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The CCG is committed to an environment that promotes equality, embraces diversity and respects human rights both within our workforce and in service delivery. This document should be implemented with due regard to this commitment. This document can only be considered valid when viewed via the CCG’s intranet. If this document is printed into hard copy or saved to another location, you must check that the version number on your copy matches that of the one online. Approved documents are valid for use after their approval date and remain in force beyond any expiry of their review date until a new version is available. Version Control Sheet

Version

Date

Reviewed By

Comment

0.6

19.12.14 Melissa Laskey Jo Higham Mary Moore

None received

27.01.15 Helen Bolton Incorporated flowchart for staff

18.12.15 Kaleel Khan Updated Policy

Analysis of Effect completed:

By: Date:

Safeguarding Children & Adults at Risk Policy

Policy Number

Target Audience

All staff employed or commissioned by Bolton NHS CCG

Approving Committee

Date Approved

January 2013

Last Review Date

February 2015

Next Review Date

January 2017

Policy Author

Kaleel Khan

Version Number

7.0

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Contents

1 Introduction & Aims ......................................................................................................................... 3

2 Accountability, Responsibilities and Training .................................................................................. 4

3 Principles ......................................................................................................................................... 8

4 Internet .......................................................................................................................................... 10

5 Emails ............................................................................................................................................ 11

6 Monitoring and review ................................................................................................................... 11

7 Legislation and Related Documents ............................................................................................. 12

8 Appendix 1: Other relevant Procedural Documents ..................................................................... 13

9 Appendix 2a: – NHS Bolton CCG Governance Arrangements ..................................................... 16

10 Appendix 2b: NHS Bolton CCG Safeguarding Contact details ..................................................... 17

11 Appendix 3 Flowchart Recognition and Referral for Child Protection ........................................... 18

12 Appendix 4 Flowchart Recognition and Referral for Adult Safeguarding ..................................... 19

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1 Introduction & Aims

1.1 This policy applies to NHS Bolton Clinical Commissioning Group (CCG), their

employees, members, volunteers and learners whether they work either directly or

indirectly with children, adults and their families, or commission services for these

groups.

1.2 NHS Bolton CCG has statutory responsibilities to safeguard children, young

people and adults at risk of harm and exploitation. The organisational philosophy is

that safeguarding is everybody’s business and that all staff should respond and act

to raise safeguarding awareness and address emerging issues.

1.3 This philosophy should be included within all commissioning intentions,

services commissioned and contractual arrangements. The organisation will hold to

account all provider organisations contracting with NHS Bolton CCG regarding their

safeguarding responsibilities and processes as outlined in the NHS Accountability

and Assurance Framework (DH 2013)1.

1.4 As a commissioning organisation, NHS Bolton CCG has a statutory duty to

ensure that all health providers, from whom it commissions services, have robust

single and multi-agency policies and procedures in place to safeguarding and

promote the welfare of children and protect vulnerable adults from abuse or the risk

of abuse. NHS Bolton CCG and health providers must be linked to local

Safeguarding Children and Adult Boards and contribute to multi agency working.

1.5 The local Safeguarding Children and Adult Boards will hold NHS Bolton CCG

to account for fulfilling its statutory duties. For children, this will be achieved through

the section 11 (Children Act 2004) audit process which is led by Bolton Safeguarding

Children Board (BSCB).

1 http://www.england.nhs.uk/wp-content/uploads/2013/03/safeguarding-vulnerable-people.pdf

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2 Accountability, Responsibilities and Training 2.1 This policy demonstrates that NHS Bolton CCG recognises Safeguarding

