views and make informed choices wherever possible.
3.3. Safeguarding Culture
A strong safeguarding culture at SSG means:
- Risks of harm are actively identified and reduced
- Roles and responsibilities are clearly understood
- Concerns are acted upon appropriately and consistently
- Staff and volunteers feel confident to raise concerns
3.4. Equality Statement
SSG is committed to anti-discriminatory practice and equal protection from harm for all people, regardless of age, disability, gender identity, race, ethnicity, faith, sexual orientation, or background.
SSG recognises that adults from minority or marginalised groups may face additional barriers to safety, disclosure and access to services. In response, we are committed to ensuring safeguarding responses are inclusive, culturally competent and tailored to individual circumstances.
4. Legislation and Statutory Guidance
4.1. The policy is informed by, and complies with, the following:
- The Care Act 2014
- Mental Capacity Act 2005
- The Human Rights Act 1998
- The Equality Act 2010
- Sexual Offences Act 2003
- The Protection of Freedoms Act 2012
- The Safeguarding Vulnerable Groups Act 2006
- The Data Protection Act 2018 & UK GDPR
- Domestic Violence, Crime and Victims Act 2004
- Information Sharing Guidance 2018
- Charity Commission Safeguarding Guidance 2018
4.2 Safeguarding is embedded across SSG's governance and operations. In addition to this policy, the following associated policies contribute to our safeguarding approach:
- Code of Conduct Policy
- Bullying and Harassment Policy
- Whistleblowing Policy
- Complaints Policy
- Professional Boundaries Policy
- Data Protection Policy
- Confidentiality Policy
- Recruitment and Selection Policy
5. Key Definitions
5.1 Adult Safeguarding
Safeguarding means protecting an adult's right to live in safety, free from abuse and neglect. It involves preventing both the risk and experience of abuse, while promoting the adult's wellbeing including, where appropriate, respecting their views, wishes, feelings and beliefs. (Care and Support Statutory Guidance 2022, issued under the Care Act 2014).
5.2 Adults at Risk
Under the Care Act 2014, an adult at risk is as a person 18 or over who:
- Has needs for care and support, regardless of whether the local authority is meeting any of those needs
- Is experiencing, or at risk of, abuse or neglect
- Is unable to protect themselves from abuse or neglect as a result of their care or support needs
Being an adult at risk can be temporary or changeable.
5.3 Abuse
Abuse is a violation of an individual's human and civil rights and includes any act or omission that results in harm, mistreatment, or exploitation by a person or persons.
It may occur as a single incident or a pattern of repeated behaviour and may result from deliberate actions or a failure to act appropriately. Abuse may be intentional or unintentional, but nonetheless causes harm, distress, or a loss of dignity, either temporarily or over time.
Who can Abuse Affect
Abuse can affect one or more individuals and can occur in personal relationships, service settings, or wider community contexts. Anyone can experience abuse, and equally, anyone can perpetrate abuse.
While abuse is often carried out by someone known to the adult, often in a position of trust, power, or influence, it may also be perpetrated by any individual. Adults can be both victims and perpetrators of abuse or neglect.
Types of Abuse
The types of abuse covered by the safeguarding legislation include:
- Physical abuse
- Sexual abuse
- Psychological or emotional abuse
- Financial or material abuse
- Institutional abuse
- Discriminatory abuse
- Exploitation and modern slavery
- Domestic abuse, stalking and honour based violence (DASH)
- Radicalisation and being drawn into terrorism
These categories are not mutually exclusive, and many cases involve a combination of abuse types.
Recognising Abuse
Staff must be alert to indicators of harm, including changes in behaviour, physical signs, financial irregularities, or disclosures. Abuse may be subtle, hidden, or coercive. For possible examples and indicators of abuse, see Appendix 1.
5.4 Vulnerability
Within adult safeguarding, vulnerability refers to an adult's increased risk of harm, abuse, or exploitation due to their personal circumstances or situation. It may reduce their ability to make, communicate, or act upon informed decisions freely, or to protect themselves from harm.
