SAFEGUARDING CHILDREN
THROUGH THE COMMISSIONING
OF SERVICES POLICY
Page 1 of 21
Policy Owner
Policy Author
Directorate
Ratifying Committee
Date of Approval
Date of Review
Deputy Directors of Nursing & Quality
Deborah Brice
Nursing & Quality
Corporate Policy Sub Committee
March 2013
07.02.2013
Document History
Version
1
2
Final
Update/Review for CCG
Author
Deborah Brice
Deborah Brice
Deborah Brice
Deborah Brice
Page 2 of 21
Date
15.06.10
20.07.10
16.08.10
07.02.13
Contents
Section No. Section Name
Page No.
Executive Summary
4
1.
Introduction
5
2.
Terms / Acronyms Used
5
3.
Background
6
4.
National Policy
6
5.
Key Guidance and Legislation
7
6.
The Children Act 2004
8
7.
NHS Standards
9
8.
Local Arrangements
10
9.
Responsibilities of Clinical commissioning Group’s
10
10.
Contractual Service Agreement for Safeguarding
Children
12
11.
Special Requirements for Specific NHS
Organisations
16
12.
Assurance of Quality of Service Provision for
Safeguarding Children
17
13.
References
17
14.
Related Policies and Documents
17
Appendix 1
Equality Impact Assessment Stage 1 Screening
19
Appendix 2
Privacy Impact Assessment Stage 1 Screening
21
Page 3 of 21
Executive Summary
All NHS bodies have a statutory duty to make arrangements to Safeguard and
promote the welfare of children under Section 11 Children Act 2004. Following
the passage of the Health and Social Care Bill statutory responsibility
transferred from Primary Care Trust’s and Strategic Health Authorities to
Clinical Commissioning Groups and the NHS commissioning Board. The
Statutory responsibilities for NHS providers Safeguarding Children remains
unchanged1.
This policy sets out a framework for the statutory responsibilities of
safeguarding children requirements under Section 11 of the Children Act 2004
for East North and Hertfordshire Valleys Clinical Commissioning Groups.
It describes the Contractual Service Agreement for Safeguarding Children
including specialist requirements for specific NHS organisations and
independent Contractors.
It outlines the process for Assurance of Quality of Service Provision for
Safeguarding Children in all provider and commissioned services.
The policy sets safeguarding children in the context of National Guidance and
multi-agency partnership working within Hertfordshire
1
A Child –centred system: responding to the Munro Review of Child Protection (relates to
recommendation 8) DFE & DoH July 2011
Page 4 of 21
1.
Introduction
1.1
East & North Herts CCG is committed to being an organisation within
which diversity, equality and human rights are valued. We will not
discriminate either directly or indirectly and will not tolerate harassment
or victimisation in relation to gender, marital status (including civil
partnership), gender reassignment, disability, race, age, sexual
orientation, religion or belief, trade union membership, status as a
fixed-term or part-time worker, socio - economic status and pregnancy
or maternity.
1.2
East & North Herts CCG works to a framework for handling personal
information in a confidential and secure manner to meet ethical and
quality standards. This enables National Health Service organisations
in England and individuals working within them to ensure personal
information is dealt with legally, securely, effectively and efficiently to
deliver the best possible care to patients and clients.
1.3
East & North Herts CCG via the Information Governance Toolkit,
provides the means by which the NHS and CCG can assess our
compliance with current legislation, Government and National
guidance.
1.4
Information Governance covers: Data Protection & IT Security
(including smart cards), Human Rights Act, Caldecott Principles,
Common Law Duty of Confidentiality, Freedom of Information
Regulations and Information Quality Assurance
2.
Terms / Acronyms Used
CAF = Common Assessment Framework
Children’s NSF = National Service Framework for Children, Young People
and Maternity Services
DFE = Department for Education
HSCB = Hertfordshire Safeguarding Children’s Board
IMR = Individual Management Reviews
ISA = Independent Safeguarding Authority
LSCB = Local Safeguarding Children’s Board
NHS = National Health Service
CQC=Care Quality Commission
PCT = Primary Care Trust
Page 5 of 21
CCG=Clinical Commissioning Group
RCPCH = Royal College of Paediatrics and Child Health
SCR = Serious Case Review
SI = Serious Incident
3.
Background
3.1
Clinical Commissioning Groups should ensure that all providers from
whom they commission services have comprehensive and effective
policies and procedures to safeguard children.’
