Scope 

This policy applies to all people working for PNH Support or on our behalf in any capacity, including employees, trustees, agency workers, seconded workers, volunteers, contractors and suppliers. 

All staff and volunteers who have contact with adults who could be at risk of abuse or neglect have a duty to act if they have any concern that an adult is being abused, neglected or exploited. 

Safeguarding is everyone’s responsibility. The safeguarding team (see below) is responsible for addressing any safeguarding concerns, but looking after the safety of the team and those we interact with is up to all of us. This policy applies to all staff and Trustees, as well as freelancers, volunteers, sessional workers and visitors working with PNH Support. PNH Support intermittently undertakes community work, and this policy should be kept in mind with all interactions. This policy applies in all circumstances, including digitally. 

Our commitment 

Safeguarding is a fundamental part of the work of PNH Support and we are committed to carrying out the following key objectives: 

  • Contributing to the successful achievement of PNH Support’s aims and excellent standards of service for people affected by paroxysmal nocturnal haemoglobinuria (PNH). 
  • Being alert to the potential indicators of abuse or neglect for adults at risk and knowing how to act on those concerns in line with local guidance. 
  • Ensuring adults impacted by PNH who are in contact with PNH Support and have care and support needs, whether provided or not, are protected effectively from abuse, harm and neglect. This includes self-neglect. 
  • Providing a clear framework for action whenever abuse is witnessed, disclosed or suspected 
  • Understanding the principles of confidentiality and information sharing in line with local and government guidance and PNH Support’s information sharing and confidentiality policies. 
  • Ensuring all staff and volunteers are clear about their responsibility and receive training appropriate to their role 
  • Ensuring that PNH Support complies with existing legislation. In carrying out these statutory duties/responsibilities, account must be taken of: 
  • HM Government (2014) The Care Act 
  • Department of Health (2017) Care and Support Statutory Guidance 
  • NHS England (July 2015) Safeguarding Vulnerable People in the NHS – Accountability and Assurance Framework 
  • Department for Constitutional Affairs (2007) Mental Capacity Act 2005: Code of Practice 
  • Department of Health 2011 Safeguarding Adults: The Role of Health Services 
  • The policies and procedures of the relevant Local Safeguarding Adults Board (LSAB) 
  • HM Government (2011) Prevent Strategy 
  • Mental Capacity Act (2005) including 2011 and 2019 amendments 
  • Equality Act 2010 
  • Safeguarding Vulnerable Groups Act 2006 
  • Data Protection Act 1998 and 2018 

In line with equality legislation, PNH Support is committed to safeguarding adults who may be at risk of abuse irrespective of their protected characteristics as outlined in the Equality Act 2010. The nine protected characteristics being – age; gender; race; disability; marriage/civil partnership; maternity/pregnancy; religion/belief; sexual orientation and gender reassignment. 

Purpose 

  • Even where this policy is most applicable, there might still be crossover with other policies. This policy is not intended to replace anyone’s right to raise a formal complaint or grievance.  
  • The wording of this document may not cover every eventuality or set of circumstances, and as such PNH Support will take care to consider on a case-by-case basis when a safeguarding case arises – prioritising the wants and needs of the person being harmed, or at risk of being harmed.  
  • This policy will be particularly flexible when staff/volunteers are working away and are considering how to support community members. Those involved in preparation should make safeguarding plans for the event, that can be guided by this policy and supported by the Safeguarding Lead. 

Key safeguarding principles 

The following principles underpin the work of PNH Support: 

