Safeguarding: Vulnerable Adults Protection Policy

The Federation of Synagogues (Federation) is fully committed to the protection of all vulnerable adults ensuring that their welfare is preserved.

The Federation of believes that all vulnerable adults, whatever their age, culture, disability, gender, language, racial origin, religious beliefs and/or sexual identity, have the right to protection from abuse.

1.1 Definitions

For the purpose of this policy a vulnerable adult is a person who is eighteen years of age or over, and who may be in need of community care services by reason of mental or other disability, age or illness, and who is or may be unable to take care of him/herself, or unable to protect him/herself against significant harm or exploitation.

Representatives are defined as employees of The Federation, volunteers and or independent contractors (consultants) required to carry out work on behalf of the Federation including in shuls, welfare groups etc. Local Level is defined as any location in which the Federation carries out its work or activities.

The Federation understands its duty of care to safeguard all vulnerable adults involved in any activities undertaken by or on behalf of the Federation. The Federation strongly believes that it has a responsibility to safeguard the welfare of vulnerable adults by protecting them from abuse. To this end the Federation will make sure that its policies, procedures and practices as they relate to representatives will protect vulnerable adults. All suspicions and allegations of abuse will be taken seriously and responded to swiftly and appropriately.

1.2 Historical Abuse

When allegations of historical abuse are made this procedure should also be followed.

1.3 Safeguarding Vulnerable Adults Policy

The Federation will promote an environment where vulnerable adults are safe from abuse.

The aim of the Federation’s Vulnerable Adults Protection Policy is to promote good practice by

providing an environment in which vulnerable adults feel safe and valued
providing representatives working on behalf of Federation with clear guidelines and procedures to follow that will not only help avoid inappropriate, misguided or wrong behaviour, but will also provide information as to what action to take should they be concerned about a vulnerable adults’ welfare.
protecting the Federation’s name and reputation from being brought into disrepute.

Dayan Posen Is the named person who is the Vulnerable Adults Protection Officer for the Federation and in his absence the Deputy Vulnerable Adults Protection Officer Anna Mileberg.

If you have a query on Shabbos / Yom Tov and you believe a vulnerable adult may be at serious risk, please contact 999.

If a representative suspects that a vulnerable adult may be a victim of abuse, they must immediately inform the named person at the local level about their concerns.
Abuse can be of a sexual, emotional or physical nature. It can also be the result of neglect.
The Vulnerable Adults Protection Officer will work closely with the HR Department when investigating any allegations of abuse. All parties involved at local level will handle such investigations in a sensitive manner, but the interests of the vulnerable adult will be of paramount importance.
All information relating to individual vulnerable adult protection issues is confidential.
Information can only be passed onto the appropriate persons.
All representatives working with vulnerable adults are required to have been checked by Disclosure & Barring Service, in order ensure that there is no evidence of offences involving vulnerable adults or abuse.

1.4 Abuse

Abuse may be defined as the wrongful application of power by someone in a dominant position. It involves an imbalance of power and exploitation without a full and informed consent. Abuse can take several different forms and may be a single act or repeated acts.

Physical abuse – includes hitting, slapping, kicking, pushing, withholding or misuse of medication
Sexual abuse – includes sexual assault and rape, or sexual acts where the vulnerable person has not (or could not give) given consent or was forced into consenting
Psychological abuse – includes threats of harm, emotional abuse, humiliation verbal abuse, intimidation, coercion, harassment, withdrawal of support, isolation and deprivation (physical and sensory)
Material / financial abuse – includes fraud, theft, exploitation, financial transactions, misappropriation e.g. willed inheritance, property, benefits and possessions

1.5 Neglect & Acts of Omission

Neglect includes ignoring physical care and medical needs, withholding basic living requirements eg, adequate nutrition, safe and warm environment, withholding necessary medication and failure to provide access to appropriate health and social care services and / or educational services.

1.6 Good practice guidelines for Employees, Volunteers and Contractors working with Vulnerable Adults:

All representatives should be encouraged to demonstrate exemplary behaviour in order to protect themselves from false allegations. The following are common sense examples of how to create a positive culture and climate.

If one of the following occurs, you should report this immediately to another colleague in a senior position and record the incident. You should also ensure the carers/relatives of the vulnerable adult are informed:

if you accidentally hurt a vulnerable adult.
if he/she seems distressed.
if a vulnerable adult seems to be sexually aroused by your actions.
if a vulnerable adult misunderstands or misinterprets something you have done.

