1.0 Introduction
1.1 Everyone has the right to live free from violence, abuse, neglect and exploitation. This right is underpinned by the Human Rights Act 1998 and the statutory safeguarding duties set out in the Care Act 2014 and its statutory guidance.
1.2 Adult safeguarding is the means by which Lighthouse Pathways works to prevent harm, recognise risk and respond effectively to concerns about abuse or neglect. Safeguarding applies to the prevention of abuse, early detection, protection, and support for adults following any intervention. It must be person-centred, proportionate and outcome-focused.
1.3 For the purposes of this policy, the term "safeguarding" is used (in Scotland the term "adult protection" may be used).
1.4 Safeguarding duties apply where an adult:
- has care and support needs (whether or not a local authority is meeting those needs); and
- is experiencing, or at risk of, abuse or neglect; and
- because of those needs, is unable to protect themselves from abuse or neglect.
1.5 CQC expects providers to operate effective safeguarding systems, including:
- clear procedures and training to safeguard adults using services
- staff competence aligned to role requirements
- awareness and application of the Mental Capacity Act 2005 and consent
- appropriate referrals to Local Authority Safeguarding Adults teams
- learning from safeguarding incidents
- cooperation with safeguarding enquiries
- statutory notifications to CQC where required (in line with regulations)
1.6 The Care Act 2014 emphasises wellbeing, including:
- personal dignity and respect
- physical and mental health and emotional wellbeing
- protection from abuse and neglect
- individual control over day-to-day life and care
- participation in work, education and community life
- social and economic wellbeing
- domestic, family and personal relationships
- suitability of living accommodation
- contribution to society
1.7 Safeguarding is not a linear, one-size-fits-all process. It is a series of proportionate steps and decisions made with the adult (and/or their representative) and partner agencies.
1.8 The aims of adult safeguarding are to:
- stop abuse or neglect wherever possible
- reduce risk through preventative strategies
- support adults to make choices and maintain control
- promote wellbeing and recovery after harm
- provide accessible information to help adults recognise abuse and seek help
2.0 Purpose
2.1 Lighthouse Pathways will work with local statutory services (Adult Social Care, police, NHS services where relevant) to protect adults at risk and respond effectively to concerns, complaints, incidents or disclosures indicating potential abuse or neglect.
2.2 Lighthouse Pathways is committed to prevention and to having robust procedures to identify, record, escalate and refer concerns appropriately.
2.3 Lighthouse Pathways follows the six safeguarding principles in the Care Act statutory guidance:
- Empowerment - supporting individuals to make informed choices and give consent
- Prevention - taking action before harm occurs
- Proportionality - least intrusive response appropriate to the risk
- Protection - support and representation for those in greatest need
- Partnership - working with local services and communities
- Accountability - transparency and clear responsibilities
2.4 Lighthouse Pathways will act within legal frameworks. Unlawful behaviour is not condoned. Concerns about conduct will be addressed through safeguarding processes, disciplinary pathways and referral to professional regulators where appropriate.
2.5 The primary concern in any safeguarding situation is the safety and wellbeing of the adult. Adults have the right to make choices, including choices involving risk, provided they have capacity and are not subject to coercion or undue influence.
2.6 Lighthouse Pathways recognises that some adults may require independent support (advocacy) to participate in safeguarding processes. Where an adult has substantial difficulty and has no appropriate person to support them, the local authority may arrange an independent advocate.
2.7 Safeguarding practice must be culturally sensitive and inclusive. Where communication needs exist (language, neurodiversity, disability), Lighthouse Pathways will use appropriate interpreters and reasonable adjustments.
3.0 Responsibilities
3.1 Overall accountability for safeguarding arrangements sits with the CEO, supported by the Head of Operations (HOO) and the Clinical Lead.
3.2 Lighthouse Pathways will appoint a Designated Safeguarding Lead (DSL - Adults) and a Deputy DSL, appropriately trained (typically Level 3 for the DSL, with role-appropriate training for deputies).
3.3 Lighthouse Pathways is responsible for ensuring:
- safe recruitment and vetting (including DBS checks as appropriate)
- role-appropriate safeguarding training
- systems for reporting, recording, reviewing and learning
- effective liaison with local safeguarding services
- appropriate statutory notifications and regulator referrals where required
3.4 All staff and clinicians must:
- maintain professional boundaries
- act immediately on safeguarding concerns
- record and escalate concerns according to this policy
- never assume someone else will report a concern
- follow whistleblowing routes if concerns are not acted upon
3.5 Professional boundaries: Personal relationships with service users are not acceptable. Boundary blurring increases risk and must be escalated promptly.
4.0 Prevention
4.1 Lighthouse Pathways uses safer recruitment and vetting, including DBS checks (where eligible/required) and verification of identity, professional registration, right to work, and references.
4.2 Where a concern relates to a staff member/clinician, Lighthouse Pathways will consider:
- referral to the DBS (where criteria are met)
- referral to professional regulators (NMC, GMC, HCPC)
- police referral where a crime may have occurred
- CQC notification where required
4.3 Lighthouse Pathways recognises safeguarding is multi-agency. Effective safeguarding requires timely information sharing, coordination and engagement with local safeguarding teams and police as appropriate.
4.4 Interventions must be proportionate and least restrictive, supporting independence and wellbeing.
4.5 Information sharing must be lawful, necessary, proportionate and secure, in line with GDPR and the Data Protection Act 2018.
