Introduction 

LSSC is a friendly, inclusive, integrated sports and recreation club with vision impaired and fully sighted adult members of all ages and abilities. LSSC is committed to providing safe, enjoyable physical activity and sporting opportunities for all of its members. 

Policy statement

LSSC is committed to creating and maintaining a safe and positive environment for all members. It accepts its responsibility to assist in the welfare of all members and to safeguard them from poor practice, abuse and bullying. (See further information in the appendices.)

All individuals within LSSC have a role and responsibility to help ensure the safety and welfare of adults. 

LSSC accepts that we are required to fulfil our duty of care, which means that we must do everything that can be reasonably expected of us to help safeguard and protect people from harm, and to act when we suspect that someone is being harmed, or is at risk of harm.

LSSC Designated Safeguarding Lead is Beverley Williamson: 07593452149

           Deputy Designated safeguarding lead is Terry James : 07880677086

London’s Safeguarding Adults hotline on 0845 618 9762 open 24 hours a day, 7 days a week

What is adult safeguarding?

The official definition of “Adult safeguarding” is working with adults with care and support needs to keep them safe from abuse or neglect. It is an important part of what many public services do, and a key responsibility of local authorities (Care Act 2014).

The safeguarding duties apply to an adult who:

• has needs for care and support (whether or not the local authority is meeting any of those needs)
• is experiencing, or is at risk of, abuse or neglect
• is unable to protect themselves from either the risk of, or the experience of, abuse or neglect, as a result of those care and support needs

Adults who fulfil this criteria are ‘adults at risk’. 

People can have a need for care and support for a variety of reasons – for example they may have a learning disability, a physical disability, a chronic health condition or have a mental health issue. Such conditions may bring with them additional vulnerabilities, however having care and support needs does not mean that people are automatically adults at risk and need safeguarding.  

Safeguarding adults is underpinned by:

The Care Act 2014

Mental Capacity Act (MCA) 2005

Types of abuse suffered by adults identified in the Care Act 2014 are:

• Physical
• Sexual
• Psychological/Emotional/Mental
• Financial and material
• Neglect and act of omission
• Discriminatory
• Organisational
• Modern Day Slavery
• Domestic Violence
• Self Neglect – including hoarding

Other types of harm that adults may experience include:

• Cyber Bullying (Appendix E)
• Forced Marriage
• Female Genital Mutilation
• Hate Crime
• Radicalisation (Appendix D)

Safe recruitment and safeguarding training

We want to make sure that all of our members have the right skills and qualities to create a safe environment. Appropriate training will also be identified and offered, including safeguarding adults training.

Communication

LSSC will make available its Safeguarding Adults Policy and Procedures to all members and partner organisations. 

We recognise that some committee members may have a high level of safeguarding training and others may not. Therefore:

• an annual audit will be carried out of training needs amongst the committee members and suitable training arranged. 
• Safeguarding will be included in the agenda for committee meetings. 

Definitions 

Vulnerable adult: 

A person aged 18 or over who is or may be in need of community care services because of mental or other disability, age, illness and is or may be unable to take care of him or herself or take steps to protect themselves from significant harm or exploitation. This could include people with learning disabilities, sensory impairments, mental health needs, older people and people with physical disability or impairment. The term vulnerable adult may include any individuals who may be vulnerable as a consequence of their role as a carer in relation to any of the above. 

Safeguarding:

The process of protecting children and vulnerable adults from abuse or neglect, preventing impairment of their health and development and ensuring they are growing up in circumstances consistent with the provision of safe and effective care that enables them to have optimum life chances. 

Poor Practice: 

Poor practice includes any behaviour that contravenes LSSC’s Code of Conduct. 

Capacity:

While it is not for individuals to make a decision about whether an adult lacks capacity, it is important to have an understanding of the notion of capacity when safeguarding vulnerable adults. 

Capacity refers to an individual’s ability to make a decision or take a particular action for themselves at a particular time, even if they are able to make other decisions. For example, they may be able to make small decisions about everyday matters such as what to wear for a sports activity, or what a healthy sports diet would be, but they lack the capacity to make more complex decisions about financial matters.

Policy Aims 

This Safeguarding Policy is mandatory for all members of LSSC.

The aims are: 

• To create a healthy and safe environment for all activities including sports. 
• To ensure vulnerable adults are listened to, and kept safe from harm. 
• To ensure that members who supervise or administer sessions are well informed, supported and enabled to provide the best possible practice. 