  • Every individual has the right to live in a safe environment and to be free from abuse or the threat of abuse. 
  • It is every individual’s right to live an independent life based on self-determination and personal choice and this includes the right to take risks. 
  • The wishes of the adult at risk will be respected within the context of their capacity to anticipate and understand risk. 
  • Adults at risk will not be assumed to have impaired mental capacity. 
  • All staff/volunteers will promote the empowerment and well-being of people with PNH 
  • All staff/volunteers will be aware of the policy and procedures for safeguarding adults at risk. 
  • Staff /volunteers working closely with adults at risk will have an enhanced Disclosure and Barring Service (DBS) check processed by the Disclosure and Barring Service, before working with adults. 
  • Staff/volunteers working closely with adults at risk will have the appropriate support and training to ensure they are able to recognise and act on the suspicion, disclosure or witnessing abuse. 
  • All staff/volunteers will seek to prevent the abuse or neglect of adults at risk. 
  • All disclosures and suspicions of abuse or neglect will be reported and recorded. 
  • All disclosures and suspicions of abuse or neglect will be referred to the relevant authorities, with the individual’s consent, except where a best interest decision is taken following the framework set out in the Mental Capacity Act, or where there is an overriding public interest that would justify information sharing e.g. because others may be at risk of serious harm. 
  • The case will only be shared with the limited number of individuals who need to know about it, other than this, all details will remain confidential. 
  • Staff/volunteers will be aware of local authority multi-agency policies and procedures and how information that is processed by them, is stored and used. 
  • Where other procedures apply to a disclosure of abuse (e.g. grievance, complaints, disciplinary) the welfare and safety of the adult at risk remains paramount. 
  • Any complaints within a safeguarding context will be reported to the safeguarding lead. An investigation will be conducted, and subsequent report will be compiled following that investigation. 
  • All staff/volunteers will keep clear and accurate records on our CRM system, follow safeguarding procedures, and receive training, which is appropriate to their role. 
  • Staff/volunteers will receive regular supervision with their line manager and safeguarding issues will be discussed during these sessions and outside of them as necessary 

Definitions 

  • PNH Support defines safeguarding as support and care to protect people from abuse, neglect and harm. We encourage a proactive approach, so that where possible we can prevent harm before it takes place.  
  • Safeguarding is generally associated with punishment and the involvement of police and social services. This policy aims to challenge that, centering on individuals and considering the multitude of ways that people might feel safer. 

Adult safeguarding is the process of protecting adults with care and support needs from abuse or neglect. It is about people and organisations working together to prevent and stop the risks and experiences of abuse and neglect, while ensuring the adults’ wellbeing is promoted, including where appropriate, having regard to their views, wishes, feelings and beliefs in deciding on any action. 

Safeguarding adults 

This safeguarding policy applies to any adult at risk (18 years and over): 

  1. who has needs for care and support, whether provided or not, and 
  1. is experiencing, or at risk of, abuse or neglect, and 
  1. as a result of those care and support needs is unable to protect themselves from either the risk of, or the experience of abuse or neglect 

Section 42 Enquiry by local authority (Care Act 2014) 

Section 42 applies where a local authority has reasonable cause to suspect that an adult in its area (whether or not ordinarily resident there): 

  1. has needs for care and support (whether or not the authority is meeting any of those needs), 
  1. is experiencing, or is at risk of, abuse or neglect, and 
  1. as a result of those needs is unable to protect themself against the abuse or neglect or the risk of it. 

The local authority must make (or cause to be made) whatever enquiries it thinks necessary to enable it to decide whether any action should be taken. PNH Support will cooperate with the local authority in making enquiries under this section. 

Self-determination 

  • One important difference between safeguarding adults (18 and over) and safeguarding children and teenagers (17 and under) is an adult’s right to self-determination. Adults may choose not to have any safeguarding intervention, and it is only in extreme circumstances that the law intervenes.  
  • This will often only happen when an adult is assessed to lack capacity to make decisions around safeguarding  or where the concerns may extend to children, such as when they are living in the same household (see the PNH Support Children and Young People Safeguarding Policy).  
  • Our safeguarding culture should celebrate and respect self-determination—taking the lead from the person experiencing harm and prioritising their wants, needs and confidentiality. We should inform and consult people on all decisions affecting them before we take any actions regarding those decisions.  

Refusal to give consent 

  • A referral should be made with the consent of the individual. If, however there is a very significant risk to the individual or others, there is a duty to share this with the appropriate statutory services.  
  • Very significant risk is defined as a threat to life.  
  • In such an instance all efforts should be made to explain to the individual concerned what is being done and why. 