Vulnerability can arise from impaired decision making capacity, experiences of coercion or control, or other personal or situational factors. Adults in such circumstances may require additional support to safeguard their rights, wellbeing, and safety.
5.4 Capacity
Capacity refers to an individual's ability to make a specific decision at that time. A person has capacity if they can understand, retain, and weigh relevant information and communicate their decision by any means. Capacity is decision-specific and may fluctuate over time.
A person with capacity has the right to make their own decisions, including decisions others may consider unwise. Capacity and consent are central to safeguarding. Where choice is undermined by coercion, control, or an unequal power dynamic, consent cannot be considered meaningfully given.
Capacity is assessed by appropriately trained professionals, including health and social care practitioners or other relevant specialists in line with the Mental Capacity Act 2005.
The Mental Capacity Act 2005 outlines five key principles that must guide all decisions and actions relating to capacity:
- 1. Presumption of capacity:Every adult must be assumed to have capacity unless it is established otherwise.
- 2. Support to decide:All practicable steps must be taken to help a person make their own decision before concluding that they lack capacity.
- 3. Unwise decisions:A person is not to be treated as lacking capacity simply because they make a decision others consider unwise.
- 4. Best interests:Any act or decision made on behalf of a person who lacks capacity must be made in their best interests.
- 5. Least restriction:Any decision made on behalf of someone lacking capacity must be the least restrictive of their rights and freedoms.
6. Care Act 2014 Principles
6.1 The Care Act 2014 sets out the following principles that underpin the safeguarding of adults:
- Empowerment: Support and encourage vulnerable people to make their own decisions and give informed consent
- Prevention: Act before harm can occur
- Proportionality: Use the least intrusive, appropriate response
- Protection: Provide support and representation appropriate to the risk presented
- Partnership: Partner with local authorities and organisations to provide the best support
- Accountability: Remain transparent and responsible for delivering safeguarding
6.2 Making Safeguarding Personal
The Care Act 2014 set out a requirement for 'Making Safeguarding Personal' through which all safeguarding practices should be person-led and outcome focused. SSG will ensure adults at risk will, wherever possible, be involved in discussions about the safeguarding process and supported to exercise choice and control. The views and wishes of an adult at risk will be considered as part of safeguarding decision making.
7. Preventing Abuse
7.1 Safer Recruitment
SSG is committed to maintaining robust safer recruitment practices to ensure that all staff and volunteers are suitable to work safely with vulnerable adults. Enhanced DBS checks will be completed for all eligible roles and will be repeated every three years to ensure ongoing suitability.
All recruitment and selection processes will follow safer recruitment principles, including the use of structured interviews, identity verification, reference checks and assessment of skills and values. These measures help ensure that only individuals who are appropriate, competent and aligned with SSG's safeguarding responsibilities are appointed to roles within the organisation.
7.2 Training and Support
SSG recognises its duty to ensure all staff and volunteers understand their safeguarding responsibilities and are equipped to recognise, prevent, and respond to concerns of abuse or neglect. To support this, SSG provides clear guidance, mandatory structured training, and ongoing support to help staff minimise risk and maintain safe practice.
All staff and volunteers receive Safeguarding Adults training as part of their induction, with refresher training at least every two years. Additional training is provided where required to meet specific roles or emerging needs.
Staff can seek advice and support any at time from the Information Coordinator and Safeguarding Lead. Managers will ensure safeguarding is regularly discussed during supervision and team meetings, sharing learning from practice, incidents, or policy updates to strengthen staff awareness and confidence. An open door approach will be maintained to enable staff to raise concerns promptly and access ongoing guidance and support.
7.3 Code of Conduct
All staff, volunteers and contractors are required to adhere to the organisation's Code of Conduct, which sets clear expectations for professional behaviour, boundaries, and respectful interactions. The Code of Conduct promotes safe practice, helping to prevent harm, abuse, or misuse of power. Breaches of the Code of Conduct are taken seriously and may result in disciplinary action in line with organisational procedures.
