Draft Safe Home-Shaping Lives - Policy and Procedures 27-02-2023

Policies & Procedures
Version Information
Version 1.0
Release Date 27/02/23
Author Tia Folivi
Document Owner Tia Folivi
Document Control
Approvals
Name Role Version Date
Version History
Version Date Change Description Author
0.1 February 2023 Document Created
1.0 February 2023 Document updated and
approved
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Semi-Independent Home Policies and Procedures

Important Telephone Contacts
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Contents
Document: Policies & Procedures...........................................................................................................1
Version Information................................................................................................................................1
Document Control...................................................................................................................................1
Approvals................................................................................................................................................1
Version History........................................................................................................................................1
Registered Young people’s Home Policies and Procedures.....................................................................2
Important Telephone Contacts...............................................................................................................2
Semi-independent provision - Key Principles..........................................................................................8
Foreword.................................................................................................................................................9
Other central HR policies and procedures...............................................................................................9
1. ADMISSION AND MOVING ON PROCEDURES..................................................................................10
With regard to the administration of the young person’s admission....................................................10
With regard to the administration of a young person moving on.........................................................11
2. Behaviour Management Policy........................................................................................................12
3. HEALTH CARE..................................................................................................................................15
4. EDUCATION POLICY........................................................................................................................17
5. PERMITTED DISCIPLINARY MEASURES (Sanctions)......................................................................18
6. RESTRICTIVE PHYSICAL INTERVENTION POLICY...........................................................................21
7. RECORDING OF FILES PERTAINING TO YOUNG PEOPLE...............................................................23
8. CARE AND PLACEMENT PLANNING..............................................................................................26
9. USE OF EACH YOUNG PERSON’S PLACEMENT PLAN........................................................................28
10. COUNTERING BULLYING................................................................................................................30
Measures to be considered...................................................................................................................32
11. LOG BOOKS AND STATUTORY RECORDING..............................................................................33
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12. CONFIDENTIALITY..........................................................................................................................35
Matters relating to young people..........................................................................................................35
Matters relating to This home...............................................................................................................36
Matters relating to colleagues...............................................................................................................36
13. ADMINISTRATION OF FINANCE......................................................................................................38
14. REPAIRS AND MAINTENANCE........................................................................................................39
15. FIRE AND EMERGENCY PROCEDURES............................................................................................40
16. COUNTERING RISKS ASSOCIATED WITH SIZE.................................................................................42
17. HEALTH AND SAFETY POLICY...................................................................................................43
General..................................................................................................................................................43
Risk Assessment....................................................................................................................................45
COSHH (Control of Substances Hazardous to Health)............................................................................46
RIDDOR (Reporting of Injuries, Diseases and Dangerous Occurrences Regulations).............................47
18. ROOM SEARCHES.....................................................................................................................49
19. SAFEGUARDING POLICY & PROCEDURES......................................................................................50
Policy.....................................................................................................................................................50
Principles...............................................................................................................................................50
Recruitment and Selection....................................................................................................................51
Safeguarding Young people and Young People Against Radicalisation and Extremism.........................51
PROCEDURES.........................................................................................................................................52
Staff Selection and Vetting....................................................................................................................52
Barring, Criminal Offences and Staff Suitability.....................................................................................52
Induction and Training..........................................................................................................................53
Staff Conduct.........................................................................................................................................53
Members of staff and volunteers must always;....................................................................................53
Individual support and maintaining boundaries with young people and young people........................54
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Allegations and Suspicions of Abuse - Reporting Concerns...................................................................55

Concerns regarding employees or volunteers.......................................................................................55
Receiving A Disclosure...........................................................................................................................56
Use of Camera, Recording Equipment and Mobile Phones...................................................................57
Deprivation of Liberty Safeguards (DOLS).............................................................................................58
Responsibilities summary......................................................................................................................58
Appendix A - Behaviour Management Guidelines.................................................................................59
Appendix B – Types and Indicators of Abuse.........................................................................................61
Physical abuse.......................................................................................................................................61
Emotional abuse....................................................................................................................................62
Sexual abuse..........................................................................................................................................62
Neglect..................................................................................................................................................63
Organised or multiple abuse.................................................................................................................63
Female Genital Mutilation (FGM)..........................................................................................................63
Fabricated or induced illness.................................................................................................................64
Young person Sexual Exploitation (CSE)................................................................................................64
Appendix C – Other definitions.............................................................................................................65
Appendix D – The Prevent Strategy.......................................................................................................67
The Prevent Strategy: Overview and Contact details............................................................................67
Appendix E – LADO workflow (relevant for This home).........................................................................69
LADO-ASV Flow Chart for Schools and other Organisations..................................................................69
Appendix F – reporting workflow..........................................................................................................70
Appendix G - Key Safeguarding Contacts and information....................................................................71
20. ARRANGEMENTS FOR REGULATING AND VETTING VISITORS........................................................72
21. HIV, AIDS, HEPATITIS B AND SERIOUS INFECTIONS........................................................................73
22. SAFER RECRUITMENT PRACTICES POLICY......................................................................................76
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23. THE SUPPORT OF YOUNG PEOPLE WHO HAVE BEEN ABUSED......................................................79