Children and Adults at Risk as a shared responsibility, with the need for effective

joint working between agencies and professionals that have different roles and

expertise if those vulnerable groups in society are to be protected from harm. In

order to achieve effective joint working there must be constructive relationships at all

levels, promoted and supported by:

the commitment of senior managers and board members to safeguarding

children and adults at risk

clear lines of accountability within the organisation for safeguarding activity

service developments that take account of the need to safeguard all service

users, and is informed, where appropriate, by the views of service users

staff training and continuing professional development so that staff have an

understanding of their roles and responsibilities, and those of other

professionals and organisations in relation to safeguarding children and adults

at risk

safe recruitment and working practices including recruitment and vetting

procedures

effective interagency working, including effective information sharing

2.2 NHS England

2.3 Is responsible for ensuring that the health commissioning system as a whole

is working effectively to safeguard and promote the welfare of children and adults. It

is accountable for the services it directly commissions including primary care

services. NHS England leads and defines improvement in safeguarding practice and

outcomes whilst the CCGs work co-operatively and constructively with NHS England

to fulfil its safeguarding statutory duties.

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2.4 NHS Bolton CCG

2.5 The ultimate accountability for safeguarding sits with the Chief Officer of NHS

Bolton CCG and NHS England. Any failure to have systems and processes in place

to protect children and adults at risk in the commissioning process, or by providers of

health care that the CCG commissions, would result in failure to meet statutory and

non-statutory constitutional and governance requirements.

2.6 NHS Bolton CCG must demonstrate that robust arrangements are in place to

evidence compliance with safeguarding responsibilities. NHS England will monitor

compliance with safeguarding as required in the Accountability and Assurance

Framework (DH 2013), or any superseding guidance.

2.7 NHS Bolton CCG, as a commissioning organisation, must:

Function with reference to NHS Bolton CCG resources made available by

NHS England2

Include clear standards for safeguarding in commissioning arrangements with

all providers.

Monitor provider compliance against the standards of delivery detailed in NHS

Bolton CCG Safeguarding Children, Young People and Adults at Risk

Contractual Standards and Training Recommendations (2014-2015).

Have Proper Constitutional and Governance arrangements with capacity and

capability to deliver safeguarding duties and responsibilities, as well as

effectively commission services ensuring that all service users are protected

from abuse and neglect. These arrangements will support continual

improvement of quality and organisational learning of lessons from incidents

and individual experience.

Ensure that safeguarding is at the forefront of service planning and a regular

agenda item of the NHS Bolton CCG Board business.

Safeguarding considerations must run through all service planning for NHS Bolton CCG.

2 http://www.england.nhs.uk/resources/resources-for-ccgs/#safe

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2.8 NHS Bolton CCG must also:

Requirement Evidence Establish clear lines of accountability for safeguarding, reflected in governance arrangements.

See appendix 2a: Governance Arrangements

Have arrangements in place to co-operate with the local authority in the operation of the Local Safeguarding Children and Safeguarding Adults Boards.

This is achieved through representation by members of the CCG Safeguarding team on Boards, the Executive to the Boards and the subgroups beneath which drive forward the local priorities.

Have a Safeguarding Adult’s Lead and a lead for the Mental Capacity Act and Prevent and secure the expertise of a Designated Doctor and Nurse for Safeguarding Children and for LAC and a Designated paediatrician for Sudden Unexpected Deaths in Childhood.

See appendix 2b: Roles and contact details of members of the CCG Safeguarding Team Details of the responsibilities of Designated professionals are contained within ‘Working Together to Safeguard Children 2013’3

Ensure that plans are in place to train all staff who are in contact with children, adults who are parents/carers and adults at risk in the course of their normal duties. This will ensure that they are trained, commensurate with the levels in the Intercollegiate Document (2014), and competent to be able to recognise, respond and refer their concerns in line with local guidance.

See Bolton NHS CCG Strategic Framework for Training

Identify an Executive Lead for Safeguarding with the authority to make commissioning decisions on behalf of the CCG. The Executive Lead will be a member of Bolton Safeguarding Children’s Boards (BSCB) and Bolton Safeguarding Adult’s Board (BSAB). These Boards are the key mechanism for agreeing how local organisations will effectively co-operate to safeguard and promote the welfare of children and adults at risk.