8. Roles and Responsibilities
Board of Trustees
The Board of Trustees holds overall responsibility for safeguarding within the organisation. Trustees delegate day to day operations to the Senior Management Team but retain oversight and have a duty of care to ensure safeguarding arrangements are managed appropriately, risks are managed, and vulnerable adults and the organisation are protected.
Senior Management Team
The Senior Management Team is responsible for ensuring that effective safeguarding policies and procedures are in place, communicated to all staff and volunteers, and implemented to protect adults at risk. They also ensure that staff are appropriately supported to fulfil their safeguarding responsibilities.
Safeguarding Lead
The Safeguarding Lead coordinates safeguarding activity within SSG, ensures safe and best practice, and provides leadership, advice, and expertise on safeguarding matters. They oversee the development, implementation, and review of safeguarding arrangements and plans, ensuring safeguarding activity is effective and of high quality.
SSG Safeguarding Lead: Maria Marsden, CEO
Information Coordinator
The Information Coordinator is the first point of contact for safeguarding concerns, responsible for recording information, liaising with staff, and completing safeguarding referrals and risk assessments in line with procedures. Concerns will be escalated to the Safeguarding Lead where risks remain high or unresolved.
Staff and Volunteers
All staff and volunteers have a responsibility to be aware of potential safeguarding risks, report concerns promptly and follow organisational safeguarding procedures in line with this policy.
9. Partnership Working
SSG will work with local authorities, police, health providers, safeguarding boards and other agencies to share relevant information, contribute to enquiries, and ensure effective multi- agency safeguarding.
10. Reporting Concerns
10.1 Reporting and Escalation of Concerns
All staff and volunteers must follow SSG's internal and external reporting procedures. SSG's external safeguarding procedure is aligned with Manchester City Council's safeguarding procedures and the Manchester Safeguarding Partnership. Concerns must be reported immediately to the Safeguarding Lead and the Information Coordinator. In emergencies, staff must contact emergency services.
Any safeguarding concerns involving staff or volunteers must be reported immediately to the Safeguarding Lead, and appropriate action will be taken. Where a staff member or volunteer has caused harm, or posed a significant risk of harm, SSG will consider making a referral to the Disclosure and Barring Service (DBS). If a staff member or volunteer is dismissed or removed from SSG due to a safeguarding concern, a referral to the DBS will be made.
As part of SSG's safeguarding responsibilities, all safeguarding concerns will be escalated to Manchester City Council commissioners, in line with commissioning and contractual requirements. When required, SSG will also report serious incidents to the Charity Commission and notify relevant external agencies, in line with Charity Commission guidance and organisational procedures.
10.2 Reporting Concerns About Others
Safeguarding concerns may relate to the safety or wellbeing of other residents, as well as individuals not living within SSG's accommodation, such as family members or others known to a resident.
Residents are encouraged and supported to raise such concerns. Staff must respond appropriately and manage all concerns in line with safeguarding procedures, including referrals to relevant external agencies where required.
11. Information Sharing, Confidentiality and Record Keeping
Safeguarding information will be shared strictly on a need to know basis and stored securely in accordance with GDPR, data protection legislation, and SSG's Data Protection Policy. Records must be accurate, factual, objective, and kept up to date.
Information will be shared with informed consent wherever possible. Adults should be made aware of what information is being shared, with whom and for what purpose. However, information may be shared without consent where there is a legal obligation to do so or where seeking consent would increase the risk of harm to the adult or others.
Confidentiality cannot be guaranteed where safeguarding concerns arise. If a disclosure or concern indicates that an adult or others may be at risk of harm, staff must share this information in line with safeguarding procedures. Confidentiality will be respected as far as possible throughout the safeguarding process, and all safeguarding information will be handled sensitively and securely.
12. Complaints, Monitoring and Learning
Safeguarding related complaints will be managed through the Complaints Policy. Learning from incidents, audits, and feedback will inform service improvement and policy development.
13. Policy Review
This policy will be reviewed every three years or sooner in response to legislative change, learning from safeguarding incidents, or organisational development.