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The John Townsend Trust
Working names within the The John Townsend Trust:
The Royal School for Deaf Children Margate
Westgate College
Community Living Services
Monkshill Farm
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VULNERABLE ADULT SAFEGUARDING
POLICY & PROCEDURES
(All Safeguarding information is confidential and should only be discussed with relevant
parties)
Rationale
1. The Royal School for Deaf Children Margate (RSDCM), Westgate College (WGC) and the
Community Living Services are required to provide a safe and secure environment for all
vulnerable adults and staff in which everyone is safeguarded from abuse and risk of potential
abuse and where all are valued and treated with respect. Programmes in College, residential and
community services will include opportunities to learn about personal, social and sexual
development including the development of appropriate relationships, personal privacy and
keeping safe.
2. The Trust has a duty to intervene in suspect vulnerable adult matters in order to:



protect the vulnerable adult and prevent further abuse
refer the vulnerable adult to the relevant agencies for assessment with a view to providing
appropriate intervention and treatment
collate evidence as may be required by relevant agencies for any subsequent and appropriate
legal proceedings
The Trust complies with Kent and Medway Safeguarding Policies, protocols and guidance and has
developed its own Vulnerable Adult Policy in accordance with these multi-agency guidelines.
Guidelines
1. All Trustees/Directors, Governors and staff and volunteers are required to ensure that they are
aware of their responsibilities with respect to protection and safeguarding matters.
2. All eligible staff are subject to enhanced Disclosure & Barring Services checks and volunteers are
subject to rigorous personal risk assessment before commencing employment or activities within
the Trust.
3. The Trust will establish a Vulnerable Adult Safeguarding Team chaired by a named person who
will be responsible for ensuring that policy guidelines and procedures are fully implemented.
Anyone over the age of 18 are defined as Vulnerable Adults. Any references to staff include volunteers.
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4. The Trust will implement the policy through regular meetings of this Vulnerable Adult
Safeguarding Team and in-service staff training. The Vulnerable Adult Safeguarding Team
consists of Senior Management and other professionals from the Trust.
The designated Co-ordinator is the chairperson of the Vulnerable Adult Safeguarding Team. The
chairperson is responsible for ensuring that:


