Safeguarding Policy & Procedures


modulo makes a positive contribution to a strong and safe community and recognises the right of every individual to stay safe.

modulo comes into contact with children and vulnerable adults when assessing them for equipment and delivering it to them once an order has been received. Also when visiting clients to repair or adjust any equipment.

Activities are usually controlled and carers are usually present.
Controlled activities also include administrators who can access data on vulnerable people.

This policy seeks to ensure that Independence Mobility undertakes its responsibilities with regards to protection of children and vulnerable adults and will respond to concerns appropriately. The policy establishes a framework to support staff in their practices and clarifies the organisation’s expectations.


Safeguarding is about embedding practices throughout the organisation to ensure the protection of children and vulnerable adults wherever possible. Child and adult protection is about responding to circumstances that arise.

Abuse is a selfish act of oppression and injustice, exploitation and manipulation of power by those in a position of authority. This can be caused by those inflicting harm or those who fail to act to prevent harm. Abuse is not restricted to any socio-economic group, gender or culture.

It can take a number of forms, including the following:

  • Physical abuse
  • Sexual abuse
  • Emotional abuse
  • Bullying
  • Neglect
  • Financial (or material) abuse

    Definition of a child:
    A child is under the age of 18

    Definition of Vulnerable Adults:
    A vulnerable adult is a person aged 18 years or over who may be unable to take care of themselves or protect themselves from harm or from being exploited.
    This may include a person who:

  • Is elderly and frail
  • Has a mental illness including dementia
  • Has a physical or sensory disability
  • Has a learning disability
  • Has a severe physical illness
  • Is a substance misuser
  • Is homeless


All staff have a responsibility to follow the guidance laid out in this policy and related policies, and to pass on any welfare concerns using the required procedures.

We expect all staff to promote good practice by being an excellent role model, contribute to discussions about safeguarding and to positively involve people in developing safe practices.

Additional specific responsibilities:

The Designated Senior Manager is Chloe Mitchell. This person’s responsibilities are;

  • Ensuring the policy is in place and appropriate.
  • The policy is accessible
  • The policy is implemented
  • The policy is monitored and reviewed
  • Ensuring staff have access to appropriate training/information
  • Receive any staff concerns about safeguarding and respond to all seriously, swiftlyand appropriately
  • Take forward any concerns
  • Keep up to date with local arrangements for safeguarding and CRB/DBS checks.

    Implementation Stages

    Our Safeguarding Policy is embedded within the company and is implemented via a range of policies and procedures within the organisation. These include:

  • Whistleblowing –ability to inform on other staff/ practices within the organisation
  • Grievance and disciplinary procedures – to address breaches of procedures/ policies
  • Health and Safety policy, including lone working procedures, mitigating risk to staff and clients
  • Equal Opportunities policy– ensuring safeguarding procedures are in line with this policy, in particular around discriminatory abuse and ensuring that the safeguarding policy and procedures are not discriminatory
  • Data protection (how records are stored and access to those records)
  • Confidentiality (or limited confidentiality policy) ensuring that service users are aware of our duty to disclose
  • Staff induction
  • Staff training
  • Safe recruitment

Safe practices are used to recruit and select staff, introduce them to their role and help them carry out their duties safely.

During our recruitment, selection and induction, our supervision processes help to show staff how much we value vulnerable people.

modulo ensures safe recruitment through the following processes:

  • Providing the following safeguarding statement on application forms during interviews –‘recruitment is done in line with safe recruitment practices.’
  • Job descriptions discussed during interviews for all roles involving contact with childrenand vulnerable adults will contain reference to safeguarding responsibilities.
  • Interviews are conducted according to equal opportunity principles. We carry out a face to face interview with a transparent scoring system (usually by Chloe Mitchell and Anthony Mitchell).
  • Questions are based on the relevant job description and person specification
  • CRB/DBS checks will be conducted for specific roles for all staff working with children and vulnerable adults.
  • 2 reference are requested and followed up
  • CRB/DBS checks from another employer will not be deemed to be sufficient.
  • We will ensure that our established staff and roles are regularly reviewed through re-checking CRB’s/DBS are in place for holders of all identified posts.
  • Existing staff who transfer from a role which does not require a CRB/DBS check to onewhich involves contact with children and vulnerable adults will be subject to a CRB/DBS check.

    Service delivery contracting and sub-contracting.

    Contracts and memorandums of agreement for partnership delivery work include clear minimum requirements and arrangements for safeguarding and non-compliance procedures’.

    Communications training and support for staff

    Independence Mobility commits resources for induction and training of staff, effective communications and support mechanisms in relation to Safeguarding

    Induction includes;

  • Discussion of the Safeguarding Policy (and confirmation of understanding)
  • Discussion of other relevant policies
  • Ensuring familiarity with reporting processesTraining

    All staff who, through their role, are in contact with children and vulnerable adults will have access to safeguarding training at an appropriate level. Sources and types of training will include

  • One to one meetings
  • Team meetings
  • Participation in joint client visits
    Chloe Mitchell will attend relevant courses such as Introduction to working together to safeguard children and young people and report back to staff as part of refresh training. The training aims to help the rest of the team to identify any risks which may lead to abuse and to feel able to raise concerns.