Objectives 

The objectives are: 

• To raise the level of awareness of members about abuse and it’s various forms. 
• To raise the level of awareness of members about what all vulnerable members are entitled to be protected from. 
• To ensure that all members are able to recognise signs and symptoms which could signify abuse. 
• To promote the general welfare, health and full development of all members during all activities. 
• To develop effective procedures in recording and responding to accidents, complaints and alleged or suspected incidents of abuse. 

Duty of Care 

Duty of care means that measures are put in place as are reasonable in the circumstances to ensure that individuals will be safe to participate in an activity to which they are invited to or which is permitted. This duty occurs in two ways: 

1. A Legal Duty of Care 
2. A Moral Duty of Care 

The Legal Duty of Care has a strict definition. The most obvious example of this is in Health and Safety procedures where clear guidance is provided about what reasonable steps should be taken to minimise the hazards related to activities, substances or situations.  

In many sports activities, given the health and safety considerations, it is recognised that a sports organisation or individual owes a duty of care to its members. However, it is also understood and recognised that accidents can and do happen, and that it is not possible to predict every eventuality. Liability for the legal duty of care would only arise when an incident occurs and it can be demonstrated that the risk was foreseeable but no action had been taken to remedy it. 

The Moral Duty of Care is more correctly a responsibility for safety and welfare. To determine if a breach of the duty of care has occurred the ordinary civil law of negligence would be applied. The question is whether the accused in acting, or omitting to act, has failed to reach the standard of a reasonable person. 

Who Should Be DBS Checked?

Some members of LSSC are Vulnerable Adults regularly using its facilities and the following roles must have DBS checks:

• Club Chairman

• Designated Safeguarding Lead

• Any member who regularly supports Vulnerable Adults

• Drivers

• Website Administrators/ Forum moderators

The following roles should only be DBS checked if they involve Significant Access to Vulnerable Adults :

• Committee members

• Other members

Before requesting a DBS Disclosure the Designated safeguarding Lead, must satisfy themselves that the position that the individual will be working in involves ‘Significant Access’ to Vulnerable Adults or is a Regulated Activity. 

For the purposes of LSSC a Regulated Activity, as defined by the Safeguarding Vulnerable Groups Act would include :

• Training, teaching or instruction provided wholly or mainly for Vulnerable Adults such as coaching a group of cyclists with a specific disability, for example a group with learning disabilities

Driving a vehicle which is being used only for the purpose of conveying Vulnerable Adults and any person caring for the Vulnerable Adult, for example taking a group of cyclists to an event.

The fact that an individual may come into contact with Vulnerable Adults is insufficient to subject them to a DBS check. Eligibility for a DBS check depends on the specific role a person will perform whilst conducting their duties within an organisation. LSSC will provide prospective DBS applicants with a form to complete to establish the role and duties they are expected to fulfil whilst carrying out their role and DBS applications made accordingly.

The Designated Safeguarding Lead will advise Committee members who are unsure of the appropriate level of vetting for any role.

Code of Conduct 

The Code of Conduct is partly a value statement but also a useful framework and tool to reduce situations where abuse may occur. The following is a broad overview of the care which should be taken. 

You should: 

• Treat all children and young people and adults with respect. 
• Provide an example for good conduct you wish others to follow. 
• Ensure that whenever possible there is more than one non-vulnerable adult present during activities with vulnerable adults, or at least that you are within sight or hearing of others. 
• Respect the right to personal privacy and encourage members to feel comfortable and caring enough to point out attitudes or behaviours they do not like. 
• Remember that someone else might misinterpret your actions, no matter how well intentioned. 
• Be aware that physical contact may be misinterpreted. 
• Recognise that special caution is required when you are discussing sensitive issues with vulnerable adults. 
• Challenge unacceptable behaviour and report all allegations / suspicions of abuse. 
• Members should build relationships which are balanced and based on mutual trust .

You should not: 

• Have inappropriate physical or verbal contact. 
• Allow yourself to be drawn into inappropriate attention-seeking behaviour or make suggestive or derogatory remarks or gestures in front of children, young people or adults. 
• Jump to conclusions about others without checking facts. 
• Either exaggerate or trivialise abuse issues. 
• Show favouritism to any individual. 
• Rely on your good name or that of LSSC to protect you. 
• Believe ‘it could never happen to me’. 
• Take a chance when common sense, policy or practice suggests another more prudent approach. 
• You should give guidance and support to inexperienced members.

Physical Contact in Sport 

There are a number of principles that should be followed when the activity involves physical contact. 