3.2
Clinical commissioning Group’s are expected to ensure that
safeguarding children are integral to clinical governance and audit
arrangements. Service specifications should include clear service
standards for safeguarding children and assurance should be sought
for compliance.
3.3
In relation to primary care providers Clinical Commissioning groups
should work in consultation with the Local Area Teams who will be
responsible from April 2013 for ensuring that all independent contactors
including GP practices and staff have robust systems and practices in
place to ensure they fulfil their role in safeguarding children.
Working Together to Safeguard Children 2010
All NHS Trusts are required to register with the Care Quality
Commission for the services they provide. As part of this registration
each Trust must declare its position with regard to compliance with the
Health and Social Care Act (Regulated Activities) regulation 2008, and
the Care Quality Commission (registration) regulations 2009.
Safeguarding is covered by regulation 11 and by outcome 7 in the
associated guidance.
The Care Quality Commission may seek evidence and assurance that
regulations and guidance have been complied with.
All GP practices and other primary medical services are required to be
registered with the Care Quality Commission by April 2013.
4.
National Policy
4.1
Following the death of Victoria Climbie in February 2000 and the
subsequent Laming Review 2009 there has been extensive national
published guidance and legislation to assist practitioners in working
together to safeguard and promote the welfare of children. The inquiry
report into Victoria’s death informed the Green Paper (Every Child
Matters) which sets out a vision of the outcomes to be achieved for all
children to;
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•
Be Healthy
•
Stay Safe
•
Enjoy & Achieve
•
Make a Positive Contribution
•
Achieve Economic Wellbeing
4.2
These outcomes were encompassed within legislation; the Children Act
2004 and the Health and Social Care Act 2012 which included the
plans for integrated delivery of services around the needs of children
through the creation of the Health and Wellbeing Boards, the
requirement for Local Authorities to set up Local Safeguarding
Children’s Boards (LSCBs) and a new duty on agencies to make
arrangements to safeguard and promote the welfare of children.
4.3
To comply with National Safeguarding Children requirements, East &
North Herts Clinical Commissioning Group has a duty to ensure that
safeguarding is reflected within all partnership agreements and that
NHS standard contracts require providers to comply with local
Commissioners Policies.
4.4
East & North Herts Clinical Commissioning Group fully recognise their
responsibilities in protecting and safeguarding the welfare of children.
We acknowledge responsibility for taking reasonable steps to promote
safe practice, protect children from harm, abuse or exploitation and to
work with providers to continually improve service quality.
5.
Key Guidance and Legislation
5.1
The key guidance and legislation for the Clinical Commissioning
Group’s regarding the discharge of safeguarding children
responsibilities is contained within;
•
The Children Act 1989
•
Letter from Jacqui Smith MP to PCT’s ; Child protection
responsibilities of Primary Care Trusts; January 2002
•
The Victoria Climbié Inquiry Report by Lord Laming; 2003
•
Lord Laming Progress Report 2009
•
Munro review DFE 2011
•
Every Child Matters Green Paper 2003
•
Every Child Matters ‘Change for Children’ 2004
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•
National Service Framework for Children, Young People and
Maternity Services 2004
•
The Children Act 2004
•
Health and Social Care Act 2012
•
Care Quality Commission (CQC) Essential standards of Quality and
Safety 2010
•
Statutory guidance on making arrangements to safeguard and
promote the welfare of children under s11 of the Children Act 2004
•
Arrangements to secure children’s and adult safeguarding in future
NHS The New Accountability and Assurance Framework - interim
advice 2012
•
Working Together to Safeguard Children 2010
6.
Children Act 2004
6.1
Section 11 of the Children Act 2004 places a duty on key persons and
bodies to make arrangements to ensure that in discharging their
functions they have regard to the need to safeguard and promote the
welfare of children. The NHS bodies covered by Section 11 are
Strategic Health Authorities, Designated Special Health Authorities,
Primary Care Trusts, NHS Trusts and NHS Foundation Trusts.
6.2
The Department for Children, Schools and Families (DCSF) have
published statutory guidance on making arrangements to safeguard
and promote the welfare of children under s11 of the Children Act
2004. This has been updated in 2010 to reflect Working Together to
Safeguard Children 2010.
6.3
Part 1 covers the general arrangements to safeguard and promote the
welfare of children and these are common to most of the agencies to
which the duty applies.