    Communications and discussion of safeguarding issues

    Commitment to the following communication methods will ensure effective communication of safeguarding issues and practice:

  • Provision of a clear and effective reporting procedure which encourages reporting of concerns
  • Encouraging open discussion (e.g. during supervision and team meetings) to identify any barriers to reporting so that they can be addressed.
  • Inclusion of safeguarding as a discussion prompt during supervision meetings/ appraisals to encourage reflectionTypical support mechanisms would include:
  • Debriefing support for staff so that they can reflect on the issues they have dealt with.
  • Seeking further support as appropriate e.g. access to counselling.
  • Staff who have initiated protection concerns will be contacted by Chloe Mitchell within 48 hoursProfessional boundaries

    If the professional boundaries and/or policies are breached this could result in disciplinary procedures.

  • Independence Mobility does not allow staff to accept gifts/ rewards or hospitality from an organisation or client as an inducement for either doing/ not doing something in their official capacity
  • Personal relationships between a member of staff and a client who is a current service user is prohibited. This includes relationships through social networking sites such as facebook.
  • Inappropriate behaviour / language is not acceptedReporting and allegations management

    If someone tells about abuse they are experiencing

    • Remain calm, no shock or disbelief
    • Say it was the right thing to do
    • Ask the person to explain and describe
    • Listen
    • Don’t ask probing questions
    • Be empathetic
    • Tell them to report the concerns to the Manager
    • Explain the Manager will seek consent before referring DO NOT
    • Put yourself at risk
    • Contact the alleged perpetrator
    • Be judgemental
    • Make promises you can’t keep
    • Tell anyone who doesn’t need to know
    • Stage an interviewImmediate Actions
    • Is anyone at immediate risk? Call an ambulance/GP/Police
    • Separate the perpetrator and victim
    • Preserve evidence where possible (discourage washing or drinks; in case of swabs)
    • Do not handle evidence
    • Following the organisations procedures eg verbal report to manager
    • Make a written account as soon as possible with facts, not opinion, date and sign it

If a member of staff is suspected

  • Follow the whistle blowing procedure or if a Manager is suspected alert Social Services or the Social Care Office
  • A Manager must support the alleged victim
  • Support the wider staff team
  • Support the investigation
  • Be fair to the alleged perpetrator
  • Implement disciplinary procedures and possible suspension without predjudice and according to employment lawmodulo recognises its duty to report concerns or allegations against its staff within the organisation or by a professional from another organisation

    The process for raising and dealing with allegations is as follows:
    First step: Any member of staff from Independence Mobility is required to report any concerns in the first instance to Chloe Mitchell (the safeguarding manager). ‘A written record of the concern will be completed by the safeguarding manager. If the complaint is concerning Chloe Mitchell please report to Kerry Palmer.

    Second step- contact the local authority for advice.

    Third step – follow the advice provided

    Independence Mobility recognises its legal duty to report any concerns about unsafe practice by any of its staff to the Independent Safeguarding Authority (ISA), according to the ISA referral guidance document

    When the alleged perpetrator is a service user

    Some abusive behaviour has become culturally acceptable as ‘challenging behaviour’.

  • Abusive acts must be logged and monitored
  • Assess the immediate risk
  • Contact the relevant therapist/ Social Services
  • Maybe ensure 2 people are there in futureIndependence Mobility recognises its duty to report concerns or allegations against its staff within the organisation or by a professional from another organisation.


  • The organisation will monitor the following Safeguarding aspects:
  • Safe recruitment practices
  • CRB/DBS checks
  • References applied for new staff
  • Training – register/ record of staff training
  • Monitoring whether concerns are being reported and actioned
  • Checking that policies are up to date and relevant
  • Reviewing the current reporting procedures in place
  • During appraisals staff should also be expected to discuss safeguarding

Managing Information

Information will be gathered, recorded and stored in accordance with the following policies

Data Protection Policy Confidentiality Policy

All staff must be aware that they have a professional duty to share information with other agencies in order to safeguard children and vulnerable adults. The public interest in safeguarding children and vulnerable adults may override confidentiality interests. However, information will be shared on a need to know basis only, as judged by the Designated Senior Manager.

All staff must be aware that they cannot promise service users or their families/ carers that they will keep secrets.


modulo has an established complaints procedure in place for how someone would make a complaint. If necessary this will be taken forward by the designated senior manager.
Conflicts in respect of safety of vulnerable adults will be taken forward by Chloe Mitchell.

Communicating and reviewing

modulo will make clients aware of the Safeguarding Policy through a statement which is displayed on the website.

Reviewing of the policy i.e. looking at the policy, checking it is still appropriate and making changes as necessary will take place once a year unless there are changes in circumstances or legal requirements.

This policy will be reviewed by Chloe Mitchell, every year and when there are changes in legislation.