INSTITUTE OF OUR LADY OF MERCY

Registered Charity No. 290544

INSTITUTE SAFEGUARDING POLICY

Policy Author

Catherine Marcroft (Safeguarding Lead)

Document Type	Safeguarding Policy
Document Number	SP0425
Document Version Number	1.0
Date of Approval By Trustees	10.04.2025
Date of Issue	10.04.2025
Date for Review	10.04.2028

Version Control and Amendment Log

Version No.	Type of Change	Date	Description of change(s)
0.1	New draft policy created	03/04/2025	To include more detailed items to existing policy and to add in further items such as Mental Capacity and Deprivation of Liberty, Prevent and an Equality impact statement
0.2	Amendments	07/04/2025	Amendments made during consultation with Care Quality Consultant such as a change to terminology and a change to order of items

Contents

Section		Page
1	Policy Statement	3
2	Scope	3
3	Objectives	3
4	Safeguarding Principles	3
5	Roles and Responsibilities	4-6
6	Practice Guidance	7
7	Procedure	7-8
8	Safer Recruitment	8
9	Safeguarding Training	9
10	PREVENT	10
11	Whistleblowing	11
12	Recording and storage of safeguarding concerns and case files	11
13	Mental capacity act 2005 and deprivation of liberty safeguards (dols)	12
14	Equality impact statement	13

1.POLICY STATEMENT:

The Institute of Our Lady of Mercy is committed to the National Safeguarding Policies and Procedures of the Catholic Church in England and Wales, to take all reasonable steps to protect all who are vulnerable from any form of abuse and to promote a safe environment for them. This commitment flows from the fact that we are all made in the image and likeness of God and the Church’s common belief in the dignity and uniqueness of every human life. We start from the principle that each child, young person and adult at risk has a right to expect the highest level of care and protection, love, encouragement and respect that we can give. We will liaise closely and openly with statutory agencies to ensure that any concerns or allegations of abuse are promptly reported and appropriately dealt with, victims supported and alleged source of harm held to account. The Institute’s commitment to the ‘One Church’ approach to safeguarding in the Catholic Church in England and Wales is also affirmed by this statement. Our expectation is that this statement will be accepted and upheld by our Sisters and Associates, Staff, Volunteers and all who work for and with us in the Institute and also those who use our premises and individuals who use or access our services.

2.SCOPE:

This policy and procedure applies to all within the IOLM regardless of their role or the activities they undertake. It is the responsibility of all within IOLM to prevent abuse, whether by action or omission. Abuse in this policy refers to: physical; sexual; emotional; spiritual; neglect; self-neglect; organisational; material; psychological; financial; domestic or verbal. Additionally, behaviour which effectively results in modern day slavery or where there is evidence of discrimination or radicalisation, this needs to be recognised and addressed as a safeguarding concern.

3.OBJECTIVES

1. To create a safe and supportive environment for all individuals in our care.
2. To prevent abuse, neglect, and exploitation of vulnerable individuals.
3. To promote a culture of safeguarding, where individuals feel safe and supported.
4. To ensure compliance with relevant laws, regulations, and standards.

4.SAFEGUARDING PRINCIPLES:

Principles of Safeguarding

This policy is founded on key safeguarding principles:
Protection – Everyone has the right to be protected from abuse and exploitation.
Prevention – Proactive measures and procedures reduce opportunities for harm.Partnership – Working in cooperation with safeguarding bodies, statutory agencies, families, and communities.
Proportionality – Actions taken will always be appropriate and proportionate to the level of risk and severity of harm.
Accountability – Transparent safeguarding practices, accountability, and clear reporting procedures.
Empowerment – Supporting individuals to understand their rights and encouraging them to voice concerns.