Identify an Executive Lead for Safeguarding with the authority to make commissioning decisions on behalf of the CCG. The Executive Lead will be a member of Bolton Safeguarding Children’s Boards (BSCB) and Bolton Safeguarding Adult’s Board (BSAB). These Boards are the key mechanism for agreeing how local organisations will effectively co-operate to safeguard and promote the welfare of children and adults at risk.

3https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/281368/Working_together_to_safeguard_children.pdf

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2.9 All staff, including managers employed by NHS Bolton CCG

2.10 This policy, and the associated documents and links, are designed to support

staff and managers in their safeguarding duties.

2.11 Managers within the CCG are responsible for ensuring that practice reflects

the standards laid out within this policy and that staff are given adequate resources

and support to comply with them.

2.12 All staff are responsible for ensuring that they are aware of the requirements

to safeguard children and adults at risk and for ensuring that they comply with these.

2.13 All staff involved in the commissioning of services must consider this policy

when they develop and commission services and must include the safeguarding

standards in all contracts.

2.14 All staff have a responsibility to inform senior managers or the safeguarding

team of any child protection or adult safeguarding concerns.

2.15 Managers are responsible for ensuring that staff are aware of and can access

this policy, and the associated documents in this policy.

2.16 Access to Advice and Support for Staff

2.17 Staff can access advice and support from the NHS Bolton CCG Safeguarding

Team: see contact details in appendix 2b and flowchart for what to do in the event of

a safeguarding concern: see appendix 3

2.18 Provider organisations can access advice and support from the Named

Professionals in their organisations safeguarding team or the safeguarding lead.

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2.19 Breaches of Policy

2.20 This policy is mandatory. Where it is not possible to comply with the policy or

a decision is taken to depart from it, the Associate Director of

Safeguarding/Designated Nurse must be informed.

2.21 This policy will be reviewed annually.

3 Principles

3.1 Definitions

3.2 Commissioning: The process of arranging continuously improving services

which deliver the best quality outcomes for patients and meet the populations health

needs

3.3 Children: As defined in the Children Act 1989 and 2004, a child is anyone who

has not yet reached their 18th birthday. ‘Children’ therefore means children and

young people throughout.

3.4 Safeguarding and promoting the welfare of children is defined in England, in

both the Children Act 2004 (Section 11 guidance) and Working Together to

Safeguard Children (2013) as:

protecting children from maltreatment

preventing impairment of children's health or development

ensuring that children grow up in circumstances consistent with the provision

of safe and effective care

taking action to enable all children to have the best outcomes

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3.5 Child protection: is defined as being that activity taken to protect children who

are suffering or at risk of suffering significant harm, as per section 47 of the Children

Act 1989.

3.6 Care Act (2014) has replaced the term “vulnerable adult” with the term “adult

at risk”. However, the terms remain interchangeable within the definition below.as a

person aged 18 years or 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”.

3.7 Safeguarding Adults: Care Act (2014) states: 14.7 Safeguarding means

protecting an adult’s right to live in safety, free from abuse and neglect. It is about

people and organisations working together to prevent and stop both the risks and

experience of abuse or neglect, while at the same time making sure that the adult’s

wellbeing is promoted including, where appropriate, having regard to their views,

wishes, feelings and beliefs in deciding on any action” .

3.8 The Office for Security and Counter-Terrorism, in the Home Office, works to

counter the threat from terrorism. Their work is covered in the government’s counter-

terrorism strategy, CONTEST.

3.9 NHS Bolton CCG Prevent Lead is a member of the Channel Panel chaired by

the Local Authority (Bolton Council) and cases managed by Greater Manchester

Police.

3.10 NHS Bolton CCG Prevent Lead is also accountable to the NHS Bolton CCG

Chief Nurse and NHS England to ensure the Prevent duty is embedded in NHS

Bolton CCG.

3.11 The strategy is based on 4 areas of work:

pursue: to stop terrorist attacks

prevent: to stop people becoming terrorists or supporting terrorism

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protect: to strengthen our protection against a terrorist attack

prepare: to mitigate the impact of a terrorist attack

3.12 NHS Bolton CCG Prevent Lead is responsible for ensuring reporting on CCG

Prevent referrals and training rate to the Department of Health through the health

regional Prevent co-ordinators (RPCs).Within NHS Bolton CCG, Prevent issues are

managed through the local authority (Bolton Council) Channel Panel.

