PDSA Policy Safeguarding
PDSA is fully committed to safeguarding the welfare of vulnerable groups i.e. children and adults at risk.
PDSA encourages a culture where people are easily able to speak up if they feel something is wrong. This policy, in conjunction with the associated procedures, enables anyone to easily report worries or concerns relating to a child or adult at risk, whilst making sure that those concerns are dealt with appropriately and in a sensitive manner.
All colleagues are expected to behave with respect and consideration towards other colleagues, to clients and supporters at all times and to uphold PDSA's values. Colleagues have a moral obligation, as well as a requirement to adhere to this policy and the related legislation and guidance.
In this policy and the supporting procedure the following definitions will apply:
- third party means any individual or organisation PDSA comes into contact with and includes actual and potential clients, customers, suppliers, contractors, distributors, business contacts, agents, sponsors, advisors, workers and officials, politicians and political parties.
- colleagues means all individuals acting on PDSA's behalf, including all employees, agency staff, volunteers, Council and Members of any other person associated with PDSA's subsidiaries or their employees, wherever located.
Safeguarding Procedure – Objectives
The objectives of this policy and the supporting procedure are to:
- Outline PDSA's commitment to the safeguarding and protection of children and adults at risk;
- outline the measures and practices in place to safeguard and promote the welfare of children and adults at risk who come into contact with PDSA;
- set out the responsibilities of PDSA and all colleagues, in observing and upholding our position on minimising the risk of unacceptable behaviour; and
- provide information and guidance to our colleagues on how to recognise and deal with potentially unacceptable situations.
This policy applies to all colleagues and third parties where appropriate.
PDSA will monitor compliance with the policy and procedure on a quarterly basis and review it periodically through the Safeguarding Steering Group.
1.1 What is safeguarding?
Safeguarding is about protecting the health, wellbeing and human rights of children and adults at risk, to live free from abuse, harm and neglect. This includes employees, volunteers, clients, supporters and other individuals whom we may come into contact with.
A child or young person is defined by the Children Act 2004 as ‘a person who has not yet reached their 18th birthday’. The terms ‘child’ and ‘young person’ are interchangeable.
An adult at risk is defined by the Care Act 2014 as ‘an adult who has needs for care and support by reason of mental or other disability, age or illness and is experiencing, or at risk of abuse or neglect and as a result of those care and support needs is unable to protect themselves from either the risk of, or the experience of abuse or neglect’.
Safeguarding involves the process of reporting worries or concerns and taking the appropriate action to keep children and adults at risk safe from all forms of abuse, including physical, emotional and sexual harm. The term safeguarding also encompasses preventative measures that are put in place such as recruitment protocols, working practices and guidance and reporting mechanisms.
For any concerns that are not related to children or adults at risk please refer to PDSA’s other complaint resolution procedures: Whistleblowing, Bullying and Harassment, Volunteer Problem Solving and Grievance.
1.2 What is Abuse?
Abuse can occur in several ways:
- Physical Abuse: Non-accidental use of force that results in bodily injury, pain, or impairment. This includes, but is not limited to, being slapped, burned, cut, bruised or improperly physically restrained.
- Sexual Abuse: Non-consensual sexual contact of any kind. This includes, but is not limited to, forcing sexual contact with self or forcing sexual contact with a third person.
- Emotional Abuse: Wilful infliction of mental or emotional anguish by threat, humiliation, intimidation or other abusive conduct. This includes, but is not limited to, isolating or frightening a child or adult.
- Financial Exploitation: Improper use of an individual's funds, property, or resources by another individual. This includes, but is not limited to, fraud embezzlement, forgery, falsifying records, coerced property transfers or denial of access to assets.
- Active neglect: The willful failure by a caregiver to fulfil care-taking functions and responsibilities. This includes, but is not limited to, abandonment, deprivation of food, water, heat, cleanliness, eyeglasses, dentures, or health- related services.
- Passive neglect: The non-willful failure to fulfil care-taking responsibilities because of inadequate caregiver knowledge, infirmity, or disputing the value of prescribed services.
- Self-Neglect: The adult's inability, due to physical and/or mental impairments, to perform tasks essential to caring for oneself.
Abuse in one or more of the above forms can occur within a range of situations including, but not limited to, domestic violence, bullying, institutional abuse, discrimination, hate crime, self-harm, sexual exploitation and trafficking, forced marriage and honour-based violence.
