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Protection of Vulnerable Adults Policy

Based on OMBC safeguarding board policy

Version 1 13/4/2025

1.     Aim and scope of this policy
2.     Definitions
3.     What is abuse and examples of Abuse
4.    Examples of Abuse
5.     People who might abuse
6.     Responsibilities of the organisation
7.     Responsibilities of employees and volunteers
8.     Support for those who report abuse
9.     Rights of vulnerable adults
10.   Organisational procedures
11.       Determining action to be taken
12.       Practice guide
13.       Key contacts for referral or reporting of concerns
14.       Information required for referral
15.       Do’s and don’ts when dealing with situations where abuse may have occurred.
16.       Appendix: Identification of abuse

Aim and scope of this policy The aim of this policy is to raise awareness of adult protection issues among paid staff and volunteers and to provide a clear framework for action when abuse is suspected. It is aimed at protecting the vulnerable adult and the worker, recognising the risks involved in lone working.
The policy covers all staff and areas of work and forms part of the Terms and Conditions of Employment and applies to all employees, trustees and volunteers.

Definitions All adults are potential victims of crime or abuse, but not all adults are vulnerable – the majority of adults are capable of protecting themselves, only a proportion will be in need of protective intervention. The broad definition of a ‘vulnerable adult’ referred to in the 1997 Consultation Paper ‘Who Decides?’ issued by the Lord Chancellor’s Department, is a person over the aged 18 years and older:

“who is, or may be in need of Community Care Services by reason of mental or other disability, age or illness: and who Is, or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation”

(Department of Health Guidance “No Secrets” March 2000)
Safeguarding Adults definition- Adults over 18 who "may be
eligible for community care services" whose independence and wellbeing would be at risk if they did not receive appropriate health and social care support. They include adults with physical, sensory impairments, mental health problems and learning disabilities, howsoever they have arisen e.g. whether present from birth or due to advancing age, chronic illness or injury. They also include carers: family and friends who provide personal assistance and care to adults on an unpaid basis.

What is Abuse?

“a violation of an individual’s human and civil rights by any other person or persons” No Secrets 2000

Abuse is ill-treatment, which causes significant harm and can result in the deterioration of a person’s physical, emotional, social or behavioural development.
Abuse reflects a lack of respect and is an infringement of legal and civil rights. It may be an abuse of power and may constitute a criminal act.
Abuse may be a single incident but is more likely to be part of a systematic pattern.
Abuse can take place in a variety of settings. These can include a person’s own home, a relative or friend’s home, a day centre, a hospital or a residential or nursing home.
Abuse can take place within both personal and professional relationships.
It can be carried out by other service users or people who deliberately form a relationship with a vulnerable adult in order to exploit them.
Criminal acts carried out by strangers are not usually included within a definition of abuse but in some cases it may be appropriate to use the Rochdale’s multi agency Safeguarding adults Procedures to ensure that the vulnerable adult receives the services and support that they need.

Consideration needs to be given to a number of factors. Abuse may consist of a single act or repeated acts. It may be physical verbal or psychological, it may be an act of neglect or an omission to act, or it may occur when a vulnerable person is persuaded to enter into a financial or sexual transaction to which he or she has not consented, or cannot consent. Abuse can occur in any relationship and may result in significant harm to, or exploitation of, the person subjected to it. Examples of Abuse “No Secrets” identifies the following main categories of abuse, which may be perpetrated as the result of deliberate intent, negligence or ignorance.

Physical
Psychological/Emotional
Sexual
Financial
Neglect/Omission
Discriminatory

Physical

Bodily assaults resulting in injuries e.g. hitting, slapping, pushing, kicking, misuse of medication, restraint or inappropriate sanctions.
Bodily impairment e.g. malnutrition, dehydration, failure to thrive.
Medical/healthcare maltreatment.
Sexual

Rape, incest, acts of indecency, sexual assault or harassment.
Engagement in sexual acts to which the vulnerable adult has not consented, or could not consent or was pressured into consenting.
Exposure to pornographic materials, being made to witness sexual acts.

