Safeguarding Adults At Risk Policy

1.1 Policy Statement

Haringey Culture Collective (HCC) has a duty of care to safeguard all adults involved in its activities from harm. HCC works with people of all ages, backgrounds and circumstances, some of whom may be adults at risk of abuse or neglect.

This policy sets out HCC’s commitment to safeguarding adults at risk and should be read alongside HCC’s Safeguarding Children and Young People Policy, which applies to individuals under the age of 18.

In fulfilling its safeguarding responsibilities, HCC will work in accordance with relevant legislation and statutory guidance, including the Care Act 2014, the Mental Capacity Act 2005, and associated statutory guidance, as well as local multi‑agency safeguarding adults policies and procedures.

1.2 Policy Aims

The aim of HCC’s Safeguarding Adults at Risk Policy is to promote good practice by:

• Supporting Adults at Risk to remain safe, live with dignity, and be protected from abuse or neglect while taking part in HCC activities.
• Promoting a culture of respect, inclusion and empowerment, recognising adults’ rights to make informed choices and to be involved in decisions about their own safety wherever possible.
• Supporting staff, freelancers, trustees and volunteers to recognise safeguarding concerns and to respond to them confidently, appropriately and proportionately, in line with this policy and statutory guidance.
• Providing clear procedures for reporting and responding to safeguarding concerns and for working in partnership with statutory agencies where required.

1.3 HCC Safeguarding Principles

HCC’s safeguarding practice for adults is guided by the following principles:

• The wellbeing, safety and dignity of individuals is paramount.
• All adults, regardless of age, disability, gender, gender identity, race, language, religion or belief, sexual orientation or socio‑economic background, have the right to live free from abuse and neglect.
• Adults should be supported to make informed choices and to be involved in decisions about their own safety, wherever possible.
• All suspicions, concerns and allegations of abuse or neglect will be taken seriously and responded to promptly and appropriately.
• All staff, freelancers, trustees and volunteers should be clear about how to recognise safeguarding concerns and how to respond in line with this policy.

1.4 Definition of to whom these guidelines apply

These guidelines apply to:

• Any situation involving Adults at Risk, whether or not they are accompanied by other adults.
• All staff, freelancers, volunteers, trustees, contractors and consultants working with or on behalf of HCC, including within HCC projects, activities or premises.
• In the case of contractors and consultants, it is the responsibility of the relevant HCC programme manager to ensure that all individuals are made aware of, understand, and adhere to this policy.

Staff
For the purposes of this policy, staff refers to any adult who is employed, commissioned or contracted to work with or on behalf of HCC, in a paid or unpaid capacity, including employees, freelancers, artists, facilitators, trustees, volunteers, contractors and consultants.

Designated Safeguarding Officer (DSO):
Kenneth Tharp, Director of Culture and Communities, Haringey Council
(acting in an independent safeguarding capacity on behalf of HCC)

The DSO is responsible for receiving safeguarding concerns, making referrals to statutory agencies where appropriate, and overseeing safeguarding practice within HCC.

Deputy Designated Safeguarding Officer:
Beki Bateson, HCC Creative Director

Chief Executive Officer (safeguarding escalation and organisational oversight):
Clara Dublanc, Chief Executive Officer

Adult
An adult is defined as a person aged 18 years or over.

Adult at Risk
An adult at risk is defined, in line with Section 42 of the Care Act 2014, as a person aged 18 or over who:

• has needs for care and support (whether or not those needs are being met), and
• is experiencing, or is at risk of, abuse or neglect, and
• because of those needs is unable to protect themselves from abuse or neglect.

In the context of HCC’s work, an adult at risk may include a person who:

• has a learning disability;
• has a physical disability and/or sensory impairment;
• has mental ill‑health or a personality disorder;
• has a long‑term illness or condition;
• misuses substances or alcohol;
• is a carer who provides personal support and may themselves be at risk of abuse;

• is unable, at a particular time, to demonstrate the mental capacity to make specific decisions relating to their safety or care.