Physical contact during sport should always be intended to meet the particpants’ needs, NOT the adult’s. The adult should only use physical contact if their aim is to: 

• To treat an injury 
• To prevent an injury or accident from occurring 
• To meet the requirements of the sport or develop sports skills or techniques but in strict accordance with guidelines recommended by the relevant National Governing Body. 

The member should always seek to explain the nature and reason for the physical contact. Unless the situation is an emergency, the member should ask for permission. 

Members should be encouraged to voice concerns they have if any physical contact makes them feel uncomfortable or threatened. 

Contact should not involve touching genital areas, buttocks, breasts or any other part of the body that might cause distress or embarrassment. Physical contact should always take place in an open or public environment and not take place in secret or out of sight of others.  

Guidelines for Transporting Vulnerable Adults 

Car Journeys

The key points are: 

When members make the travel arrangements to and from an activity without the knowledge of the organising body it is the responsibility of them to ensure the arrangements are both safe and appropriate. 

When LSSC makes the arrangements for travel there must be a risk assessment undertaken by members. The risk assessment will need to cover the following areas: 

• Ensuring all vehicles are correctly insured. 
• Ensuring all drivers have a valid and appropriate license and valid DBS if applicable. 
• Ensuring all safety measures are available i.e. seatbelts. 
• Ensuring all drivers have adequate breaks. 

Along with safeguarding the vulnerable adult it is also important that any members are aware of the good-practice that is required to protect them: 

• Always tell another member that you are transporting a vulnerable adult, giving details of routes, length of journey and arrival times. 
• Take all reasonable safety measures (seat belts) 
• Take another member with you where possible 

Sharing of Information 

If someone does not want you to share information or you do not have consent to share the information, please ask yourself the following questions: 

1. Is the adult placing themselves at further risk of harm? 

2. Is someone else likely to get hurt?

Has a criminal offence occurred? This includes: theft or burglary of items, physical abuse, sexual abuse, forced to give extra money for lessons (financial abuse) or harassment. 

4. Is there suspicion that a crime has occurred? 

If the answer to any of the above questions is YES – then you must share this information with or without consent with LSSC Safeguarding lead or the deputy. Please see contact numbers at front of policy.

When sharing information there are 7 golden rules that should always be followed: 

1. Seek advice if in any doubt. Without disclosing the identity of the person where possible, consult with your Safeguarding Lead or deputy or your local Council social services. 

2. Be transparent. The GDPR is not a barrier to sharing information but to ensure that personal information is shared appropriately, except in circumstances where by doing so places the person at significant risk of harm. 

3. Consider the public interest. Base all decisions to share information on the safety and well-being of that person or others that may be affected by their actions. 

4. Share with consent where appropriate. Where possible, respond to the wishes of those who do not consent to share confidential information. You may still share information without consent, if this is in the public interest. 

5. Keep a record. Record your decision and reasons to share or not to share information. (see incident record form in the appendices.) 

6. Accurate, necessary, proportionate, relevant and secure. Ensure all information shared is accurate, up to date and necessary and share only with those who need to have it. 

7. Remember the purpose of the GDPR is to ensure personal information is shared appropriately, except in circumstances where by doing so may place the person or others at significant harm. 

Assessing capacity 

A person’s capacity must be assessed at the point at which the decision is needed, taking into account relevant and immediate circumstances as well as possible long term issues. 

Adults are assumed to be competent to give consent in making decisions, unless otherwise demonstrated by their capacity being affected by such things as: medication, substances and some untreated mental health issues. For adults, this means that they have the capacity to choose how they live and make decisions about their safety, even if we do not agree with certain decisions. If you are unsure or concerned that the person may not have the mental capacity to make an informed choice about their safety or evaluate the risk of abuse with their situation, you can report this to the LSSC Safeguarding Lead or London Council or your own local council.

What to do in responding to a concern (see Appendix B) 

It is not your role to take individual responsibility for deciding whether or not abuse is or has actually taken place. However, there is a responsibility to protect vulnerable adults by referring to the Safeguarding Lead or deputy. 

Appendix A lists the main forms of abuse.

Follow the flow chart in Appendix B.

The LSSC Safeguarding Lead will take the appropriate action, informing Social Services who will take responsibility for informing the police. Where there is an immediate need to protect the vulnerable adult from danger the police must be advised. 

Once the incident / allegation has been reported it is the responsibility of the LSSC Safeguarding Lead to inform social services or police without delay. If the Safeguarding Lead or deputy is not available, the person discovering or being informed of the abuse should immediately contact social services, if appropriate, who will become responsible for what steps to take next. 