Abuse 

Abuse can take place in-person or in a virtual environment, such as an online discussion board or chat room. Abuse or neglect may also be unintentional. The primary focus must be to safeguard the adult at risk. If there are concerns about an adult’s welfare and a belief that the person is suffering or likely to suffer abuse or neglect, then the information gathered must be shared with statutory services and/or the Police if it is believed or suspected that a crime has been committed. 

Abuse can be: 

  • Physical – including assault, hitting, slapping, pushing, kicking, misuse of medication, female genital mutilation, restraint or inappropriate physical sanctions. 
  • Neglect and acts of omission – including ignoring medical, emotional 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. This also relates to self-neglect. 
  • Self-neglect – is any failure of an adult to take care of themself that causes, or is reasonably likely to cause within a short period of time, serious physical, mental or emotional harm or substantial damage to or loss of assets. This includes hoarding. 
  • Sexual – including rape, sexual assault, indecent exposure, sexual harassment, inappropriate looking or touching, sexual teasing or innuendo, sexual photography, subjection to pornography or witnessing sexual acts. These apply when the adult has not consented or was pressurised into consenting. 
  • Emotional and psychological – including threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling intimidation, coercion, harassment, verbal abuse, cyber bullying, isolation or withdrawal from services or supportive networks. 
  • Financial or material – including theft, fraud, exploitation, internet scamming, pressure in connection with wills, property or inheritance or financial transactions, or the misuse of or misappropriation of property, possessions or benefits. 
  • Discriminatory –  on any of the grounds in the Equality Act 2010 including racist, religious, sexist, that based on a person’s disability, age or sexuality and other forms of harassment, slurs or similar treatment. 
  • Institutional abuse – is the mistreatment, abuse or neglect of an adult at risk by a regime or individuals. It can take place within settings and services that adults at risk live in (including their own home where care is provided) or use, and it violates the person’s dignity, resulting in a lack of respect for their human rights. 
  • Domestic abuse – is categorised by 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 family members regardless of gender or sexuality. This can encompass but is not limited to the following types of abuse: 
  • Physical 
  • Emotional 
  • Psychological 
  • Sexual 
  • Financial 

This includes honour-based abuse and forced marriage, and victims are not confined to one gender or ethnic group. 

  • 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. 
  • Data breaches – including those under General Data Protection Regulations (GDPR) 

Prevent  

The aim of “Prevent” is to stop people from becoming terrorists or supporting terrorism and operates in the ‘pre-criminal space’, i.e. before any criminal activity has taken place. 

Health services are a critical partner in Prevent. There are many opportunities for staff to help protect people from radicalisation. Staff/volunteers must be able to identify the signs that someone is vulnerable to radicalisation, interpret those signs correctly and access the relevant support. 

“Channel” 

“Channel” is a multi-agency process within Prevent, which aims to support those who may be vulnerable to being drawn into violent extremism. It works by identifying individuals who may be at risk, assessing the nature and extent of the risk; and where necessary, referring cases to a multi-agency panel, which decides on the most appropriate support package to divert and support the individual at risk. 

Staff may meet people who are vulnerable to radicalisation. People with mental health issues or learning difficulties may be more easily drawn into terrorism. 

Hate Crime 

PNH Support is committed to working in partnership with the Police and other agencies (e.g. social services) to ensure that hate crime is identified, reported and dealt with in a timely and person centred manner. The Police and other organisations should work together to intervene within the safeguarding adults procedures to ensure a robust, coordinated and timely response to situations where adults at risk become a target for hate crime. Coordinated action will aim to ensure that victims are offered support and protection and action is taken to identify and prosecute those responsible.  

A hate crime is any criminal offence that is perceived by the victim or any other person, to be motivated by a hostility or prejudice based on: 

  • disability 
  • race or ethnicity 
  • religion or belief 
  • sexual orientation 
  • transgender identity 

This can be committed against a person or property. Anyone could be a victim of a hate crime. A victim does not have to be a member of the group at which the hostility is targeted 

Safeguarding procedure 

Recruitment and training 

Staff and volunteers who work closely with adults will be subject to DBS check processed by the Disclosure and Barring Service in England and Wales. 