24. ROSTERING / SHIFT HANDOVERS..................................................................................................80
25. STAFFING POLICY..........................................................................................................................82
26. SLEEPING-IN, BED-TIME AND NIGHT SUPERVISION......................................................................86
27. PHYSICAL CONTACT BETWEEN STAFF AND YOUNG PEOPLE..........................................................87
28. SPENDING ONE-TO-ONE TIME ALONE WITH YOUNG PEOPLE.......................................................88
29. CARE PRACTICES TOWARDS YOUNG PEOPLE OF THE OPPOSITE SEX............................................90
30. NEEDS OF YOUNG PEOPLE FROM MINORITY ETHNIC GROUPS.....................................................95
31. PRACTICES IN THE HOME TO COMBAT RACISM............................................................................96
32. INFORMATION COMMUNICATION TECHNOLOGY (ICT) ACCEPTABLE USAGE POLICY....................98
Internet and email Conditions of Use....................................................................................................98
Clear Desk and Clear Screen Policy........................................................................................................99
Working Off-site....................................................................................................................................99
Viruses.................................................................................................................................................100
Telephony (Voice) Equipment Conditions of Use................................................................................100
Actions upon Termination of Contract................................................................................................100
33. DELEGATED AUTHORITY, NOTIFICATIONS AND ON-CALL PROCEDURE........................................102
On-call procedure for This home.........................................................................................................103
34. REVIEWS................................................................................................................................105
35. DEALING WITH AGGRESSION AND VIOLENCE........................................................................107
36. RISK-TAKING...............................................................................................................................109
37. DEALING WITH SEXUALITY AND PERSONAL RELATIONSHIPS.......................................................111
38. WORKING WITH PARENTS/CARERS............................................................................................113
39. MEDICATION STORAGE AND ADMINISTRATION POLICY.............................................................115
1. Introduction and relevant other guidance.............................................................................115
2. Training and competence of staff to administer medication.................................................115
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3. Signing in/ out of medication.................................................................................................116

4. Medication audits..................................................................................................................116
5. Changes to medication..........................................................................................................117
6. Storage of medication............................................................................................................117
7. Consent and capacity.............................................................................................................117
8. Encouraging young people to take medication......................................................................117
9. Self-administration of medicines...........................................................................................118
10. Administration.....................................................................................................................118
11. Record Keeping....................................................................................................................119
12. Errors in administration and or recording............................................................................120
13. Disposal of medication.........................................................................................................120
This home Consent and Agreement for Medication Administration...................................................121
MEDICATION LIST (EXAMPLE)..............................................................................................................123
40. FIRST AID POLICY.........................................................................................................................124
41. COMPLAINTS PROCEDURE..........................................................................................................126
42. SMOKING POLICY AND ALCOHOL POLICY....................................................................................129
43. DRUGS AND SUBSTANCE ABUSE POLICY................................................................................131
44. GIFTS POLICY..........................................................................................................................133
45. WHISTLE- BLOWING BY STAFF...............................................................................................134
46. TRANSPORT POLICY.....................................................................................................................136
47. Running Away or Missing from Home or Care (RMFHC).............................................................138
48. EQUALITY AND DIVERSITY POLICY..............................................................................................140
Methods..............................................................................................................................................140
49. THIS HOME DATA PROTECTION POLICY.....................................................................................143
50. YOUNG PEOPLE’S RIGHTS POLICY...............................................................................................145
51. E-Safety Policy.............................................................................................................................147
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Context................................................................................................................................................147
Aims.....................................................................................................................................................147
Supporting our residents to use technology safely.............................................................................147
Responsibilities of All Staff and Residents...........................................................................................150
52. CODE OF CONDUCT (STAFF)........................................................................................................152
SCHEDULE OF MATTERS RESERVED FOR APPROVAL BY THE BOARD OF DIRECTORS..........................154
Modern Slavery Act 2015 Statement...................................................................................................156
Business Ethics Policy..........................................................................................................................158
Anti-Bribery and Corruption Policy......................................................................................................163
Anti-Bribery and Corruption Policy......................................................................................................165
Prevention of Fraud.............................................................................................................................168
Supplier privacy notice policy..............................................................................................................171
GDPR: GENERAL DATA PROTECTION REGULATION POLICY.................................................................173
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Semi-independent provision - Key Principles

Young people in semi-independent provision should be loved, happy, healthy, safe from harm
and to develop, thrive and fulfil their potential.
Semi-independent provision should value and nurture each young person as an individual with
talents, strengths and capabilities that can develop over time.
Semi-independent provision should foster positive relationships, encouraging strong bonds

between young people and staff in the Home on the basis of jointly undertaken activities,
shared daily life, domestic and non-domestic routines and established boundaries of
acceptable behaviour.
Semi-independent provision should be ambitious, nurturing young people’s social learning and
out-of-school learning and their ambitions for their future.
Semi-independent provision should be attentive to young people’s need, supporting emotional,

mental and physical health needs, including repairing earlier damage to self-esteem and
encouraging friendships.
Semi-independent provision should be outward facing, working with the wider system of
professionals for each child, and with young people’s families and communities of origin to sustain
links and understand past problems.
Semi-independent provision should have high expectations of staff as committed members of a

team, as decision makers and as activity leaders. In support of this, young people’s homes should
ensure all staff and managers are engaged in on-going learning about their role and the young
people and families they work with.
Semi-independent provision should provide a safe and stimulating environment in high-quality

buildings, with spaces that support nurture and allow privacy as well as common spaces and
spaces to be active.
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Other central HR policies and procedures

The Employee Handbook has wider policies relevant to HR for This home including:
 Annual leave and other absences
 Sickness policy
 Grievance and disciplinary policy and procedure
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1. ADMISSION AND MOVING ON PROCEDURES