3.13 NHS Bolton CCG Commissioners (and/or delegated commissioners) are

responsible for ensuring service specifications, invitations to tender and services

contracts fully reflect safeguarding requirements, including Prevent. When reviewing

contracts, commissioners should ensure that a review of performance on

safeguarding is included in the reporting requirements and any issues on

Safeguarding, including Prevent are reported to the Prevent Lead who will liaise with

Local Authority and the Police.

3.14 Healthcare staff are well placed to recognise individuals, whether patients or

staff, who may be vulnerable and therefore more susceptible to radicalisation by

violent extremists or terrorists. It is fundamental to our ‘duty of care’ and falls within

our safeguarding responsibilities.

3.14 NHS Bolton CCG must ensure that all suspected and alleged PREVENT

cases within NHS Bolton CCG must be discussed and made to NHS Bolton CCG

Prevent Lead who will decide if a PREVENT referral should be then made to the

Channel Panel via Greater Manchester Police for consideration.

4 Internet 4.1 The internet has become a significant tool in the distribution of indecent

photographs/ pseudo photographs of children and adults. Internet chat rooms,

discussion forums and bulletin boards are used as a means of contacting children

and adults with a view to grooming them for inappropriate or abusive relationships,

which may include requests to make and transmit pornographic images of

themselves or to perform sexual acts in front of a webcam. Contacts made initially in

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a chat room are likely to be carried on via email, instant messaging services, mobile

phone or text messaging.

4.2 NHS Bolton CCG must ensure that all staff are aware of the proper use of the

internet in line with this policy and also in line with NHS Bolton CCG Confidentiality

and Data Protection Policy and Acceptable Use Policy (Including IT Email and

Internet).

5 Emails

5.1 NHS Bolton CCG must ensure that staff are aware of the proper use of emails

and NHS Bolton CCG do not share inappropriate images, language or text is used or

distributed using NHS email accounts internally or externally. If this policy is

breeched the Safeguarding Team must be informed immediately.

6 Monitoring and Review

6.1 In order to ensure that local guidance is followed effectively across NHS

Bolton CCG the Quality and Safety Committee (Q&SC) and Integrated Bolton

Safeguarding Committee (BISC) will be responsible for maintaining on-going

systems of audit and monitoring and Bolton Adult Safeguarding Board.

6.2 This policy will be reviewed every 2 years, and in accordance with the

following as and when required:

• Legislative changes

• Good practice guidance

• Case law

• Serious incidents

• Safeguarding Adults Reviews (where applicable)

• Changes to organisational infrastructure

6.3 The CCG will ensure that requirements of the MCA and DoLS legislation is

included within all commissioned services through inclusion in NHS Contracts.

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6.4 Commissioned services will provide quarterly data through information

reporting requirements within the adult safeguarding dashboard which will be

scrutinised within the CCG’s Quality committee.

7 Legislation and Related Documents

7.1 Every member of staff has a role to play in protecting and supporting

vulnerable individuals who pass through our care.

7.2 This policy should be read alongside:

Bolton NHS CCG safeguarding induction information

Bolton NHS CCG Strategic Framework for Training

Bolton NHS CCG Managing Allegations Made Against Staff in Respect of

Children and Young People Policy

Safeguarding Information Resource Pack for Primary Care Services: Children,

Young People and Adults at Risk

7.3 Other local guidance supporting this policy can be found at:

Bolton Safeguarding Children Board website: for those working with children

and young people4

Greater Manchester Safeguarding Partnership website5

Greater Manchester Safeguarding Children Procedures Manual6

Bolton Safeguarding Adults Board Procedures Manual, launched Feb 20157

Bolton Council: Safeguarding Adults page8

4 http://boltonsafeguardingchildren.org.uk/working-with-children-and-young-people/