They are aware of changes to legislation and requirements
Trust policies and procedures are amended to incorporate those changes
1. The Safeguarding Team are responsible for monitoring and reviewing the effectiveness of the
Trust’s policy and procedures in providing all vulnerable adults with a safe and secure
environment.
2. The Safeguarding Co-ordinator is required to make certain that appropriate records are properly
maintained and kept secure.
3. The Safeguarding Team will ensure that all information relating to abuse or suspected abuse
remains CONFIDENTIAL and that only those that NEED TO KNOW are informed.
4. Staff MUST NOT investigate allegations of abuse. Investigation of abuse is the legal
responsibility of the statutory agencies: Social Services and Police.
5. All staff, Trustees/Directors, Governors and volunteers must become familiar with Vulnerable
Adult Safeguarding Policies and Procedures as part of their induction programme.
6. Staff must follow required procedures to protect vulnerable adults and to record and report any
causes for concern, suspected abuse or actual abuse.
7. Any staff who believe that a vulnerable adult is in need of support and services, is at risk of
suffering or has suffered significant harm may contact Social Services, CQC or Police directly.
8. The Trust must ensure that staff are provided with appropriate support in order that they can
cope with any concerns or complications arising from their work relating to all safeguarding
matters.
Conclusion
The successful implementation of the policy guidelines and associated procedures will ensure abuse
is recognised and appropriately dealt with and that vulnerable adults are safeguarded by being
provided with a safe, caring and secure environment.
This Policy should be read in conjunction with our Policies on Anti Bullying, Whistleblowing, Physical
Intervention, Lone Working, Safer Recruitment and Guidance for Safer Working Practice for Adults
who work with Children and Young People.
Reviewed:
Passed by:
C Orpwood – Matron May 2012/May 2013/Feb 2014/Jan 2015/April 2016/May 2015/Jul 2015
Wendy Eadsforth – CEO/Principal – May 2012/June 2013/Feb 2014/Jan 2015/April 2016/May 2015
/July 2015
Passed by:
Board of Directors June 2012/July 2013/Feb 2014/Jan 2015/April 2016/May 2015/July 2015
Next Review due: April 2016
(EPIA Feb/Dec 2011)
Anyone over the age of 18 are defined as Vulnerable Adults. Any references to staff include volunteers.
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VULNERABLE ADULT SAFEGUARDING PROCEDURES
These procedures complement the Trust’s Vulnerable Adult Safeguarding Policy. All staff must follow
these when reporting any suspected cases of abuse.
A. All staff or volunteers employed by the Trust have a responsibility to ensure the health, safety
and welfare of all vulnerable adults. However, staff directly involved in education and care of
vulnerable adults have an increased duty of care and should monitor them at all times.
B. Whilst the young people are in the care of the Trust, staff should be particularly vigilant where a
vulnerable adult is known to have a history of safeguarding concerns or where any form of abuse
or ill treatment is suspected. Risk assessments should be undertaken and regularly updated.
These assessments will identify the perceived risks, quantify the level of risks and outline
strategies in order to manage and minimise levels of risk in particular situations.
All information relating to alleged or suspected abuse must remain CONFIDENTIAL.
All staff must become familiar with the definitions and classifications of abuse (see Appendix I Classification of Abuse) and the signs and symptoms of abuse (see Appendix II – Signs and
Symptoms).
Reporting Suspected Abuse
1. It is the duty of all staff irrespective of title and location to report cases of abuse or suspected
abuse. It is vital that detailed records are kept and that information is shared with the
appropriate people.
2. It is imperative that all information relating to abuse or suspected abuse remains CONFIDENTIAL.
Therefore only those that “need to know” should be informed.
3. Staff should report all concerns immediately to any member of the Safeguarding team or Senior
Staff On-Call, together with a written account of their concerns. See Appendix IV (Adult Cause for
Concern Report Form). Members of the Vulnerable Adult Safeguarding team or Senior On Call
will then inform the Safeguarding Team Co-ordinator, CEO/Principal, Responsible Individuals or
the Registered Manager. They will:
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consult with an appropriate member of the Vulnerable Adult Safeguarding Team. No
decisions will be made in isolation by one person;
if necessary, seek a consultation with Kent Social Services, Central Referral Unit 08458
247102, who will advise on further action;
inform an adult with parental responsibility for the vulnerable adult to pass information
concerning that vulnerable adult to Social Services unless PERMISSION SEEKING MAY PLACE
THE VULNERABLE ADULT AT RISK OF SIGNIFICANT HARM OR JEOPARDISE A CRIMINAL
INVESTIGATION;
notify regulatory bodies and placing authorities in conjunction with a formal referral
Any member of staff who believes that a vulnerable adult is in need of support and services, is at risk
of suffering or has suffered significant harm may make a referral direct to Social Services or the
Police.
Disclosures
Staff must remember that abuse is a difficult subject for vulnerable adults to disclose. They may find
it hard to talk about what is or has been happening to them for many reasons: age,
language/hearing/learning difficulties, mistrust of adults, protection of others, or that they do not
feel safe enough to talk.
Anyone over the age of 18 are defined as Vulnerable Adults. Any references to staff include volunteers.
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Where a vulnerable adult feels able to disclose abuse to an adult, it is generally a sign of a strong and
trusting relationship. Staff should ensure conversations are held in a quiet area free from
interruptions and be supportive. Staff should not question the vulnerable adult!
If a vulnerable adult chooses to talk to a member of staff and discloses abuse, it is important that the
following action is taken at the earliest opportunity:
 LISTEN Repeat their words.
 STOP Do not ask questions.
 REASSURE Tell them that they are not to blame: “It is not your fault.”
 BELIEVE Tell them that you believe what he/she has told you.
 AFFIRM “I am glad you told me. It was right to tell me. You have been brave to come and
tell me.”
Further considerations and actions include:
 CONFIDENTIALITY. Never tell them you will keep it a secret - tell them you must talk to
other people who can help. Ask if they want to talk to anyone else. Do not discuss with
colleagues, friends or neighbours or others.

FOLLOW UP. Maintain the trust built up in your relationship by making an arrangement
with the vulnerable adult to speak with them again later.

REPORT. Immediately report your understanding of what has taken place to a member
of the Vulnerable Adult Safeguarding Team (see Reporting Abuse). Report verbally and
write what the vulnerable adult said. Remember to date and sign what has been written
and give a copy to the appointed person. All information relating to abuse or suspected
abuse must remain confidential. This written account must be made either during or
immediately following the disclosure. Give as much detail as possible including what you
signed to the vulnerable adult as well as what the vulnerable adult told you. A member
of staff may not fully understand the vulnerable adult’s communication. This needs to be
acknowledged by the member of staff (it may be necessary to request the presence of an
appropriate adult with the necessary signing skills). There is a Vulnerable Adult Cause for
Concern Form available for this (Appendix IV). However, if such a form is not available,
write down the content of the conversation including what the vulnerable adult said and
signed and what you said and signed, recording the date and time. The Cause for
Concern Report must be handed to a member of the Vulnerable Adult Safeguarding
Team or the On-Call Duty Manager by the end of that working day/shift.