Staff working at This home do not underestimate the impact that moving to a new home has on each
individual young person and will attempt to make the transition for the young person as smooth as
they are able through attention to detail and sensitivity towards the individual. Details of how this is
managed by staff can be found in The Statement of Purpose. Staff are advised to read this document
in conjunction with this policy.
Staff are mindful also of the difficulties for young people currently resident within the home when a
new resident moves in or a young person moves out and the upheaval and anxiety this may cause.
With regard to the administration of the young person’s admission:

 The Manager will ensure that all relevant LAC materials are in place prior to the young
person’s admission except for Placement Plan, which will be completed at the placement agreement
meeting. If this information is not available, the Manager may refuse to continue with arrangements
for the placement or agree with the placing social worker a date by when this information must be
available.
 Once the pre-admission visit date has been agreed, the Key Worker will be available to
answer any questions the young person and their family/key kin may have. This can
minimise the anxiety some young people and their families have regarding the move. In
addition, the Key Worker will provide the young person and their family/key kin with
relevant written information on the Home that they can take away with them and read.
They will be advised that they may contact the Home for clarification on any points.
 Young people will, on admission, have a Welcome Pack prepared by the Key Worker. This
will include a range of basic toiletries, welcome card (to be signed by young people and staff
at the Home) and a copy of the young person’s guide to living at This home. The Key Worker
will ensure that there is fresh linen on the bed and clean towels, flannel and other basic
items are available.
 During the first week of their stay, the young person will be gradually introduced to other
young people and staff and will be made familiar with the layout of the Home and its
accommodation. They will be appraised of fire and health and safety guidelines as soon as is
practicably possible. The Key Worker should inform the young person that they will have a
member of staff close at hand during the first few weeks of their stay to answer any
questions or queries they may have in order that they feel more comfortable. The Key
Worker will organise outings for the young person to buy personal items for their room such
as posters or plants to make the room more personal to them.
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 During the first month the young person will be gradually introduced to the immediate
locality, systems pertaining to young people that are in place at the Home e.g., meetings,
Key Work sessions and recording in order that they begin to feel familiar with their
surroundings and the reason and purpose of their placement.
 Where appropriate, and as part of the care plan, young people will be encouraged to
maintain previous relationships and contacts through a variety of methods.
 All staff should help young people to manage the anxiety of moving to a new home by
assisting them in familiarising themselves with the Home to ensure they make the best of
their stay and become familiar with what is expected of them, and what they can expect
from the Home.
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We will, exceptionally, take young people into the Home as emergency admissions. Where this is the
case, special thought has gone into how they and the resident group can best manage this change.
NB 1) The Manager must inform the local authority when a young person is admitted from out of
authority.
NB 2) The Manager must complete a pre-admission risk assessment before admitting any young
person.
With regard to the administration of a young person moving on:

 The young person will be involved in the change as much as possible. This will include visits
to the new setting, plans for the move and building relationships with new staff prior to
moving. This will include social stories, pictures and tea visits as appropriate to the individual
 This home staff will assist the new service with care plans, and getting to know the young
person and how they like to be supported, offering shadowing opportunities at This
home to new staff
 This home residents will be informed of the move with social stories as required and a
leaving party will be held for the individual.
 A scrap book about their stay at This home will be created by staff and given to the
individual when they leave
 Ex-residents are supported to maintain relationships with residents they were friendly with
at This home, this can mean meeting up socially after they have moved on.
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2. Behaviour Management Policy

(also see Safeguarding policy Appendix A: Behaviour Management Guidelines)
The Manager and staff strive to create a positive, caring and appropriate environment for the young
people.
Any assessment and future planning for young people should be supported with a
Behaviour Management Plan.
A Behaviour Management Plan will be distinctly individual for each child, in alignment to the child's
background and needs.
It is expected that any behaviours which give concern about the following will result in a Behaviour
Management Plan:
Concerns:
 Bullying or other similar behaviours

