Safeguarding policy

Version 1.0 February 2025

  1. Scope
  2. Purpose and objectives
  3. Policy statement
  4. Definitions
  5. Our approach
  6. Compliance
  7. Sustainability
  8. Responsibilities
  9. Equality, diversity and inclusion
  10. Related documents
  11. Legislation and regulation
  12. Review
  13. Appendix A – Examples of abuse

1 - Scope

Safeguarding people is everyone’s responsibility. Some of our customers are at risk of abuse, harm, or neglect (including self-neglect). We all have a responsibility to protect them.

This policy applies to all employees working within Sovereign Network Group (SNG). This includes those working in both a paid and voluntary capacity, Board members and those working for SNG as a contractor or sub-contractor. It also applies to customers of SNG who concerns regarding an adult may have who reside or visit properties owned or managed by SNG.

This policy covers the safeguarding of all customers over the age of 18, regardless of tenure type, who live in properties owned or managed by Sovereign Network Group (SNG). All instances of suspected or actual abuse towards children will be managed in accordance with this policy and associated procedures.

Children and Young People Safeguarding Policy should be read in conjunction with this document in case under 18’s are involved in any case.

Where our employees have been emotionally impacted by supporting customers with safeguarding issues, we’ll make sure they have the help and advice they need. Anyone who needs support can contact their line manager, mental health first aiders or the Employee Assistance Programme (EAP). Where there has been a serious incident, we will refer impacted people to the EAP or provide group or individual critical incident support internally or via a commissioned provider.

2 - Purpose and objectives

  • Ensure that SNG promotes and enables safeguarding regardless of any support need, through appropriate training and raising awareness of the tools and powers available to deal with abuse and neglect
  • Explain what safeguarding is, the types of harm, abuse or neglect and outlines the steps we’ll take to identify and respond to safeguarding concerns
  • Outline SNG’s approach to dealing with safeguarding adults at risk of harm, abuse or neglect who use or are connected to our services
  • Develop a culture that does not tolerate such abuse, and which encourages people to raise concerns of what they see, hear, are told or have a gut feeling about
  • Outline how we will work with our service partners to develop partnership working with other agencies to support safeguarding
  • Outline how we will work with appropriate local authority departments and the police to support them in fulfilling their statutory duties
  • Outline SNG’s expectations of partners who are in contract with us and are working on our behalf to have appropriate safeguarding procedures in place and to raise safeguarding concerns with us
  • Comply with legal and regulatory requirements.

3 - Policy statement

We want to ensure customers are safe and secure in their homes, and feel they are being treated fairly and with respect. We have a duty of care to our customers, and we will always report our concerns to the local authority and/or police as appropriate, working in partnership with other agencies to address any safeguarding issues.

We’ll always take time to understand the situation, making sure that our response is customer centred. We’ll be helpful, sensitive and supportive – providing quick and straightforward advice to reduce the risks they face.

SNGs approach in underpinned by the six principles of safeguarding set down in the Care Act 2014. These principles are:

  • Prevention: it is always preferable to take action before harm occurs.
  • Proportionality: the least intrusive response appropriate to the risk presented.
  • Protection: support and representation for those in greatest need.
  • Empowerment: people being supported and encouraged to make their own decisions and informed consent.
  • Partnership: local solutions through services working with communities, who can have a key part to play in preventing, detecting and reporting abuse and neglect.
  • Accountability: accountability and transparency in delivering safeguarding.

4 - Definitions

Safeguarding - Protecting a person’s right to live in safety, free from abuse and neglect.

Adult at risk - Any person over 18 who:

  • has care and support needs (eligible under the Care Act 2014)
  • is experiencing or at risk of abuse and/or neglect
  • is unable to protect themselves from abuse and/or neglect.

Partnership - People and organisations working together to prevent and stop both the risks and experience of abuse and neglect.

Mental Capacity - Mental capacity is the ability to make an informed decision based on understanding a situation, the options available the consequences of the decision and being able to articulate a response. Assessment should be decision and time specific. It is assumed that everyone has capacity until proved otherwise. Please refer to Mental Capacity Act Guidance notes.

