Safeguarding Policy

Safeguarding Policy

Date Approved by Trustees October  2018
Date of next review October  2019
Person responsible  Jo-anne King
Associated Documents:
Recruitment Policy
Anti-bullying Policy
Whistle Blowing Policy

Approved by Board of Directors
(insert Electronic Signature) William Taylor
Date: 2.10.18


Green Tracks Enterprise is a small Market Garden providing horticulture training and work experience for people with additional needs.

Green Tracks Enterprise aims to create a safeguarding culture and environment where opportunities for abuse, neglect or exploitation to occur are minimised, and within this a culture where adults at risk and everyone working at Green Tracks Enterprise have the confidence to voice any concerns or fears they may have about abuse, neglect or exploitation and where they feel able to disclose allegations of harm or abuse.

Green Tracks Enterprise recognises a responsibility to ensure the safety and wellbeing of all adults at risk involved in Green Tracks Enterprise’s activities.

The protection of these groups is a priority. Safeguarding is the duty of all staff and service users.

The Policy aims to describe the actions that must be taken when abuse, neglect or exploitation is suspected or disclosed.

Furthermore this policy aims to meet legislative and Audit requirements



The policy and procedures aim to integrate strategies relevant to issues of adult protection / abuse contained in current legislation.

Safeguarding adults is underpinned by:

    • The Care Act 2014
    • Mental Capacity Act (MCA) 2005
    • Safeguarding Vulnerable Groups Act 2006
    • Counter-Terrorism and Security Act 2015
    • Keeping children safe in Education 2018


Types of abuse suffered by adults identified in the Care Act 2014 are:

    • Physical
    • Sexual
    • Psychological/Emotional/Mental
    • Financial and material
    • Neglect and act of omission
    • Discriminatory
    • Organisational
    • Modern Day Slavery
    • Domestic Violence
    • Self Neglect – including hoarding


Other types of harm that adults may experience include:

    • Cyber Bullying
    • Forced Marriage
    • Female Genital Mutilation
    • Mate Crime
    • Radicalisation



Green Tracks Enterprise believes in and fosters the following principles in relation to the protection of adults at risk:

    • The welfare of adults at risk is paramount. All adults at risk have an absolute right to a life free from abuse, neglect or exploitation.
    • All adults at risk should have access to relevant procedures and services for addressing issues of abuse, neglect and exploitation, including the civil and criminal justice system and victim support services.
    • The protection of adults at risk is everyone’s responsibility. We recognise a duty to care for all service users at Green Tracks Enterprise
    • All staff working or involved with adults at risk have a duty to report and refer any concerns, however minor they may appear to be, about possible abuse, neglect or exploitation
    • Green Tracks Enterprise recognises that adults at risk may have the mental capacity to make an unwise decision, however as an organisation we recognise our duty to put appropriate and reasonable support in place to minimise the possibility of significant harm.
    • All adults at risk – whatever their age, culture, disability, gender, sexual orientation, racial origin, language and/or religious belief - have the right to protection from any form of harm.
    • Green Tracks Enterprise will follow statutory and specialist guidelines in working with adults at risk when responding to all allegations and/or suspicions of abuse.
    • Green Tracks Enterprise is committed to supporting multi-agency training, education and information for everyone concerned to create a climate in which adult abuse is regarded as unacceptable. Green Tracks Enterprise acknowledges the value of staff training in supporting a respectful and inclusive culture, in enabling the identification of abuse, and in encouraging proactive communication about safeguarding concerns. All staff will therefore receive safeguarding training and training in the use of Green Tracks Enterprise’s safeguarding policy and procedures every two years. They will also receive training on Positive Approaches to managing and understanding behaviour that challenges.
    • Green Tracks Enterprise requires all staff who undertake regulated activity with service users to hold an enhanced DBS check.
    • We recognise that all matters relating to the protection of adults at risk are confidential


We also embrace the principles stated by the Department of Health (DoH) with the Social Care Institute for Excellence (SCIE), May 2011.