 Absenting behaviour
 Anxiety or withdrawal
 Challenging behaviour
 Drug or substance misuse
 Violence or aggressive behaviour
 Challenging behaviour
 Drug or substance misuse
 Lack of awareness of person safety
 Offending or offensive behaviour
 Self-Harming behaviour
 Sexually exploitative or inappropriate sexual behaviour
The Care Plan should incorporate the Management Plan.
Behaviour Management Plans must summarise the behaviours causing concern and the strategies
being proposed/used by staff to be able to manage the specific behaviour.
Where the same behaviour is exhibited outside the placement, e.g., at school, we make sure staff
and other professionals work in partnership, ensuring consistency where appropriate.
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Behaviour Management Plans (form part of Young people's Placement Plans), must be subject to
Placement Plan Reviews.
1. Staff, through positive role modelling, training, supervision and growing experience will
convey a sense of wanting to form constructive relationships with young people, and of
wanting to care for young people at the Home.
2. Generally, young people will behave within a setting they value and respect. Some young
people will seek to jeopardise positive relationships or may ‘test them out’ due to low self-
esteem or lack of trust in adults/those with authority. This can take the form of self-harm,
hurting others or destroying property/possessions.
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3. This can prove very difficult for staff at times but can be combated by high standards of care,
a positive living environment and increased self-worth. The whole staff group will strive to
create a positive ethos in which to care for young people, drawing on their professionalism,
expertise and literature/training on the subject.
4. Young people will be involved in discussing the implications of negative behaviour which
demand staff intervention and methods of curtailing this. This enables young people to
make choices and have increased control over their lives whilst managing any risk
appropriately. This will take place both in groups and individually, formally and informally.
Individual discussion of behaviours will take place within the Key Work session.
5. Young people who come to the Home will be given a copy of the Welcome Pack, which
includes the rules of the Home, sanctions and rewards. It is important that staff and young
people clearly understand what behaviours are acceptable and what are not. Group
discussions allow young people and staff an opportunity to discuss values and define what
acceptable and unacceptable behaviour is and examine the consequences of both. This will
primarily take place during one-to-one meeting with between key workers and their
allocated young people and House Meetings.
6. Young people should be encouraged to take responsibility for their actions and behaviour as
part of their emotional development and move towards independence. Compromise and
negotiation should be key factors in managing behaviour where management of risk allows
this to be the case.
7. It is imperative that staff are aware of the histories of the young people they are caring for
and in turn this should influence their behaviour, attitude and responses to individual young
people. They should also be aware of any Care Plan issues that deal with the care and
control of young people who present particular behavioural difficulties. Additionally, staff
meetings and handover meetings will discuss individual and group behaviour by the young
people and develop strategies for the management of such behaviour.
8. Staff, through training, literature and knowledge of young people, should be encouraged to
detect early signs of tension which may lead to disruption or negative behaviours. Staff
should work as a team to ensure good communication and understanding of specific roles to
gain confidence in working alongside one and other. Staff should, as a team, discuss
methods of diffusing potentially difficult situations which may include diversionary tactics,
group meetings, privacy for young people, one-to-one attention of staff, explanation of
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certain situations, giving young people choice and upholding young people’s dignity.
9. In a situation where a young person’s behaviour requires staff intervention, where possible
the initial response should be through dialogue. Staff may feel it necessary to reinforce
dialogue through actions such as adopting a particular non-confrontational stance, standing
in the way of the young person (to prevent them leaving), placing a hand on the young
person’s arm in a non-threatening manner or, in extreme cases, the use of physical intervention if
the young person/staff member/other young person or any other visitor or member of the public
is in immediate physical danger or where there is a serious risk to
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property. All of these are acceptable if their use is persuasive rather than coercive.
10. Staff presence is often enough to deter continued difficult behaviour accompanied by an
appropriate look or statement and this can encourage young people to manage their
behaviour within acceptable limits. Alternatively, it may encourage the young person to
engage in discussion about their behaviour/distress. On occasions, a young person may
require a period of time to ‘cool down’ and staff members, if appropriate, should suggest
this. Staff will try to give the young person one or two options to manage their behaviour, thereby
retaining control.
11. The application and maintenance of safe, consistent, understandable and predictable
boundaries will assist young people in managing their own lives more successfully and
encourage appropriate behaviours. There will always be occasions when boundaries are
temporarily disregarded such as an extension of bedtime or an additional excursion.
However, when boundaries are disregarded it should always be explained fully to the young
person why this is and that this is a temporary measure.
12. The staff team should differentiate between ‘one-off’ interventions and repeated methods
of care and control. They must be able to show that the method of intervention is in
keeping with the incident. Staff should avoid tactics/interventions that will potentially
escalate the situation and be mindful of the young person’s age and level of understanding
when dealing with conflict.
13. Staff at the Home will always work towards rewarding and/or encouraging positive
behaviours to minimise negative and difficult behaviours. Sanctions are dealt with under
separate procedures in this file.
3. ALTH CARE
1. All staff at the Home will be actively engaged in the promotion of young people’s health
care. This will include assisting young people in menu planning and food shopping to ensure
a healthy, balanced diet is followed. This will also encompass risk assessments for particular
activities within the Home, undertaking discussions with individual and, where appropriate,
groups of young people on health matters pertaining to physical well-being, sexual health,
emotional and mental good health. Staff will actively discourage young people from the use
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of tobacco, alcohol and drugs.
2. During the initial planning stages of admitting a young person to the Home, information is
acquired from the Placing Authority, the social worker and family/key kin in relation to the
young person’s health history, current concerns/requirements and developmental issues.
This information is found on the LAC materials in the young person’s file. Consent for
medical treatment is also documented here. Arrangements will also be made by the time le
young person is admitted to the Home for the transfer of medical records from previous
medical practitioners.
3. In providing health care, consideration should be given to the young person’s religious,
cultural and historical background.
4. Once a young person is admitted to the Home the allocated Key Worker will ensure that
they are registered with the local GP or GP of their choice, the optician and dentist. Also,
within the first month the young people, depending on their needs will be registered with
CAMHS and sexual health clinic. Young people are encouraged to undertake routine checks
and advised of the benefits of this. Young people should be encouraged to take increasing
control over health matters affecting them, giving due consideration to their age and
understanding in managing such matters.
5. Young people are entitled to refuse medical examinations and staff will not force them to
undertake such examinations. This may have implications for their health and if this is the
case, this should be shared with the placing authority, the social worker and anyone with
parental interest and a decision on how to progress should be sought and duly recorded.
Young people should be requested to undertake regular health assessments via the GP.
6. Some young people who are looked after have suffered considerable trauma that manifests
itself in behaviours, which give rise to concern to their emotional well-being. If this is the
case, advice should be sought from the Placing Authority / social worker as to the
appropriateness of a referral for psychiatric/psychological assessment and/or treatment.
7. Young people will be provided with a number of homely remedies (see Medication Policy) to
be administered by staff. They will also be provided with appropriate toiletries, or money to
purchase the same, in order that they can look after their health needs. This may include
skin-care products, shampoos, lotions etc. that can be administered by the young person. In
dealing with such issues, staff should always be sensitive and caring in their approach.
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8. All staff should actively discourage young people from use of illegal substances and any
concerns reported to the Manager/Responsible Individual and placing authority / social
worker.
9. Staff in the Home are trained in First Aid and are aware of where First Aid boxes are located
and how to complete the young person’s individual medication chart and medication log.
Staff will routinely check recordings to see if there is any concern over the use of medication
and report this to the Manager who will in turn decide what action should be taken.
10. The Home ensures that there is a varied menu to meet nutritional needs. Staff are to
encourage all young people to meet their ‘five a day’ and also encourage exercise levels
based on NHS guidance - this is considered in the monthly reviews.
11. PHSE including facts around drugs and alcohol will be supported in Key-working.
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4. EDUCATION POLICY
This policy should be read in conjunction with The Statement of Purpose.
1. We positively promote the inclusion of “looked after” young people in the wider community
and recognises the need for the young person to develop appropriate social learning and
attachments. Wherever possible, young people will be registered at local mainstream
schools and, if at all viable, will remain at their current school. However, mainstream school
is often deemed as inappropriate and young people will therefore be enrolled at local
special schools as named in their Education, Health and Care plans.
2. The optimum time for integration will be assessed on the basis of the young person’s ability
to feel realistically confident about attending school, be able to concentrate for given
periods of time, be able to address work sheets, be punctual and be respectful. However, it
is the aim of the service to integrate pupils immediately into the school upon their arrival at
the Home.
3. In addition, at This home, we are able to facilitate in partnership with local providers a
wide range of creative alternatives to mainstream school both within This home and in
the local area. Dependent upon the needs of the young person, a combination of any or
all the following can be utilised in a full or part-time capacity:
a. Local 6th form colleges.
b. Home Tuition.
c. One-to-one time at the young people’s home with Key Worker or other identified staff.
d. Work experience programmes.
e. Supported Internship Program
f. Support at This home with homework and project work
4. Staff acknowledge and reward all successes achieved at school and support the young
person and the school by attending all meetings and briefings.
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5. PERMITTED DISCIPLINARY MEASURES

