Safeguarding policy

2. Our commitment

2.1 We are committed to working to:

• raise awareness of safeguarding adults and children to ensure that everyone can play their part in preventing, identifying and responding to abuse
• increase understanding and raise the awareness of employees within the service of risks relating to safeguarding
• provide information and support in accessible ways to help people understand the different types of abuse and what to do to raise a concern about the safety or wellbeing of an adult or child
• ensure safeguarding concerns are addressed promptly and through the appropriate channels
• this will be achieved by having a safeguarding lead, referral processes and training on how to identify and act on abuse

3. Responsibilities

3.1 All staff must be aware of their responsibility to act when they become aware of a potential safeguarding issue. Conversations with potentially vulnerable service users should be managed in line with the processes and guidance in place. The processes and guidance will apply to all Housing Ombudsman Service staff, whether directly employed or acting on behalf of Housing Ombudsman Service.

3.2 The organisation will have individuals who have responsibility for supporting and making decisions about conducting referrals if required, and considering alternative actions, where necessary. The safeguarding lead is responsible for adherence to safeguarding policies and procedures, ensuring that the organisation is up to date with safeguarding training, managing, and reporting as required.

4. Adults at risk

4.1 For adults at risk the core of this policy is to ensure individuals are supported appropriately in accordance with the Care Act 2014. The definition of safeguarding there is ‘Protecting an adult’s right to live in safety, free from abuse and neglect.’ While the Act refers to “adults at risk” this term is interchangeable with the term “vulnerable adult”.

This policy aims to support processes to identify at risk service users and take appropriate action.

4.2 The obligation as an organisation is to identify and act where there is a concern about a service user who may be at risk of harm; may be intending to harm someone else or is otherwise at risk. An individual’s role within Housing Ombudsman Service may vary but is primarily to identify potential risks and act as a referrer to the appropriate service as required. An adult at risk is defined as any individual aged over 18 who:

• has needs for care and support and.
• is experiencing, or is at risk of, abuse or neglect; and
• as a result of those care and support needs is unable to protect themselves from either the risk of, or the experience of abuse or neglect

Types of abuse and neglect include physical abuse, domestic abuse, financial / material abuse, neglect, and self-neglect (not an exhaustive list). An adult at risk may:

1. have mental health needs
2. be elderly or frail due to ill health
3. have a learning disability
4. have a physical disability or sensory impairment
5. may be at higher risk because of discrimination given their characteristics as contained in the Equality Act 2010
6. Self-harm
7. have dementia or other cognitive impairment which may reduce their mental capacity to make decisions
8. misuse alcohol or substances
9. be a care leaver
10. self-neglect their needs putting them and others at risk
11. be a victim of Modern Slavery

4.3 There can be multiple risks present, and this increases risk as does a situation where the adult has lost mental capacity to make their own decisions. The loss of mental capacity can be as a result of some cognitive impairment, but it can be that another is controlling by applying undue influence, duress and intimidation to prevent the adult at risk exercising their own agency and autonomy. This can extend to that adult being unable to seek, engage or receive help for protection.

4.4 Abuse may be carried out deliberately or unknowingly and may be a single act or repeated acts. The perpetrator of the abuse may be family, friends, strangers or criminals. Abuse can happen anywhere including in the adult’s own home. The adult victim of abuse may not be able to protect themselves from such abuse and as such needs protection under the law.

4.5 Under the Care Act 2014 and the Human Rights Act 1998, everyone has the right to live free from abuse and neglect. Some adults at risk may find it hard to get the help and support they need to stop the abuse. An adult may be unable to protect themselves from harm or exploitation due to many reasons, including their mental or physical incapacity, sensory loss or physical or learning disabilities. This could be an adult who is usually able to protect themselves from harm but may be unable to do so because of an accident, disability, frailty, addiction or illness or duress.