5 http://www.gmsafeguardingchildren.co.uk/

6 http://greatermanchesterscb.proceduresonline.com/chapters/contents.html

7 http://www.proceduresonline.com/bolton/asg/index.htm

8 http://www.bolton.gov.uk/website/pages/Safeguardingvulnerableadults.aspx

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8 Appendix 1: Other relevant Procedural Documents

In discharging statutory safeguarding duties and responsibilities, account

must be taken of the following legislative frameworks and guidance:

Documentation Links

Children Act 1989 http://www.legislation.gov.uk/ukpga/1989/

41/contents

Children Act 2004 http://www.legislation.gov.uk/ukpga/2004/

31/contents

Care Act 2014 http://www.legislation.gov.uk/ukpga/2014/

23/contents/enacted

Safeguarding children and young

people: roles and competences for

health care staff

Intercollegiate Document (2014)

http://www.rcn.org.uk/__data/assets/pdf_fil

e/0008/474587/Safeguarding_Children_-

_Roles_and_Competences_for_Healthcar

e_Staff_02_0....pdf

Statutory guidance on making

arrangements to safeguard and

promote the welfare of children under

section 11 of the Children Act 2004 (HM

Government 2007)

http://webarchive.nationalarchives.gov.uk/

20130401151715/https://www.education.g

ov.uk/publications/eorderingdownload/dfe

s-0036-2007.pdf

Working Together to Safeguard

Children (HM Government 2013)

https://www.gov.uk/government/uploads/s

ystem/uploads/attachment_data/file/28136

8/Working_together_to_safeguard_childre

n.pdf

NICE guideline 89: When to suspect

child maltreatment (updated 2013) –

National Institute for Health and Care

Excellence

http://publications.nice.org.uk/when-to-

suspect-child-maltreatment-cg89

Working together to safeguard children

A guide to inter-agency working to

safeguard and promote the welfare of

https://www.gov.uk/government/publicatio

ns/working-together-to-safeguard-

children--2

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children (March 2015)

What to do if you’re worried a child is

being abused (HM Government 2015)

https://www.gov.uk/government/publicatio

ns/what-to-do-if-youre-worried-a-child-is-

being-abused--2

Safeguarding children who may have

been trafficked: practice guidance

(DFE/Home Office 2011)

https://www.gov.uk/government/uploads/s

ystem/uploads/attachment_data/file/17703

3/DFE-00084-2011.pdf

Safeguarding Children in whom illness

is fabricated or induced (DCSF 2008)

This isn’t the link to the up to date link

This is on Gov.uk website.

https://www.gov.uk/government/uploads/s

ystem/uploads/attachment_data/file/27731

4/Safeguarding_Children_in_whom_illnes

s_is_fabricated_or_induced.pdf

Multi-agency practice guidelines:

Handling cases of Forced Marriage (HM

Government 2014)

https://www.gov.uk/government/uploads/s

ystem/uploads/attachment_data/file/32230

7/HMG_MULTI_AGENCY_PRACTICE_G

UIDELINES_v1_180614_FINAL.pdf

Information sharing: Guidance for

practitioners and managers (HM

Government 2015)

https://www.gov.uk/government/uploads/s

ystem/uploads/attachment_data/file/41962

8/Information_sharing_advice_safeguardi

ng_practitioners.pdf

Mental Capacity Act 2005: Code of

Practice (Department for Constitutional

Affairs 2007)

https://www.gov.uk/government/uploads/s

ystem/uploads/attachment_data/file/22466

0/Mental_Capacity_Act_code_of_practice.

pdf

Mental Capacity Act 2005: Deprivation

of liberty safeguards - Code of Practice

to supplement the main Mental Capacity

Act 2005 Code of Practice (MOJ 2008)

http://webarchive.nationalarchives.gov.uk/

20130107105354/http://www.dh.gov.uk/pr

od_consum_dh/groups/dh_digitalassets/

@dh/@en/documents/digitalasset/dh_087

309.pdf

Safeguarding Adults: The Role of

Health Service Practitioners (DH 2011)

https://www.gov.uk/government/uploads/s

ystem/uploads/attachment_data/file/21571

4/dh_125233.pdf

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NHS Safeguarding Accountability and