(Sanctions)
1. There are measures which can be used in the control and discipline of young people at This
home. It is required that all staff understand that the preferred method of control is based
on the reward of positive behaviours rather than the sanctioning of negative behaviours
and that, when sanctions are used, they are designed to help, not punish, the young
person. There must be a consistent approach by all staff to the management and control of
young people which emphasises reparation and restitution rather than punishment.
2. Staff should always give a verbal warning to young people in respect of unacceptable
behaviour and attempt to discourage the young person from continuing the behaviour.
When sanctions are applied, care must be taken to explain in full to the young person the
reason for the sanction. It should always be relevant to the incident and carried out as soon
as practicably possible. If the situation allows, young people should be given the
opportunity of re-negotiating sanctions by way of adopting a mature and increasing level of
responsibility for their actions.
3. The following are acceptable sanctions within the Home;

a. Verbal reprimands. These should not be defamatory or derogatory (i.e., they
should condemn the behaviour rather than the individual). Emphasis should be
placed on the need for staff to communicate with the young person on an equal
level that gives the young person choices or an opportunity to negotiate. Time and
space for the young person to assess choices is imperative.
b. Reparation or Restitution of Damaged Goods or Property. Paying for damage to
property is acceptable, but great care should be taken as to how much money an
individual loses on a regular basis. An opportunity to repair damage with a Key
Worker’s supervision/help or travelling with staff to repay fines is more desirable as it provides an
ideal opportunity for discussion about behaviour/responses to behaviour etc.
c. Curtailing of Leisure Activities. Care should be taken as to the repercussions of such
action for the rest of the group and the individual concerned. Leisure activities
should, in themselves, be used as opportunities to develop individual skills, staff and
young person’s’ relationships/experiences and promote group identity. These
factors should be considered before taking such action.
d. Additional Household Chores. Before taking such action, staff should consider (1)
whether they are able to enforce such a measure, (2) whether the effect would be
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to degrade the young person in front of their peers, and (3) whether such measures
would help the young person learn from their actions for the future.
e. Increasing Supervision. This form of control can be effective if there are targeted
times when difficult behaviour is occurring (mealtimes, bedtimes). Any increase in
supervision needs to be planned with specific tasks for individual staff to achieve
with young people.
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4. When exerting a measure of control, staff members should first be aware of what they are
trying to achieve and also how far they should go in trying to achieve their goal. It is
advisable, where practicably possible to discuss these issues with other staff members. It is
also essential that the sanction is not personalised and, where possible, the young person
has participated in deciding upon the sanction.
5. It is important to establish within the Home a working system of control that the staff group
understand, accept and have the necessary skills to put into practice. At all times staff will
accord young people with respect, maintain their rights and allow for power sharing within
the whole group and with individuals.
6. The following sanctions are not permitted under any circumstances; staff found using any of
these would be subject to disciplinary action.
a. Corporal punishment.
b. Deprivation of food or drink.
c. Deprivation of sleep.
d. Restriction or refusal of visits or communications.
e. Requiring a young person to wear distinctive or inappropriate clothing.
f. The use or withholding of medication or medical or dental treatment.
g. The use of accommodation to physically restrict the liberty of any young person.
h. The imposition of fines.
7. Any incident that warrants the application of a sanction must be recorded on an incident
form, which will be placed on the individual young person’s file. Young people are invited to
add their comments to the management and understanding of the incident on this form.
Details must include;
a. The young person’s name
b. Details of the inappropriate behaviour
c. Nature of the disciplinary measure/sanction
d. The names of staff present
e. The date of the incident
f. The signature of the person authorised on behalf of the person carrying on the
home.
8. A Central Sanctions Log Book is held in addition to individual Sanctions Sheets.
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9. Such records will be regularly monitored by the Manager who will also comment in writing
on the appropriateness of the disciplinary measure/sanction. Key Workers will analyse the
use of sanctions in informing both the LAC and internal Care Plans when planning for the
young person.
Young people are informed through the written Welcome Pack and during Key Work sessions of
sanctions and the reason for their application.
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All staff members are required to sign a copy of this policy as part of their induction to This
home and in doing so undertake to work within this policy.
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6. RESTRICTIVE PHYSICAL INTERVENTION POLICY