Induction for all trustees/staff/volunteers will include a full introduction to PNH Support’s safeguarding policies. 

Safeguarding reporting process 

No suspicion of abuse, harm or neglect should be ignored. You may become aware of possible abuse when you: 

  • witness a form of abuse 
  • recognise one or more of abuse indicators 
  • are told about abuse by the person with PNH 
  • are told about abuse by a visitor, carer, relative or friend 
  • observe online abuse on forums and discussion boards 
  • receive a complaint. 

If there is an emergency, you should encourage the person to call emergency services. If you don’t believe they will, you must override confidentiality and report the incident directly. You will inform the person of your actions, unless this would put you at risk, and then discuss with the Safeguarding Lead. 

You have a duty to report any disclosure, reports or suspicions of abuse, harm or neglect. All referrals to the Safeguarding Lead, and any ongoing safeguarding work should be recorded. 

If the concerns have been raised by a trustee/member of staff/volunteer other than the Safeguarding Lead, they should seek advice from the Safeguarding Lead. 

The Safeguarding Lead should refer all safeguarding cases to the relevant investigatory and regulatory authorities and should support the local authority under section 42 of the Care Act. No staff member/volunteer should undertake any kind of investigation unless requested to do so by the leading authority.  

Responding to disclosure – reassure, report and record. 

Where an adult discloses abuse, harm or neglect to a staff member/volunteer, they should: 

  • Reassure – stay calm, listen and show empathy. Reassure them that it will be taken seriously and explain that the issues will be reported internally and what may happen next. 
  • Report – immediately report to the relevant authorities or the Safeguarding Lead if you have any concerns about how the case should be taken forward. 
  • Record – write up notes of the conversation clearly and factually within 24 hours. 

You should not start any investigation or confront or make contact with the alleged perpetrator. 

You should (with the support of the Safeguarding Lead): 

  • Ask for the individual’s consent (where appropriate) to inform the necessary authorities. Where the individual is unable or unwilling to give informed consent, a referral may be made if it is in their best interests. 
  • Inform or contact anyone the person wishes to have for support. 

Making a referral 

You should refer any incidents of abuse to the local authority. Where there is the possibility of a criminal act, you should contact the police, obtaining permission where possible. 

All referrals should be made (following discussion with the Safeguarding Lead where appropriate) within one working day. 

The initial referral should be made by phone to the appropriate person or department. This should be followed up in writing within 24 hours. 

It is not acceptable for referrals to be made only by letter, email or voicemail. The referral should be as comprehensive as possible. The local authority and/or the Police will carry out the investigation. Under no circumstances should a staff member/volunteer attempt to investigate. 

Suspecting or witnessing abuse, harm or neglect 

If you suspect or witness abuse, harm or neglect you should: 

  • Report it to the relevant authorities with the support of the Safeguarding Lead where appropriate. 
  • Record your observations or concerns 

You should not seek to: 

  • Investigate suspected abuse, harm or neglect. 
  • Seek proof before reporting your concerns. 

Concerns about people who work with adults at risk 

Where there are concerns that someone is behaving in a way that demonstrates unsuitability for working with adults at risk, in their present position, or in any capacity, you must report this to the designated Safeguarding Lead. 

The allegation or concern may arise in either the trustee, staff member or volunteer’s work or private life. Examples could include: 

  • Committing a criminal offence against or related to adults at risk. 
  • Failing to work collaboratively with social care agencies when issues about the care of adults at risk for whom they have caring responsibilities are being investigated. 
  • Behaving towards adults at risk in a manner that indicates they are unsuitable to work with this client group. 
  • Where an allegation or concern arises relates to the individual’s private life such as perpetration of domestic abuse; behaviours to his/her own children; or behaviour to others that may impact upon the safety of adults to whom they owe a duty of care. 
  • Where inadequate steps have been taken to protect vulnerable individuals from the impact of violence or abuse and neglect. 

