Safeguarding Policy
INTRODUCTION
Safeguarding is everybody’s business and as such the West Midlands Combined Authority
Safeguarding Policy applies to all employees working in the WMCA. It’s therefore important that
employees know who to tell, and what to do, if there is a problem. The overall responsibility for
safeguarding sits with the Chief Safeguarding Lead Officer, Head of Human Resources although
concerns are managed in the first instance via the Designated Safeguarding Leads.
1.PURPOSE
The WMCA Safeguarding Policy sets out the standards required of all WMCA employees and those
individuals, agencies, community groups and public and private sector partners that we work with, to
ensure that all children, young people and vulnerable adults are safeguarded from abuse and neglect
and where any safeguarding incidents occur, they are fully and appropriately reported and managed.
2.0 PRINCIPLES
The guidance given in the policy and procedures is based on the following principles: -
- the welfare of child / vulnerable adult is the primary concern.
- all children / vulnerable adults, whatever their age; gender; racial origin; religious belief;
disability and sexual identity have the right to protection from abuse. - it is everyone’s responsibility to report concerns, but it is the responsibility of the relevant
Local Authority Children’s Services / Vulnerable Adult Board and / or Police to determine
whether abuse has taken place (i.e., where the concern was raised/individual lives). - all incidents or allegations of suspicious poor practice or abuse will be taken seriously and
responded to appropriately.
3.0 INTERNAL POLICIES
This safeguarding policy needs to be read in conjunction with several other WMCA policies such as
Whistle Blowing Procedures etc. Links to these policies will be provided in the appendices.
4.0 External GUIDELINES
There are several external guidelines that should also be read in conjunction to the WMCA
safeguarding policy. These are: -
West Midlands Adult Safeguarding Multi Agency Guidelines
West Midlands Guidelines for Childrens
Working Together to Safeguard Children (2018)
Mental Capacity Act 2005
Care Act 2014
Childrens Act 2004
Please see the appendices for links to these documents
5.0 AIMS
The Safeguarding Policy and Procedure aims to: -
- Assist and support all employees to understand the importance of the safeguarding
vulnerable children and adults, and how to keep themselves and others safe. - Establish the importance of safer recruitment practices, linked to the vetting policy and
procedure. - Establish a training protocol for all staff for both children and adult safeguarding.
- Define a reporting protocol for safeguarding concerns.
- Ensure that the principles of the Children Act 2004, Care Act 2014 and Working Together
2018 are adhered to.
WMCA recognises the stressful and traumatic nature of safeguarding children, young people and
vulnerable adults and will provide support to the staff as appropriate.
6.0 DEFINITIONS
6.1 Safeguarding is the term used in England to mean actions to protect a person’s right to live in
safety free from abuse and neglect. All those who work for, or with, the WMCA, have a duty, through
the work they do, to protect children, young people and adults who are vulnerable because of age,
disability, mental impairment or any other factors which heighten their risk of abuse, harm or neglect.
6.2 A Child is a person under the age of 18 years. Young people aged 16 or 17 who are living
independently of family or care givers are still defined as “children “and have a statutory right to
protection from abuse harm or neglect. The WMCA approach to safeguarding children follows the
guidance set out in “Working Together to Safeguard Children (2018)
6.3 A Vulnerable Adult is defined in the Care Act 2014 as someone who is in need or at risk as a result
of a physical and/or mental disability or because of impairment due to age or illness. This also applies
to an adult who is unable to take care of themselves, or who is unable to prevent themselves from
harm or exploitation
6.4 If an adult lacks the mental capacity to care for themselves, there are legal safeguards under the
Mental Capacity Act for decisions to be taken on their behalf to keep them safe, but there are strict
legal criteria which must be met before decisions which affect the way an adult life, without their
consent.