1 The regulations do allow for action to be taken in an emergency. It allows for ‘the taking of
any action immediately necessary to prevent injury to any person or serious damage to
property’. By injury is meant significant injury. This would include, for example, actual or
grievous bodily harm, physical or sexual abuse, risking the lives of, or injury to, the self or
other by wilful or reckless behaviour, and self-poisoning. It must be possible to show that,
unless immediate action had been taken, there were strong indicators that injury would
follow.
2 Restrictive Physical Intervention is the positive application of force with the intention of
restricting the actions of the young person. That is, in order to protect a young person from
harming themselves or others or seriously damaging property. The proper use of Restrictive
Physical Intervention requires skill and judgement, as well as knowledge of non-harmful
methods of restraint. The onus is on staff to determine the degree of restraint appropriate
and when it should be used. Staff must be careful that they do not over-react.
3 A staff member who has reason to be concerned about a young person who becomes
dysregulated or indicates their intention to leave without permission, or intention to be
aggressive to another young person or staff, should take immediate action. They should
give clear instructions and warning about the consequences of what will happen if there is
non- compliance. The staff member may use their physical presence to obstruct an exit
and thereby create an opportunity to express concern and remonstrate with the young
person. Where it is clear that if the young person were to leave the Home and there was a
strong likelihood of injury to themselves or others, it would be reasonable to use
Restrictive Physical Intervention to prevent them from leaving. However, this will only deal
with the immediate problem and careful follow-up work will be necessary, probably with
additional professional advice to bring about longer-term stability and prevent the
repeated use of Restrictive Physical Intervention.
4 Restrictive Physical Intervention should avert danger by preventing or deflecting a young

person’s action, or perhaps by removing a physical object that could be used to harm
themselves or others. Restrictive Physical Intervention skilfully applied may be eased by
degrees as the young person calms down in response to physical contact.
5 The principles relating to the use of Restrictive Physical Intervention may be summarised as
follows:
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a. Staff must have grounds for believing that immediate action is necessary to prevent
the young person from significantly injuring themselves or others or causing serious
damage to the property.
b. Staff should take steps in advance to avoid the need for Restrictive Physical
Intervention, e.g., through dialogue, distraction and diversion.
c. Only the minimum force necessary and for the minimum duration to prevent injury
or damage should be applied.
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d. Every effort should be made to secure the presence of other staff members before
applying restraint. These staff can act as assistants and, if required, witnesses.
e. Other young people should be encouraged to withdraw from the area for the dignity
of the individual being restrained and for their own well-being (potential injury,
resurrection of their own issues).
f. As soon as it is safe, restraint should be gradually relaxed to allow the young person
to regain self-control. Staff should talk calmly to the young person, advising them of
what they are doing and what is required in order that restraint can cease.
g. Restraint will only be used as an act of care and control, not punishment.
h. Restrictive Physical Intervention should not be used purely to force compliance with
staff instructions when there is no immediate risk to people or property.
i. Only approved taught physical intervention can be used, and this may only be
undertaken by trained staff
6 If Restrictive Physical Intervention has been used, staff must complete a Physical
intervention Form as soon as practicably possible and always within 24 hours and pass to the
manager for review. There is space on the form for young people to write their views on
what took place and they should be encouraged, at the right time, to complete this. In
addition, staff must complete the Restrictive Physical Intervention List in the incident form
folder. Staff must inform the Manager of the incident as soon as possible.
7 Young people will be de-briefed after a restraint and will also be given the opportunity to
make a complaint. Relevant forms, telephone numbers and contacts will be provided for the
young person. Further, all young people whose behaviour has necessitated RPI will be
considered for referred to their GP, psychologist or other health professional. These findings
will be recorded on the relevant documents.
8 All staff will, within their first year of appointment, undertake physical intervention restraint
training course and subsequent re-certification. This specifically teaches conflict
management and restraint techniques in order that any use of Restrictive Physical
Intervention can be appropriately applied ensuring that young people retain dignity, respect
and control. It also ensures that staff are safe and protected when applying restraint.
9 Staff are obliged to “reflect” within 24 hours on the RPI and this must be recorded on the
Incident Form. This is detailed in the RPI Log. Within 48 hours of the use of the measure, the
Manager or authorised person will have spoken to the staff who implemented the RPI about
the measure and will have signed the record to confirm it is accurate. Within 5 days of the
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use of the measure the Manager or authorised person will add to the record confirmation
that they have spoken to the child/young person about the measure.
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7. RECORDING OF FILES PERTAINING TO YOUNG