We all have a moral responsibility for Safeguarding, especially the welfare and safety of children and adults at risk. Colleagues at all times are expected to show respect for, and understanding of, the rights, safety and welfare of the children and adults at risk they engage with, and will conduct themselves in a way that reflects the values of PDSA and in line with this policy.
2.1 Overall Responsibilities
The Council of Trustees have overall responsibility for Safeguarding within PDSA with the Director of Human & Corporate Resources, being the overall Director responsible.
2.2 Colleagues Responsibilities
All colleagues should have an awareness of this policy and understand how to comply with its requirements.
As representatives of PDSA, all colleagues must act with honesty and integrity at all times.
Where colleagues have worries about suspected abuse, either an external threat to PDSA or suspicions about the actions of another PDSA colleague, they must speak up and report this as soon as possible. PDSA and its people have a duty of care to help, protect and safeguard the welfare of children and adults at risk whom they may come into contact with during the course of their activities.
Colleagues are responsible for declaring any convictions in line with the Rehabilitation of Offenders Act 1974 on application to PDSA. They are also responsible for declaring any subsequent convictions of any nature during the course of their employment / volunteering experience at PDSA. Failure to do this may result in disciplinary action.
2.3 Line Manager Responsibilities
Line Managers ave an additional responsibility to embed good safeguarding practice, encourage a culture of openness and understanding within their teams. Line Managers must:
a) Ensure that all colleagues working in their teams are aware of PDSA's approach to safeguarding and ensure our colleagues, clients and supporters and protected from harm.
b) Ensure risks are identified in their environment and procedures and controls are in place to minimise those risks of safeguarding issues within their areas.
c) Ensure that procedures and controls within their teams are complied with.
d) Ensure that all colleagues within their teams are familiar with this policy and with the warning signs of safeguarding issues.
e) Ensure that colleagues feel able to speak up and pass on any worries or suspicions of safeguarding issues and that they are escalated in line with this procedure and/or the Working with Young Persons and Adults at risk Policy.
3.0 Reporting Concerns
PDSA encourages individuals to feel able to raise concerns internally, sensibly and responsibly without fear of reprisal or victimisation. PDSA will not tolerate any victimisation of individuals, including those who have raised a genuine concern under this procedure.
If there are worries, an allegation or an incident involving the welfare of a child or adult at risk (ie. a safeguarding issue) this should be passed on and reported immediately as set out below. It is important to note worries do not need to be proven before they are passed on.
- In line with the Working with Young Persons and Adults at risk policy the matter should be reported to the Area Veterinary Manager (AVM), Area Retail Manager (ARM) or Head of Department as appropriate.
- Colleagues may also ‘Speak Up’ about any concerns or worries they may have by contacting the dedicated Speak Up free telephone number, email inbox or web page.
4.0 Managing Concerns about the Behaviour of Employees of Volunteers
Where allegations of inappropriate behaviour in contravention of this policy are made against an employee, a thorough investigation will be carried out. Subject to the outcome of the investigation, this could result in disciplinary action up to and including dismissal for gross misconduct.
Where the allegations involve a volunteer the Volunteer Problem Solving procedure will be invoked and where necessary the Volunteer Agreement will be terminated.
In all cases, a decision will be made as to whether the suspected or alleged incident needs to be referred to the relevant authority e.g. the police and /or social services etc.
In consultation with the Director of Human & Corporate Resources and the Director General, safeguarding incidents, will be fully disclosed to the Charity Commission, in line with their guidance, as a Serious Incident Report and other relevant authorities as required.
5.0 PDSA's Activities
As a diverse organisation, we recognise that we carry out a number of different activities which will involve working with or supporting children and/or adults at risk. It is important for us to understand the practices that are in place to ensure safeguarding
5.1 Delivering our Public Benefit
At times our veterinary teams may interact with clients that may be adults at risk or children. When working with vulnerable clients our veterinary colleagues must use their judgement to assess whether they have the mental capacity to consent to procedures and associated costs.
In these cases, where veterinary colleagues have concerns they should identify whether the client has someone who can support them at each appointment or through the appointment of a long-term agent who will act on the clients behalf.
In addition, at times, veterinary staff may encounter vulnerable clients who are emotionally distressed. In these cases, veterinary staff are expected to follow the guidelines set out in the Dealing with Emotionally Distressed Clients guidelines and report any concerns through line management where a decision can be made as to whether the matter needs to be reported to the appropriate authorities.