6.5 There are different types of abuse and neglect, and these can take many different forms. They
include acts of commission such as:
- Financial abuse
- Sexual Abuse and sexual exploitation
- Psychological and emotional abuse
- Organisational or institutional abuse
- Modern slavery and forced marriage
- Discriminatory abuse, bullying, and name calling which the aim of harming a person’s mental
well-being. - Domestic abuse including coercive control
There are acts of omission such as:
- Neglect and lack of care
- Emotional abuse
- Self-neglect
7. PREVENTING ABUSE AND NEGLECT
All those who work for, or with, the WMCA have a responsibility:
- to understand what is meant by safeguarding
- to know how to report any incident of concern to their Designated Safeguarding Leads or
Points of Contacts - to ensure that any services or resources which are commissioned by the WMCA have proper,
well-managed safeguarding procedures and policies in place, particularly where they involve
children and young people and/or adults who may be vulnerable or at risk of abuse, neglect
or harm of exploitation - to ensure they receive regular safeguarding training, appropriate to their roles and
responsibilities at work and that people who they manage, also have access to safeguarding
training - Recruit staff in accordance with Disclosure and Barring Service (DBS) Regulations, where
appropriate and ensure all organisations and agencies with whom the WMCA works also does
so and ensure all contractors and sub-contractors comply with this requirement
8. REPORTING A SAFEGUARDING CONCERN
Everyone who works for, or with, the WMCA has a responsibility under the law to report any concerns
about the possible abuse, harm or neglect of a child, young person or vulnerable adult. Anyone
worried about concerns of abuse must report them, so they can be investigated and dealt with. This
may include a statutory safeguarding referral or reporting immediate danger to the relevant agency
or emergency service. All staff have a duty to report concerns regarding colleagues who do not adhere
to this policy and should follow the Whistleblowing policy to raise these concerns. Please see the
safeguarding procedures on how to report a concern.
9. MANAGING A SAFEGUARDING CONCERN IN THE WMCA/ ROLES AND RESPONSIBILITIES
Our safeguarding Procedure details how we must deal with safeguarding concerns. The procedure
adopts 2 approaches to ensure we meet the requirements and aims of the policy. These are:
9.1 Partnership working
The WMCA will work as required in partnership with all the local safeguarding partnerships for
children and safeguarding Adult Boards throughout the West Midlands. The West Midlands Children’s
Safeguarding Partnership and the West Midlands Adult Safeguarding Boards bring together all the
multiagency arrangements in each local authority area in the West Midlands and provide the overarching procedures that govern how every agency, responsible for investigating and responding to
children and adult safeguarding, will manage their procedures and practices. Each local authority in
the West Midlands manage safeguarding investigations involving people who live in their area.
9.2 Effective staff management
The WMCA will ensure that all individuals with whom we work are safeguarded and protected from
abuse and neglect through vigilant staff recruitment, supervision and our commissioning and
procurement procedures. We will recruit in accordance with the Disclosure and Barring Service (DBS)
regulations, where appropriate, to achieve safer services for our citizens, communities, and
employees. We will ensure that those who collaborate with us do the same.
We will act quickly to remove any risk, or perceived risk, when employees are alleged to be suspected
of abuse or neglect within, or without, the workplace. We will conduct thorough investigations and
follow our disciplinary and other relevant processes, making referrals to relevant agencies such as the
Police and/or local authority, DBS and other body as required such as a professional regulator.
We will maintain a secure system where information relation to allegations of safeguarding is
confidentially secured and maintained in line with our GDPR Policy.
We will ensure there are clear internal procedures for employees and those agencies from whom we
commission services, or work with, in partnership, to record and manage safeguarding concerns and
incidents and encourage safe working practices and procedures in all our work
10. ROLES AND RESPONSIBILITIES
All employees and those with whom we work, have responsibility for safeguarding. The overall
accountability within the WMCA is the Chief Safeguarding Lead Officer who is Head of Human
Resources. Here are the various roles: -
10.1 WMCA will: -
accept the responsibility to implement procedures to provide a duty of care for children/
vulnerable adults, safeguard their well-being and protect them from abuse.
- require employees to adopt and abide by WMCA’s Code of Conduct; Code of Behaviour for
Employees; and the Safeguarding Policy and Procedures. - ensure employees feel confident in reporting any safeguarding issues.
- respond to any allegations appropriately and implement the appropriate disciplinary and
appeals procedures where necessary.
10.2 Appointed Officers
WMCA will ensure there are appointed officers within the organisation with a specific responsibility
for safeguarding. The responsible officers for safeguarding within the WMCA are as follows:
10.3 Chief Safeguarding Lead
The Chief Safeguarding Lead Officer for the WMCA is the Head of Human Resources, who has the lead
responsibility in safeguarding and protecting children, young people and vulnerable adults.