EXAMINATION. Do not attempt a detailed examination or remove the vulnerable adult’s
clothing to look at an injury. It may be possible to observe them in the course of normal
activities (e.g. in PE). If they wish to show injuries or where there is medical need for
examination, staff should contact the Medical Centre and arrange for a member of the
nursing staff to body map the vulnerable adult and treat any injury as required. This
should occur only as part of the evidence gathering process where concerns are being
clarified. Where there are clear concerns and a referral is made, the adult should only be
examined by a doctor recognised by the statutory agencies.
Staff should also be aware of the following before or after the disclosure:


Pressure on the vulnerable adult by the perpetrator or others may lead to later denial by
the adult.
A vulnerable adult may try to tell everyone about what has happened. If this occurs, the
adult should be directed to a member of the Vulnerable Adult Safeguarding Team or to a
named person.
Anyone over the age of 18 are defined as Vulnerable Adults. Any references to staff include volunteers.
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Where a vulnerable adult has chosen to report abuse to a member of staff who is not on the
Vulnerable Adult Safeguarding Team, that person will remain in a supportive role (should they and
the child/adult wish) and work with the Vulnerable Adult Safeguarding Team and other agencies as
appropriate. All referrals must be treated in CONFIDENCE – ON A NEED TO KNOW BASIS.
Safety of Victims
Changes in a vulnerable adult’s behaviour or any incidents where there is concern about possible
abuse should be recorded by members of staff in a factual, objective manner. These behaviours
should continue to be monitored in all settings in accordance with the Traffic Light guidelines (see
appendix III). Any further concerns should be discussed with the Vulnerable Adult Safeguarding Coordinator, CEO/Principal or members of the Vulnerable Adult Safeguarding Team.
As the majority of vulnerable people are residential, it is possible to keep them on site if they are in
need of an urgent place of safety. If it were necessary, it would be possible to keep a vulnerable
adult on site instead of sending them home for the weekend. This would have to be discussed and
agreed with the appropriate Social Services Department. Similarly, in the case of day
students/service users, it would be possible for them to stay on site again, only if considered
necessary by Social Services.
Should a tenant or tenant abuse situation occur, then the Vulnerable Adult Safeguarding team
member will support the alleged victim to contact the Police. The Vulnerable Adult Safeguarding
team member will also contact Social Services to advise them of the situation. If it is confirmed that
abuse has indeed taken place, The John Townsend Trust have the right to cancel the offending
tenant’s tenancy agreement with immediate effect. However, the decision to take this measure must
be agreed with the Senior Management Team before this is put into action. If this is agreed by the
Senior Management Team, the Vulnerable Adult Safeguarding team member of staff will contact
Social Services to advise them of this decision, and will request that Social Services support the
offending tenant to make alternative accommodation arrangements. NB: If the offending tenant is
being held in custody, by law they remain the responsibility of the Police for 48 hours after their
release.
Abuse within the Trust
If abuse occurs within the Trust or if there is suspicion or evidence to suggest that a member of staff
or fellow vulnerable adult has abused another person, the abuse must be reported to the Vulnerable
Adult Safeguarding Team and/or Social Services / Police.
Please also refer to the Trust’s Whistleblowing Policy.
If there is evidence to support suspicions of abuse, the alleged perpetrator of the abuse, or the
person who is accused, will be suspended without prejudice pending an investigation. In addition to
Social Services and the Police, the Chair of Governors, the LADO, CQC and OfSTED will be informed.
All staff appointments (including voluntary workers) are subject to the accepted vetting and barring
procedures in which disclosure of offences which might affect employment with vulnerable adults is
required.
The Disclosure & Barring Services (DBS) is consulted to ensure that employees or potential
employees are not listed as being unsuitable to work with vulnerable adults. The DBS also informs
the Trust of any concerns or warnings that may be included in their records at an enhanced level.
Should a staff member receive a conviction or caution whilst in post, this should be reported in
confidence to the CEO/Principal or the designated Safeguarding Co-ordinator.
Support and Guidance
Most staff involved in the care and education of the vulnerable adult are involved in giving support
and guidance to the vulnerable adult and in discussing areas of concern with them. Where staff are
Anyone over the age of 18 are defined as Vulnerable Adults. Any references to staff include volunteers.
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concerned about any issues, they must seek advice from any members of the Vulnerable Adult
Safeguarding Team. Support is also available (on request) for staff who receive disclosures.
Risk Assessment
Where vulnerable adults have a history of difficulty or vulnerability on entry into the Trust or where
there are subsequent concerns raised which might include matters concerning the vulnerable adult, a
Risk Assessment will be carried out. This Risk Assessment will identify different levels of risk across all
areas of the Trust. It will also outline strategies for supervising and managing vulnerable adults in
order to minimise risks for the vulnerable adult, for other vulnerable adults, for staff and for
members of the public.
Unexplained absence from college
When a vulnerable adult is repeatedly absent from college they could be at risk from significant harm
or abuse through sexual exploitation.
Systems are in place to ensure when a vulnerable adult does not return to college a telephone call is
made to the family on the day that they were expected to return. Managers who are also members
of the Safeguarding Team will be notified. Dependent on the answer given by parents or carers, our