6.4
The key features at an organisational or strategic level are having:
•
senior management commitment to the importance of safeguarding
and promoting children’s welfare
•
a clear statement of the agency’s responsibilities towards children
available for all staff
•
a clear line of accountability within the organisation for work on
safeguarding and promoting the welfare of children
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•
service development that takes account of the need to safeguard
and promote welfare and is informed where appropriate by the
views of children and families
•
staff training on safeguarding of children for all staff working with or
(depending on the agency’s primary function) in contact with
children and families
•
safe recruitment procedures in place
•
effective inter-agency working to safeguard and promote the welfare
of children
•
effective information sharing
6.5
Part 2 of the guidance gives the arrangements to safeguard and
promote children’s welfare in different agencies. Chapter 5 relates to
the NHS.
6.6
Section 11 of the Children Act sets out clearly that Clinical
Commissioning Group’s and any services provided by them or by
others on their behalf should be undertaken with due regard to their
new legal obligations. All services, therefore, that are contracted by the
CCG, whether or not they form part of the NHS, must abide by the
legislation.
7.
NHS Standards
7.1
The Care Quality Commission essential Standards of Quality and
safety sets out the guidance requirements about compliance These
essential standards of quality and safety consist of 28 regulations (and
associated outcomes) that are set out in two pieces of legislation; The
Health and Social Care Act 2008 (Regulated activity) regulations 2010
and the Care Quality Commission (registration) regulations 2009.For
each regulation, there is an associated outcome
7.2
Regulation 11 Outcome 7: Safeguarding people who use services from
abuse with the requiring that ‘people are safeguarded from abuse or
risk of abuse and in their human rights are respected and upheld.
7.3
All the relevant NHS organisations are required to discharge their duty
under the Children Act 2004 and meet the above standards.
7.4
Section 11 makes clear that the services provided by, and those
contracted by Clinical Commissioning Group’s are required to abide by
the same legal obligations.
7.5
These standards therefore apply to all services commissioned by East
& North Herts CCG.
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8.
Local Arrangements
8.1
Hertfordshire Safeguarding Children’s Board:
8.2
The Hertfordshire Safeguarding Children’s Board (HSCB) established
in 2006 in accordance with s11 of the Children Act has a membership
drawn from public, private and voluntary organisations across
Hertfordshire who have responsibilities for children and their families.
There is an independent chair for the HSCB as required.
8.3
“The Local Safeguarding Children’s Board is the key statutory
mechanism for agreeing how the relevant organisations in each local
area will cooperate to safeguard and promote the welfare of children in
that locality and for ensuring the effectiveness of what they do.”
Working Together to Safeguard Children 20102
8.4
The HSCB have a number of sub-groups which report to the HSCB
main board. These include:
•
Serious Case Review subgroup
•
Learning and Development
•
Policies and Procedures
•
Improving Outcomes Group
•
Child Death Overview Panel
•
Safer Staffing
•
Audit and Performance analysis
•
Local Child Protection Forums
8.5
The web address for the LSCB in Hertfordshire is:
www.hertssafeguarding.org.uk
9.
Responsibilities of Clinical Commissioning Groups
9.1
East & North Herts CCG should:
•
work with Local Authorities to commission and provide co-ordinated
and, where possible, integrated services
•
identify a senior lead for children and young people to ensure their
needs are at the forefront of local planning and service delivery
2
Working Together 2012 is currently awaiting launch. This new document will separate
statutory requirements and guidance .The purpose of which is to promote localism. The
expectation is that guidance and policy is set locally.
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9.2
•
ensure that health services and healthcare workers contribute to
multiagency working
•
ensure they have in place a designated nurse and doctor who have
an over arching responsibility across the CCG area, which includes
all providers
•
ensure co-relate to Local Area Team with regard to Primary Care
Services under their commission
•
ensure that funding is available to enable the Named and
Designated professionals to fulfil their roles and responsibilities
effectively
•
ensure funding is available to contribute to the HSCB’s budget, as
agreed in the business plan
•
include clear service standards for safeguarding and promoting
children’s welfare in all commissioning arrangements
•
be accountable for their own safeguarding children’s processes and
those undertaken by agencies with whom they have commissioning
arrangements
•
ensure that clinical governance arrangements are in place to assure
quality of services provided and contracted by the CCG
•
co-ordinate the health component of serious case reviews and
complete the Health overview report
•
ensure that all health agencies with whom they have commissioning
arrangements are linked into the HSCB and that there is
representation from the agency and at an appropriate level of
seniority
•
ensure the East & North Herts CCG is represented on HSCB subgroups
•
provide the strategic health lead in interagency planning within the
CCG area
Clinical Commissioning Groups should also ensure that:
•
all Primary Care Teams have appropriate access to paediatricians
trained in assessing young people who may be experiencing abuse
or neglect
•
local arrangements, including having the necessary premises,
equipment and appropriately trained staff are in place for
undertaking forensic medical examinations
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9.3
The Accountable Officer of East & North Herts CCG has the
responsibility of ensuring that the health contribution to safeguarding
and promoting the welfare of children is discharged effectively.