10.4 The Designated Safeguarding Leads (DSLs)
- WMCA has appointed three Designated Safeguarding Leads (DSLs) who will deputise for the
Chief Safeguarding Lead Officer when necessary. The contact details for the DSLs are detailed
in the associated Safeguarding Procedures. - The DSLs will be responsible for Chairing the Safeguarding Steering Group meeting which will
take place quarterly and for taking reports to the Corporate Management Team and the
Senior Management Team when required. - If there are any concerns that are raised that require the Chief Safeguarding Lead Officer to
be notified, the DSLs will do so, or in the absence of the Chief Safeguarding Lead Officer, the
DSLs will take the lead.
10.5 Points of Contacts
- The organisation has in place Points of Contacts (POCs) who will be available across the
organisation and will function as a point of contact to raise safeguarding issues. The contact
details for the POCs are detailed in the associated Safeguarding Procedures. - When a WMCA employee/volunteer/contractor/consultant has concern/s about a young
person or vulnerable adult they can contact the Points of Contact or HR. - The Points of Contact will notify HR that a safeguarding concern has been raised and HR will
call a meeting of the Safeguarding Panel members to meet to decide on how to record and
address the issues raised.
10.6 Safeguarding Panel Meeting
- The Safeguarding Panel will be comprised of up to three (but no less than two) available Points
of Contacts and a member of the HR team where necessary. The Safeguarding Panel Meeting
will be convened within 24 hours of a safeguarding concern being raised unless the issue
raised requires immediate action. - If the safeguarding concern involves an employee, an HR representative will need to be
present at the Safeguarding Panel meeting. If the issue is not related to an employee, then HR
representation is not required, and the Safeguarding Panel can comprise of up to three (but
no less than two) available points of contacts. - All information in respect of a young person or vulnerable adult will be dealt with in a strictly
confidential manner. A written record will be made by the Safeguarding Panel of what
information has been shared with whom, what, when, where, and how the matter has been
dealt with/ what action has been taken. - All records of the child, young person or vulnerable adult will be stored securely in a central
place separate from any other records and individual files will be kept for each child, young
person or vulnerable adult. Any files will be held and stored as required to comply with the
Data Protection Act 2018. - Access to these records will be restricted to the DSLs, HR and the Safeguarding Panel. Any
request/s for information made to the WMCA shall be referred to the responsible Authority
notified being either the Local Authority’s Social Services or the relevant Police force. - Any information which is held on a child, young person or vulnerable adult which will put the
child, young person or vulnerable adult at risk of significant harm should be kept strictly
confidential and should not be disclosed to a parent or guardian.
The WMCA reviews its policies and procedures regularly, but these are updated responsively as
required to cover any additional relevant areas of service provision and/or delivery undertaken by the
WMCA.
10. 7 Below are the responsibilities of various staffing groups: -
WMCA employees are responsible for:
- Always acting on safeguarding concerns. It is not expected that staff will function as child
protection workers or that they will be trained to intervene in cases of suspected abuse. All
staff, however, must always act on any suspected or potential safeguarding concerns. Doing
nothing is not an option. - Undertaking the e-learning modules for children and adult safeguarding. Other forms of
training may be undertaken based on roles and responsibilities. - Ensure safeguarding responsibilities are taken seriously and being initiative-taking in
responding to any safeguarding concerns and reporting as necessary. - Following the correct reporting procedures as always outlined in the associated Safeguarding
procedures.
Line managers are responsible for:
- Ensuring that they understand the Safeguarding Policy so that concerns are acted upon and
not ignored (this includes completion of the e-learning module and other training as required). - Supporting staff with any safeguarding concerns and ensuring the appropriate advice is sought
from HR. - Ensuring staff follow the correct reporting procedures as outlined in the associated
Safeguarding procedures. - Adopting safe recruitment practices in line with both this policy and the vetting policy.
HR is responsible for:
- Providing support, advice and guidance to line managers and employees on the
implementation of the policy. - Ensuring that the safeguarding Panel members are called together at the earliest availability
to deal with any safeguarding concerns and will be present on the Safeguarding Panel meeting
if a staff member is involved. - Providing line managers with accurate and timely advice.
- Ensuring DBS checks are renewed when required and that the relevant Safeguarding Officers
are DBS checked namely: - Chief Safeguarding Lead Officer and Designated Safeguarding Lead
Officers. As the Chief Safeguarding Lead Officer is being DBS checked then he will be supported
by one of the DSLs who is DBS checked. - When a safeguarding concern is investigated which involves a staff member, HR will need to
decide if a disciplinary investigation is required; whether Children’s or Adults Services needs
to be involved or a police investigation is required if there is a possibility of a criminal
offence. - HR will contact the relevant Local Authority or the Police to pass on the relevant information as required or when requested.