safeguarding procedures will be followed. This will include telephoning the social worker if allocated
or the duty social worker.
Our usual registers will track patterns and trends of absence and therefore if a pattern is seen
emerging, the Safeguarding Team will be alerted to follow up.
Confidentiality
All information relating to abuse of a vulnerable adult is highly confidential. Information (written or
verbal) about the vulnerable adult abuse/protection issues must NOT be shared with other people
without the consent of the statutory authorities involved and/or the advice and agreement of the
Vulnerable Adult Safeguarding Team. Staff breaking the confidentiality ruling may find they have
broken the law and become subject to disciplinary or legal action.
Staff working directly with a vulnerable adult will be advised if a Vulnerable Adult Safeguarding issue
is being investigated and the names of key persons to whom issues should be referred. Staff must
understand that they are not to investigate or try to obtain details about Vulnerable Adult
Safeguarding issues. If staff have concerns, the consultation and referral procedures should be
followed as outlined in the traffic light summary attached.
MCA and DoLS – please see separate policy.
All written information relating to abuse must be kept in a secure place in which access to the
information is controlled by a member of the Vulnerable Adult Safeguarding Team.
Appendix V outlines the Trust’s approach to preventative measures and confidentiality.
Please also refer to Vulnerable Adult Safeguarding Handbook for all Trust staff and volunteers and,
Trustees/Directors/Governors.
Reviewed:
Passed by:
C Orpwood – Matron May 2012/May 2013/Feb 2014/Jan 2015/April 2016/May 2015/Jul 2015
Wendy Eadsforth – CEO/Principal – May 2012/June 2013/Feb 2014/Jan 2015/April 2016/May 2015
/July 2015
Passed by:
Board of Directors June 2012/July 2013/Feb 2014/Jan 2015/April 2016/May 2015/July 2015
Next Review due: April 2016
(EPIA Feb/Dec 2011)
Anyone over the age of 18 are defined as Vulnerable Adults. Any references to staff include volunteers.
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APPENDIX 1
CLASSIFICATION AND IDENTIFICATION OF ABUSE
Vulnerable Adult abuse and neglect are defined for the purposes of this policy within the categories
(DfE’s Circular 10/95 and Working Together: KCC Child in Need / Child/Vulnerable Adult procedure):
1. Physical Abuse may involve hitting; shaking; throwing; poisoning; burning or scalding; drowning;
suffocating or otherwise causing physical harm to a vulnerable adult. Physical harm may also be
caused when a parent or carer fabricates the symptoms of, or deliberately induces illness in a
vulnerable adult.
2. Emotional Abuse is the persistent emotional maltreatment of a vulnerable adult such as to cause
severe and persistent adverse effects on the vulnerable adult’s emotional development. It may
involve conveying to vulnerable adults that they are worthless or unloved, inadequate, or valued
only insofar as they meet the needs of another person. It may include not giving the vulnerable
adult opportunities to express their views, deliberately silencing them or ‘making fun’ of what
they say or how they communicate. It may feature age or developmentally inappropriate
expectations being imposed on vulnerable adults. These may include interactions that are
beyond the vulnerable adult’s developmental capability, as well as overprotection and limitation
of exploration and learning, or preventing the vulnerable adult participating in normal social
interaction. It may also involve seeing or hearing the ill-treatment of another. It may involve
serious bullying (including cyber-bullying), causing vulnerable adults frequently to feel frightened
or in danger, or the exploitation or corruption of vulnerable adults.
Some level of emotional abuse is involved in all types of maltreatment of a vulnerable adult
though it may occur alone.
3. Sexual Abuse involves forcing or enticing a vulnerable adult or young person to take part in
sexual activities, not necessarily involving a high level of violence, whether or not the vulnerable
adult is aware of what is happening.
The activities may involve physical contact, including assault by penetration (for example, rape or
oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of
clothing. They may also include non-contact activities, such as involving vulnerable adults in
looking at, or in the production of, sexual images, watching sexual activities, encouraging
vulnerable adults to behave in sexually inappropriate ways, or grooming a vulnerable adult in
preparation for abuse (including via the internet). Sexual abuse is not solely perpetrated by adult
males. Women can also commit acts of sexual abuse as can other adults and children.
4. Sexual Exploitation
“The sexual exploitation of vulnerable adults involves exploitative situations, contexts and
relationships where young people (or a third person or persons) receive ‘something’ (e.g. food,
accommodation, drugs, alcohol, cigarettes, affection, gifts, money) as a result of performing,
and/or others performing on them, sexual activities.
Sexual exploitation of a vulnerable adults can occur through use of technology without the young
person’s immediate recognition, for example, the persuasion to post sexual images on the
internet/mobile phones with no immediate payment or gain. In all cases those exploiting the
vulnerable adults have power over them by virtue of their age, gender, intellect, physical
strength and/or economic or other resources.”
“Vulnerable adults who are sexually exploited are the victims of sexual abuse, and their needs
require careful assessment. They are likely to be in need of welfare services and, in many cases,
protection. This group may include young people who have been sexually abused through the
misuse of technology, coerced into sexual activity by criminal gangs or the victims of trafficking.”
Anyone over the age of 18 are defined as Vulnerable Adults. Any references to staff include volunteers.
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5. Neglect is the persistent failure to meet a vulnerable adult’s basic physical and/or psychological
needs, likely to result in the serious impairment of the vulnerable adult’s health or development.
Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is
born, neglect may involve a parent or carer failing to:
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