  Important note:
  The presence of a disability, illness or support need alone does not mean that an individual is an adult at risk. Adult safeguarding is concerned with a person’s ability to understand, make and exercise informed choices free from coercion, pressure or undue influence, and their ability to protect themselves from abuse, neglect or exploitation.

1.5 General Duties of Staff

Protection from abuse is a fundamental human right.

• All suspicions, concerns and allegations of abuse or neglect must be taken seriously and responded to promptly and appropriately.
• Staff are not responsible for determining whether abuse has occurred and are not trained to carry out investigations. It is not the role of any member of staff to conduct investigative proceedings.
• Any safeguarding concern relating to an Adult at Risk must be reported immediately to HCC’s Designated Safeguarding Officer (DSO).
• Where appropriate, the DSO will liaise with the Haringey Adult Safeguarding Duty Team, which is the correct statutory safeguarding contact point for adults at risk in Haringey.

2.1 Personal factors

Some personal circumstances may increase the likelihood that an adult is at risk of abuse or neglect. These factors do not in themselves mean that abuse is occurring, but they may impact a person’s ability to protect themselves or seek help.

• Difficulty making specific decisions about their own safety, including fluctuating mental capacity, for example associated with mental ill‑health.
• Communication difficulties, including sensory impairment or barriers related to language.
• Physical dependency on others for personal care or daily living.
• Low self‑esteem or lack of confidence.
• Past experience of abuse or neglect.
• Childhood experience of abuse, which may increase vulnerability in adulthood.

 2.2 Social/situational factors that put Adults at Risk

Social, environmental or situational factors may also increase the risk of abuse or neglect, particularly where power imbalances exist.

• Reliance on care or support in a residential, supported or community setting.
• Not receiving the appropriate level or quality of care or support.
• Social isolation or exclusion.
• Experience of stigma or discrimination.
• Limited access to information, advocacy or support networks.
• Being targeted by anti‑social behaviour or exploitation.

The Mental Capacity Act 2005 provides a statutory framework to empower and protect individuals who may lack the capacity to make specific decisions for themselves. It applies to people aged 16 and over and sets out how decisions should be made where a person is unable to do so independently.

In line with the Mental Capacity Act, all adults are presumed to have mental capacity to make decisions about their own lives, including decisions relating to their safety, unless it is established otherwise.

This includes their ability:

• To understand information relevant to their situation and the decisions being made.
• To weigh up risks and benefits, including taking action themselves to prevent abuse or neglect.
• To participate as fully as possible in decisions about support, protection or intervention.

A person is considered unable to make a particular decision if they are unable to:

• Understand the information relevant to that decision.
• Retain the information long enough to make the decision.
• Use or weigh that information as part of the decision‑making process.
• Communicate their decision by any means (including speech, sign language, or other forms of communication).

Mental capacity is decision‑specific and time‑specific. This means that an individual may have capacity to make some decisions but not others at a particular point in time. Capacity may also fluctuate, for example due to ill‑health, distress or the effects of substances.

Where a person is assessed as lacking capacity to make a particular decision, any action taken on their behalf must be in their best interests and be the least restrictive option, in accordance with the Mental Capacity Act and its Code of Practice.

For the purposes of this safeguarding policy, abuse is understood as a violation of an individual’s rights or safety which results in harm, distress, exploitation or neglect.

In line with the Care Act 2014 and accompanying statutory guidance, safeguarding adults encompasses the prevention and response to abuse or neglect experienced by adults at risk.

Types of Abuse

The Care and Support Statutory Guidance identify the following main categories of abuse. These categories are not exhaustive and may overlap.

Physical Abuse

Physical abuse includes deliberate physical harm or injury, or the failure to act to prevent harm. This may include hitting, slapping, pushing, burning, misuse of medication, or the inappropriate or unlawful use of restraint.

Restraint may only be used where legally justified, proportionate, and necessary to prevent harm, and must be in accordance with the Mental Capacity Act 2005 where a person lacks capacity.

Sexual Abuse

Sexual abuse includes rape, sexual assault, or sexual acts which the individual has not consented to or cannot consent to.