Psychological or emotional

Threats of harm, controlling, intimidation, coercion, harassment, verbal abuse, enforced isolation or withdrawal from services or supportive networks.
Humiliation.
Bullying, shouting, swearing.
Negligent

Ignoring medical or physical care needs; failure to provide access to appropriate health, social care or educational services
Withholding necessities of life, such as medication, adequate nutrition and heating.

Financial or material

Theft, fraud, exploitation; pressure in connection with wills, property or inheritance or financial transactions, or the misuse or misappropriation of property, possessions or benefits.

Discriminatory

Harassment, slurs or other unfair treatment based on a person’s race, sex, or disability.

Other categories of abuse identified are:

Institutional abuse

Patterns of Abuse Patterns of abuse and abusing vary and reflect very different dynamics. These include:

Serial abusing in which the perpetrator seeks out and ‘grooms’ vulnerable individuals.
Sexual abuse usually falls into this pattern as some forms of financial abuse.
Long-term abuse in the context of an ongoing family relationship such as domestic abuse between spouses or generations.
Opportunistic abuse such as theft occurring because money has been left around.
Situational abuse, which arises because pressures have built up and/or because of difficult or challenging behaviour.
Neglect of a persons needs because those around him or her are not able to be responsible for their care, for example if the carer has difficulties attributable to such issues as debt, alcohol or mental health problems.
Institutional abuse which features poor care standards, lack of positive responses to complex needs rigid routines, inadequate staffing and an insufficient knowledge base within the service.
Unacceptable ‘treatment’ or programmes which include sanctions or punishment such as withholding of food or drink, seclusion, unnecessary and unauthorised use of control and restraint or over-medication.
Failures of agencies to ensure staff receive appropriate guidance on anti-racist and anti-discriminatory practice.
Failure to access key services such as health care, dentistry, prostheses.
Misappropriation of benefits and / or use of the person’s money by other members of the household.
Fraud or intimidation in connection with wills, property or other assets.

People who might abuse Abuse can happen anywhere and be by anyone e.g. informal carers, family, friends, neighbours; paid staff, volunteers; other service users; strangers Responsibilities of the organisation

To ensure staff and volunteers are aware and adequately trained

To notify the appropriate agencies if abuse is identified or suspected
To support and where possible protect individuals and ensure that all referrals carry full information in relation to identified risk and vulnerability
To CRB check volunteers and employees that have access to or work with Vulnerable Adults. No new employees, trustees or volunteers should start employment/work until references have been verified and CRB checks received. If this is not possible then new employees, trustees and volunteers must not have contact with vulnerable people until references and CRB checks are completed satisfactorily.
Responsibilities of employees and volunteers

All employees, trustees and volunteers will read and sign, the Vulnerable Adults Safeguarding Policy and follow the policy.
To declare any existing or subsequent convictions. Failure to do so will be regarded as gross misconduct, possible resulting in dismissal

Support for those who report abuse All those making a complaint or allegation or expressing concern, whether they be staff, service users, carers or members of the general public should be reassured that:

They will be taken seriously
Their comments will usually be treated confidentially, but their concerns may be shared if they or others are at significant risk
If service users, they will be given immediate protection from the risk of reprisals or intimidation
If Staff they will be given support and afforded protection if necessary in line with the Public Interest Disclosure Act 1998.

Rights of vulnerable adults The Vulnerable Adult has the right:

To be made aware of this policy
To have alleged incidents recognised and taken seriously
To receive fair and respectful treatment throughout
To be involved in any process as appropriate
To receive information about the outcome

Organisational procedures Recruitment of staff and Volunteers

Risk assessment of role to assess need for CRB Disclosures
Completion of an application form (for staff) or volunteer induction/briefing
Check references thoroughly including appropriate Disclosure
All staff and volunteers have a duty to declare any existing or subsequent convictions. Failure to do so will be regarded as gross misconduct, possibly resulting in dismissal

Training

Familiarisation with policies and procedures during induction
Training in Safeguarding available through the local authority
Further training, dependent on nature of role, in e.g. risk assessment & management, listening skills

Management and Supervision
It is the team/project leader’s responsibility to clarify with the worker or volunteer their roles and responsibilities regarding their relationships with vulnerable adults with whom they may be in contact. Regular supervision for staff and monthly meetings for volunteers will monitor the work and offer the opportunity to raise any issues.