4.6 It is important any indication of abuse is identified and referrals made to statutory agencies such as the Local Authority and the police, as appropriate, to protect the adult at risk. If you suspect someone is being abused, plans to self-harm or harm others:

1. if the person is in immediate danger ring 999
2. if the danger is not immediate, raise an adult safeguarding alert with the appropriate Local Authority (see section 6 of this policy)
3. preserve and keep good records you may hold that could possibly be evidence
4. do not confront the person or persons who may be responsible for the abuse

5. Children

5.1 A child/young person is someone under the age of 18 years. This policy outlines considerations for the safeguarding of children.

5.2 Some children and young people are in need child protection because they have suffered or are likely to suffer significant harm. The Children Acts 1989 and 2004 places a duty on Local Authorities to safeguard and promote the welfare of children who are suffering or likely to suffer significant harm.

5.3 The Children Act 2004 describes how all agencies, including those in housing, have duties to promote the welfare and protection of children working in partnership with the Local Authority. Working Together to Safeguard Children 2023 is the national guidance on safeguarding children. This statutory and non-statutory national guidance underpins the fundamental principle that a child’s welfare is paramount. The Children Act 1989 (section 17) also states that a disabled child is automatically a Child in Need and that the Local Authority has a duty to have a plan to support that child.

5.4 There are 4 main categories of child abuse:

1. neglect
2. physical abuse
3. sexual abuse including child sexual exploitation (CSE)
4. emotional abuse

5.5 Children and young people may be vulnerable to harm in many contextual safeguarding circumstances:

1. they may be a young carer
2. they may be a care leaver
3. they may have a learning disability
4. they have a physical disability or sensory impairment
5. they may have complex health needs
6. they have mental health needs
7. they have addiction needs related to alcohol or substances

This is not an exhaustive list of examples.

5.6 The perpetrator of child abuse may be family, friends, strangers or criminal groups. Abuse can happen anywhere, including in the child’s own home. A child victim of abuse cannot protect themselves and they have little independent power to protect themselves. Children may not be able to express what they are experiencing at all. They therefore need robust protection under the law. It is important any indication of abuse is identified, action taken and to work with the statutory agencies such as the Local Authority and the police to protect the child.

5.7 If there are concerns around a child action must be taken:

• if the child is in immediate danger ring 999 and then contact Children’s Social Care at the appropriate Local Authority
• if the danger is not immediate, raise a child safeguarding alert with the appropriate Local Authority. This referral should not be delayed. Anyone can report concerns into Children’s Social Care. It does not need to be a professional. Members of the public can also do so. Children’s Social care under their safeguarding function will take the necessary steps to investigate and protect the child

5.8 Housing professionals may be asked to attend a Multi-agency Risk Assessment Conference (MARAC). This is a multi-agency forum in which communities meet to discuss and share information regarding high-risk domestic abuse families. The process is led by the police. The purpose is to assess risk to the victim and agree a safety plan for the family.

6. Recording, managing and sharing confidential information

6.1 We are committed to maintaining confidentiality wherever possible and information around safeguarding issues will only be shared with those who need to know and in a proportionate manner. The information recorded will be kept secure and will comply with the Data Protection Act 2018 and General Data Protection Regulations (GDPR). The GDPR does not prevent the sharing of information for safeguarding purposes for adults at risk or for children for which there are safeguarding concerns.

6.2 Safeguarding issues and concerns will be recorded and stored in accordance with the GDPR principles. Reporting against the information collected will take place and will be provided to the Executive Leadership Team at least once each year.

6.3 Where there is immediate risk to harm for an adult or child, information will be shared with the police and then with adult safeguarding team or Children’s social care as appropriate. Contact details will differ depending upon the Local Authority to be contacted. Sharing information and concerns without delay with the police and Local Authority works to prevent harm and protect adults at harm and children.

6.4 Depending on the circumstances, consideration may be given to seeking consent from the adult at risk, but this will be very much on a case by case, and advice will be sought from an appropriate individual (such as the safeguarding lead).

7. Support for colleagues

7.1 We have a commitment to all colleagues to support them when managing challenging conversations. We do this by providing supporting resources including training, our Employee Assistance Programme and support from safeguarding specialists within the organisation.

Published October 2025