This includes situations where:

a person lacks the mental capacity to give informed consent; or

a person has been coerced, pressured or exploited, particularly where the perpetrator is in a position of trust, power or authority.

Psychological or Emotional Abuse

Psychological or emotional abuse is behaviour that causes mental distress or emotional harm. This may include:

threats, intimidation or harassment;

humiliation, blame or controlling behaviour;

denial of basic human and civil rights such as privacy, dignity or self‑expression;

isolation, over‑dependence or deprivation of social contact.

Such abuse can undermine an adult’s self‑esteem, independence and ability to protect themselves or exercise choice.

Financial or Material Abuse

Financial or material abuse is a criminal offence and includes the unauthorised or improper use of a person’s money, property, assets or benefits.

This may include theft, fraud, exploitation, pressure in relation to financial decisions, or the misuse or misappropriation of possessions or benefits.

Neglect and Acts of Omission

Neglect includes the persistent failure to meet basic care needs, whether deliberate or unintentional, resulting in harm or serious risk to health or wellbeing.

This may include failure to provide food, medication, personal care, safety or appropriate support.

 Self‑Neglect

Self‑neglect refers to a wide range of behaviour involving neglecting to care for one’s personal hygiene, health, environment or safety.

Indicators may include:

extreme lack of self‑care that threatens health or safety;

failure to seek or accept help to meet care or support needs;

inability or unwillingness to manage personal affairs.

Self‑neglect may be linked to deteriorating physical or mental health, but should always be approached in a person‑centred and respectful way.

Discriminatory Abuse (including Hate Crime)

Discriminatory abuse occurs where abuse or neglect is motivated by prejudice or discriminatory attitudes.

This may relate to age, disability, gender, gender identity, race, religion or belief, sexual orientation, culture or language.

Hate crime is a form of discriminatory abuse and includes any incident perceived by the victim, or any other person, to be motivated by hostility or prejudice, whether or not it meets the threshold of a criminal offence.

Some individuals, including LGBTQI+ people, may face additional barriers to reporting abuse or may fear not being believed or being further stigmatised.

 Organisational or Institutional Abuse

Organisational abuse arises from poor care practices or systems within a service or setting, leading to the denial of choice, dignity, privacy, autonomy or safety.

This may include rigid routines, unsafe practices, lack of person‑centred care or cultures that tolerate neglect or poor treatment.

Domestic Abuse

Domestic abuse includes any incident or pattern of behaviour between adults who are, or have been, intimate partners or family members.

This may include physical, emotional, psychological, sexual or financial abuse, controlling or coercive behaviour, intimidation, or threats.

Modern Slavery and Human Trafficking

Modern slavery encompasses slavery, servitude, forced or compulsory labour, and human trafficking.

People may be exploited through sexual exploitation, forced labour, domestic servitude, criminal exploitation, or forced marriage.

Safeguarding responsibilities apply regardless of whether exploitation occurs locally or across borders.

There are several circumstances under which HCC may have concerns that an Adult at Risk has experienced, or is experiencing, abuse or neglect.

These may include:

• Disclosure from an Adult at Risk – an individual may tell a member of staff about abuse they are experiencing, or have experienced in the past.
• Disclosure from a third party – a family member, carer, neighbour, friend or acquaintance may raise concerns.
• Observation – staff may identify possible indicators of abuse or neglect through observation, including unexplained injuries, changes in behaviour, presentation or emotional wellbeing.
• Colleague conduct – concerns may arise regarding the behaviour or conduct of a colleague when working with an Adult at Risk.

Staff should remain alert to possible indicators of abuse or neglect and consider whether a safeguarding concern may be present. The presence of an indicator does not in itself confirm abuse, but it:

• Must be regarded as a possible indicator of risk or significant harm.
• Justifies careful consideration and discussion with HCC’s Designated Safeguarding Officer (DSO), or in their absence, the Deputy Designated Safeguarding Officer.
• May require a safeguarding concern to be raised with the Haringey Adult Safeguarding Duty Team, in line with this policy.

The absence of indicators does not mean that abuse or neglect has not occurred. A non‑exhaustive list of possible indicators of abuse and neglect is provided in Appendix 1.