There may be times where our veterinary staff experience displays of inappropriate behaviour from clients. PDSA does not expect its staff to tolerate this and immediate action should be taken to promote the safety of staff and other individuals present on the premises. The Inappropriate Behaviour process offers guidance and support on what to do in this situation.
There may also be situations where veterinary colleagues recognise the signs of potential animal abuse and have concerns of wider domestic abuse involving our clients, in these circumstances concerns should be discussed with the individual’s line manager in the first instance and escalated appropriately in order to reach a decision on whether any follow up action should be taken. Further guidance relating to reporting animal abuse can be found in the Reporting Cases of Suspected Cruelty guidelines.
When fundraising, the Code of Fundraising Practice, including (Treating Donors Fairly), is followed in order to ensure protection of vulnerable donors
5.3 Working with Volunteers
The Working with Young Persons and Adults at risk Policy is followed, in order to ensure protection of young people and adults at risk.
5.4 Working in the Community
When undertaking community activities where children may be present, which may include school visits, Pet Check vehicles or other community groups, risk assessments are undertaken and any additional appropriate measures are put in place. This includes ensuring PDSA employees are always accompanied by a teacher, parent or guardian.
6.0 Recruitment Practices
In order to ensure that our people feel and are safe we adopt the following practices throughout our recruitment activity.
6.1 Safe Recruitment
Our colleagues are recruited knowing what behaviours are expected of them. These behaviours underpin everything we do.
Our safer recruitment practices are currently under review, in the interim period please contact your HR Shared Services should you have any queries or concerns regarding our recruitment practices.
6.2 Disclosure & Barring Service (DBS) Checks
PDSA will ensure it regularly assesses the requirement for roles, both new and existing, to be DBS checked in every department. Where a DBS check is considered essential, for a role, activity or project involvement, a check will be undertaken prior to the commencement in that role, activity and/or project.
Periodic rechecks will be undertaken at a frequency appropriate for the role; in any case, this will be as a minimum requirement every three years. However, it is expected that colleagues will make us aware immediately of any changes that may affect them with regards to this.
PDSA employees should also participate in regular training and departmental meetings which include consideration of lone working, safeguarding issues and appropriate policies.
Awareness of this policy forms part of the induction process for all new colleagues. Further role specific training is provided where required.
All existing colleagues will complete annual refresher training at a level appropriate to their role, on how to implement and adhere to this policy.
It is not possible to provide an exhaustive list of safeguarding scenarios or indicators of abuse, so colleagues are strongly encouraged to use their training, experience and judgement in determining when to take action in relation to an identified safeguarding concern.
Whilst safeguarding indicators or warning signs can be extremely varied the below examples may help to aid understanding:
- A Line manager is verbally abusive towards a young volunteer
- Persistent requests for a donation are made from an adult at risk
- A volunteer, who is classed as an adult at risk, informs their line manager they are being physically abused at home
- A volunteer inappropriately touches a young volunteer
- A young volunteer is left to run the shop alone in the absence of the Shop Manager
- An adult at risk volunteer enters into a relationship with a paid member of staff.
8.0 Monitoring and review
The Director of Human & Corporate Resources will chair the Safeguarding Steering Group and coordinate a quarterly review of any concerns raised, which will be presented to the Senior Management Team. No specific personal details with regards to the concerns will be included in the summary. Safeguarding is a standard agenda item at full Council meetings. The Director General will provide an update of any concerns raised to the Chairman of PDSA’s Council and the Trustees.
The Director of Human & Corporate Resources will also proactively monitor the overall implementation of this policy and its effectiveness to ensure it continues to accomplish the policy statement. The suitability, adequacy and effectiveness of the policy and procedure will be considered and any improvements identified will be made as soon as possible.
To ensure its effectiveness and that it remains fit for purpose, this procedure will be reviewed annually by the HR department.
Supporting procedures and Information:
Working with young people and adults at risk Policy
Young & vulnerable person’s risk assessment
Generic risk assessment – following adoption of the Safeguarding Policy
Dealing with emotionally distressed clients
Reporting cases of suspected cruelty guidelines
Inappropriate behaviour process
Code of Fundraising Practice
Bullying & Harassment Procedure
Problem Solving Procedure for Volunteers