Record Keeping
There should be a written record of any concerns. This confidential information will be kept in a locked drawer by the appropriate person, and will be kept for as long as deemed necessary, in line with Data Protection principles.All incidents should be discussed in supervision with team/project leader.
Reporting systems and records kept by paid workers or volunteers about vulnerable adults should only include contacts and referrals made, including date, time, reason and referral agency. (Any specific projects that need to keep more detailed records will be identified by the Team/project Leader and made known to the team.)

Planning
Wherever possible paid staff and volunteers should avoid lone working with a vulnerable adult. But if unavoidable, one to one contact should take place in an environment where other staff or volunteers are present or within sight.

Access to an independent person
Any vulnerable adult who comes into contact with staff or volunteers regularly, should be given information on their right to talk with an independent person, and their name and contact arrangements. This will normally be the Manager or [add in another key contact if relevant]. Determining action to be taken All allegations or suspicions are to be treated seriously. No abuse is acceptable and some abuse is a criminal offence and must be reported to the Police as soon as possible. To determine the appropriate action it is important to consider:
Risk – does the vulnerable adult, staff member or volunteer understand the nature and consequences of any risk they may be subject to, and do they willingly accept such a risk?

Self-determination – is the vulnerable adult able to make their own decisions and choices, and do they wish to do so

Seriousness – a number of factors will determine whether intervention is required. The perception of the victim must be the starting point. Factors informing assessment of seriousness will include:

the perception by the individual and their vulnerability;
the extent of the abuse;
the length of time it has been going on;
the impact on the individual;
the risk of repetition or escalation involving this or other vulnerable adults;
whether a criminal offence is being committed.

Summary The employee or volunteer’s primary responsibility is to protect the vulnerable adult if they are at risk.
Each employee or volunteer has a duty to take action.
Employees or volunteers should not have to cope alone.
Practice guide Actions and Considerations The first priority should always be to ensure the safety and protection of vulnerable adults. To this end it is the responsibility of all staff to act on any suspicion or evidence of abuse or neglect and to pass on their concerns to a responsible person or agency.

In situations of immediate danger, take urgent action by calling the relevant emergency services (e.g. Police, ambulance, GP)
Remember to have regard to your own safety. Leave the situation if it is not safe for you.
Listen to the vulnerable adult, offer necessary support and reassurance.
Issues of confidentiality must be clarified early on. For example staff or volunteers must make it clear that they will have to discuss the concerns with their team/project leader.
Where a vulnerable adult expresses a wish for concerns not to be pursued then this should be respected wherever possible. However, decisions about whether to respect the service user’s wishes must have regard to the level of risk to the individual and others, and their capacity to understand the decision in question. In some circumstances the vulnerable adult’s wishes may be overridden in favour of considerations of safety.
Decisions to override the vulnerable adult’s wish not to take the matter further should if possible be the product of discussion with appropriate team/project leader.
Note your concerns and any information given to you or witnessed by you.
Report concerns to the appropriate team/project leader.