5.ROLES AND RESPONSIBILITIES

Responsibilities

Responsibilities include ensuring that:

IOLM has the necessary safeguarding policies, processes and procedures in place.
Everyone in IOLM knows how to safeguard its people and what to do when a safeguarding concern occurs, including how/when/to whom it should be reported.
There is an embedded robust, ‘living’ safeguarding culture, within IOLM.
The trustees are compliant with their legal and regulatory safeguarding duties.
All children must be accompanied by an adult at all times when on our premises.

Roles

The Trustees

The Trustees have a duty to maintain appropriate governance and oversight of safeguarding in line with this policy and national guidelines. Certain functions of the Board will be delegated to others within the IOLM, as indicated below.

The Institute Leader

The Institute Leader is responsible for ensuring appropriate policy, procedures and best practice are in place for the effective delivery of a robust safeguarding service. Certain functions of the leader will be delegated to members, as indicated below.

Safeguarding Trustee

IOLM’S Safeguarding Trustee is accountable for reporting on safeguarding to the Trustee Board, which has overall oversight of and responsibility for safeguarding.

Safeguarding Trustee Sub-Committee

IOLM’S Safeguarding Trustee Sub-Committee is accountable to the Safeguarding Trustee.

The Safeguarding Trustee Sub-Committee supports, assists and advises the Trustees, via the Safeguarding Trustee, to ensure the Trustees are discharging their safeguarding duties correctly.

Designated Safeguarding Lead (DSL)

The Designated Safeguarding Lead is accountable to the Safeguarding Trustee and Safeguarding Trustee Sub-Committee and acts as the main source of support, advice and expertise for safeguarding in IOLM.

Further details of the roles of the Safeguarding Trustee, Safeguarding Trustee Sub-Committee and Designated Safeguarding Lead

The Safeguarding Trustee, Safeguarding Trustee Sub-Committee and Designated Safeguarding Lead are expected to work together to:

Advise IOLM how to adopt its safeguarding policy, standards and operational framework.
Ensure that a robust culture of people safeguarding is embedded throughout IOLM.
Provide strategic oversight for all aspects of safeguarding work and ensure IOLM’S safeguarding policies and procedures are up to date and fully effective, in helping protect people from potential or actual harm.
Provide assurance to the Trustee Board that IOLM’S agreed safeguarding, procedures and standards are adhered to by all involved within IOLM.
Respond appropriately and quickly to all identified safeguarding risks and escalate to the relevant local authorities and regulators/organisations as necessary, including Social Services, the Police, the Charity Commission, the RLSS Safeguarding Team (or alternative chosen safeguarding service provider) and, as appropriate, fellow Trustees and the Catholic Safeguarding Standards Agency (CSSA).

As the main source of support, advice and expertise for safeguarding in IOLM, the DSL will also:

Advise and support the Senior Leadership Team in developing and establishing IOLM’S approach to safeguarding.
Play a lead role in maintaining and reviewing IOLM’S plan for safeguarding.
Coordinate the distribution of policies, procedures and safeguarding resources throughout IOLM.
Advise on training needs and development, providing training where appropriate.
Provide safeguarding advice and support to staff and volunteers.
Manage (with ongoing support as necessary from the Safeguarding Trustee and Safeguarding Trustee Sub-Committee) safeguarding concerns, allegations or incidents reported to IOLM (these can be delegated to the RLSS, but the DSL will retain oversight).
Manage (with ongoing support as necessary from the Safeguarding Trustee and Safeguarding Trustee Sub-Committee) referrals to key safeguarding agencies of any safeguarding incidents.

Responsibilities of the Safeguarding Trustee, Safeguarding Trustee Sub-Committee and Designated Safeguarding Lead

The Safeguarding Trustee, Safeguarding Trustee Sub-Committee and Designated Safeguarding Lead need to:

Understand safeguarding legislation and best practice.
Be familiar with and use the RLSS and the CSSA services and guidelines, so that safeguarding issues are properly considered and addressed, as a priority
Ensure that appropriate vetting and recruitment checks are undertaken for IOLM’S people including, where necessary, Disclosure and Barring Service checks and overseas equivalents[1].