Assurance Framework (DH )2013

http://www.england.nhs.uk/wp-

content/uploads/2013/03/safeguarding-

vulnerable-people.pdf

Bolton Safeguarding Children Board

policies, including Framework for Action

http://boltonsafeguardingchildren.org.uk/w

orking-with-children-and-young-people/

Bolton Safeguarding Adults Board

Procedures Manual, launched Feb 2015

http://www.proceduresonline.com/bolton/a

sg/index.htm

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9 Appendix 2a: – NHS Bolton CCG Governance Arrangements

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10 Appendix 2b: NHS Bolton CCG Safeguarding Contact details

Name Title Contact

Mary Moore Chief Nurse Mary.moore11@nhs.net 01204 462026 07767618901

Pam Jones Associate Director Safeguarding /Designated Nurse

pam.jones8@nhs.net 01204 463389 07920 478715

Helen Bolton Safeguarding Specialist Practitioner (children)

helen.bolton2@nhs.net 01204 462203 07920 477223

Kaleel Khan Designated Adult Safeguarding Manager CCG Lead for MCA/DoLS and Prevent

kaleelkhan@nhs.net 01204 462204 07826 954350

Dr Charlotte Mackinnon

Named GP – Safeguarding charlotte.mackinnon@nhs.net

Dr Gabi Lipshen

Designated Doctor gabi.lipshen@boltonft.nhs.uk gabi.lipshen@nhs.net 01204 463500

Charlotte McManus

Safeguarding Team Administrative Support / PA to Designated Nurse

charlottemcmanus@nhs.net 01204 463390

Dr Ian Freeman

Named Doctor Safeguarding/SUDC Paediatrician

01204 390658

Dr Val Coupes Named Doctor Safeguarding /Designated Doctor LAC

01204 463500

Joanne dorsman

Designated Nurse LAC (Interim) 01204 463393

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11 Appendix 3 Flowchart Recognition and Referral for Child Protection

Health Professional has a suspicion or concern about

neglect, emotional or physical abuse of a child or young person

May wish to contact:

Practice

Safeguarding Lead

(or Deputy)

Named or

Designated

Professional

NSPCC Helpline for

advice

May wish to share concerns with other professionals:

Health Visitor

School Nurse

Midwife

Dentist,

Optometrist, etc.,

where appropriate

All information considered by the health professional

Concerns are allayed Concerns are on-going

Keep a detailed record Health professional contacts Children’s Social Care Service or Police in accordance with Bolton

LSCB Procedures – Framework for Action

No further action Follow inter agency procedures, record all contacts, contribute to on-going enquiries, keep child

under review (depends on level of concern), follow up if no response form Children’s Social Care Team

Health Professional has a suspicion or concern about sexual abuse of a child or young person.

Contact Bolton Children’s Social Care Referral & Assessment Team immediately as the child may need forensic examination at SARC. For further information on the indicators of sexual abuse please go to www.nice.org/cg89

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12 Appendix 4 Flowchart Recognition and Referral for Adult Safeguarding Full procedures can be found at Bolton Council Multi-agency safeguarding policy and procedures at

the following web link: http://www.proceduresonline.com/bolton/asg/

Concerns are allayed

No further action. Consider support needs

Keep a detailed record

Follow inter-agency procedures, record all contacts, contribute to ongoing enquiries, keep adult

under review [depends on level of concern], check outcome of

Adults Social Care services referral

Health professional contacts Adult Social Care Service or Police in accordance with Bolton LSAB Procedures

Concerns are ongoing

All information considered by The health professional

May wish to contact

• Practice Safeguarding Lead

[or deputy]

• Safeguarding Adults Lead in CCG

May wish to share concerns with other professionals

• District Nurse

• OT • Midwife

• CPN

Health Professional has a suspicion

or concern that an adult is at risk of or

has been significantly harmed