provide adequate food, clothing and shelter (including exclusion from home or
abandonment);
protect a vulnerable adult from physical and emotional harm or danger;
ensure adequate supervision (including the use of inadequate care-givers) or
ensure access to appropriate medical care or treatment
It may also include neglect of, or unresponsiveness to a vulnerable adult’s emotional needs.
6. Discrimination is any form of harassment, slur or similar treatment including comments or acts
that are racist, sexist or based on a personal disability.
7. Financial or material Abuse is theft, fraud, exploitation, pressure in connection to Wills, property
or inheritance or financial transactions or the misuse or misappropriation of property,
possessions or benefits.
8. Medication Errors – Safeguarding Protocols
(Reference: Kent & Medway Safeguarding Board)
When would a medication error be considered as a safeguarding concern?
Incident should be assessed on an individual basis taking into account the needs, wishes and
health of the adult concerned, in addition to a discussion with a line manager, safeguarding lead,
pharmacist, pharmacy advisory service and, where indicated, with the social services agency. The
following examples show medication errors which are appropriate for making a safeguarding
referral (not an exhaustive list). Any medication error which:

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leads to harm or death
requires medical intervention to assess the adult for actual or potential harm e.g. GP
consultation or attendance at A&E
was deemed to be a deliberate act
was administered covertly without appropriate consultation/supervision
is part of a pattern or culture e.g. same drug, same carer or same adult, considering
frequency and duration of incidents
involves in the administration of a controlled drug
involves more than one adult e.g. missed drug rounds
involves medication often associated with misuse or abuse e.g. benzodiazepines or opioids
The safety and well-being of all adults at risk are paramount and continual errors, even without
harm, are a key indicator to prompt the review of systems regarding medicine management, staff
compliance and training needs. The NHS is required to report and investigate medication errors
as per specific organisational policy or procedure. Since July 2013, non-NHS providers are
required to notify CQC about medication errors that cause:
 a death
 an injury
 abuse or a safeguarding concern
 an incident reported to or investigated by the police
Organisations should seek advice from local health and safety advisors, pharmacies or
governance departments regarding the need to inform others such as:

Health and Safety Executive (HSE)
Anyone over the age of 18 are defined as Vulnerable Adults. Any references to staff include volunteers.
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

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National Patient Safety Authority (NPSA)
Medicines and Healthcare Regulatory Authority (MHRA)
Registrants Professional Body e.g. National Medical Council (NMC), General Medical Council
(GMC), Allied Health Professionals (AHP)
(See Appendix VI and VII)
Reviewed by:
Reviewed by:
Passed by:
Passed by:
Next Review due:
(EPIA Feb 2011)
Chris Orpwood – Matron May 2012/June 2013/Feb 2014/Jan 2015/May 2015/July 2015
Wayne Ross – Registered Manager April 2015/May 2015/July 2015
Wendy Eadsforth – CEO/Principal – May 2012/June 2013/Feb 2014/Jan 2015/April 2015/May 2015
/July 2015
Board of Directors – June 2012/July 2013/Feb 2014/Jan 2015/April 2015/May 2015/July 2015
April 2016
Anyone over the age of 18 are defined as Vulnerable Adults. Any references to staff include volunteers.
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Appendix II
VULNERABLE ADULT POLICY
ABUSE INDICATORS
NB: This table gives possible signs of abuse. Please be aware that some or all of these behaviours may occur without abuse taking place.
PHYSICAL ABUSE
PHYSICAL:
 Unexplained bruises, welts, lacerations,
abrasions, burns or factures affecting any part
of the body, in various stages of healing.
EMOTIONAL / PYSCHOLOGICAL ABUSE
PHYSICAL:
 Failure to thrive
 Delays in physical development or
progress.
SEXUAL EXPLOITATION AND GROOMING
PHYSICAL

Serious self-harming

Being sexually active

Sexually transmitted infections

Pregnancy, termination, miscarriage

Physical injuries – internal or external
SEXUAL ABUSE
PHYSICAL:
 Difficulty in walking, sitting down
 Stained or bloody underclothing
 Pain or itching in genital area
 Bruising, bleeding, injury to genitalia and/or
anal areas
 Vaginal discharge
 Bed wetting
 Excessive crying
 Unexplained sickness
BEHAVIOURAL:
 Flinching when approached or touched
 Reluctance to change clothes for PE
 Wary or frightened of adult contact
 Difficult to contact
 Apprehension when other children cry
 Crying irritably
 Afraid to go home
 Rebelliousness in adolescence
 Reported injury by adults
 Aggressiveness, impulsiveness, withdrawal,
depression
 Regression to child-like behaviour
 Apathy
 Poor peer relationships
 Panic in response to pain
 Financial Abuse
BEHAVIOURAL:
 Sucking, biting, rocking
 Anti-social, destructive behaviour
 Sleep disorders
 Inhibition of play
 Compliancy, passivity, aggressiveness,
demanding
 Inappropriate infant behaviour
 Impairment of development
BEHAVIOURAL:

Running away or going missing

Unauthorised absence/disengaging from
education

Overt sexualised dress

Excessive secretive use of phone,
particularly late at night

Reduced contact with family or friends

Meeting adults through the internet in an
unsafe way

Challenging or criminal behaviour

Having access to premises not know to
parent/carer

Sexualised risk taking, including on the
internet e.g. accessing pornography, sites
that promote hate or self harming

Taking or receiving indecent images of
themselves or peers (sexting)

Being associated with gangs and/or being a
member

Chronic alcohol and drug use
BEHAVIOURAL:
 Inappropriate sexual behaviour or
knowledge
 Promiscuity
 Sudden changes in behaviour
 Running away from home
 Wary of adults
 Unusual avoidance of touch
 Reporting assault
 Substance abuse
 Withdrawal - no trust in adults
 Over compliance
 Complaints of unexplained abdominal pains
 Eating, sleeping, bed wetting, soiling
problems
 Poor peer relationships
 Possessing unexplained money or gifts
 Sexually explicit drawings or stories
 Non-attendance
Anyone over the age of 18 are defined as Vulnerable Adults. Any references to staff include volunteers.
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NEGLECT
PHYSICAL:
 Consistent hunger
 Poor hygiene
 Inappropriate dress
 Consistent lack of supervision
 Unattended physical or medical needs
 Abandonment
DISCRIMINATION
PHYSICAL:

Any form of harassment

Racist comments

Sexist comments

Personal disability comments
FINANCIAL OR MATERIAL ABUSE
PHYSICAL:
 Theft
 Fraud
 Exploitation
 Pressure in connection to property,
financial transactions or misuse of property,
possessions or benefits
BEHAVIOURAL:
 Begging
 Stealing food
 Constant fatigue, listlessness
 Poor relationship with carer
 Frequent delays in collecting young person
BEHAVIOURAL:

Being withdrawn/isolated.

Fearfulness and anxiety.

Refused access to services.

Excluded inappropriately from normal
activities, conversation or peer group.

Resistance or refusal to access services
that are required to meet needs.

Expressions of anger and frustration.

Loss of self-esteem
BEHAVIOURAL:

Unusual or inappropriate monetary activity.

Lack of personal belongings, resources or
services which they can clearly afford.

Person managing an adult’s financial affairs
who is evasive or uncooperative.

Inappropriate dress/poor personal hygiene.

Stealing food.
Anyone over the age of 18 are defined as Vulnerable Adults. Any references to staff include volunteers.
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APPENDIX III
Vulnerable Adult Safeguarding
Guidelines for Staff
The health, safety and welfare of all young people who are in the Trust is of paramount importance. All
staff should be aware of the Trust’s Vulnerable Adult Safeguarding Policy and Procedures and ensure that
these are followed at all times. These guidelines detail the steps which staff should take in following the
three stage traffic light system; outlining increasing levels of concern.
STOP & THINK – OBSERVE RECORD MONITOR

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


All staff should be vigilant in their supervision of young people at all times.
Any indications that a vulnerable adult may be suffering, or at risk of, harm should be treated seriously and action
taken.
In some circumstances staff may be concerned but have little evidence over and above their knowledge of the
vulnerable adult – a ‘gut feeling’ that something is wrong.
They may feel that the vulnerable adult is behaving a different way towards other young people or staff or when
they are due to go home, on returning back or in the company of particular persons.
Staff should keep a record of these concerns and discuss them with colleagues to see whether they have similar
views or to see if they might know of any circumstances which would account for changes in behaviour.
It is important that records are kept in a short, concise and factual manner giving times, dates and observations
together with any other relevant details.
Cause for Concern forms may be used for this purpose.
GET READY – CONSULT AND CLARIFY
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If the initial monitoring and recording fails to resolve that feeling of unease – that “things weren’t quite right”
which prompted the action in the first place, talk to the designated Vulnerable Adult Safeguarding Co-ordinator
or a member of the Vulnerable Adult Safeguarding team.
Sharing observations and written records may help to clarify issues, placing them in context not only of adult
procedures but within the broader framework of the adult’s overall development and wellbeing.
If levels of concern are judged to warrant it, a consultation with the Central Referral Unit will be undertaken. In
these cases a member of the Vulnerable Adult Safeguarding Team – normally the co-ordinator - will outline
concerns to Social Services. A consultation number is assigned to the case and a record sent to the Trust.
Advice may range from:
 keeping a watchful eye on the situation,
 asking staff to clarify with the vulnerable adult what was seen and said,
 talking with parents/carers (e.g. in the case of unexplained marks or bruises
following a weekend at home or a holiday),
 contacting local Social Services in the vulnerable adult’s home area for more
information
To treating the case as a referral.
Anyone over the age of 18 are defined as Vulnerable Adults. Any references to staff include volunteers.
Page 13 of 18
GO – GRAVE CONCERN

Where there is clear evidence that a vulnerable adult’s health, safety and welfare have been or are likely to be at
risk, a referral should be made through a member of the Vulnerable Adult Safeguarding Team to the Central
Referral Unit, Out of Hours Team, Police or local Social Services as appropriate.