Other Roles:

Members/Staff

All members/staff have an obligation to ensure they know how to respond to safeguarding concerns by making themselves familiar with the content of this policy and the procedure contained within it and any other associated policies/procedures.

General

Everyone involved in the work of IOLM has a duty to disclose to the Designated Safeguarding Lead or Chair of the Trustees Sub-Committee any safeguarding concerns that have been raised about them.

6.PRACTICE GUIDANCE

Action must be taken if a concern is raised that a child or adult is suffering or is likely to be suffering from significant harm. This includes, but is not limited to:

Someone who is at serious risk of harm from self or others
Someone who poses a serious risk of harm to someone else
A concern about a child or adult at risk of harm from someone else
Concerns over someone’s mental capacity that places them or others at risk of harm

Action must also be taken in line with the Roman Catholic Church’s mandatory reporting policy. This means appropriate action must be taken if there are reasonable grounds to believe that someone who holds any role within the Catholic Church is going to or has committed a crime, is going to or has caused harm, poses a risk or is otherwise unsuitable to work in their role.

7.PROCEDURE

Reporting Concerns and documenting

If someone is in immediate danger or there is a safeguarding emergency, call 999.

All concerns about the safety or wellbeing of an individual must be reported immediately to the Designated Safeguarding Lead (DSL), or the leadership team within the setting in which the safeguarding concern has occurred. You should consider the following three statements to establish whether a safeguarding concern needs to be reported to the Police, Local Authority and the Religious Life Safeguarding Service (RLSS), or if it should be logged as a safeguarding incident.

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

If all three statements apply, a referral must be made to the Police, Local Authority and RLSS. Referral forms must be completed within 24 hours. Following this, the Safeguarding Cases and Concerns Tracking System [SCTS0425] and Activity Log [AT0425] must be completed. Then, the Designated Safeguarding Lead and IOLM Leader should be informed.

If all three statements do not apply, a safeguarding incident form [IN0425] should be completed.

If you are not sure if the three statements apply, contact the Designated Safeguarding Lead for advice. If unavailable, contact RLSS. RLSS operate an out of hours service.

Safeguarding Investigations:

The institute will conduct investigations into safeguarding concerns, in partnership with external agencies as necessary.

Support for Individuals:

Individuals who have experienced abuse, neglect, or exploitation will be provided with support and protection, in accordance with their individual needs.

8.SAFER RECRUITMENT

IOLM will ensure that all recruitment practices are safe and compliant with relevant regulations and standards.

Job Descriptions

All job descriptions will include safeguarding responsibilities and requirements.

Person Specifications

All person specifications will include safeguarding competencies and requirements.

Interviews

All interviews will include safeguarding questions and scenarios.

References

We will obtain references for all candidates.

DBS Checks

IOLM will ensure that congregation members, lay staff and volunteers are subject to the appropriate Disclosure and Barring Service (DBS) checks in line with both statutory and Catholic Church requirements. Anyone who is seeking to work with children or adults whether in a paid or unpaid capacity must be provided with the opportunity to self-disclose relevant conviction information. This is a DBS Code of Practice requirement and applies to anyone being asked to have an Enhanced Disclosure.

Appointments

Appointment to a role will not be confirmed until a satisfactory DBS Disclosure check has been received and previous employment references confirmed as being acceptable. Appointments will be based on the person’s experience, skills and ability to meet the set criteria and job specification for the specific role. It is essential to ensure that all documentation relating to the applicants is kept in a secure place and is confidential. On appointment, all new employees are to read all relevant policy and procedure documentation and sign to say they have understood the contents and are willing to follow them.

Training

All staff and volunteers will receive safeguarding training.

9.SAFEGUARDING TRAINING

Safeguarding training is essential for all Sisters in active ministry, staff and volunteers to ensure that they are aware of their roles and responsibilities in safeguarding and promoting the welfare of everyone.