These principles refer to the interventions for work with adults at risk and are not a statutory duty but reflect good practice and are compatible with health and social care law. The DoH principles underpinning safeguarding adults are:

    • Empowerment: Presumption of person led decisions and informed consent
    • Protection: Support and representation for those in greatest need
    • Prevention: it is better to take action before harm occurs
    • Proportionality: Proportionate and least intrusive response appropriate to the risk presented
    • Partnership: Local solutions through services working with their communities. Communities have a part to play in preventing, detecting and reporting neglect and abuse
    • Accountability: Accountability and transparency in delivering safeguarding


Radicalisation Indicators

In respect of safeguarding individuals from radicalisation, Greentracks works to the Prevent element of the Government’s Counter Terrorism Strategy, and where deemed appropriate seeks external advice for referrals to the Channel Programme. This programme aims to work with the individual to address their specific vulnerabilities, prevent them becoming further radicalised and possibly entering the criminal justice system because of their actions. It is recognised that radicalisation can occur to an individual from any section of society and is not particular to any racial, ethnic or social group. It is further recognised that in many instances the process of radicalisation is essentially one of grooming by others.

Possible signs of radicalisation include:

    • The individual’s views become increasingly extreme regarding another section of society or government policy
    • They are observed downloading, viewing or sharing extremist propaganda from the web
    • They become withdrawn and focused on one ideology
    • The individual becomes increasingly intolerant of more moderate views
    • The individual may change their appearance, their health may suffer (including mental health) and they may become isolated from family, friends, peers or social groups.
    • The individual expresses a desire/intent to take part in or support extremist activity


Roles and responsibilities

Green Tracks Enterprise Safeguarding Officer
The Safeguarding Officer

Is responsible for the overall coordination and management of all Safeguarding issues at Green Tracks Enterprise, which includes reporting, assessment, investigation and following up of incidents.

    • Provides support, supervision, advice to all staff at Green Tracks Enterprise regarding safeguarding, supported by the Directors as appropriate.
    • Plans and resources the appropriate assessment and supervision of service users to ensure their safety and safeguarding in collaboration with the manager
    • Liaises with relevant stakeholders like families and social workers.
    • Seeks appropriate support /guidance.  This may include calling the Local Authority Safeguarding Team.
    • Makes sure that there is a completed incident form and any other documentation necessary, which is kept securely in the individual’s folder in the locked cabinet.
    • Ensures that steps are taken to keep the abused adult safe while the initial enquiries are made.
    • Is responsible for the initial training and refresher trainings of all members of staff as well as making sure that all members of staff work according to best practice.
    • Is responsible for keeping up to date with best practice and legislation regarding safeguarding.
    • Will report /discuss any incidents involving accidents and Health and Safety concerns, with the Director responsible for Health and Safety so that learning and follow up can take place.
    • Will communicate all strategies designed to reduce the risk of further incidents.
    • Will review this Policy annually.
    • Will write anonymised reports ( up to 4 times a year if appropriate and one annual summary report) and updates to the board of Directors.


The Safeguarding Officer upon receiving an incident report of an allegation or suspicion of abuse or concerns will:

    • In the case of an incident that poses immediate danger, take necessary steps to ensure the safety of the service user in question and any other person who might be at risk
    • Listen and record concerns/allegations/disclosure
    • Assess the information received and decide on the appropriate steps of action
    • Ensure that the victim and the suspected abuser are separated from each other as soon as   possible after the potential abuse is reported
    • Report the matter to the appropriate local authority and seek advice within one working day of the alert
    • In some serious situations, it might be necessary for the safeguarding Co-ordinator to immediately notify the police prior to contacting the local authority safeguarding team
    • Ensure that the Safeguarding Incident Report is completed by the person who reported the original concern
    • Assess the situation at this point in the process and decide on appropriate next Steps.
    • If necessary, and in collaboration with the Director responsible for Safeguarding, continue to:  review the details of the case as required, share and review the advice from the local authority safeguarding team, plan actions that need to be undertaken in following up the details of the completed safeguarding form
    • Ensure that written records are kept of all conversations, meetings etc. relating to the safeguarding issue


Procedure for the Safeguarding Officer if an allegation involves a member of staff working with service users
The Safeguarding Officer will:

    • Ensure that the victim is safe
    • Inform the Local Authority with regard to local authorities’ multi agency safeguarding policy and procedure. The Local Authority and Safeguarding Co-ordinator will decide if the allegation meets the criteria for a strategy meeting based on whether the member of staff working with service users has:
    • Behaved inappropriately in a way that has harmed or may have harmed an adult at risk
    • Possibly committed a criminal offence against or related to an adult at risk



The board of directors has the overall legal and governance responsibilities for all activities at Green Tracks Enterprise. A named Director is responsible for overseeing safeguarding activities, reviewing incidents and for liaising regularly with the Safeguarding Officer.

The governing body will ensure that Green Tracks Enterprise will safeguard and promote the welfare of service users and work together with other agencies to ensure adequate arrangements  are in place to identify, assess and support those service users who are suffering harm.

All relevant policies will be reviewed annually by the governing body. The governing body will not receive details of individual service users’ situations or identifying features of families as part of their oversight responsibility (unless the service user concerned is an adult, has the capacity to decide on the issue of information sharing and wishes to disclose such detail)


All staff

Have the responsibility to alert the Safeguarding Officer immediately if they have any concerns regarding the safety of an adult at risk.


The Police

The early involvement of the police may have benefits, in particular:

    • It will help ensure that evidence is not lost or contaminated
    • Early referral or consultation with the police will establish whether a criminal act has been committed and this will give the opportunity of determining if and at what stage, the police need to become involved
    • A higher standard of proof is required in criminal proceedings than in disciplinary or regulatory proceedings (where the test is the balance of probability)
    • Police officers have considerable skill in investigating and interviewing and their early involvement may prevent the abused adult being interviewed unnecessarily on subsequent occasions
    • Police investigations should proceed alongside those dealing with health and social care issues


Response to referrals (Local Authority)

The person who alerts one of the agencies to concerns about actual or suspected abuse should have their referral acknowledged, preferably in writing, with a summary of the action likely to be taken.

The adult at risk should be central to the whole process and be aware of, and participating in, any action taken or planned (as appropriate, particularly when this involves a child)

The person alleged responsible will need to be informed of the allegation and how this is done will be guided by the strategy meeting. For example, the Police will want to manage this if there is a criminal investigation.



Alerters can be any of the responsible people mentioned above as well as health workers, social workers, college staff, or any member of the public. The Alerter must use the procedures described below.



In the event of an Incident or Accident

  1. Where someone is in immediate danger or seriously injured, immediately deal with the emergency first and call the emergency services on 999 if appropriate – to dial out press “9”.
  2. Call Safeguarding Officer immediately (leaving a message where necessary):

    Sharon Goulding - 07708 566300
    Jo-anne King (Director responsible for Safeguarding) - 07929 545739

    If you are unable to reach someone within 2 hours, please call:

    Social Care Direct
    Telephone - 0345 8 503 503
    Fax - 01924 303455
    Mincom - 01924 303450
    Email -
    Explain the situation and ask for advice if necessary.
  3. On the same day, ensure that an Incident Form is completed and emailed to Sharon Goulding, Green Tracks Enterprise Safeguarding Team will then follow the incident as appropriate.
  4. If the incident was also an accident – if someone was injured or nearly injured – you should also make a note in the Accident Book and file appropriately in the Accident Folder (see Accident Procedure).  If you need help, ask Sharon Goulding.


Guidance on identifying an incident

It may not be clear sometimes if an incident should be reported.  For example, if a service user had an argument or nearly hit someone but nobody was hurt, offended or injured.  In these circumstances, it is always best to report and discuss the situation either with one of Green Tracks Enterprise Safeguarding Team. If the issue is not considered an incident, then it will be quite clear after discussion that this is the case.  Always check.  Always report.

All allegations and suspicions of abuse will be taken seriously and responded to swiftly and appropriately.

The need to protect an adult at risk is paramount. It is therefore the responsibility of all staff to report any safeguarding concerns they may have and not to decide whether a concern constitutes abuse or not without seeking advice of the Safeguarding Officer. Even if a member of staff thinks or believes that an allegation or disclosure may be untrue, it is still their duty to report it.