The Federation does not expect staff or volunteers to do things which could be construed as being of a personal nature for vulnerable adults. Avoid taking on the responsibility for tasks for which you are not appropriately trained.

The following should also be avoided except in emergencies – if a case arises where the situation is unavoidable such as the vulnerable adult sustains an injury and needs to go to hospital, it should be with the full knowledge and consent of someone in charge or the vulnerable adult’s carer/relative.

1.6.1 The following should never be sanctioned. You should never:

Engage in rough physical or sexually provocative games, including horseplay.
Share a room with a vulnerable adult.
Allow or engage in any form of inappropriate touching.
Make sexually suggestive comments to a vulnerable adult, even in fun.
Reduce a vulnerable adult to tears as a form of control.
Allow allegations made by a vulnerable adult to go unchallenged, unrecorded, or not acted upon.
Do things of a personal nature for vulnerable adults.
Invite or allow vulnerable adults to stay with you at your home unsupervised.

1.6.2 Employees and Volunteers should watch for possible signs of concern, but always being wary of jumping to incorrect conclusions

The vulnerable adult has any injury which is not typical of the bumps of and scrapes normally associated with everyday living.
The vulnerable adult regularly has unexpected injuries.
Confused or conflicting explanations are given on how injuries were sustained.
There are significant changes in behaviour, performance, or attitude.
The vulnerable adult talks of an experience in which he or she may have been significantly harmed.

1.6.3 If a vulnerable adult talks of abuse

Listen to what is being said
Accept what is being said
Allow the vulnerable adult to talk freely
Reassure the vulnerable adult but not make promises which it might not be possible to keep
Do not promise confidentiality- it might be necessary to refer to social services
Reassure them what has happened is not their fault
Stress that it is the right thing to tell
Listen rather than asking direct questions

1.6.4 Record keeping

Make notes as soon as possible after the conversation

Do not destroy notes in case they are needed later on

Record the date, time, place and any noticeable non-verbal behaviour and the words used by the vulnerable adult

Draw a diagram to indicate the position of any bruising or other injury

Record statements and observations rather than interpretations or assumptions

1.7 Confidentiality

All information about any individual vulnerable adult and any individual volunteer or staff member will be treated as confidential and will not be communicated to others, save those who need to be involved for due process to take place.
Representatives will only discuss any individual vulnerable adult with the carer/relatives of that vulnerable adult, other than for planning and management purposes.
Representatives will not discuss matters of supervision with any outside parties and should draw any concerns to the attention of the Vulnerable Adults Protection Officer immediately or in his absence the HR Director.
Staffing and the other matters will remain confidential within the Federation and those directly related to the personal issues.

1.8 Procedure for Recruitment and training of staff and volunteers

1.8.1 Working with vulnerable adults

The Federation recognizes that anyone may have the potential to abuse vulnerable adults in some way and therefore all reasonable steps are taken to ensure unsuitable people are prevented from working with vulnerable adults.

Pre-selection checks must include the following:

Consent should be obtained from an applicant to seek information from the Disclosure & Barring Service.
One confidential reference should be taken up, including one regarding previous work with vulnerable adults. This reference must be taken up and confirmed in writing not just by telephone contact.
Evidence of identity should be provided (eg, passport or driving licence with photo).
Independent contractors will have to provide details of a confidential reference regarding previous work with vulnerable adults.

1.8.2 Interview and induction

All representatives will be required to undergo a selection interview carried out to acceptable protocol and recommendations.

All representatives will receive formal or informal induction, during which:

A check should be made that the application form has been completed in full (including sections on criminal records and self-disclosures).
Their qualifications should be substantiated.
The job requirements and responsibilities should be clarified.
Vulnerable adult protection procedures are explained, and training needs are identified.
The reference will be verified.

1.8.3 Training

In addition to pre-selection checks, the safeguarding process includes training after recruitment to help representatives to:

Analyse their own practice against established good practice, and to ensure their practice is likely to protect them from false allegations.
Recognise their responsibilities and report any concerns about suspected poor practice or possible abuse.
Respond to concerns expressed by a vulnerable adult.
Work safely and effectively with vulnerable adults.