Training Objectives

To understand the institute’s safeguarding policies and procedures.
To recognize signs of abuse, neglect, and exploitation.
To know how to report safeguarding concerns.
To understand the importance of confidentiality and information sharing.

Specific Safeguarding Training

The Religious Life Safeguarding Service (RLSS) deliver role specific training to the Trustees and Designated Safeguarding Lead. They also offer advanced safeguarding training for those staff working in Care Homes, Convents with Care and our school. The DSL delivers safeguarding training to staff. Online platforms are used, such as Flexebee and Curve.

Training Content

Safeguarding Policies and Procedures: Overview of the Institute’s safeguarding policies and procedures.
Recognising Abuse and Neglect: Signs and symptoms of abuse, neglect, and exploitation.
Reporting Safeguarding Concerns: Procedures for reporting safeguarding concerns.
Confidentiality and Information Sharing: Importance of confidentiality and information sharing in safeguarding.
Mental Capacity Act 2005 and Deprivation of Liberty Safeguards (DoLS): Overview of the Mental Capacity Act 2005 and DoLS.

Training Delivery

Induction Training: All new staff and volunteers will receive safeguarding training as part of their induction.

Regular Training Updates: All staff and volunteers will receive regular safeguarding training updates.

Training Evaluation

Evaluation Forms: Training evaluation forms will be completed by all staff and volunteers.

Training Records: Training records will be kept for all staff and volunteers.

Responsibilities

Designated Safeguarding Lead (DSL): The DSL will oversee the delivery of safeguarding training.

Management: Managers along with the DSL will ensure that all staff and volunteers receive safeguarding training.

Staff and Volunteers: All staff and volunteers will attend safeguarding training sessions.

10.PREVENT

Introduction

The PREVENT strategy is a UK government initiative aimed at preventing individuals from becoming involved in extremist or terrorist activities. IOLM are committed to promoting a safe and inclusive environment for all whom we support.

Objectives

To identify and support individuals who may be vulnerable to extremist or terrorist influences.
To prevent the spread of extremist or terrorist ideologies within our institute.
To promote a culture of respect, tolerance, and understanding.

Key Principles

Respect and Inclusion: We promote a culture of respect and inclusion, where all individuals feel valued and supported.
Identifying Vulnerabilities: We identify individuals who may be vulnerable to extremist or terrorist influences and provide support and guidance.
Partnership Working: We work in partnership with local authorities, police, and other agencies to prevent extremism and terrorism.

Procedures

Risk Assessment: We conduct regular risk assessments to identify potential vulnerabilities.
Staff Training: Staff receive training on PREVENT and how to identify and support vulnerable individuals.
Reporting Concerns: Concerns about extremist or terrorist activity are reported to the Designated Safeguarding Lead (DSL) and referred to the relevant authorities.

Responsibilities

Designated Safeguarding Lead (DSL): The DSL is responsible for overseeing PREVENT implementation.
Management: Management is responsible for ensuring compliance with PREVENT regulations.
Staff: Staff are responsible for reporting concerns and supporting vulnerable individuals.

11.WHISTLEBLOWING

The Institute of Our Lady of Mercy is committed to achieving the highest possible standards of service and ethical practice. To achieve these ends, we encourage freedom of speech.

Our Whistleblowing Policy refers to the process whereby employees are able to report any serious concerns about the treatment of people in our care or to which we minister.

It is our belief that, should a member of staff witness malpractice, they should be able to report their concerns without fear of reprisals and be assured that their concerns will be fully investigated. Harassment or victimisation of a whistleblower will not be tolerated and would be treated as a formal disciplinary offence.

A worker is protected if:

They honestly think what they are reporting is true
They think they are telling the right person
They believe that their disclosure is in the public interest

And believes:

That a criminal offence has been committed, is being committed, or is likely to be committed.
Abuse, neglect or bullying has taken place.
That a person has failed, is failing or is likely to fail to comply with a particular legal obligation.
That a miscarriage of justice has occurred, is occurring or is likely to occur.
That the health and safety of any individual has been, is being, or is likely to be endangered.
That the environment has been or is likely to be damaged.
That information indicating the occurrence of any of the above has been, is being, or is likely to be deliberately concealed.