REMEMBER IT IS NOT NECESSARY OR ADVISABLE FOR YOU TO SEEK EVIDENCE. By supporting the vulnerable adult and carefully logging any information given to you at this stage, you will lay the foundations for an effective formal investigation.
Understand the need not to contaminate, or to preserve evidence if a crime may have been committed. Discussion and Decision Making Information should be shared with your team/project leader, who must approve any actions to be taken and any documentation or correspondence being sent out.
Employees and volunteers with concerns – whether about a service user or a colleague - should discuss them with their team/project leader on the same day. If the team/project leader is not available, then any concerns should be discussed with another senior member of the Church or the Vicar.
The decision to refer or not to refer should be made by the team/project leader. [named lead person] should be informed.
When considering the decision as to whether to refer elsewhere (e.g. to Police, Social Services) the following should be taken into account:

The wishes of the vulnerable adult, & their right to self-determination
The mental capacity of the vulnerable adult
Known indicators of abuse
Definitions of abuse
Level of risk to this individual
The seriousness of the abuse
The effect of the abuse on the individual
Level of risk to others
The effect of the abuse on others
Whether a criminal offence has been committed
Whether other statutory obligations have been breached
The need for others to know
The ability of others (e.g. Police, Social Services) to make a positive contribution to the situation

Mental Capacity and Consent The consent of the vulnerable adult must be obtained except where:

The vulnerable adult lacks the mental capacity to make a decision, and a risk assessment indicates that referral would be in their best interests; or
Others may be at risk; or
A crime has been committed.

Summary of Manager’s responsibilities On being informed, the Relevant Manager will:

Ascertain whether the situation might fall within the definitions of abuse outlined in this policy
Consider the vulnerable adult’s capacity to make decisions
Ascertain whether an advocate or appropriate adult might be necessary
Ascertain any immediate action required
Ascertain whether an investigation is necessary in accordance with internal personnel policies and procedures
Where abuse is suspected conclude that a referral be made to the appropriate agency

Key contacts for referral or reporting of concerns When a member of staff suspects abuse of a vulnerable adult, discussion must immediately take place between the “alerter” (the person who identifies abuse) and their care/line manager. If there is any doubt about how to respond, they should contact the following services:

Adult Duty Intervention Service (ADIS) on 0161 770 1515
Care Management Team on 0161 770 6900 (if known to care management)
If out of office hours, the Emergency Duty Team (EDT) on 0161 770 6936.

Other useful contacts: Action on Elder Abuse operate the UK and Ireland's only national, freephone helpline for anyone concerned in any way about the abuse of older people. freephone number is 0808 808 8141

For advice contact Adult Safeguarding Team at Rochdale , Tel: 0300 303 8886

Information required for referral

Name of alleged victim, address, age, gender, ethnic background, principal language spoken, any disability
Details of GP and any known medication
Whether the individual is aware of and has consented to the referral/report.
The mental capacity of the individual
If appropriate, advice on preferred method or environment when approaching the alleged victim or perpetrator.
Details of alleged abuse and information about suspicions
Reasons / background to concerns and therefore this referral
Details of any protection arrangements which have already been made
Details of anyone else to whom this referral has also been made
Details of the alleged perpetrator and if they are a vulnerable adult
Details of any other professional involved
Details of carers and any significant family members, neighbours, friends

Information passed on must be relevant, necessary and up to date. Confirm in writing information given verbally. Do’s and don’ts when dealing with situations where abuse may have occurred Staff member or volunteer should:

Stay Calm
Listen patiently
Reassure the person they are doing the right thing by telling you
Explain what you are going to do
Report to relevant Manager
Write a factual account of what you have seen, immediately.

Staff member or volunteer should not:

Appear shocked, horrified, disgusted or angry
Press the individual for details (unless requested to do so)
Make comments or judgements other than to show concern
Promise to keep secrets
Confront the abuser
Risk contaminating evidence

Appendix: Identification of abuse Physical abuse signs
NB: Some ageing processes can cause changes which are hard to distinguish from some aspects of physical assault e.g. skin bruising can occur very easily due to blood vessels becoming fragile.