The Federation requires:

All representatives to attend a recognised good practice and vulnerable adult protection awareness training workshop, to ensure their practice is exemplary and to facilitate the development of a positive culture towards good practice and vulnerable adult protection.
relevant representatives to receive advisory information outlining good practice and informing them about what to do if they have concerns about the behaviour of another person towards a vulnerable adult.
Attendance of update training when necessary.

1.9 Procedure for responding to allegations against a Federation employee, volunteer, or consultant

It is not the responsibility of any representative to decide whether or not vulnerable adult abuse has taken place. However, there is a responsibility to act on any concerns through contact with the appropriate authorities.

The Federation will assure all representatives that it will fully support and protect anyone who in good faith reports his/her concern that a colleague is, or may be, abusing a vulnerable adult.

The Federation will seek social services advice on who should approach the alleged abuser.

The Federation understands that it has a duty towards its employees to treat them in a fair and reasonable manner at all times, including if an allegation has been made against them. Consideration will be given to the kind of support those members of staff/volunteers against whom an allegation of abuse has been made.

Where there is a complaint against a member of staff there may be three types of investigation:

a criminal investigation
a vulnerable adult protection investigation
a disciplinary or misconduct investigation.

The results of the police and vulnerable adult protection investigation may well influence the disciplinary investigation, but not necessarily so.

1.9.1 Action

1.9.1.1 Concerns about poor practice

If, following consideration, the allegation is clearly about poor practice, the Federation will deal with it as a misconduct issue.

1.9.1.2 Concerns about suspected abuse

Any suspicion that a vulnerable adult has been abused by a representative should be reported to the Vulnerable Adults Protection Officer, who will take such steps as considered necessary to ensure the safety of the vulnerable adult in question and any other vulnerable adult who may be at risk.

The Federation will refer the allegation to the social services department which may involve the police or go directly to the police if out of-hours.

The relatives or carers of the vulnerable adult will be contacted as soon as possible following advice from the social services department.

The Federation will also notify the relevant department who will deal with any media enquiries.

1.9.2 Confidentiality

Every effort will be made to ensure that confidentiality is maintained for all concerned. Information should be handled and disseminated on a need-to-know basis only.

This includes the following people:

the relatives/carers of the vulnerable adult who is alleged to have been abused
the person making the allegation
social services/police
the alleged abuser (and relatives/carers if the alleged abuser is another vulnerable adult).

Information should be stored in a secure place with limited access to designated people, in line with data protection laws (eg, that information is accurate, regularly updated, relevant and secure).

1.9.3 If you suspect a vulnerable adult is being abused

Immediately or as soon as is practicable inform The Vulnerable Adults Protection Officer Dayan Posen on 020 8202 2263, or in his absence, Anna Mileberg, the Deputy Vulnerable Adults Protection Officer.

If you have a query on Shabbos / Yom Tov and you believe a vulnerable adult may be at serious risk, please contact 999.

1.9.3.1 What to say to the vulnerable adult

It is essential that vulnerable adults know what they have said will not get them in trouble, and that they were right to talk about it.

Vulnerable adults may well ask that you do not tell anyone else. This is a promise you cannot make.

It is generally a good idea to let the vulnerable adult say as much or as little as they wish, and avoid questioning them

1.9.3.2 Record what has been said

It is essential that you write down a summary of what the vulnerable adult has said as soon as possible afterwards-preferably within an hour, please note that this summary is legally admissible as evidence provided it has been recorded within 24 hours.

Write clearly what has been said
Your comments to the vulnerable adult
What action you took
Note what was happening before the disclosure took place
Who else was nearby

As this record be used in evidence at a later date, it is essential that you record only what actually happened: this must be an accurate record.

1.9.3.3 Responding to a vulnerable adult’s disclosure of abuse

Remain calm
Allow the vulnerable adult to say what has happened, without interruption
Show the vulnerable adult through body language that you are listening
Avoid asking questions or challenging
Reassure the vulnerable adult
Tell the vulnerable adult that she or he has done the right thing in saying something
Tell the vulnerable adult that you will need to tell someone else, so they can be helped
Explain to the vulnerable adult what is going to happen next
Report the disclosure immediately to the Vulnerable Adult Protection Officer
Complete a summary as soon as possible afterwards.
- Allegations involving other representatives

Any representative who has reason to suspect that a vulnerable adult may have been abused by another representative, must immediately inform the Vulnerable Adults Officer, Dayan Posen on 020 8202 2263 or in his absence, Anna Mileberg, Deputy Vulnerable Adults Protection Officer.