6.1 How disclosure can take place

Disclosure of abuse or neglect may occur in different ways and can be particularly common in arts and creative settings, where creative activity may enable emotions or experiences that have previously been suppressed to surface.

Adults at Risk may be more likely to disclose concerns to individuals they perceive as temporary or informal, such as artists or workshop facilitators, rather than to established members of staff.

Disclosure may take place:

• Verbally – where an Adult at Risk directly tells someone about abuse or neglect they are experiencing or have experienced.
• Non‑verbally – through creative expression such as writing, visual work, music or song lyrics, or through changes in behaviour or presentation.

Disclosure may be presented as a request for secrecy, as the Adult at Risk may be concerned about the consequences of sharing their experiences. In these circumstances, staff, volunteers or contractors should:

• Reassure the person that they have done the right thing by speaking up; and
• Explain sensitively that the information will need to be shared with HCC’s Designated Safeguarding Officer (DSO), and that confidentiality cannot be promised where there are safeguarding concerns.

Any adult who receives a disclosure has a responsibility to ensure that the concern is passed to the DSO without delay.

6.2 How to receive a disclosure

First: Take immediate action if required

• Ensure the person is not in immediate danger.
• Seek medical assistance if required.
• Contact the emergency services if a crime has been committed or there is immediate risk.
• Do not disturb anything that may be required as evidence.

Second: Listen to the Adult at Risk

• Take the concern seriously and listen carefully.
• Remain calm and supportive.
• Do not ask leading questions or probe for detail.
• Show empathy without making assumptions or jumping to conclusions.
• Do not promise complete confidentiality.
• Do not confront or question the alleged abuser.
• Share factual observations and concerns without interpretation.

Third: Record what you have heard or observed

A clear, accurate written record should be made as soon as possible and should include:

• The date, time and location of the alleged incident or disclosure.
• What the Adult at Risk said, in their own words where possible.
• Observations about appearance, behaviour or emotional state.
• Details of any injuries or visible indicators.
• The names of any witnesses or other people involved.
• Any immediate actions taken.
• Any relevant considerations regarding mental capacity or best‑interest decisions.
• A clear distinction between fact, opinion and professional concern.

Fourth: Report the concern

• The written record and details of the disclosure must be passed promptly to HCC’s Designated Safeguarding Officer (DSO), or to the Deputy DSO if the DSO is unavailable. 

7.1 Code of Behaviour

Abuse can occur in a wide range of contexts, including within domestic, community and cultural settings. Some individuals may seek paid or voluntary roles that give them access to Adults at Risk in order to cause harm.

Staff, freelancers and volunteers who have regular contact with Adults at Risk play an important role in identifying safeguarding concerns and responding appropriately. Any concerns about poor practice, boundary issues or potential abuse must be reported in line with this policy.

Where an Adult at Risk engages with HCC having experienced abuse outside HCC activities, creative and cultural engagement may support confidence, wellbeing and recovery. In such circumstances, HCC will work in partnership with relevant agencies where appropriate to support the Adult at Risk’s safety and wellbeing.

All staff are expected to behave in a professional and appropriate manner at all times. Adhering to good practice helps to create a safe, respectful environment and also protects staff from misunderstandings or unfounded allegations.

7.2 What Good Practice means

Good safeguarding practice includes, but is not limited to:

• Treating all individuals with respect, dignity and fairness.
• Placing the safety, wellbeing and wishes of Adults at Risk above artistic, organisational or performance goals.
• Maintaining appropriate professional boundaries with Adults at Risk at all times.
• Building balanced, respectful relationships that support Adults at Risk to participate in decisions affecting them, in line with their wishes and capacity.
• Ensuring that any physical or manual support is necessary, proportionate, provided openly, and undertaken with the Adult at Risk’s consent, or in line with best‑interest decision‑making where capacity is lacking.
• Keeping relevant skills, qualifications and insurance up to date where required within an arts context.
• Ensuring appropriate arrangements are in place where supervision is required in changing or private spaces, including working in pairs where necessary.
• Making careful, risk‑assessed decisions during trips or residential activities, ensuring safeguards are in place without unnecessary restriction.
• Avoiding entering an Adult at Risk’s private space, or inviting them into staff accommodation, except where this is necessary for safety and agreed through risk assessment.
• Providing constructive, supportive feedback and avoiding behaviour that may be humiliating, dismissive or coercive.
• Recognising individual capacity, needs and preferences, and avoiding pressure to participate beyond what has been freely agreed.
• Keeping a written record of any accidents or injuries, including details of any assistance or treatment provided.
• Ensuring appropriate consent is obtained before the use of photography, video footage or any form of broadcast involving Adults at Risk, in accordance with HCC policy.