OD are responsible for:
- Ensuring that e-learning is provided to all staff and other training relevant to their role and
responsibilities. - Chief Safeguarding Officer, DSLs and PoC are all provided with the relevant safeguarding
training for their role.
Recruitment is responsible for:
- Scrutinising applicants, verifying identity and academic or vocational qualifications, obtaining
professional and character references, and checking previous employment history. It also
includes undertaking interviews and appropriate checks through the Disclosure and Barring
Service (DBS) where staff may be working with children, young people and vulnerable adults. - All recruitment materials will include reference to the WMCA’s commitment to safeguarding
and promoting the wellbeing of young people and vulnerable adults. - Under the Safeguarding Vulnerable Groups Act 2006, employers and employment businesses
and agencies are under a duty to pass information about certain individuals to the DBS. The
duty to refer information arises where an employee has resigned or been dismissed, or would
or could have been dismissed, because he or she has harmed, or may harm, a child, young
person or vulnerable adult. The duty applies only in relation to individuals conducting
regulated activities.
Legal and Procurement are responsible for:
- To ensure that all service providers who work directly with vulnerable adults or children on
our behalf have safeguarding policies available and published which are at least as robust as
the WMCA's, and a copy of this is received ahead of contractual awards being made. - Companies also need to provide their GDPR policy, Complaints Procedures and DBS certificate
numbers of staff engaged in the projects.
11.1 Governance and Accountability
11.1 The effective governance and accountability for this policy is assured through the following
assurance measures:
1st line of assurance – day to day operations; reporting to Line Managers or Points of Contacts or HR
any concerns. HR will call the Safeguarding Panel together for an emergency meeting.
2nd line of assurance – Chief Safeguarding Lead Officer and Designated Safeguarding Leads will be
responsible to ensure that Quarterly meetings take place to review safeguarding training and audits
of safeguarding concern that are being raised by the organisation.
3rd line of Assurance- Monitoring and ownership of the policy by the Corporate Management Team
and Senior leadership Team who will receive reports and audits from the Chief Safeguarding Lead
Officer.
12 Data Protection and Privacy
12.1 We will share information for the purposes of safeguarding and comply with our statutory duty
to share information under the duty of candour.
12.2 We will manage data in accordance with the GDPR Policy
12.3 We will ensure that we keep young people's data and information including the safeguarding
concerns in a safe and this is only shared on a need to know basis.
13.0 Equality and Diversity
An Equality Impact Assessment was conducted on this policy with risks mitigated via the procedure,
training and monitoring work.
14. Measures and Monitoring
We will monitor any safeguarding concerns within the WMCA or with its partners or those from whom
we commission services. If there are concerns the Designated Safeguarding Leads will support with
this process.
This Policy and the accompanying procedures and training plan will be reviewed every 3 years or
within that timescale if legislation and/or guidance changes or if, through other operational activity
within the WMCA or with those who we work with, give rise to additional improvements in Policy,
Procedures and/or practices.
15. Safeguarding Training
E-learning
All WMCA staff will have access to an e-learning module which provides a basic awareness of
safeguarding for children, young people and vulnerable adults. The training will support employees
to:
- analyse their own practice against established good practice, and ensure their practice
reduces the likelihood of allegations against them. - recognise their responsibilities and report any concerns about suspected poor practice or
possible abuse or exploitation. - respond appropriately to concerns expressed by a child/vulnerable adult; and
- work safely and effectively with children, young people and vulnerable adults.
Completion of the e-learning training will be mandatory and will be recorded and monitored.
The e-learning module will be reviewed every 2 years; however, if significant changes are made within
National Safeguarding Policy during this time, all staff will be required to re-take the e-learning module
before then.
As part of the eLearning module, employees will be required to take a quiz to check their learning. If
they fail the quiz, then they will have to retake the eLearning module.
Face to face / Virtual training
Face to face/virtual safeguarding training will also be available for staff in Chief Safeguarding Officer,
HR/ OD, Designated Safeguarding Leads and Line Managers.