It is not the job of staff to investigate any safeguarding concerns they may have.

The following procedure must be followed by all staff or volunteers when:

    • a service user discloses to them that abuse has, or may have, occurred
    • they witness an incident that would be considered to be abusive
    • they have a significant concern that a service user may have been or is being abused
    • The response to an incident has to be proportionate to the event and those responsible have to keep in mind the empowerment of the person who has been affected. The individual must feel in control and in this consent it is important to include the individual and seek consent.



    • When a service user makes a disclosure of abuse, staff will not question the alleged victim about the incident
    • At this point it is not appropriate to gather specific information about what has happened. Avoid leading questions; respond to the service user but do not interrogate as any further questioning by staff could affect the validity of any statement collected by the police at a later date
    • Listen without displaying shock or disbelief
    • Accept what you are told; you do not need to decide whether or not it is true
    • Clarify anything you do not understand



    • Acknowledge the service user’s courage in making a disclosure
    • Do not promise confidentiality
    • Avoid making statements or promises that are incorrect or unrealistic
    • Remind them they are not to blame; avoid criticising the alleged perpetrator
    • Do not promise that “everything will be all right now” (it might not be)



    • The service user may be in a state of shock or very anxious, therefore it is important to explain carefully what you will do next, i.e. inform the Safeguarding Officer
    • Always encourage and allow the individual to be involved in any next steps and where possible support the service user to speak directly to the Safeguarding Officer, accompanied by a supportive adult if wished for by the service user
    • Seek to ensure the person’s safety
    • Do not confront the alleged perpetrator
    • If the alleged abuse happened very recently, do not allow access to any room where this may have occurred. Any items handed on by the victim are to be passed to the Safeguarding coordinator.



Recording must be done as soon as possible and during the disclosure if appropriate, including:

    • Name of service user and date of disclosure
    • Facts of the conversation/disclosure
    • Date and time of the alleged incident(s)
    • Use of the service user’s own words where possible
    • Your observations of the service user’s behaviour, appearance and emotional state
    • Cross out mistakes with one clear line but do not use Tippex and do not destroy your original notes. They may be needed later on and must be given to the Safeguarding Officer.



  • Making a disclosure can be emotionally and psychologically traumatic and/or distressing. It is therefore important to consider what kind of support will be needed for the service user
  • Service user disclosures and allegations can be extremely stressful and time consuming; it is important to ensure you, as the recipient, seek appropriate support through discussion with your supervisor or directly with a safeguarding team member as appropriate.


Responding to a Disclosure

The abused person may not understand they are being abused and so not realise the significance of what they are telling you.  Some disclosures may happen many years after the abuse.  There may be good reasons for this, the alleged abuser may no longer be working with them, and the abused person may feel threatened. When someone discloses to you remember you are not investigating

    • Do stay calm and try not to show shock
    • Do listen very carefully
    • Do reassure the person they have done the right thing by telling you
    • Do record what the person has told you using their words
    • Do tell the person you are treating the information seriously
    • Do be aware there may be the possibility of forensic evidence
    • Do reassure the person that they are not at fault and will not be blamed
    • Do tell the person that you will need to share their disclosure with the appropriate person i.e. Safeguarding Officer
    • Do not press the person for more details
    • Do not pass on the information to anyone other than the relevant Local authority Safeguarding Team.
    • Do not contact or speak to the alleged abuser about the allegation.  The accused person may need to be suspended.  This does not mean the person accused is guilty.  Enough time needs to be given for facts to be gathered
    • Do not promise to keep secrets
    • Do not make promises you cannot keep (such as ‘ I will not let this happen to you again’)


Procedure in the case of witnessing abuse and/or assault

    • Seek to ensure the person’s safety, without endangering yourself
    • Assess the situation and where someone is at severe risk of harm contact the emergency services by dialling 999
    • Contact the Safeguarding officer immediately
    • Seek to ensure the service user has no contact with the alleged abuser. It may be necessary to inform other staff that there has been an incident but information passed to them must be kept to a minimum


Procedure where a member of staff or volunteer has concerns of abuse and/or neglect

    • Discuss concerns directly with the Safeguarding Officer
    • If the concerns involve an adult working with service users, please refer to the Whistle Blowing Policy and Procedure for guidance


Informing families of service users

Green Tracks Enterprise aims to work with parents/carers in safeguarding matters as appropriate.


