1.1 Adult safeguarding is the process of protecting vulnerable adults from neglect, abuse or exploitation. The Care Act 2014 introduced this as a statutory duty for local authorities, with three main strands:
- A duty for a local authority to carry out enquiries (or cause others to) where it suspects an adult is at risk of abuse or neglect.
- A requirement for all areas to establish a Safeguarding Adults Board (SAB)
- SABs to carry out safeguarding adults reviews (SARs)
- The ability for SABs to require information sharing from other partners to support SARs or other functions.
1.2 The Act sets out clear expectations of partner organisations in contact with vulnerable adults who are or may be at risk of abuse or neglect. This includes housing organisations and staff.
1.3 This policy outlines MCC Housing Services’ role within the safeguarding framework set out in legislation and guidance and overseen in Manchester by the Manchester Safeguarding Partnership (MSP).
1.4 Adult safeguarding is built of six key principles (balancing safety from/prevention of harm with an adults capacity to choose and control their behaviour)
- empowerment – supporting adults to take decisions and informed consent
- prevention – taking action before harm occurs
- proportionality – taking the least intrusive appropriate response
- protection – support and representation
- partnership – services working with communities
- accountability – and transparency
1.5 MCC Housing Services will actively work to safeguard those adults in need who are our tenants or who live in our properties, and will adopt a multi-agency approach, working openly and proactively with other agencies as necessary to share information so that vulnerable adults are protected from abuse, exploitation and neglect.
1.6 Effective safeguarding is not something we see as an ‘’add-on’’, but rather is embedded in our ways of working, especially in relation to staff who have contact with tenants. It can be a complex and sensitive issue to address, so it is important that there are clear mechanisms for staff to raise their concerns, robust recording and follow-up processes and support for staff.
1.7 MCC Housing Services recognise that some tenants due to their vulnerabilities struggle to properly maintain their tenancies. This may result in untidy gardens, unkempt properties or hoarding. MCC Housing Services will take all reasonable steps to secure for these people appropriate support to manage their tenancies. MCC Housing Services has a more detailed policy and procedure on hoarding and self-neglect, which should be read in conjunction with our main Safeguarding Adults Policy.
1.8 We have an internal procedure for dealing with safeguarding matters which is provided to employees. All relevant referral forms are included within the procedure.
1.9 MCC Housing Services will ensure that all staff who encounter children and vulnerable adults as part of their day-to-day role are vetted via the Disclosure and Barring Service (DBS). All certificates will be reviewed every 3 years.
1.10 We will refer any member of staff (after appropriate investigation) to the DBS where they have:
- Been cautioned or convicted for a relevant offence
- Engaged in relevant conduct in relation to children and/or vulnerable adults (i.e. action or inaction that has harmed a child or vulnerable adult or put them at risk of harm)
1.11 MCC Housing Services recognises the importance of confidentiality and will ensure that any information shared regarding a vulnerable adult will be done so in line with the Data Protection Act 2018, the Human Rights Act 1998 and General Data Protection Regulations (GDPR) 2018, although this will not be at the expense of leaving a vulnerable person at risk. MCC Housing Services has a dedicated Data Protection Policy, and will ensure that all staff are aware of and adhere to the policy in relation to safeguarding adults.
1.12 We will ensure the safeguarding adults policy is available publicly to tenants and the wider community. The latest version of the policy will be available on the website, and hard copies made available upon request if necessary. We include advice about our safeguarding process in our tenant handbook and on our website.
2. Principles of Policy
2.1 All staff who encounter adults who fit the criteria in their everyday work have a responsibility to:
- Safeguard and promote the welfare of vulnerable people
- Be able to recognise situations where adults with care and support needs are being abused or exploited by others or are suffering from neglect
- Be aware of indicators of domestic violence and harassment
- Recognise signs indicating that a tenant is unable to properly manage their tenancy due care or support needs.
2.2 Staff who deal directly with tenants will receive training and guidance on working with vulnerable people. MCC Housing Services will ensure that appropriate information and advice is also provided to our repairs contractors and will ensure that our retirement scheme managers receive specific training in relation to older people.
2.3 We will ensure that all staff are aware of the safeguarding adults procedure and understand their individual responsibilities in their role and as a MCC Housing Services employee in relation to safeguarding adults. We will ensure that all staff are effectively following the procedure whenever a potential safeguarding adult concern is identified.
2.4 MCC Housing Services understands the importance of partnership working. Where suspected abuse, exploitation or neglect is identified, we will ensure that staff liaise with the appropriate agency or agencies to ensure that the most appropriate form of support is sought. MCC Housing Services will assist with this wherever possible, by providing support and advice where appropriate, attending multi-agency meetings as and when required and working closely with all agencies to support vulnerable adults.