Abuse - Abuse is the violation of an individual’s human and civil rights by any other person or persons. Abuse can occur in any relationship and may result in significant harm to the person subjected to it. Abuse may consist of a single act or repeated acts, and it can be intentional or unintentional. For examples of abuse please see Appendix A.

Neglect and acts of omission - The act includes not being provided with enough food or with the right kind of food or not being taken proper care of. Leaving you without help to wash or change dirty or wet clothes, not getting you to a doctor when you need one or not making sure you have the right medicines all count as neglect.

Self-Neglect - When a person is unable, or unwilling, to care for their own essential needs. It can cover a wide range of behaviour including neglecting personal hygiene, health or surroundings, refusal of necessary support.

Multi-Agency Risk Assessment Conference (MARAC) - It is a meeting attended by agencies to discuss cases of safeguarding that professionals consider to be ‘high risk’. The purpose of the MARAC is so that all the agencies involved in helping victims can agree how best to offer protection and reduce risk.

Multi-Agency Public Protection Arrangements (MAPPA) - The mechanism through which statutory agencies aim to manage risk posed by sexual and violent offenders, in a coordinated way in order to protect the public.

Safeguarding Adult Review (SAR) - Safeguarding Adult Boards must arrange a (SAR) when an adult dies as a result of, or has experienced serious abuse or neglect, whether known or suspected and there is concern that partner agencies could have worked more effectively together. The aim of SAR is to identify learning and improvement action.

Multi-agency Safeguarding Hub (MASH) - Single point of contact for all professionals to report safeguarding concerns.

5 - Our approach

5.1 Our position on safeguarding

Because safeguarding is so important to us our Chief Customer Officer is responsible for leading our approach to safeguarding.

When we identify concerns, where appropriate we will report them to the local authority or the police, who have a statutory duty to investigate concerns.

We will assume capacity and engage our partners to carry out an assessment when a person's capacity is in doubt.

Occasionally we won’t be happy with the response from a local authority or the police, as we might think the person is still at risk. When this happens, we will escalate within the statutory agency. If we remain concerned, we will refer to our Chief Customer Officer, for next steps, which may include escalating to the most senior level in the local authority or chair of the safeguarding board to review the case (please see Escalation Guidance).

5.2 Prevention

To prevent abuse, harm or neglect, we’ll:

  • raise awareness and encourage everyone to report concerns to us or local authority safeguarding teams
  • ensure staff receive appropriate training to enable them to identify and report safeguarding concerns
  • ensure our processes enable trades and contractors to report safeguarding concerns
  • proactively work with local statutory safeguarding teams and boards/groups – focusing our efforts in areas of higher risk
  • use the data to improve the service we offer
  • learn from serious incidents so we improve preventative measures.

5.3 Responding to safeguarding concerns

Our approach with adults at risk is to be person-led and outcome focused. We will aim to engage and empower the person to enhance their involvement, choice and control to improve their quality of life, well-being and safety.

We will take the most effective, reasonable and proportionate course of action, taking into consideration the vulnerability of those involved and the level of risk.

We will work in partnership with other organisations and signpost to agencies who can provide support where appropriate.

If we suspect or identify possible harm to, abuse of or neglect, we’ll report it to the local authority team with responsibility for Safeguarding Adult. If there’s an immediate risk to safety or a crime has been committed, we’ll call the police or an ambulance.

We’ll:

  • be non-judgemental, listen sympathetically and try to understand the issue
  • treat the report seriously, record the details and respond quickly, reporting the concerns to the local authority where appropriate
  • seek the customer’s permission to make a referral, unless there is a risk of serious harm
  • work with the customer, their family, carers and support network so they can stay safe, signposting to and liaising with support services
  • manage the risks, and agree what both SNG staff and the customer need to do, working with other agencies and family members
  • consider supporting them to improve the security of their home, such as changing locks or fitting alarms.

Where a victim is considered to be at high risk following referral to the local authority safeguarding team, we may work with them to explore alternative accommodation options.

5.3.1 Recruitment

For specific job roles, a Disclosure & Baring Service (DBS) check is undertaken as part of the recruitment process.

All employees are required to confirm they will abide by this safeguarding policy and the Code of Conduct. The code sets out the standards of practice we expect of employees – in terms professional competence, integrity, acting as a representative.