Informing external agencies

Green Tracks Enterprise will inform the Local authority in accordance with local Multi –Agency Safeguarding policies and procedures within 24 hours, in the event of a possible, alleged or suspected abuse or serious cause for concern.

When an incident of abuse has been perpetrated (or allegedly perpetrated) against an adult at risk who lacks capacity with regard to the specific issue, the Local Authority may appoint an Independent Mental Capacity Advocate (IMCA) under s 35 of the Mental Capacity Act 2005. The IMCA is usually appointed at the time of creating a safeguarding plan for the adult at risk and their role is to ascertain the individual’s wishes and preferences; to give support, and to explore alternative options with the person.


False Allegations of Abuse

People can sometimes make false allegations of abuse.

Formal risk assessments should be written for people who are known to have told falsehoods in the past about being victims.  All allegations of abuse must be heard and investigated but some allegations can be conducted more softly because of the record of previous falsehoods. The involvement of the police is generally helpful.

After an investigation has concluded that there is no evidence to support an allegation, the person accused should be given a written exoneration and acknowledgement of the stress involved in the investigation.


Suspension of a member of staff (employed or voluntary)

Green Tracks Enterprise recognises that when an allegation is made against an adult working with service users it can be a difficult and distressing experience for the adult concerned and others who are involved in reporting or managing the allegation, accordingly Green Tracks Enterprise will seek to support all such staff through the appropriate supervisors and other relevant colleagues.

When a member of staff or volunteer is suspended following a safeguarding allegation against them, it is important to remember that suspension is a neutral and not a disciplinary act. No presumption of guilt can or should be made.

Following the suspension of a member of staff or volunteer, neither the suspension nor the issues precipitating it should be discussed with others.

Where a member of staff or volunteer is returning to work following an investigation, specific measures will be put in place to support them.



Who is an adult at risk?

Care Act 2014 defines an adult at risk as a person aged 18 or over who ‘ 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 serious exploitation’ (Who Decides: Lord Chancellor’s Department 1997)

An adult at risk is a person who is unable, or less able, to protect themselves from harm, neglect or abuse that arises as a result of the action or inaction of others.

‘Safeguarding Adults’ (ADSS October 2005) proposes we need to ensure protection procedures are inclusive and enable any adult or child to receive an appropriate response. Safeguarding vulnerable adults is everyone’s business, raising a concern about abuse involves:

    • Recognising if a person is a child or adult at risk
    • Recognising signs and signals of abuse
    • Responding to disclosures
    • Acting when necessary to protect an adult and to preserve evidence
    • Reporting a disclosure, concern or allegation.

In addition “safeguarding adults at risk” emphasizes the public duty of all agencies to protect the human rights of all citizens in terms of helping people access mainstream services such as the police. It also emphasizes that safeguarding work is the responsibility of all agencies and must be effectively linked to other measures such as those for domestic violence which are overseen by the Community Safety Partnership.

The term “community care services” includes all social and health care services provided in any setting or context. The term “harm” should be taken to include not only ill treatment (including sexual abuse and forms of ill treatment that are not physical), but also the impairment of, or an avoidable deterioration in, physical or mental health. It should also be taken to include the impairment of physical, intellectual, emotional, social or behavioural development.

The impact of harm upon a person will be individual and depend upon each person’s circumstances and the severity, degree and impact or effect of this upon that person.

The following would indicate that the effect of harm for the person is likely to be significant:

    • The person’s life could be or is under threat, for example due to neglect or physical abuse;
    • There is or could be a serious, chronic and/or long lasting impact on the person’s health/physical/emotional,/psychological wellbeing;

The person has little or no choice or control over vital aspects of their life, environment or financial affairs.


What is Abuse?