If a vulnerable adult discloses to a member of staff:
 Listen
 Reassure
 Record
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Do not directly question the vulnerable adult about any specific aspects of their disclosure.
Staff may clarify by asking “Tell me again…What happened…Where…Who”.
Do not ask any leading questions.
Do note what the vulnerable adult is saying to and what is said to the vulnerable adult.
It is important that staff keep a detailed account of what was said at the time.
Should any subsequent enquiry become an investigation with possible court action, the Trust records and
testimony would be likely to form an important part of the evidence.
The Vulnerable Adult Safeguarding Policy and Procedures are designed to protect children/vulnerable adults and
staff. Make sure staff are:
 Vigilant & professional.
 Know and understand the policy.
 Follow the procedures.
IF IN DOUBT CHECK IT OUT
Please familiarise yourself with Allegations Management Advisors (AMA) Guidance for Safer Working Practice for
adults who work with children and young people January 2009.
AMA network established by Department for Children’s Schools and Families.
Anyone over the age of 18 are defined as Vulnerable Adults. Any references to staff include volunteers.
Page 14 of 18
APPENDIX IV
The John Townsend Trust
The Royal School for Deaf Children Margate
Westgate College for Deaf People
Community Living Services
Monkshill Farm
If you have difficulty reading or understanding this document please request a larger print format
or further support from our HR Department
VULNERABLE ADULT SAFEGUARDING
CAUSE FOR CONCERN FORM
(Reviewed July 2015)
Name of person completing this report: ____________________________________________
This report should be completed IMMEDIATELY following any incident which raises any concern about possible
vulnerable adult abuse (e.g. on observation of an unexplained/suspicious injury, behaviour(s) observed by a member of
staff/ vulnerable adult or something said by a vulnerable adult which causes concern). This form must then be passed
to a member of the Trust’s Vulnerable Adult Safeguarding Team for action.
Vulnerable Adult(s) involved:
1) _______________________________________________________________________________
2) _______________________________________________________________________________
3) _______________________________________________________________________________
Place where incident/observation/injury/disclosure occurred:
___________________________________________________________________________________
Others present:
1) _______________________________________________________________________________
2) _______________________________________________________________________________
3) _______________________________________________________________________________
Please record exactly what you saw or heard:
This incident was reported to: ________________________________________________________
Anyone over the age of 18 are defined as Vulnerable Adults. Any references to staff include volunteers.
Page 15 of 18
Any further action:
Signature
of Reporter: ________________________________
Dated: _________________________________
Signature of Vulnerable
Adult Safeguarding Team Member:
________________________________________
Dated: _________________________________
Discussed at SMT on date:
_______________________________________________________
Members present:
_______________________________________________________
_______________________________________________________
_______________________________________________________
_______________________________________________________
_______________________________________________________
_______________________________________________________
Actions completed on date:
_______________________________________________________
Signature of Team member
closing the case:
_______________________________________________________
Anyone over the age of 18 are defined as Vulnerable Adults. Any references to staff include volunteers.
Page 16 of 18
APPENDIX V
PREVENTATIVE MEASURES
The curriculum in personal, social, health and moral education includes a focus on the development of normal, caring
and loving relationships in the context of ordinary living and personal development. It is intended that this curricular
programme will help young people to develop normal, healthy and caring attitudes.
Residential or enrichment curriculum programmes also emphasise personal and social development including the
development of appropriate relationships, personal privacy and self care together with social and independence skills
in domestic and community settings.
Educational programmes sometimes enlist the help of people from outside agencies, e.g. on subjects such as
“stranger-danger”. Where appropriate, vulnerable adults should have the Vulnerable Adult Safeguarding procedure
brought to their attention. They should know whom they should see to talk about concerns.
In-service training on vulnerable adults is provided to staff through induction and organised case discussions and
annually through in-service or external courses. Staff are able to consult with the Vulnerable Adult Safeguarding Coordinator, Vulnerable Adult Safeguarding Team members, specialist staff, including visiting specialists, as necessary.
CONFIDENTIALITY
All information relating to vulnerable adult abuse is highly confidential. Information (written or verbal) about
vulnerable adult abuse/protection issues must NOT be shared with other people without the consent of the statutory
authorities involved and/or the advice and agreement of the Vulnerable Adult Safeguarding Team. Staff breaking the
confidentiality ruling may find they have broken the law and become subject to disciplinary or legal action.
Staff working directly with a vulnerable adult will be advised if a vulnerable adult issue is being investigated and the
names of key persons to whom issues should be referred. Staff must understand that they are not to investigate or
try to obtain details about vulnerable adult issues. If staff have concerns, the consultation and referral procedures
should be followed as outlined in the traffic light summary (Appendix III).
All written information relating to abuse must be in a secure place in which access to the information is controlled by
a member of the Vulnerable Adult Safeguarding Team.
References:
Kent Safeguarding Procedures
Anyone over the age of 18 are defined as Vulnerable Adults. Any references to staff include volunteers.
Page 17 of 18
Appendix VI
Threshold Guidance for Assessing and Reporting Medication Errors
All agencies must have robust procedures in place to provide assurance in relation to the prescribing, dispensing, administration, storage and documentation of medicines and must
ensure their staff have the requisite level of training and competency regarding medicine management, (Registered Practitioners have a duty to work within their sphere of practice and
competency level).
Lower Level Harm
Tiers 1-2
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Follow organisations incident reporting procedure
Consider impact of recurrent minor incidents/errors
Consider impact of recurrent quality in care/practice concerns
Discuss with line manager/GP/Doctor/Pharmacist
Discuss with local safeguarding lead or local authority (KCC/Medway)
Consider patient/service users ability to consent
Consider need for safeguarding alert K&M Multi-Agency SA Protocols 2014
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Missed medication/
administration error on one
occasion – no harm or distress
experienced by adults at risk.
Delay in administration of
medication, but no significant
harm or distress experienced by
adults at risk.
Sufficient organisational
measures in place i.e. gaps in
provision and/or uptake of
training, supervision or audit.
Adults at risk and/or their
representative identifies
medication error, but are
satisfied with agency
actions/response.
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Recurring missed medication or
administration errors.
Medications not available when
vulnerable adult is transferred to or
discharged from care environment.
Insufficient organisational measures
in place to provide assurance.
Complaint from adults at risk and/or
their representative but, following
investigation, they are satisfied with
agency actions/ response.
Harmful
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No harm to adults at risk
Complete Safeguarding Alert
Follow local incident reporting procedure/investigation
Consider need to initiate SI/RCA investigation process
CQC notification
These incidents/concerns should be addressed under Multi-Agency Safeguarding
Protocols for Kent and Medway.

