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Safeguarding Policy

Sarflix Care Recruitment Ltd

1. Why this policy exists

Sarflix Care Recruitment Ltd supplies nurses, care assistants and support workers to care homes, NHS services and home care providers. The people our workers support are often adults with care and support needs, who may be less able to protect themselves from abuse or neglect. Some settings also bring our workers into contact with children, for example visiting relatives.

This policy explains how we prevent harm, how everyone connected with Sarflix must recognise and report concerns, and what we do when a concern is raised. It matches the reporting steps in our Compliance and Safeguarding Statement, section 5.2.

Safeguarding is everyone’s responsibility. Every person who works for or with Sarflix has a personal duty to act on a concern. Nobody should assume someone else will report it.

2. Our commitments

• We have zero tolerance of abuse, neglect and poor practice.
• We recruit safely, so that people who pose a risk are kept out of care work.
• We train every worker to recognise and report abuse before their first shift.
• We act on every concern the same day and work openly with clients, local authorities and regulators.
• We put the wishes and wellbeing of the person at risk at the centre of what we do.
• Anyone who reports a concern in good faith will be supported and never disadvantaged.

3. The law and guidance we follow

• Care Act 2014 and the Care and Support Statutory Guidance, chapter 14 (safeguarding adults)
• Safeguarding Vulnerable Groups Act 2006, as amended by the Protection of Freedoms Act 2012
• Conduct of Employment Agencies and Employment Businesses Regulations 2003, including regulation 22
• Mental Capacity Act 2005
• Children Act 1989 and 2004, and Working Together to Safeguard Children
• Modern Slavery Act 2015
• Public Interest Disclosure Act 1998
• UK GDPR and the Data Protection Act 2018
• The multi agency safeguarding procedures of the Nottinghamshire Safeguarding Adults Board, and of the board for any other area where we supply staff

4. The six safeguarding principles

We follow the six principles of the Care Act 2014:

We also follow the approach of Making Safeguarding Personal: asking the person what they want to happen, wherever it is safe to do so.

5. Recognising abuse and neglect

The Care Act 2014 statutory guidance recognises these types of abuse:

Signs can include unexplained injuries, sudden changes in behaviour or mood, fear of a particular person, weight loss, poor hygiene, missing money or belongings, and a person being kept apart from others.

6. What every worker must do

If you see or hear something that worries you, or someone tells you they are being harmed:

1. Make the person safe. Call 999 if anyone is in immediate danger or a crime is happening.
2. Report to the person in charge at the placement, following the client’s safeguarding procedure, because the client holds the duty of care on site.
3. Report to the Sarflix Safeguarding Lead the same day, on +44 7760 892378, including out of hours. Reporting to the client does not replace reporting to us.
4. Write down what you saw and heard as soon as you can: the date, time, place, who was there and the person’s own words. Sign and date it. Do not add your opinion.

When someone tells you about abuse:

• stay calm, listen and take them seriously;
• do not promise to keep it secret, and explain who you need to tell;
• do not ask leading questions or investigate yourself;
• do not confront the person you think is responsible;
• preserve any evidence and do not clean or tidy the area.

If the Safeguarding Lead cannot be reached, contact the Deputy Safeguarding Lead through hello@sarflixrecruitment.co.uk, or report directly to the local authority (see section 13). Never delay a report because a Sarflix contact is unavailable.

7. What the Safeguarding Lead does

1. Records the concern in the safeguarding log within 24 hours, with the facts as reported and no speculation.
2. Confirms with the client that a safeguarding referral has been made to the relevant local authority, and makes the referral directly if the client has not.
3. Considers the person’s wishes and mental capacity, and whether police involvement is needed.
4. Where the concern is about a worker we supplied, removes that worker from bookings while the matter is looked into. This is a neutral act, not a finding of fault.
5. Makes any referral to the Disclosure and Barring Service and professional regulators set out in section 9.
6. Supports the worker who raised the concern and keeps them updated as far as confidentiality allows.
7. Reviews every closed case for lessons learned and changes our process where needed.

8. Allegations against Sarflix workers or staff

Where an allegation is made against someone employed or supplied by Sarflix:

• the Safeguarding Lead is told the same day, and the Deputy if the allegation is about the Safeguarding Lead;
• the worker is not offered further shifts while the matter is assessed;
• we cooperate fully with the client, the local authority, the police and any investigation, and do not carry out our own investigation in a way that could harm theirs;
• where the allegation involves a child, we contact the Local Authority Designated Officer (LADO) for the area the same working day;
• the worker is told what they need to know, is treated fairly, and is offered support;
• a written record is kept of the allegation, the actions taken and the outcome.

9. Referrals to the DBS and regulators

As an employment agency and employment business, Sarflix is a “personnel supplier” under the Safeguarding Vulnerable Groups Act 2006, and has a legal duty to refer a person to the Disclosure and Barring Service when:

• we have removed them from regulated activity, or would have done if they had not left; and
• we think they have harmed or posed a risk of harm to a child or adult, or have received a caution or conviction for a relevant offence.

We make the referral once we have enough information, usually after the relevant investigation, and not when an allegation is first made. Failing to refer when the duty applies is a criminal offence.

Where a worker holds a professional registration, we also refer to their regulator, such as the Nursing and Midwifery Council, where the concern affects their fitness to practise.

10. Safer recruitment

No worker starts a shift until we have completed and recorded:

• an interview, including questions about safeguarding and values;
• identity and right to work checks;
• an enhanced DBS check with adult barred list check (and children’s barred list check where the role requires it), through our registered umbrella body;
• two references, including the most recent employer, with any gaps in employment explained;
• checks of qualifications and professional registration, such as the NMC register;
• confirmation that mandatory training, including safeguarding, is complete and in date.

Checks are kept up to date and recorded with expiry dates. Our Appropriate Policy Document explains how we protect criminal record information.

11. Training

• Every worker completes safeguarding adults training, and safeguarding children awareness, before their first shift.
• Training is refreshed at least every year, or sooner if the law or local procedures change.
• The Designated and Deputy Safeguarding Leads complete training for safeguarding leads and keep it up to date.
• We keep a signed record of all training.

12. Confidentiality, consent and sharing information

Safeguarding information is shared only with those who need to know to protect someone. Data protection law does not stop us sharing information to keep people safe: we can share without consent where that is needed to prevent harm, under Schedule 1 paragraph 18 of the Data Protection Act 2018. Where it is safe and possible, we tell the person what we are sharing and why.

Where an adult has mental capacity and does not want action taken, we respect their wishes unless others are at risk, a crime has been committed, a member of staff is involved, or the person is being coerced. Records are kept securely in restricted storage and kept for 25 years, then reviewed before deletion.

13. Key contacts

For shifts outside Nottinghamshire, the worker reports to the local authority for the area where the person at risk lives.

14. Whistleblowing

Any worker can raise a concern about wrongdoing directly with a Director, without fear of detriment. Qualifying disclosures are protected by the Public Interest Disclosure Act 1998. If you do not feel able to raise a concern with us, you can contact the Care Quality Commission, the local authority or the charity Protect.

15. Monitoring and review

The directors review the safeguarding log every three months to spot patterns and improve practice. This policy is reviewed every three months, after any serious incident, and whenever the law or local procedures change.