In addition to other professionals that trustees/staff/volunteers may work with, there is a duty to report any concerns about colleagues or volunteers, who may be involved in abuse, harm or neglect, to a line manager/Chair of the Board or Safeguarding Lead. When an allegation is made concerning a member of staff, they should be made aware of their rights under employment legislation and internal disciplinary procedures. 

When an allegation is made concerning a volunteer, volunteering activities should cease where relevant whilst an investigation is undertaken by the relevant authority. 

If there is concern about a trustee, you should discuss this with your line manager/Chair of the Board or Safeguarding Lead who will take appropriate action (concerns relating to trustees will be discussed with the Chair of the Board. Concerns relating to the Chair of the Board, will be discussed with the Board of trustees. If the Safeguarding Lead is implicated in an allegation, you should discuss this with the Chair of the Board. The principles of the Whistleblowing policy apply in these circumstances. 

All concerns and allegations will be considered in line with the Local Safeguarding Adults Board (LSAB) relevant to managing allegations against people who work with adults at risk. The designated Safeguarding Lead will inform the local authority of all allegations that come to their attention that meet the criteria outlined by the LSAB. 

In instances where the allegation suggests that an adult is at risk of significant harm the case must be referred to the respective local authority. 

Concerns about alleged perpetrators who have additional needs 

Where the person who is alleged to have carried out the abuse has care and support needs or impaired mental capacity they should be assured of their right to the support of an Appropriate Adult if they are questioned in relation to a suspected crime by the police under the Police and Criminal Evidence Act 1984 (PACE). Victims of crime and witnesses may also require this support. A witness might need the help of a Registered Intermediary because of their age, or a learning, mental or physical disability or disorder. Registered Intermediaries are provided through the Ministry of Justice Witness Intermediary Scheme. 

Under the Mental Capacity Act, people who lack capacity and are alleged to be responsible for abuse, are entitled to the help of an Independent Mental Capacity Advocate (IMCA) to support and represent them in the enquiries that are taking place. This is separate from the decision to provide the victim of abuse with an Independent Advocate under the Care Act or an Independent Mental Health Advocate (IMHA) if detained under the Mental Health Act 1983. 

Reporting hate crime 

PNH Support is committed to supporting those who are a victim in the appropriate reporting of hate crime. Some people may feel that the incident is too minor to bother the Police with but reporting it makes a difference – to the victim, their friends/family and to their community. Underreporting is a major issue in relation to all hate crime. By reporting hate crime when it happens, it can help stop it happening to someone else. It will also help the police to better understand the level of hate crime in the local area and improve the way they respond to it. 

If you have witnessed or been a victim of hate crime, you must report it. This can be done in a number of ways: 

  • In an emergency always ring 999 
  • For non-emergencies ring 101 

If you do not want to talk to the police or fill in the reporting forms, you can still report a hate crime by contacting Crimestoppers on 0800 555111. You do not have to give your name and what you say is confidential. It is free to call. 

Information sharing 

Sharing information with other agencies e.g. the Police or local authority will be in line with General Data Protection Regulations (GDPR), the Care Act and other relevant legislation as described in the Data Protection Policy. Information sharing is vital to safeguarding and promoting the welfare of adults in need of care and support services. 

DBS disclosure (PNH Support staff and volunteers) 

It is a legal requirement to inform the Disclosure and Barring Service when: 

  • PNH Support has withdrawn permission for an individual to work with adults or would have done so had that individual not resigned, retired, been made redundant or been transferred into another position 
  • PNH Support believes the individual has engaged in activity that causes concern for the safeguarding of adults (relevant conduct) 
  • There is harm or risk of harm to adults; or 
  • An individual has received a caution or a conviction for a relevant offence. 

Key contacts 

PNH Support’s Adult Safeguarding lead: Virginia Bertelli (virginia@pnhuk.org) 

Policy owner: Safeguarding Lead (see above) 

Last review: February 2025 

Next review: February 2026