It is not the responsibility of anyone working for HCC, in a paid or unpaid capacity, to determine whether abuse or neglect has taken place. All staff, freelancers, trustees and volunteers do have a responsibility to act on any safeguarding concerns in line with this policy.

HCC will ensure that any individual who raises a safeguarding concern in good faith is supported and protected.

8.1 Concerns about practice

Where a concern relates to poor practice, boundary issues or behaviour that does not involve suspected abuse or neglect, the matter will be managed through HCC’s internal procedures.

• The concern will be addressed by the Designated Safeguarding Officer (DSO) in consultation with the Chief Executive Officer (CEO) as a potential misconduct issue.
• If the concern relates to the practice of the DSO, or where concerns remain unresolved, the matter must be reported directly to the CEO.
• Where the concern involves the CEO, the DSO will report the matter to the Chair of the HCC Board of Trustees, who will determine the appropriate course of action.

8.2  Concerns about suspected abuse

Any suspicion or allegation that an Adult at Risk has been abused or neglected must be reported immediately to HCC’s Designated Safeguarding Officer (DSO).

If the DSO is unavailable, concerns must be reported to the Deputy DSO or, where necessary, escalated to the CEO.

The DSO will:

• Make an initial assessment of the risk to the Adult at Risk.
• Take reasonable and proportionate steps to safeguard the person, including identifying communication needs, personal support arrangements and access requirements.
• Seek urgent medical assistance where required.
• Contact the police where a criminal offence is suspected.
• Raise a safeguarding concern with the Haringey Adult Safeguarding Duty Team, which is the appropriate statutory safeguarding route for adults at risk in Haringey.
• Liaise with the CEO where the alleged abuser is a member of staff, freelancer or volunteer, and where a decision is required regarding suspension or other immediate protective action.
• Where the alleged abuser is another programme participant, ensure appropriate arrangements are made to prevent contact while safeguarding the wellbeing and rights of all individuals involved.

9.1 Responsibilities of the Designated Safeguarding Officer

The DSO will:

• Act as the central point of contact for all safeguarding adults concerns within HCC.
• Take a consultative and advisory role for staff, freelancers, trustees and volunteers, including supporting de‑briefing after safeguarding referrals where appropriate.
• Ensure that safeguarding concerns are recorded accurately and that written referrals and supporting documentation are completed and submitted to the Haringey Adult Safeguarding Duty Team within appropriate timescales following initial contact.
• Lead liaison with statutory safeguarding partners, including the Adult Safeguarding Duty Team and the police where relevant.
• Support the dissemination and understanding of this policy and associated good‑practice guidance across HCC.
• Ensure that procedures are followed where allegations are made against a member of staff, freelancer or volunteer, in line with this policy and HCC’s disciplinary processes.

The CEO retains overall accountability for safeguarding within HCC and will support the DSO in ensuring that safeguarding responsibilities are met at an organisational level.

10.1 Indicators of Abuse and Neglect

The indicators listed below are examples only and are not exhaustive. The presence of one or more indicators does not confirm that abuse or neglect has occurred. However, they may indicate that an Adult at Risk is experiencing harm or is at risk of harm and should be discussed with HCC’s Designated Safeguarding Officer.