5.3.2 Allegations against our employees (direct and indirect)

Any allegations against our employees will be investigated by an appropriate manager in conversation with HR. We will report allegations to the local police and safeguarding team as appropriate.

Employees who want to raise a concern can find more information about our Whistleblowing Policy. Where a staff member has been found to have perpetrated abuse, we will report this to the Disclosure and Barring Service (DBS) as appropriate.

5.4 Data protection and information sharing

Where appropriate, SNG will share information with relevant partners—such as regulatory bodies, law enforcement agencies, or trusted third-party service providers—to effectively carry out its functions and duties. We will work within the provisions of the Data Protection Act and, where applicable, the UK General Data Protection Regulation (GDPR), which establish clear guidelines for the sharing of information and the protection of confidentiality and privacy.

SNG is committed to ensuring that personal data is treated fairly, lawfully, and appropriately, with the rights of individuals being upheld at all times. However, if an individual’s safety is at risk, we are required to report our concerns to the responsible authorities and share the necessary information to protect that individual.

When we store or share information, we will consider the JAPAN test:

Justified - Is what we’re doing justifiable in the circumstances i.e. can we justify the need to collect/store/share/destroy the personal information we are handling?

Authorised - Are we authorised to do this? Or is someone else designated as responsible for managing the recording or disclosure of this personal information?

Proportional - Is what we are doing proportional to the purpose? Could we achieve it by recording or sharing less or no personal information?

Auditable - Have we recorded what we’ve shared, with whom and why, so there is evidence of our actions?

Necessary - Is what we are doing necessary or can the end result be achieved in some other way without this disclosure?

6 - Compliance

In order to recognise and effectively respond to cases of safeguarding, all staff are expected to complete mandatory training. Some roles may be offered additional training in this area.

Safeguarding cases will be logged, managed and reported through our housing (case management) system and will be kept in line with data protection legislation, policies and data retention schedules.

We will work with appropriate local authority departments to support them in fulfilling their strategic duties.

Assurance reports will be provided to our Executive Board to demonstrate the effectiveness of this Policy.

7 - Sustainability

  • At Sovereign Network Group, we recognise the critical importance of sustainability in our operations and services. We are committed to embracing sustainable practices that contribute to environmental protection, social equity, and economic viability.
  • Examples of sustainability specific to this policy may include community engagement, customer empowerment and risk mitigation. By integrating these practices into our operations, we aim to create lasting value for our business, our customers, and the broader community, aligning with our long-term commitment to sustainable development.

8 - Responsibilities

Chief Customer Officer

  • Overall responsibility for Safeguarding in SNG
  • Ultimate point of escalation with local authority

Safeguarding Core Group

  • Ensures compliance with the policy
  • Regular review of performance
  • Review of learning from serious incidents

Head of Tenancy Sustainment

  • Strategic lead for Safeguarding
  • Chairs the Safeguarding Core Group
  • Review of this policy and of our safeguarding procedure
  • Service development (including: Staff training design)

Regional Directors and Heads of Service

  • Communication, implementation and operational compliance of this policy.
  • Cascading the policy and procedure

Safeguarding Operational Development Group

  • To be a sounding board on key strategic decisions around safeguarding
  • To raise solution focussed ideas/concerns about our current approach or tools
  • To support continuous improvement based on experience and internal/imported best practice
  • To be an ambassador for the work of the group and the conduit for conversations with the wider business about safeguarding

Responsible managers

  • Regularly monitor each safeguarding case against our performance targets, provide appropriate advice and support to the responsible officer dealing with a case, ensure that they receive appropriate training; and ensure that all cases are appropriately recorded and ensure appropriate actions are taken prior to case closure.

Responsible officers

  • Responsible for completing referrals, investigating and monitoring cases, reviewing actions and reporting critical incidents or immediate concerns to the Line Manager.
  • Following the policy

All Staff and those working in contract with us

  • Complete the mandatory training and know how to report concerns.

