Safeguarding Policy (Merged & Expanded Version)

1. Purpose

The purpose of this policy is to ensure that DLTC provides a safe, supportive environment for all clients, trainees, and staff by promoting awareness of safeguarding responsibilities and ensuring effective procedures for responding to concerns about abuse, neglect, or exploitation.

DLTC is committed to upholding the highest standards of professional practice and to protecting children, young people, and adults at risk.

2. Scope

This policy applies to:

  • All DLTC Directors, Supervisors, Therapists, and Trainees;
  • Clients receiving therapy or training through DLTC;
  • Contractors, visitors, and room hirers who may have contact with clients.

It must be read in conjunction with:

  • Clinical Responsibility Policy
  • Complaints Policy and Procedure
  • Health and Safety Policy
  • Risk Management (Trainees) Policy
  • GDPR – Privacy Notice
3. Safeguarding Commitment

DLTC recognises its duty to protect and promote the welfare of children, young people, and adults at risk. This includes:

  • Preventing abuse where possible;
  • Recognising signs of harm and acting promptly;
  • Responding sensitively and professionally to disclosures or suspicions of abuse;
  • Working collaboratively with other agencies where required.

DLTC Directors act as joint Safeguarding Leads for the organisation.

4. Definitions of Abuse

DLTC adopts the definitions used by the Care Act 2014 and Working Together to Safeguard Children (2018). Abuse may include, but is not limited to:

  • Physical abuse – causing physical harm or injury.
  • Emotional or psychological abuse – threats, humiliation, coercion, or controlling behaviour.
  • Sexual abuse – any sexual act or activity without consent.
  • Financial or material abuse – theft, fraud, misuse of funds.
  • Neglect or acts of omission – failure to provide care or attention.
  • Discriminatory abuse – harassment, slurs, or unfair treatment based on identity.
  • Organisational abuse – poor care practices within settings.
  • Self-neglect – neglecting one’s own care, health, or hygiene.

Refer to Appendix 2 for more details

5. Roles and Responsibilities

Directors (Safeguarding Leads)

  • Hold ultimate responsibility for all safeguarding matters.
  • Maintain up-to-date knowledge of legislation and best practice.
  • Provide guidance to trainees and supervisors on handling safeguarding concerns.
  • Report serious incidents to statutory authorities where necessary.
  • Maintain secure safeguarding records in accordance with GDPR.

Supervisors

  • Discuss safeguarding issues promptly in supervision.
  • Ensure trainees are confident in identifying and escalating concerns.
  • Support reflective practice and appropriate documentation.

Trainees and Therapists

  • Be alert to signs of abuse, neglect, or risk of harm.
  • Follow the DLTC Safeguarding Procedure (below) immediately if concerns arise.
  • Record all observations and disclosures accurately and confidentially.
  • Never promise confidentiality where abuse or harm is disclosed.
6. Safeguarding Procedure

Step 1 – Recognise and Respond

  • Stay calm and listen without judgment.
  • Do not investigate or ask leading questions.
  • Reassure the person that their disclosure will be taken seriously.

 

Step 2 – Report Immediately

  • Inform the Supervisor and a DLTC Director (Safeguarding Lead) as soon as possible.
  • If a person is in immediate danger, contact emergency services (999).

 

Step 3 – Record

  • Complete a Safeguarding Concern Form including:
  • Date, time, and names involved;
  • Nature of the concern;
  • Actions taken and who was informed.
  • Send the form securely to the DLTC Directors.

 

Step 4 – Review and Follow-up

  • The Directors will decide next steps: referral to local safeguarding authorities, internal review, or closure.
  • The Supervisor and trainee (where appropriate) will be informed of the outcome where appropriate.
7. Managing Risk and Confidentiality

All safeguarding cases will be recorded in the Safeguarding Log maintained by the Directors. Information is shared on a need-to-know basis only. Client consent is sought where appropriate, unless this places the person or others at risk. Records are retained securely for seven years. Learning outcomes from cases may inform training and policy improvement.