A history of unexplained falls or minor injuries
Bruising in well protected areas, or clustered from repeated striking
Finger marks
Burns of unusual location or type
Injuries found at different states of healing
Injury shape similar to an object
Injuries to head/face/scalp
History of GP or agency hopping, or reluctance to seek help
Accounts which vary with time or are inconsistent with physical evidence
Weight loss due to malnutrition, or rapid weight gain
Ulcers, bed sores and being left in wet clothing
Drowsiness due to too much medication, or lack of medication causing
recurring crises/hospital admissions

Sexual abuse signs

Disclosure or partial disclosure (use of phrases such as ‘It’s a secret’)
Medical problems, e.g. Genital infections, pregnancy, difficulty walking or sitting
Disturbed behaviour e.g. depression, sudden withdrawal from activities, loss of previous skills, sleeplessness or nightmares, self-injury, showing fear or aggression to one particular person, repeated or excessive masturbation, inappropriately seductive behaviour, loss of appetite or difficulty in keeping food down.
Behaviour of others towards the vulnerable adult
Circumstances – e.g. two service users found in a toilet area, one in a distressed state

Psychological or emotional signs:

Isolation
Unkempt, unwashed, smell
Over meticulous
Inappropriately dressed
Withdrawn, agitated, anxious not wanting to be touched
Change in appetite
Insomnia, or need for excessive sleep
Tearfulness
Unexplained paranoia, or excessive fears
Low self esteem
Confusion

Neglect signs

Physical condition poor
Clothing in poor condition
Inadequate diet
Untreated injuries or medical problems
Failure to be given prescribed medication
Poor personal hygiene

Financial or material signs

Unexplained or sudden inability to pay bills
Unexplained or sudden withdrawal of money from accounts
Disparity between assets and satisfactory living conditions
Extraordinary interest by family members and other people in the vulnerable person’s assets

Discriminatory signs

Lack of respect shown to an individual
Signs of substandard service offered to an individual
Exclusion from rights afforded to others, such as health, education,
criminal justice

Other signs of abuse

Inappropriate use of restraints
Sensory deprivation e.g. spectacles or hearing aid
Denial of visitors or phone calls
Failure to ensure privacy or personal dignity
Lack of flexibility of choice e.g. bedtimes, choice of food
Restricted access to toilet or bathing facilities
Lack of personal clothing or possessions
Controlling relationships between care staff and service users

Data Protection Policy

The Way Back Machine

Definitions

Last updated	11/09/2026
Company	The Way Back Machine.
GDPR	Means the General Data Protection Regulation.
Responsible Person	Means Jamie Watson, company director.
Register of Systems	Means a register of all systems or contexts in which personal data is processed by the Company.

1. Data protection principles

The Company is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be:

a. Processed lawfully, fairly and in a transparent manner in relation to individuals.  

b. Collected for specified, explicit and legitimate purposes and not further processed in a  manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered incompatible with the initial purposes.  

c. Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.  

d. Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.  

e. Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals.  

f. Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.  

2. General provisions

a. This policy applies to all personal data processed by the Company.  

b. The Responsible Person shall take responsibility for the Company’s ongoing  compliance with this policy.  

c. This policy shall be reviewed annually.  

3. Lawful, fair and transparent processing

a. To ensure its processing of data is lawful, fair and transparent, the Company shall maintain a Register of Systems.  

b. The Register of Systems shall be reviewed at least annually.  

c. Individuals have the right to access their personal data and any such requests made to  the Company shall be dealt with in a timely manner.  

4. Lawful purposes

a. All data processed by the company must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).  

b. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.  

c. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Company’s systems.  

5. Data minimisation

a. The Company shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

6. Accuracy

a. The Company shall take reasonable steps to ensure personal data is accurate.  

b. Where necessary for the lawful basis on which data is processed, steps shall be put in  place to ensure that personal data is kept up to date.  

7. Archiving / removal

a. To ensure that personal data is kept for no longer than necessary, the Company shall put in place an archiving policy for each area in which personal data is processed and review this process regularly.  

b. The archiving policy shall consider what data should/must be retained, for how long, and why.  

8. Security

a. The Company shall ensure that personal data is stored securely using modern software that is kept-up-to-date.  

b. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.  

c. When personal data is deleted this should be done safely such that the data is irrecoverable.  

d. Appropriate back-up and disaster recovery solutions shall be in place.  

9. Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Company shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO
(more information on the ICO website).

END OF POLICY