No harm to adults at risk
Significant Harm
Critical
Tiers 4
Tiers 3-4
Missed drug round or recurrent
episodes of missed medication or
error(s)
Medication error involving
controlled drug occurs.
Medication error involving insulin,
anticoagulants, antipsychotics,
dementia drugs.
Use of medication that is not
consistent with the adult’s needs
or expressed wishes.
Pain inadequately controlled
causing deterioration in physical
and/or mental health.
Unsafe practice or systems for the
prescription, dispensing,
administration, storage or
documentation of medicines.
Referrer or vulnerable adult and/or
representative express concerns
not resolved.
Actual harm/risk of significant harm
to one or more adults at risk
Anyone over the age of 18 are defined as Vulnerable Adults. Any references to staff include volunteers.
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Deliberate mal-administration of
medications.
Covert administration of medication
without proper medical authorisation
or consent from child at risk.
Adverse side effects experienced as a
result of the mal-administration of
medication.
Medical intervention required
following medication error e.g. GP
consultation / A&E attendance.
Inappropriate sedation of patient.
Absence of, or inadequate monitoring
of drug levels.
Medication error involves medication
often associated with drug misuse or
abuse e.g. benzodiazepines or opioids.
MCA not considered when an adult at
risk chooses not to take medication.
Actual harm or risk of significant harm to
one or more adults at risk

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
Complete Safeguarding Alert
Agencies contribute to statutory
investigation process
CQC notification
These incidents/concerns should be address
as potential criminal matter – contact
Police/Emergency Services immediately.
 Pattern of recurring errors or an
incident of deliberate maladministration that results in ill-health
or death of an adult at risk.
 Adults at risk and/or their
representative have identified serious
concerns and Tier 4 response is their
desired outcome.
 Urgent remedial action required and
implemented through safeguarding
adults or quality improvement
strategies.
Serious harm or death of adults at risk
Page 18 of 18
Appendix VII
Threshold Guidance for Assessing and Reporting Medication Errors
COMPLEX
Serious concerns
Thresholds for child
Protection Met
KCC Adult Social Care Contact details:
For a telephone consultation
9-5pm:
03000 416161
Out of Hours:
03000 419191
Secure email: CentralDutyTeam@kentgcsx.gov.uk
Secure fax:
0300 419191
HIGH RISK
Tier 3-4
Thresholds for adult
protection met
Managed under Kent &
Medway Safeguarding
Protocols
Safeguarding Alert to be
made
In addition
Consider need for internal
SI/RCA incident
investigation
Increasing Need or Risk
Tier 1-2
One off event or more targeted
service input/current controls
alleviates risk and addresses
need(s)
Discuss with social services/line
manager/medicines
management & manage under
internal processes/ procedures,
e.g. internal investigation, HR
Policy or Serious Incident/Root
Cause Analysis investigation
Consider need for Safeguarding
Alert
Anyone over the age of 18 are defined as Vulnerable Adults. Any references to staff include volunteers.
Medway Adult Social Care Contact details:
For a telephone consultation
9-5pm
01634 334466
Out of Hours:
0300 419191
9-5pm
01634 334504
Out of Hours:
03000 412345
Secure email: ss.acessandinfo@medway.go.uk.cjsm.net
Out of Hours: CentralDutyTeam@kentgcsx.gov.uk
CQC
Tel:
03000 616161
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REMEMBER
When sending confidential information:
Contact the recipient individual or agency
Confirm details of secure email/fax
Advise fax/email being sent
Check fax/email received