8. Training and Awareness

Complete safeguarding training upon induction and renew it every three years.

Be familiar with this policy and related procedures.

Participate in reflective practice discussions on safeguarding scenarios.

9. Related Policies

Clinical Responsibility Policy

Complaints Policy and Procedure

Health and Safety Policy

Risk Management (Trainees) Policy

GDPR – Privacy Notice

10. Review and Version Control

This policy will be reviewed annually or sooner in response to legislative or organisational changes.

v15.10.25 – Updated for consistency with DLTC Complaints, Clinical Responsibility, and Risk Management Policies; clarified procedures, roles, and documentation.

Review Due: November 2026

 

 

 

Appendix 1 – Legislative and Policy Context

This Safeguarding Policy is grounded in UK statutory and professional frameworks governing safeguarding practice
for both adults and children. These include, but are not limited to:
- Care Act 2014 and Care and Support Statutory Guidance (updated 2024)
- Children Act 1989 and 2004
- Working Together to Safeguard Children (2018)
- Counter-Terrorism and Security Act 2015 (Prevent Duty)
- Modern Slavery Act 2015
- Serious Crime Act 2015
- Data Protection Act 2018 and UK GDPR
- Human Rights Act 1998
- Equality Act 2010
- NHS England Safeguarding Accountability and Assurance Framework (2022)
- Professional standards from HCPC, BACP, UKCP, BPS, ACP-UK.

 

 

 

Appendix 2 – Categories of Risk and Abuse (Detailed)

This appendix outlines the full range of safeguarding risks identified in national guidance and DLTC’s operational practice.
It is divided into two parts: Adults (per the Care Act 2014) and Children (per the Children Acts 1989 & 2004 and “Working Together to Safeguard Children”, 2018).

Part A – Adults (Care Act 2014 Categories)

The Care Act 2014 defines safeguarding duties for adults with care and support needs. Safeguarding means protecting an adult’s
right to live in safety, free from abuse and neglect. The categories of abuse are as follows:

1. Physical Abuse – Includes hitting, slapping, burning, shaking, misuse of medication, unreasonable restraint, or poor manual handling.
• Signs: Unexplained or untreated injuries, bruises in various stages of healing, burns in unusual places, reluctance to reveal injuries.

2. Sexual Abuse – Any sexual activity the adult does not or cannot consent to, including rape, sexual assault, or harassment.
• Signs: Withdrawal, flinching, genital discomfort, pregnancy, inappropriate sexualised behaviour.

3. Financial or Material Abuse – Theft, fraud, exploitation, misuse of benefits or assets, or denial of access to money.
• Signs: Unpaid bills, lack of access to money, unusual withdrawals, or disclosure of coercion.

4. Psychological / Emotional Abuse – Includes intimidation, threats, humiliation, isolation, or coercive control.
• Signs: Low self-esteem, anxiety, withdrawal, compulsive behaviours, or fearfulness.

5. Neglect and Acts of Omission – Failure to provide essential care such as food, heating, or medication.
• Signs: Poor hygiene, malnutrition, untreated illness, depression, or isolation.

6. Self-Neglect – When a person is unable or unwilling to care for their hygiene, health, or living environment.
• Signs: Unsafe living conditions, malnutrition, refusal of help, hoarding, or social isolation.

7. Discriminatory Abuse – Harassment or unfair treatment based on protected characteristics (e.g., race, gender, disability, religion).
• Signs: Use of derogatory language, exclusion, withdrawal from services, or identity-based hostility.

8. Organisational / Institutional Abuse – Occurs in care settings where poor practice or policy harms people.
• Signs: Unsafe or unhygienic conditions, lack of dignity, or institutional neglect.

9. Domestic Abuse – Abuse between adults who are partners or family, including coercive control (Serious Crime Act 2015).
• Signs: Withdrawal, unexplained injuries, controlling partner, or restricted autonomy.