9 - Equality, diversity and inclusion

  • Sovereign Network Group is committed to the fair, respectful and equal treatment of its customers, employees and applicants.
  • We will apply this policy consistently, fairly and will not discriminate against anyone based on the protected characteristics; age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation, determined in the Equality Act 2010.
  • We’ll make sure our services and workplaces are as inclusive and accessible as possible and take seriously any concerns that we’ve not acted in a fair way, dealing with them as quickly as we can.
  • We are committed to helping customers to access information about their homes and services in a way that suits individual needs. We will also consider any reasonable adjustment requests in line with our Vulnerability and Reasonable Adjustments Policy.

10 - Related documents

  • Safeguarding procedure
  • Safeguarding Escalation procedure
  • Safeguarding Children and Young People Policy
  • Domestic Abuse Policy
  • Vulnerabilities and Reasonable Adjustments Policy

11 -  Legislation and regulation

  • SNG is committed to ensuring compliance with all applicable legislation. To achieve this, we will take reasonable measures, including regularly reviewing our policies and procedures and updating them as necessary to reflect any changes in the legal landscape.
  • The legislation listed in this policy is not intended to cover all legislation applicable to this policy. To comply with clause 1.1 of the Regulator of Social Housing’s Governance and Financial Viability Standard, which requires adherence to all relevant law, SNG will take reasonable measures to ensure compliance with all applicable legislation by reviewing policies and procedures and amending them as appropriate. Any queries relating to the applicable legislation should be directed to the policy owner.
    • Data Protection Act 2018
    • Care Act 2014
    • Mental Capacity Act 2005
    • Human Rights Act 1998
    • Sexual Offences Act 2003
    • Protection of Freedoms Act 2012
    • Modern Slavery Act 2015
    • Equality Act 2010
    • Safeguarding Vulnerable Adults Act 2006
    • Counter-Terrorism and Security Act 2015 (Prevent Duty)
    • Housing Act 1985 & 1996
    • Deprivation of Liberties Safeguards 2007
    • Disability Discrimination Act 2003
    • Safeguarding Adults – National Framework of Standards 2005
    • Regulator for Social Housing – Consumer Standards
    • Local Authority Guidelines as appropriate

12 - Review

This document will be reviewed at least once a year, or sooner if significant changes occur or a local incident occurs in the relevant legal or operational landscape.

Appendix A – Examples of abuse

There are many types of abuse – the categories generally recognised in Adult Safeguarding and in the Safeguarding of Children & Young People are listed below. This list is not exhaustive.

Our Safeguarding Procedure details how we manage our safeguarding cases.

Psychological/Emotion Abuse - Threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, cyber bullying, isolation, unreasonable and unjustified withdrawal of services or supportive networks.

Physical Abuse - Assault, hitting, slapping, pushing, misuse of medication, restraint.

Sexual Abuse - Rape, indecent exposure, sexual harassment, inappropriate looking or touching, sexual teasing or innuendo, sexual photography, subjection to pornography or witnessing sexual acts, sexual assault, sexual exploitation and/or acts to which the adult has not consented or was pressured into consenting.

Financial or Material Abuse - Where someone else controls your spending, access to cash, assets or finances.

Domestic Abuse - Controlling, coercive, threatening behaviour, violence or abuse between those aged 16 or over who are, or have been intimate partners or family members, regardless of gender or sexuality, so called ‘honour’ based violence, female genital mutilation (FGM), forced marriage. Please see Domestic Abuse Policy and Domestic Abuse Employee Support Policy.

Discriminatory Abuse - Harassment, slurs or similar treatment because of race, gender and gender identity, age, disability, sexual orientation, religion.

Institutional or Organisational Abuse - Neglect and poor care practice within an institution or specific care setting such as a hospital or care home, neglect and poor care practice in relation to care provided in one’s own home. Neglect or poor professional practice as a result of the structure, policies, processes and practices within an organisation.

Modern Slavery - Trafficking in persons’ and ‘human trafficking’ for the act of, recruiting, harbouring, transporting, providing, obtaining a person for compelled labour or commercial sex acts through use of, force, fraud, coercion.

Exploitation or Grooming - The act of using an adult / child for, profit, labour, sexual gratification, or some other personal or financial advantage.

Prevent Duty – radicalisation or extremism - The act or process of causing someone to adapt radical positions on political or social issues. The aim of early identification and early intervention is to divert people away from being drawn into terrorist activity.