IT IS YOUR ROLE TO REPORT NOT TO JUDGE 

Dealing with Allegations against members 

Should a member become aware of an allegation (against another member) of an incident of abuse taking; or have taken place, it is vital that the procedures already detailed must be adhered to and the following actions are covered: 

• Take the allegation seriously. It is your duty to consider any allegation to be potentially dangerous to children or vulnerable adults and therefore report it. 
• Complete the incident report form (Appendix C ) with as many details of which you are aware. 
• Report the allegations and pass the form to the LSSC Safeguarding lead within 24 hours. 
• Do not judge or investigate. As member it is important not to lose focus of your role. By reporting an allegation quickly, any necessary investigations and / or judgement can then be made by trained professionals. 
• Maintain confidentiality. It is extremely important that any allegations are not discussed (unless absolutely necessary) as any breaches could be damaging to the vulnerable adult and to any investigation that may follow. 
• Any requests for information from members of the or the media should be directed to the LSSC Safeguarding Lead and should be given the ‘no comment’ response. 

Confidentiality 

Protection of vulnerable adults raises issues of confidentiality which must be clearly understood by all. The following guidelines should be adopted when concerns around adult protection arises to ensure that the referral procedure complies with the Data Protection Act (1998), the Freedom of Information Act (2004) and The General Data Protection Regulation (GDPR) May 2018.

• Members have a responsibility to share relevant information about the protection of vulnerable adults with the Safeguarding Leads; investigatory agencies and adult social services. 
• Clear boundaries of confidentiality will be communicated to all. 
• All personal information regarding a vulnerable adult will be kept confidential. All written records will be kept in a secure area for a specific time as identified in the data protection guidelines. Records will only record details required in the initial contact form. 
• If an adult confides in a member and requests that the information is kept secret, it is important that the member of staff tells the adult sensitively that he or she has a responsibility to refer cases of alleged abuse to the appropriate agencies. 
• Within that context, the adult must, however, be assured that the matter will be disclosed only to people who need to know about it. 
• Where possible, consent must be obtained from the adult before sharing personal information with third parties. In some circumstances obtaining consent may be neither possible nor desirable as the safety and welfare of the vulnerable adult is the priority. 
• Where a disclosure has been made, staff must let the adult know the position regarding their role and what action they will have to take as a result. 
• Members must assure the adult that they will keep them informed of any action to be taken and why. The adults involvement in the process of sharing information must be fully considered and their wishes and feelings taken into account. 

Appendix A

Main forms of abuse 

Abuse is defined as actions or a failure to act which causes harm to a vulnerable person or puts them at risk. The main forms of abuse for adults are: 

Physical 

Physical abuse is the non-accidental infliction of physical force that results (or could result in) bodily injury, pain or impairment. 

Emotional 

Emotional abuse describes acts or behaviour which impinges on the emotional health of, or which causes distress or anguish to, individuals. This may also be present in other forms of abuse. 

Financial 

Financial abuse describes the unauthorized, fraudulent obtaining and improper use of funds, property or any resources of a vulnerable person. 

Sexual 

Sexual abuse describes direct or indirect involvement in sexual activity without consent. This could also be through the inability to consent, or by pressurisation/ inducement to consent to take part 

Neglect 

Neglect describes the persistent failure of carers or supporters to meet a vulnerable adults basic physical or psychological need, likely to result in the serious impairment of health or development 

Discrimination 

Discriminatory abuse exists when values, beliefs or culture results in a misuse of power that denies mainstream opportunities to some groups or individuals. It includes discrimination on the basis of race, age, gender, sexuality, disability or religion. 

Institutional 

Institutional abuse describes abuse by an organisation imposing rigid and insensitive routines; poor practices embedded in systems, unskilled, intrusive or invasive interventions or any environment allowing inadequate privacy or physical comfort.

Indicators Of Abuse

Even for those experienced in working with the abuse of Vulnerable Adults, it is not always possible to recognise potential abusive situations or situations where abuse is ongoing. Indicators of abuse may include one or more of

the following:

• unexplained or suspicious injuries such as bruising, cuts or burns, particularly if situated on a part of the body not normally prone to such injuries.

• an injury for which an explanation seems inconsistent and improbable.

• an expression of concern from a third party about the welfare of an individual, unexplained changes in an individual’s behaviour, such as loss of confidence, low self-esteem.

• becoming quiet and withdrawn, sudden outbursts of temper or uncharacteristic changes in behaviour, tearful, depressed, angry, watchful and frightened.

• engaging in sexually explicit behaviour.

• distrust of others, particularly those with whom a close relationship would normally be expected.

• difficulty in making friends and socialising contrary to previous social behaviour.