Abuse is: ”A violation of an individual’s human and civil rights by another person or persons”

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 omission to act or it may occur when an adult at risk is persuaded to enter into a financial or sexual transaction to which he or she had 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. It is the person’s experience of an incident not the intent of the alleged abuser which is the basis for reporting.


Who can be an Abuser?

Children or adults at risk may be abused by a wide range of people including relatives and family members, professional staff, co-workers, volunteers, paid workers, other vulnerable adults, neighbours, friends and strangers.  There is often a particular concern when abuse is perpetrated by someone in a position of power or authority who uses his or her position to the detriment of a child or adult at risk. This is particularly relevant to people lacking mental capacity.


In what circumstances can abuse occur

Abuse can take place in any context.

The seriousness or extent of abuse is often not clear when anxiety is first expressed. It is important, therefore, when considering the appropriateness of intervention, to approach reports of incidents or allegations with an open mind. In assessing seriousness, the following factors need to be considered:

    • The vulnerability of the individual.
    • The nature and extent of the abuse.
    • The length of time it has been occurring.
    • The impact on the individual.


    • The risk of repeated or increasingly serious acts involving this or other vulnerable adults.


Remember: concerns, no matter how minor, should be reported to the Safeguarding Officer as this may lead to identifying patterns of behaviour that could lead to more serious incidents or alerts.

Restraint: Unlawful or inappropriate use of restraint or physical interventions and/or deprivation of liberty are physical abuse.


Types of Abuse and Signs and Signals of Abuse

It is important to be aware and alert to signals, non-verbal communication, or change of behaviour as this could indicate poor practice that may be being hidden or denied. Sexual and psychological signs and signals can be very similar due to the emotional impact and degree of manipulation that may be carried out in ‘grooming’ a victim.

Types of abuse  and Prevent Strategy is described in Safeguarding Training



We are not investigators, only those identified to do so as a result of a multi-agency Strategy Meeting or Safeguarding Adults Case Conference meeting should undertake investigations. The investigation is undertaken by Investigating Officer/s from appropriate statutory assessment services.

Green Tracks Enterprise may be invited to co-operate with any investigation. This may include:

    • Providing a statement
    • Attending strategy and case conferences


Preserving or Protecting Evidence

Note: In traumatic situations, it may not be possible to follow this guidance exactly.


Do the best you can

Your first responsibility is the safety and welfare of the abused person, but immediate action may be necessary to preserve or protect evidence.

Your action may be vital in any future proceedings and the success or failure of any investigation may depend upon what you do or not do in the time whilst you are waiting for the Police to arrive.


Confidentiality and Information Sharing

Adult at risk enquiries, investigations and conferences can only be successful if professional staff share and exchange all relevant information. That information must be treated as confidential at all times and staff will be bound by the ethical and statutory codes that cover confidentiality and data protection.

Disclosure of confidential personal information without the consent of the person providing it may take place under circumstances, which must be capable of justification. Problems around the disclosure of information can be avoided if the consent of the individual is obtained, preferably in writing, so long as they have mental capacity to consent.

Disclosure may be necessary in the public interest where a failure to disclose information may expose more harm than exposing information would.

All those providing information should take care to distinguish between fact, observation, allegation and opinion. It is important that, should any information exchange be challenged in respect of a breach of confidentiality or, for example, as a breach of the Human Rights Act, the information can be supported by evidence.

Concerns may arise within an agency as information comes to light about a person with whom the service is already in contact. Whilst professionals should seek in general to discuss any concerns with the individual and their carers and seek agreement to share the knowledge with other relevant agencies, this should not be done where such discussion and agreement-seeking will jeopardise the safety of the individual.

Information must be adequate, relevant and not excessive in relation to the purpose for which it is held and must be held no longer than is necessary for that purpose.

Each agency is responsible for maintaining their own records on work with vulnerable adult protection cases. The agency should have a policy stating the purpose and format for keeping the records and for their destruction.

Incident reports and any other documentation relating to an incident or a situation of abuse must be filed safely in a locked cabinet only to be seen by members of staff who are responsible for the welfare of the service user involved.


What to do if you have a concern about a Service User