In the first instance, allegations should be made as soon as possible verbally or in writing and in any case supported by a written statement/report to your manager. Other avenues of redress include our Clinical Partner or Head of People and Services, a Trustee of the Institute or the Designated Safeguarding Lead.

The matter will be investigated and will aim to be impartial and objective and as far as is reasonably practicable fair to all parties concerned in seeking to clarify the facts before any further action is taken.

IOLM have a designated Whistleblowing Policy which is available within the Staff Handbook.

12.RECORDING AND STORAGE OF SAFEGUARDING CONCERNS AND CASE FILES

IOLM has a responsibility to ensure that all case files held are accurate, up to date and stored securely.

Where RLSS is responsible for the management of a case, RLSS will ensure records are accurate, auditable, and secure and all records of any safeguarding concerns or allegations referred will be properly maintained.

13.MENTAL CAPACITY ACT 2005 AND DEPRIVATION OF LIBERTY SAFEGUARDS (DOLS)

The Mental Capacity Act 2005 (MCA) is a law that protects people aged 16 and over, who may not be able to make decisions for themselves. The Deprivation of Liberty Safeguards (DoLS) are a set of rules that ensure people are not deprived of their liberty without good reason.

Key Principles

Assume Capacity: Assume people have mental capacity unless proven otherwise.

Support Decision-Making: Provide all necessary support to enable people to make their own decisions

Unwise Decisions: Respect people’s right to make unwise decisions.

Best Interests: Make decisions in people’s best interests.

Least Restrictive Option: Choose the least restrictive option.

Deprivation of Liberty Safeguards (DoLS)

Definition: Deprivation of liberty means restricting someone’s freedom. This applies to individuals who are 18 years or over, who reside in a care home or hospital in England and Wales, and lack the capacity to make decisions about their care & treatment and are being deprived of their liberty:”

Assessment: Assessments must be done by trained professionals.

Authorization: Authorization must be obtained from the local authority.

Review: Regular reviews must be conducted.

Application to IOLM

Staff Training: Staff will receive training on the MCA and DoLS.

Assessment and Authorization: Assessments and authorizations will be conducted as required.

Peoples Rights: Everyone’s rights will be respected and protected.

Partnership Working: We will work in partnership with local authorities and other agencies.

Responsibilities

Management: The managers will oversee MCA and DoLS implementation will ensure compliance with MCA and DoLS regulations with support from the Designated Safeguarding Lead (DSL) as required.

Staff: Staff will receive training and follow MCA and DoLS procedures.

14.EQUALITY IMPACT STATEMENT

IOLM is committed to ensuring that safeguarding practices are fair, inclusive, and accessible to all individuals, regardless of age, disability, gender, race, ethnicity, sexual orientation, religion, or socioeconomic background. This policy has been developed in line with the Equality Act 2010 to promote equal protection and support for all service users and staff.

In developing and implementing this safeguarding policy, we have considered:

The diverse needs of residents, ensuring safeguarding procedures are inclusive and culturally sensitive.

The accessibility of reporting mechanisms for individuals with disabilities or communication barriers.

The training needs of staff to recognise and respond to safeguarding concerns in an anti-discriminatory manner.

Potential unintended consequences of safeguarding actions on marginalised groups and how to mitigate them.

This policy will be reviewed annually to ensure it remains inclusive, responsive to the needs of all individuals, and compliant with legal and best-practice safeguarding standards. Any identified disparities in safeguarding outcomes will be addressed through training, policy amendments, and consultation with Trustees.

[1] If any of the IOLM people are subject to a criminal records check but have been in the UK for less than six months (and have not been here before), as well as requiring a valid DBS check, an overseas criminal records check should be obtained. DBS guidance on this can be found through the link below:

Criminal records checks for overseas applicants