9.4
The Area Team of the NHS Commissioning Board is responsible for
performance managing Primary Care and Dental Services
9.5
The NHS Commissioning Board is responsible for performance
managing CCGs.
10.
Contractual Service Agreement for Safeguarding
Children
10.1
Responsibility for Safeguarding Children
10.2
The Commissioning Framework for Health and Wellbeing 2006, places
the focus on reorientation towards promoting health and wellbeing,
‘investing now to reduce future ill health costs’.
10.3
Abuse of a child can have a serious impact on all aspects of the child’s
health, development and well being which can last through adulthood.
The high cost of abuse and neglect both to individuals and to society
underpins the duty on all agencies to be proactive in safeguarding
children.
10.4
The Heath and Wellbeing Boards, statutorily established from 2013,
replace the former Children’s Trusts.
10.5
Service Standards
10.6
In line with the Commissioning Framework for Health and Wellbeing
and in accordance CQC requirements, commissioners should include
clear service standards for safeguarding and promoting children’s
welfare in all commissioning arrangements. These are set out below.
10.7
The following standards should be included within contractual
agreements and be adhered to by all organisations providing services
that have been commissioned by the East & North Herts CCG. This
includes services solely or primarily for adults as they may be parents
or carers, cared for by children or young people or represent a danger
to children.
10.8
Professional organisations should create and maintain a culture and
ethos that reflects the importance of safeguarding and promoting the
welfare of children. Children and young people should be cared for
within child friendly environments by staff who have specific expertise.
10.9
Accountability
10.10 There should be;
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•
a lead senior manager who is informed about, and who takes
responsibility for the actions of their staff in safeguarding and
promoting the welfare of children
•
a clear line of accountability through the organisation which includes
all staff
10.11 Policy
10.12 Each organisation should have a comprehensive safeguarding policy
which is in line with national and HSCB guidance and which takes
account of guidance from any relevant professional body. Inherent within
any policy should be that children without exception have the right to
protection from abuse regardless of gender, ethnicity, disability,
sexuality or beliefs. This policy should be easily accessible by staff at all
levels and subject to periodic review and updating.
10.13 Staff Training and Continued Professional Development
10.14 Staff should be trained and competent to be alert to potential indicators
of abuse and neglect in children, know how to act on their concerns
and fulfil their responsibilities in line with LSCB procedures. To achieve
this standard all organisations should;
•
have a training policy covering all staff detailing, required skills and
competencies commensurate with their role and responsibilities
•
a training strategy should be in place for this policy to be achieved
see appendix 1.
10.15 This should be in accordance with;
•
the Common Core of Skills and Knowledge for the Children’s
Workforce 2005
•
suggested Learning Outcomes for Target Groups in Training and
Development ; interagency work to safeguard and promote the
welfare of children DCSF April 2006
•
the intercollegiate document, Child Protection Roles and
Competencies for Health Staff 2010
•
hold a database detailing the uptake of all staff training so
employers can be alerted to unmet training needs and training
provision can be planned.
•
have in place a training programme that is appropriate to the role of
staff and ensure that staff are released to attend the relevant
training
•
ensure training needs analysis is linked to appraisal
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•
enable and ensure provision of staff to have update training every 3
years as a minimum
•
ensure staff are aware of any new guidance or legislation and any
recommendations from Local and National Serious Case Reviews
and Internal Management Reviews and Partnership case reviews
10.16 Safe Recruitment and Vetting Procedures
10.17 There should be a policy in place for safe recruitment practices for
staff. Where a criminal record review is mandatory this must be
undertaken routinely and updated as required.
10.18 Employers must comply with new Disclosure and barring service2012.
It merges the criminal record bureau and the Independent safeguarding
authority. The Independent Safety Authority (ISA) decides who is
unsuitable to work or volunteer with vulnerable groups including
children, drawing information from various agencies, government
departments and the Criminal Records Bureau.