10. Modern Slavery – Slavery, forced labour, human trafficking, or servitude.
• Signs: Fearfulness, lack of ID, same clothes daily, no control over finances or movement.

11. Radicalisation to Terrorism – Grooming adults into extremist ideologies (Prevent Duty 2015).
• Signs: Withdrawal, sudden behavioural changes, extremist material possession, or justification of violence.

Factors increasing vulnerability include age, physical or learning disability, mental health difficulties, or social isolation.

Part B – Children (Children Acts 1989 & 2004 Categories)

Safeguarding children focuses on protecting those under 18 from abuse or neglect. The main categories are:

1. Physical Abuse – Causing physical harm (e.g., hitting, burning, shaking).
• Signs: Bruises, burns, fractures, fearfulness, or withdrawn behaviour.

2. Emotional Abuse – Persistent ill-treatment causing severe emotional harm.
• Signs: Low self-esteem, anxiety, developmental delay, or poor relationships.

3. Sexual Abuse – Forcing or enticing a child into sexual activities.
• Signs: Sexualised behaviour, fear of people, pain or infection, regression, or disclosure.

4. Neglect – Persistent failure to meet physical or emotional needs.
• Signs: Poor hygiene, malnutrition, untreated illness, absenteeism, or unsafe environments.

Children may also be at risk from:
- Domestic abuse exposure.
- Radicalisation (Prevent Duty).
- Online exploitation or grooming.
- Modern slavery and trafficking.

Therapists must use professional judgment, consult the safeguarding lead, and document all actions.

 

 

Appendix 3 – Suicide and Self-Harm Framework (Detailed)

DLTC’s Suicide and Self-Harm Framework is informed by guidance from the British Psychological Society (BPS),
Association of Clinical Psychologists UK (ACP-UK), Health and Care Professions Council (HCPC), British Association for Counselling and Psychotherapy (BACP),
NICE Guideline NG225 (2022), and NHS England’s Safety Planning Framework (2023–2025).

Understanding Suicidal Ideation
Clients may present with depression, anxiety, hopelessness, or distress that reveals suicidal thoughts. Ideation does not always
mean imminent danger but must always be taken seriously. Practitioners are expected to maintain an ethical, compassionate approach.

Threshold Model of Suicide Risk
1. Long-term factors: family history, chronic illness, perfectionism, hopelessness.
2. Short-term factors: life stress, loss, isolation, mental illness.
3. Precipitating events: recent crises such as bereavement or legal trouble.

Why “Low/Medium/High” Risk Labels Are Problematic
Research shows these labels can be misleading. NICE (2022) advises against predictive risk scoring. Instead, risk should be dynamically formulated
based on personal, situational, and contextual understanding.

Recommended Approach:
- Risk Formulation: understand “why this person, at this time” might be at risk.
- Safety Planning: co-produce a plan with the client identifying triggers, coping strategies, and emergency contacts.
- Dynamic Assessment: update risk understanding as circumstances change.
- Holistic Assessment: consider physical, social, cultural, and environmental aspects.
- Proportionate Intervention: ensure care is responsive regardless of perceived “risk level.”

Professional and Ethical Responsibilities
Practitioners must seek supervision when risk arises, document all observations and rationale, and act promptly if imminent danger is suspected.
If immediate danger exists, contact emergency services (999).

Framework for Clinical Response:
Minimal / Emerging Ideation – Maintain regular contact, begin safety planning.
Moderate Risk – Increase contact, liaise with GP or family, review safety plan.
High Risk – Urgent safety plan, referral to mental health services, document all actions.
Imminent Risk – Contact emergency services, ensure client safety, notify supervisor.

Learning from national reports (HSIB, NCISH, Coroners’ PFD Reports) emphasises the need for timely supervision, nuanced understanding,
and avoidance of complacency when clients are labelled “low risk.” Practitioners must integrate learning into reflective practice and ongoing professional development.