2.5 Where MCC Housing Services identify issues with regards to tenancy management, appropriate support will be sought outside agencies and staff will work closely with them and the tenant in attempting to address the situation.
2.6 We will make sure that we take the views of vulnerable adults into account and balance these against their rights and need to be safeguarded and our need to ensure that tenancies are appropriately managed. This may include in some instances taking legal action to ensure that tenancy conditions are being complied with and other tenants’ rights (including to quiet enjoyment of their homes) are being protected.
2.7 In safeguarding vulnerable adults, MCC Housing Services has regard to relevant guidance issued by the Government and/or Manchester Safeguarding Partnership. MCC Housing Services will make sure that staff are sufficiently well-supported to implement the policy, and will consider learning from reviews and identify other opportunities to improve the way things are done. MCC Housing Services will make sure that learning is incorporated into our day-to-day practices.
3.1 Overall responsibility for the policy is with the Director of Neighbourhood Services. A Head of Neighbourhood Services has lead responsibility for safeguarding issues (including linking into and supporting multi-agency partnership and problem-solving arrangements and making sure that learning from reviews is incorporated into our day-to-day practices). The Tenancy Support Team Manager is the operational safeguarding lead.
3.2 The relevant Neighbourhood Housing Manager or Tenancy Support Manager (depending on the status of the case) has day-to-day responsibility for overseeing individual cases and making sure that these are regularly reviewed, appropriately progressed and escalated within MCC Housing Services or with partner agencies where necessary.
3.3 Details of safeguarding activity is included in the Risk Register Report presented at each meeting of the Audit Committee. These minutes are provided to the MCC Housing Services Board for approval. There is a Board Safeguarding Champion, appointed annually.
3.4 MCC Housing Services safeguarding policy and procedure are subject to an annual internal audit to ensure that practices are up to date and fit for purpose and that we are complying with them.
3.5 Each year the Manchester Partnership Board requires MCC Housing Services to carry out a self-assessment on its safeguarding practices to monitor their effectiveness and report back to the Board. The Head of Neighbourhood Services with lead responsibility for safeguarding at MCC Housing Services completes this as well as attending peer review sessions to ensure that our policy and procedures remain relevant and up to date and to improve the way we do things.
4. Allegations against staff
4.1 MCC Housing Services have clear procedures in place for dealing with allegations made against members of staff where concerns are raised regarding safeguarding adults. We will ensure a full investigation is carried out into such allegations, including the provision of precautionary suspension of members of staff if appropriate.
4.2 We have a zero-tolerance policy in relation to all forms of abuse, and appropriate action, including action under the Disciplinary Policy, will be taken against any member of staff found to have been responsible for abuse, neglect or exploitative behaviour.
4.3 MCC Housing Services will investigate malicious or unfounded allegations against members of staff, including close liaison with Manchester Safeguarding Partnership. Consideration will be given to a change of duties or location to protect a member of staff from further allegations. This will involve close communication with the member of staff concerned, their line manager as well as Human Resources.
5.1 The duty to safeguarding adults is underpinned in legislation. Key legislation relating to safeguarding adults includes, but is not limited to:
- Care Act 2014
- Care and Support Statutory Guidance 2016
- Human Rights Act 1998
- Mental Capacity Act 2005
- Safeguarding Vulnerable People Act 2006
- Modern Slavery Act 2015
- Counter Terrorism & Security Act 2015
- Data Protection Act 2018 (as amended)
- General Data Protection Regulations 2018
- Public Disclosures Act 1998
5.1 To ensure MCC Housing Services complies with current legislation and practice relating to safeguarding adults, this policy is linked to the Manchester Safeguarding Partnership (www.manchestersafeguardingpartnership.co.uk).
6. Linked documents
6.1 Documents linked to this policy include:
- Safeguarding adults’ procedure
- Data protection policy
- Disciplinary policy
- ASB policy & procedure
- Cuckooing policy
- Hoarding & self-neglect policy & procedure
- Domestic abuse policy & procedure
- Hate crime policy
7. Review Process
7.1 This policy will be reviewed every two years along with the accompanying procedure, or in line with any relevant legislative changes, revised guidance or learning from reviews if sooner.
Seven March 2021
Claire Tyrrell, Head of Neighbourhood Services
Sam Perrett, Tenancy Support Manager & Safeguarding Lead
Mike Stevens, Director of Neighbourhood Services