Appendices
Internal Policies
Safeguarding Procedures
Whistle Blowing
https://intranet.wmca.org.uk/file/1319/download/Whistleblowing%2520Policy.pdf
Modern slavery policy and Modern Slavery Statement
https://intranet.wmca.org.uk/section/resource-hub/hrodedi/policies-procedures-andguidance/corporate-responsibilities/modern-slavery-policy
DBS application
https://www.gov.uk/government/publications/disclosure-application-process-for-volunteers
Well-being Guidance and Promoting employee well-being guidance
https://intranet.wmca.org.uk/section/resource-hub/wellbeing/wellbeing-strategy
https://intranet.wmca.org.uk/section/resource-hub/wellbeing/promoting-employee-wellbeingguidance
Equality Diversity and Inclusion Impact Assessment
https://intranet.wmca.org.uk/section/resource-hub/equality-diversity-and-inclusion/equalityimpact-assessments
GDPR Policy https://intranet.wmca.org.uk/section/resource-hub/protective-security-dataprotection/data-protection
WMCA Prevent Policy
External Guidelines
West Midlands Adult Safeguarding Multi-Agency Guidelines
View here.
Working Together to Safeguard Children (2018)
View here.
West Midlands Procedures for Childrens
View here.
Care Act 2014
View here.
Mental Capacity Act 2005
View here.
The Safeguarding Vulnerable Groups Act 2006
View here.
Definition of terms
“employee” is used to include all WMCA employees, full or part-time, volunteers, and anyone working
on a paid or unpaid basis on behalf of WMCA.
Chief Safeguarding Officer
Laurence Adams- Laurence.Adams@wmca.org.uk
List of Designated Safeguarding Lead Officers
Jayne Middleton - Jayne.Middleton@wmca.org.uk
Claire Dhami- Dhami-Claire.Dhami@wmca.org.uk
List of Points of Contacts
Laurence Adams- Laurence.Adams@wmca.org.uk
Jayne Middleton - Jayne.Middleton@wmca.org.uk
Claire Dhami- Dhami-Claire.Dhami@wmca.org.uk
Tony O'Callaghan - Tony.OCallaghan@wmca.org.uk
Jacqui Miller - Jacqui.Miller@tfwm.org.uk
Lucy Gosling - Lucy.Gosling@wmca.org.uk
Lois Stewart- Lois.Stewart@wmca.org.uk
Linda Francis- Linda. Francis@wmca.org.uk
HR Contacts- HR Business Partners
Samantha Keenan – Samantha.Keenan@wmca.org.uk
Jessica Hall - Jessica.Hall@wmca.org.uk
Organisational Development Contacts
Lois Stewart- Organisational Development and Engagement Manager- Lois.Stewart@wmca.org.uk
Linda Francis- Organisational Development and Engagement Partner- Linda.Francis@wmca.org.uk
External Contacts
In an emergency always dial 999
West Midlands Police on 101 (24-hour non-emergency number).
Child line- 0800 1111
Contact the NSPCC on 0808 800 5000 (free service, lines open 24 hours a day).
Action on Elder Abuse Helpline 080 8808 8141
Age UK Advice Line – 0800 678 1602
Stop Hate UK – 0800 138 1625 (for victims of hate crime)
Ann Craft Trust – 0115 951 5400 (for adults with learning disabilities)
Black Country Women’s Aid – 0121 552 6448 (24hr helpline for victims of domestic abuse within the Black County, including Walsall)
Care Quality Commission – 03000 616161
Voice UK – 0808 802 8686 (for people with a learning disability or other vulnerable people who have
experienced crime or abuse)
Birmingham City Council
Safeguarding Adults
Email: CSAdultSocialCare@birmingham.gov.uk
Telephone: 0121 303 1234
Birmingham Safeguarding Adults Board: BSABsupportteam@birmingham.gov.uk
Safeguarding Childrens
Children’s Advice and Support Service -0121303888
Emergency Duty Team
01216754806
Sandwell Council
Sandwell Safeguarding Team emergency contact for Adults and Children on 0121 569 3100
Sandwell Adults Board 0121 569 5790
Sandwell’s Children’s Board 0121 569 4770
Dudley Council
For children-0300 555 0050
For adults 0300 555 0055
Out of office hours
0300 555 8574 or in an emergency call 999
Walsall Council
Walsall Adults
Call 0300 555 2922 Office hours and out of hours emergencies
Adults Board contact InitialIntake@walsall.gov.uk
Walsall Childrens
Walsall Children’s Services - 01922 658170
Out of Office hours: 0300 555 2922 or 0300 555 2836
Childrens Board: email wscb@walsall.gov.uk or call 01922 659520