• being prevented from socialising with other individuals by a carer or person in a position of authority

• displaying variations in eating patterns including overeating, loss of appetite or stealing and concealing food.

Appendix C :  LSSC Incident form
TO BE COMPLETED BY THE PERSON RAISING THE CONCERN
Date the concern is being raised:
Reference number (to be added when the concern is added to the log):
Details of the person raising the concern
Your name:	Contact phone number:
Details of adult at risk
Name:
Contact details:
Date of birth (if known):
Other relevant details about vulnerable adult/adult at risk:E.g. What marks this person as vulnerable, type of accommodation, family circumstances, support networks, physical and mental health, any communication difficulties.
Care giver/significant other/next of kin: Name:Address/contact details:
Details of the allegations
Summary of the nature of allegation/observation:
Details of person alleged to be inflicting harm/abuse (current whereabouts/likely movements in next 24 hours if known): Is the alleged perpetrator also a vulnerable adult/adult at risk? Y/N
Date and time of any specific incident?
Details of the allegation/your observations State exactly what you were told / observed and what was said. Use the persons own words as much as possible:
Are you aware of any previous concerns or incidents reported?
Summary of information given to the vulnerable adult/adult at risk:
Expectations/wishes of vulnerable adult/adult at risk, if known:
Action taken so far:
Signed: Print name:		Date

Appendix D

Radicalisation

It is important for you as a member to know where to go if you have a concern that someone may be on the route to radicalisation. 

If you have a concern  and there an is immediate risk call 999.

If there is no immediate risk call 101 and ask for Local Policing Team. 

If it is deemed there is low risk police will organise a Multi-Agency Channel meeting which will be made of key partners. The meeting will be chaired by the relevant Local Authority. 

It is important to remember that consent is gained with the individual to be part of Channel support and intervention. 

The Channel Panel members work together to review progress and reduce risks. 

The individual will exit the Channel process when all partner agencies feel that the vulnerability to radicalisation has been completely removed or significantly lessened. Once a referral has exited the process, it will be reviewed at 6 and 12 months. If concerns remain, the individual can be re-referred.

Appendix E

E Safety 

E-safety checklist 

1. Understand the safety aspects including what is acceptable and unacceptable behaviour when using digital technology such as social networking sites (e.g. Twitter and Facebook), mobile phones, game consoles and the internet. 

2. When engaging with digital technology/social networking companies (e.g. Facebook, Twitter) it is important to ensure that they adhere to relevant legislation and good practice guidelines. 

3. Review existing safeguarding policies and procedures to ensure that online safeguarding issues are fully integrated 

• reporting online concerns about possible abuse 

• reporting other breaches of terms 

4. Ensure that adequate privacy settings are in place either restricting or allowing access to photos, personal information, comments about others, friends and followers. 

Reporting concerns about possible online abuse 

Use reporting procedures described in this policy and refer concerns to the LSSC Safeguarding Leads. 

Where someone may be in immediate danger, always dial 999 for police assistance.

Bullying

“Bullying is deliberately hurtful behaviour usually repeated over a period of time, where it is difficult for those being bullied to defend themselves”

Bullying can be :

• Emotional : being unfriendly, excluding(emotionally and physically), sending hurtful text messages, tormenting, (e.g. hiding kit or equipment, threatening gestures).

• Physical : pushing, kicking, hitting, punching or any use of violence.

• Racist : racial taunts, graffiti, gestures.

• Sexual : unwanted physical contact or sexually abusive comments.

• Homophobic : because of, or focussing on the issue of sexuality.

• Verbal : name-calling, shouting, sarcasm, spreading rumours, teasing. 

Cyber Bullying

Cyber Bullying refers to bullying and harassment through the use of electronic devices such as personal computers and

mobile phones- using email, texting and social networking websites.

Cyber Bullying is deliberate and involves recurring or repeated harm inflicted through the medium of electronic devices and is meant to cause emotional distress.

Cyber Bullying might include:

• A peer who intimidates though the use of a social networking website.

• A member who sends negative feedback about another member via personaltext message.

• A member who posts negative comments about a fellow member on a club forum.

Cyber Bullying may also include threats, sexual remarks and hate speech. E-Bullies may publish personal contact information of

their victims on websites. They may attempt to act as the victim for the purpose of publishing material in their name that would defame or ridicule them.

Cyber Bullying is particularly serious due to the nature in which the abuse occurs. It is very personal and takes place in a closed private format where the victim may feel isolated and the content will not be viewed by parents,friends or siblings. It may lead to the victim re-reading any material in private perhaps leading to feelings of paranoia, depression or loneliness.