Physical Abuse

· Unexplained bruising, particularly to the thighs, buttocks, upper arms, or neck

· Injuries inconsistent with explanations given

· Signs of restraint, such as marks on wrists or arms

· Fear of receiving help with personal care

· Reluctance to be left alone with a particular person

Sexual Abuse

· Torn, stained or bloody clothing

· Pregnancy in a person who lacks capacity to consent

· Sexually explicit language or behaviour that is uncharacteristic

· Significant changes in sexual behaviour or attitudes

· Self‑harming behaviour

· Poor concentration, withdrawal, sleep disturbance

· Excessive fear or withdrawal from relationships

Psychological/Emotional Abuse

· Withdrawal or change in psychological or emotional state

· An atmosphere of silence when a particular person is present

· Low self‑esteem or loss of confidence

· Insomnia

· Aggressive, anxious or uncooperative behaviour

· Changes in appetite or significant weight loss/gain

· Signs of distress, including tearfulness or anger

· False or exaggerated claims made by others to attract unnecessary treatment

Financial/Material Abuse

· Missing personal possessions

· Unexplained lack of money or inability to maintain usual lifestyle

· Unexplained withdrawal of funds

· Power of Attorney or LPA obtained when the person lacked capacity

· Financial representatives who are evasive, reluctant or uncooperative

· Unusual interest shown by others in the person’s finances or assets

· Signs of financial hardship despite available resources

· Rent arrears, eviction notices or unpaid bills

· Lack of receipts for financial transactions carried out on the person’s behalf

· Discrepancy between living conditions and financial resources

· Unnecessary or excessive property repairs

Neglect and acts of omission

· Poor, unsafe or unhygienic living conditions

· Poor physical condition or personal hygiene

· Malnutrition or unexplained weight loss

· Untreated injuries or medical conditions

· Reluctance or failure to engage with healthcare or social services

· Accumulation of unused medication

· Inappropriate or inadequate clothing

· Reduced engagement in social interactions

Self-neglect

· Very poor personal hygiene or unkempt appearance

· Lack of essential food, clothing or shelter

· Malnutrition and/or dehydration

· Living in squalid or unsanitary conditions

· Neglecting household maintenance

· Hoarding behaviours

· Keeping animals in inappropriate or unsafe conditions

· Non‑compliance with health or care services

· Inability or unwillingness to manage medication or treat illness

Discriminatory Abuse

· Withdrawal, isolation or exclusion

· Expressions of fear, anger or anxiety

· Support that fails to meet needs linked to protected characteristics under the Equality Act

Institutional/Organisational Abuse

· Lack of choice and flexibility in services

· Inadequate staffing levels

· People appearing hungry or dehydrated

· Poor care standards

· Communal use of personal belongings

· Lack of clear procedures or guidance

· Poor record‑keeping or missing information

· Lack of activities or stimulation

· Public discussion of personal matters

· Absence of individual care or support plans

· Weak management oversight

Trafficking and Modern Slavery

· Signs of physical or emotional abuse

· Malnourished, withdrawn or fearful appearance

· Isolation from the community

· Appearing controlled or influenced by others

· Living in overcrowded or unsafe accommodation

· Living and working at the same address

· Lack of personal identification documents

· Wearing the same clothing repeatedly

· Avoidance of eye contact or fear of authority figures

Domestic Violence/Abuse

· Low self‑esteem or self‑blame

· Physical injuries such as bruising or broken bones

· Verbal abuse or humiliation in front of others

· Fear of outside intervention

· Damage to home or property

· Isolation from friends or family

· Limited or restricted access to money

To raise a safeguarding concern with HCC 
Please contact hello@haringeycollective.com with SAFEGUARDING CONCERN as the subject line and this will be sent to the Designated Safeguarding Officer as a matter of urgency. 

Haringey Council – Adult Safeguarding

Haringey Adult Safeguarding Duty Team (Advice and Referrals)
Telephone: 020 8489 1400 (Monday to Friday, office hours)
Out‑of‑hours Emergency Duty Team: 020 8489 0000

Email (professional referrals / enquiries): 
safeguardingadultduty@haringey.gov.uk
firstresponseteam@haringey.gov.uk

Emergency Services

If an adult is in immediate danger, or a crime is in progress, dial 999