5.0 Training
5.1 All staff and clinicians must complete safeguarding adults training aligned to their role and maintain in-date evidence. This is checked at onboarding, at annual compliance review, and as part of contractor/privileges review.
5.2 The Designated Safeguarding Lead must have additional training appropriate to the role (normally Level 3, plus updates).
5.3 Clinicians must also maintain up-to-date Mental Capacity Act training and demonstrate application in practice (documentation in clinical notes).
6.0 Recognition of Abuse
6.1 Abuse can occur in any setting and can be perpetrated by anyone, including family, carers, professionals, other service users, or strangers. Abuse may be intentional or unintentional and may arise from neglect, poor practice, coercion, exploitation or lack of knowledge.
6.2 In remote services, indicators may appear through: disclosures during video/phone consultations, reports via email/phone to admin staff, concerning third-party communications, risk signals in mental health history, or coercive control (someone present off-camera).
6.3 Some abuse constitutes a criminal offence. Where crime is suspected, police must be consulted and may lead the enquiry.
6.4 Adults at risk may not recognise abuse or may fear repercussions. Staff must respond with sensitivity, avoid judgement, and provide clear information about options and support.
7.0 Types of Abuse
7.1 Categories in Care Act statutory guidance include: physical abuse, domestic abuse (including coercive control), sexual abuse, psychological/emotional abuse, financial/material abuse, modern slavery, discriminatory abuse, organisational abuse, neglect and acts of omission, and self-neglect (including hoarding).
7.2 Additional considerations include: forced marriage and "honour-based" violence, sexual exploitation (including online), multiple forms of abuse occurring simultaneously, and technology-facilitated abuse.
8.0 Internal Reporting
8.1 Any suspicion, allegation or disclosure of abuse or neglect must be reported immediately to the Designated Safeguarding Lead, and recorded as soon as possible and no later than 24 hours.
8.2 All safeguarding concerns must be: recorded in the patient record (EHR), recorded in the safeguarding log/register, and linked to an incident report where applicable.
8.3 Staff must note whether the concern appears current/ongoing or historical.
8.4 Historical abuse disclosures must still be recorded and escalated to ensure risk is not continuing.
9.0 Disclosure, Discovery or Allegations of Abuse
9.1 Immediate safety first. If there is immediate danger: call emergency services (999), follow the Patient Caller Emergency Policy, and escalate to DSL immediately.
9.2 If abuse is disclosed, the person receiving the disclosure must: listen calmly, avoid leading questions or investigating, explain next steps, and document the disclosure factually.
9.3 Information to record includes: your name/role, patient details, what was disclosed (facts only), any immediate risks, and third parties involved.
9.4 The DSL will decide whether to refer to the Local Authority Safeguarding Adults team, police, or other services.
9.5 Decisions not to refer must be documented with rationale.
9.6 Where a referral is made, the DSL will record: date/time, receiving authority, person spoken to, and agreed next steps.
9.7 Lighthouse Pathways will cooperate with safeguarding enquiries and provide timely information within legal boundaries.
10.0 Consent to Share Information
10.1 Lighthouse Pathways follows the seven golden rules for information sharing: be open and honest, seek advice if unsure, seek consent where possible, and share necessary, proportionate information.
10.2 If the adult has capacity, consent should be sought. However, information may be shared without consent if others are at risk, to prevent a crime, or if a serious crime has occurred.
10.3 Where an adult lacks capacity, actions must be taken in their best interests and recorded clearly.
10.4 Safeguarding referrals may also require CQC statutory notifications.
11.0 Allegations Against a Person in a Position of Trust (PiPoT)
11.1 Staff and clinicians are in positions of trust. Allegations must be treated seriously and responded to promptly.
11.2 Any allegation regarding a staff member must be escalated immediately to the DSL, the HOO/CEO, and the Clinical Lead.
11.3 Where thresholds are met, Lighthouse Pathways will refer to the Local Authority, police, professional regulator, and DBS.
11.4 The organisation will consider interim safety measures, such as suspension, pending investigation.
11.5 Internal management actions (training, disciplinary action) will be considered even if external referral thresholds are not met.
12.0 References and Relevant Legislation and Guidance
Legislation
- Care Act 2014: Link
- Care and Support Statutory Guidance: Link
- Human Rights Act 1998: Link
- Mental Capacity Act 2005: Link
- Data Protection Act 2018: Link
CQC and professional guidance
Appendix A - Safeguarding Procedure for Triage / Admin
A1. Recognise triggers: Disclosure of abuse, coercive control, financial exploitation, or severe self-neglect.
A2. Immediate actions: Call 999 if in danger, stay calm, take factual notes, and escalate to DSL within 24 hours.
A3. What not to do: Do not investigate, do not ask leading questions, and do not contact the alleged perpetrator.
Appendix B - Safeguarding Procedure for Clinicians
B1. During consultation: Assess immediate risk, consider capacity and consent, and document facts and decisions.
B2. Referral decision: Refer to Local Authority if criteria met; contact police if crime is suspected.
Appendix C - Decision Support (When to Refer / Escalate)
Refer to local authority when: Adult meets Care Act criteria, there is serious risk/exploitation, or a pattern of coercion.
Contact police when: Immediate danger exists, or a serious crime is suspected (trafficking, sexual assault, severe fraud).
Appendix D - Mental Capacity Act (Summary)
Principles: Presume capacity, support decision-making, best interests, and least restrictive option.
Capacity test: Does the person understand, retain, use/weigh, and communicate their decision?