10.19 Managing Allegations Against Staff
10.20 Organisations should;
•
have in place procedures for responding when allegations are made
against people who work with children and comply with LSCB
policies and procedures, and guidance contained within appendix 5
of Working Together to Safeguard Children 2010
•
have a named senior officer who has overall responsibility for;
-
ensuring the organisation operates procedures for dealing with
allegations
-
resolves any inter-agency issues
-
liaises with the LSCB
-
seek advice from the Local Authority Designated Officer (LADO)
who;
-
provides advice and liaison
-
ensures cases are dealt with as quickly as possible
10.21 Inter-agency Working
10.22 Staff should be aware of and where appropriate trained to use the
Common Assessment Framework (CAF), 2006. Staff should work
together with other agencies in accordance with the HSCB policies and
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procedures for the area within that service is provided. All services
should have in place, policies and procedures that are in accordance
with national legislation and guidance including Working Together to
Safeguard Children 2010 and the Common Assessment Framework.
10.23 If staff have concerns that a child is or may be suffering significant
harm, staff should follow published guidance; What to do if you’re
worried a child is being abused; 2006.
10.24 Information Sharing
10.25 Organisations should have in place or have adopted local policies and
procedures for sharing of information where there are concerns for the
welfare of a child. Senior Managers should promote good practice in
information sharing according to the published national guidance:
Information Sharing; Guidance for Practitioners and Managers. DCSF
2008
10.26 Supervision
10.27 Organisations providing services should have a policy and
arrangements in place to provide staff with supervision and support to;
•
enable them to manage stresses within their work
•
promote good practice and quality assure the services they provide
•
ensure that staff use effective systems to record their work
•
follow local multi-agency policy and procedures
10.28 The level of supervision provided should be in accordance with the
degree and nature of contact that staff have with children, young
people and families.
10.29 A confidential service should be provided for staff for emotional support
when dealing with cases of child abuse.
10.30 Staff should be aware how to contact their own NHS Trusts, Named
Professional(s) for safeguarding or, if working outside an NHS Trust,
the CCG’s Named and Designated Safeguarding Professionals.
10.31 Vulnerable Children
10.32 Staff should be alert to the increased likelihood of harm being suffered
by disabled children and those living in special circumstances, whose
needs may not be recognised by staff employed in providing services.
10.33 Responses to Incidents and Complaints
10.34 There should be a policy with regard to incidents and complaints
relating to any aspect of safeguarding children. This should include the
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need to inform the Senior Management Lead for Safeguarding within
the organisation.
10.35 Thresholds for raising a Serious Incident (SI) should be clear and if
required advice should be sought from Named Professionals for
Safeguarding.
10.36 Within the NHS Trust the Director responsible for safeguarding
children, Named Nurse, Doctor or Professional for that Trust should be
informed about any incident or complaint relating to child protection. In
all cases the Designated Nurse should be informed.
10.37 Serious Case Reviews (SCRs)
10.38 SCRs are conducted in accordance with Chapter 8 of Working
Together to Safeguard Children 2010
•
when a child dies, including by suicide, or is seriously injured and
abuse or neglect are known or suspected to be a factor in the
death/injury
•
where the case raises concern about inter-agency working when a
child has suffered significant harm
10.39 Named Safeguarding Professionals within NHS Trusts should be
provided with additional time in which to conduct Individual
Management Reviews (IMR), which form part of Multi-Agency Serious
Case Reviews (SCRs). They will be supported by the Designated
Health Professionals. IMRs should be conducted according to the
HSCB and NHS Hertfordshire SCR Guidance
10.40 Child Death Reviews
10.41 LSCBs have a statutory duty to review all child deaths in accordance
with Working Together to Safeguard Children 2010.
10.42 Organisations involved with the management of child deaths, must be
familiar with the relevant policies and procedures for that local area and
respond accordingly.
11.
Special Requirements for Specific NHS Organisations
11.1
All NHS Trusts, excluding Ambulance Trusts, NHS Direct sites and
NHS walk-in centres should designate a Named Doctor, Named Nurse
and Named Midwife (where relevant, e.g. maternity services provided)
for Safeguarding Children who provide advice and expertise for
colleagues and other agencies and promotes good professional
practice within the Trust.
11.2
Ambulance Trusts, NHS Direct sites and NHS walk-in centres should
designate a Named Professional for Safeguarding Children.
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12.
Assurance of Quality of Service Provision for
Safeguarding Children
12.1
Organisations should;
13.
•
be able to provide assurance that their safeguarding practice meets
the Health and Social Care Act ‘essential standards of quality and
safety’ CQC 2010
•
be able to demonstrate that they are working towards meeting
standard 5 of the Children’s NSF with full compliance being
achieved by 2014
•
be able to demonstrate that they have in place arrangements as
described in paragraph 3.2
•
undertake regular case audits with reference to the standard of
record keeping, sharing information and multi-agency liaison
•
be able to demonstrate that they have acted on recommendations
from local SCRs and National Inquiries.
References
See section 5: Key Guidance and Legislation, plus:
Health and Social Care Act 2008
CQC essential standards of quality and safety 2010
The Commissioning Framework for Health and Wellbeing, 2006
The Common Core of Skills and Knowledge for the Children’s
Workforce, 2005
Child Protection Roles and Competencies for Health Staff, 2010
Safeguarding Vulnerable Group Act, 2006
Common Assessment Framework (CAF), 2006
What to do if you’re worried a child is being abused, 2006
Information Sharing; Guidance for Practitioners and Managers. DCSF
2008
14.
Related Polices and Documents
HSCB Safeguarding Children Policy and Procedures 2010
East & North Herts CCG Allegations and Suspicions of Child Abuse
against Staff
Page 17 of 21
East & North Herts CCG Serious Incident Policy
East & North Herts CCG SCR process
Page 18 of 21
Appendix 1 – Equality Impact Assessment Stage 1 Screening
1. Policy
Title: Safeguarding Children through the
Commissioning of Services Policy
Proposed
Date of Completion:
Existing
March 2013
EIA Completion Details
Names & Titles of staff involved in completing the
EIA:
Deborah Brice. Designated Nurse Safeguarding
Children, Looked after Children and Care Leavers.
Review Date: March 2014
2. Details of the Policy. Who is likely to be affected by this policy?
Staff
Patients
Public
3. Impact on Groups with Protected Characteristics
Probable impact on group?
Positive
Adverse
None
High,
Medium or
Low
Please explain your
answers
Age
Being married or in a
civil partnership
Disability, inc. learning
difficulties, physical disability,
sensory impairment etc.
Having just had a baby
or being pregnant
Race, ethnicity, nationality,
language etc.
Religion or belief
Sex (inc. being a
transsexual person)
Sexual Orientation
Other:
No impact on any of
the groups above.
Please explain and provide evidence
The NHS of the 21st century must be responsive to the needs of different
patients and individuals within society, and challenge discrimination on
the grounds of age, gender, ethnicity, religion, disability and sexuality.
The NHS will treat patients as individuals, with respect for their dignity.
Patients and citizens will have a greater say in the NHS, and the provision
of services will be centred on patients' needs. ENHCCG does not
discriminate on grounds of sex, age, sexual orientation, ethnicity,
educational level, employment, disability, marital status or religion.
4. Which equality legislative Act applies to the policy?
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Human Rights Act 1998
Equality Act 2010
Health & Safety Regulations
Mental Health Act 1983
Mental Capacity Act 2005
5. How could the identified adverse effects be minimised or eradicated?
6. How is the effect of the policy on different Impact Groups going to be monitored?
Page 20 of 21
Appendix 2 – Privacy Impact Assessment Stage 1 Screening
1. Policy
Title: Safeguarding Children through the
Commissioning of Services Policy
Proposed
Date of Completion:
March 2013
Existing
PIA Completion Details
Names & Titles of staff involved in completing the
PIA:
Deborah Brice. Designated Nurse Safeguarding
Children, Looked after Children and Care Leavers.
Review Date: March 2014
2. Details of the Policy. Who is likely to be affected by this policy?
Staff
Patients
Public
Yes
Technology
Does the policy apply new or additional
information technologies that have the
potential for privacy intrusion?
(Example: use of smartcards)
Identity
By adhering to the policy content does
it involve the use or re-use of existing
identifiers, intrusive identification or
authentication?
(Example: digital signatures,
presentation of identity documents,
biometrics etc.)
By adhering to the policy content is
there a risk of denying anonymity and
de-identification or converting
previously anonymous or de-identified
data into identifiable formats?
Multiple Organisations
Does the policy affect multiple
organisations?
(Example: joint working initiatives with
other government departments or
private sector organisations)
Data
By adhering to the policy is there
likelihood that the data handling
processes are changed?
(Example: this would include a more
intensive processing of data than that
which was originally expected)
If Yes to any of the above have the
risks been assessed, can they be
evidenced, has the policy content and
its implications been understood and
approved by the department?
No
Please explain your answers
Safeguarding children requires a
multi-agency response with all
statutory partner agencies.
This policy will impact positively on the safeguarding
children agenda and partner agencies. It has been
endorsed by the Hertfordshire Safeguarding Children
Board Policy and procedure sub-group.
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