PEOPLE
1. The purpose of recording is to ensure that pertinent information to safely care for and
promote the welfare of young people is appropriately recorded and used. It further assists
in the management of risk, allocation of resources, a chronology of events that identifies
areas of concern and progress/achievement of the young person, decision making and
ensuring accountability for the same, a record of significant life events, and a record of
statutory and legal interventions. Files and recording also serve as a tool for assessment,
planning and setting objectives.
2. Good practice dictates that this should always, where appropriate, involve the young person
and any difference in views should also be recorded and plans agreed and endorsed.
Additionally, information detailed in recordings and files can be used to ensure relevant to
this Policy.
3. Finally, records and files are used as a management tool for the development of care
packages for young people, collation of statistics to inform policies, procedures and
resources and the investigation of complaints.
4. For many of the young people who come to live in This home, the files held within the Home
are a comprehensive daily account of their achievements, areas of development, family
views and history and significant events. Therefore, it cannot be stressed enough that the
recording and care of files should reflect the value that we as professionals, carers, and
members of the community place on these young people and their lives. It follows that all
staff must ensure that policies on confidentiality are adhered to and that all written and
computer-generated client-based information is sensitively managed and stored securely in
line with the Data Protection Act 2018 and G.D.P.R. (The General Data Protection
Regulation).
5. In order that there is consistency within the staff group, the following guidelines are for all
staff members:
o Recording should be in plain English, avoiding jargon and abbreviations where possible.
Information should be accurate, concise and relevant with fact clearly separated from
opinion. Key Workers must ensure files are no more than one week in arrears. All staff
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must record information as soon as is practicably possible. Recordings should be typed

or legibly written.
o Information should be chronologically filed with the most recent document at the front
of each section. Information should be filed in the correct section and cross-referenced
where appropriate. Filing should be no more than one week in arrears. Files should not
be over-filled and completed logs and archive files should be clearly identified as such on
the spine and front cover with the young person’s name, start and end dates of the
volume.
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o Supervisors must sign-off individual recordings and monthly reports to ensure what is
written and planned is appropriate. This should be done on a minimum of a monthly
basis during supervision.
o Supervision notes pertaining to the care of the young person and planning may be
placed on the file in the appropriate section. These must be signed and dated by the
Key Worker and Supervisor. This will ensure continuity of planning, risk management
and decision-making.
o On all recording documents that pertain to young people, there is a place for the young
person to sign the recording and to record any dissent or make comment. Key Workers
will share recordings during Key Work Sessions with young people and gain their
comments and signature during that session. It is important that staff members are in
attendance whilst young people have sight of the recordings to explain and issues and
deal with issues that are sensitive in an appropriate manner.
o In all cases, young people must be advised that the Home keeps written and
computerised records about them and what is included in these records. They should
also inform the young person of their right to have access to their files. Young people
should be actively encouraged to participate in the completion of recordings particularly
fact/front sheets, plans, assessments and reviews.
o Any information received from other agencies can be stored in the main part of the file
unless the author has clearly stated that the information is confidential and cannot be
disclosed to the young person. Referrers that request anonymity should have their
identity protected in the main body of the file.
o When services are provided outside of the Home, there should be clearly documented
and negotiated expectations on recording, maintenance of records and the routing of
written information.
o In order to ensure consistency, the Manager will audit files annually. This audit will build
in suggestions from staff, young people, social workers and families/significant others to
continually evaluate and improve recording systems.
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o All records kept in relation to young people will be stored in the Clear Care System.
Some information may also be kept as hard copies in a A4 Lever Arch file in the
appropriate sections, the content of which is detailed in Schedules 3 and 4 of Young people’s Homes
(England) Regulations 2015. Files must always be kept securely (locked away) in the relevant filing
cabinet or online in an electronic copy.
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8. CARE AND PLACEMENT PLANNING

1. All young people who are resident at This home will be subject to continuous assessment.
This is to ensure that the LAC (Looked After Young people), Care Plan and internal Care and
Placement Plan which comes from this are setting targets and goals that correlate with the
young person’s current situation, taking account of areas of achievement and areas of
development.
2. Assessment is not something that will be ‘done’ to young people, they will be encouraged to
evaluate their own situations and determine what they feel is required in order for them to
realise their full potential. However, in undertaking assessments, staff must clearly evidence
their views and distinguish fact from opinion.
3. When a young person initially arrives at This home, a formal assessment will take place. This
assessment will be completed within 6 weeks of the young person’s arrival in order that all
staff that are engaged with the young person are able to contribute to the assessment and
that there is sufficient time for staff to form professional relationships with the young
person to best inform their view and knowledge. Staff will utilise recordings, observation,
historical information, information provided by the social worker/family/key kin and the
young person in preparing the assessment. It is the task of the Key Worker to complete the
assessment.
4. The initial assessment will focus, broadly, on the following areas:

o Introduction and background. This should take the form of giving context to how the
young person became resident at the Home and what is hoped to be achieved from the
placement.
o Health. This will give comprehensive information on any on-going health matters as well
as acknowledging areas of achievement and detail future plans and/or provision. Diet,
exercise, immunisations, developmental checks (optical, dental and physical), skin care,
issues relating to sexual health, mental health and substance misuse should also be dealt
with.
o Education. This will give information pertaining to education requirements and what
provision is in place to meet these needs and a historical perspective on previous
education provision, attainment or difficulty. Play and interaction with other young
people should also be included.
o Emotional and Behavioural Development. This area will concentrate on the young
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person’s emotional well-being and their views on self and their understanding of their current
situation, characteristics of temperament and self-control. Any areas of concern relating to behaviours
and responses to such behaviours should be noted here.
Recommendations for additional resources such as specialist counselling/therapy should also be
explored.
o Identity. This area is concerned with how the young person views themselves in the
context of others and the value they have, self-esteem relating to race, gender,
sexuality, age, religion and culture and feelings of belonging and acceptance.
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o Family and Social Relationships. This will comment on observations of interaction

through all mediums and should include detail on a young person’s relationships with
adults, peers and family members/key kin.
o Social Presentation and Self Care Skills. Areas to be covered are the young person’s
understanding of and ability to wash, dress and toilet themselves. The impact of self on
others and appropriateness of dress in the context of age, gender, culture and religion,
personal hygiene, ability to present appropriately in different settings, ability to care for
self with increasing independence.
o Young Person’s View. Young people should be encouraged to participate in the
assessment and read the finished document, it is here that young people can add their
comments to the assessment or indeed, be encouraged and assisted to write their own
self-assessment.
o Summary and conclusion. This will focus on information gleaned in all the above areas
both historical and current including the views of others and the young person and will
analyse the information making appropriate recommendations.
The completed assessment must be discussed with the Key Workers, Supervisor and Registered
Manager and be duly endorsed prior to its circulation to the relevant parties
5. As stated above, assessment is continuous. Assessment will be on-going in weekly Key Work
meetings with young people, assessing their behaviour and internal Care Plan objectives.
Assessment of individual young people will also take place through peers and staff in a less
formal structure at House Meetings and Staff Meetings.
6. The motivation of the young person and the sensitivity and appropriateness of the
Care/Placement Plan will be regularly reviewed with the young person through Key Work
and by the staff team through Team Meetings to ensure the plan is on track and continues
to meet the developmental needs of the young person.
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9. USE OF EACH YOUNG PERSON’S PLACEMENT PLAN

1. The Placement Plan for each young person is derived directly from the young person’s
Statutory Review. The Placement Plan is the tool by which agreements and decisions relating
to the developmental needs of the young person can be translated into a day-to-day
working format that is achievable for the young person.
2. The purpose of placement planning is to ensure a minimum level of ‘drift’ for the young
person being looked after. An ability to see where they have made progress will spur on the
young person to greater achievement as well as motivate other young people in the Home
to plan areas of their development with their Key Workers. From an outside perspective, the
Placing Authority, and others with a legitimate interest in the young person, will be able to
identify that the placement is positive for the young person and be able to offer a more
committed level of support and partnership working.
3. In practice, this means the Key Worker will meet regularly with the young person for Key
Work Sessions, determining what the priority issues affecting the young person are in terms
of what they wish to achieve and what are the stumbling blocks to achieving these
ambitions. This is sensitively balanced against the priority wishes of the Placing Authority
and others
significant in the young person’s life. In most cases, these positions are not in conflict as all
parties are aware that the young person’s needs are paramount.
4. On a day-to-day level the Key Worker will discuss with the Manager a method of breaking
down seemingly insurmountable challenges for the young person into workable, achievable
and measurable tasks. These plans will be taken to the Team Meeting for all staff members
to contribute to and for agreement on a way forward. The young person will be further
consulted, and an agreed “contract” drawn up with them.
5. On a regular, agreed timescale, and certainly leading up to the Statutory Review, the agreed
objectives between the Key Worker and the young person will be reviewed. Progress will
have been recorded on daily case notes and monthly progress reports. Positive aspects of
the placement plan will be highlighted, and the young person will be praised for the progress
they have made. Areas where progress has been less pronounced can be identified and the
young person encouraged to reflect on where the planning may have faltered and what
measures can be introduced to enable them to make similar progress as in other areas of
their plan.
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6. Placement Plans are fluid and need to take account of the highs and lows in the young
person’s life. Regardless of all other problems the young person may have, or may be
experiencing, they are also going through the trials of adolescence. There will always be
‘hiccups on the path chosen. Staff and young people will need to acknowledge this from the start of
planning. Too high an ambition will always end in disappointment. The Placement Planning process
should be viewed as a steady spiralling upwards for the young person rather than a series of staccato
steps.
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10. COUNTERING BULLYING

1. For the purposes of this policy, we define bullying as “The behaviour of one person or group
which causes distress to another person or group as a result of physical threats, assaults,
verbal abuse or intimidation”. Such activity can include teasing, horseplay, humiliation,
isolation, exclusion, coercion and damage or theft of personal possessions.
2. We view the treatment of bullying by young people as an educative process where possible.
For many young people, their attitudes and behaviours are learned. The young people
themselves may have been a victim of these behaviours or brought up with these
behaviours as the norm. Staff will attempt to remedy the causes of such behaviours rather
than the symptoms in order to achieve understanding and more long-term solutions.
3. This does not imply staff will collude with bullying by either the young people, other adults
or other members of staff. Incidences of collusion with bullying or incidences of bullying by
staff will be viewed as Gross Misconduct and will be dealt with accordingly.
4. Staff have an individual (personal) and collective (organisational) responsibility to challenge

bullying whether this be personalised (belief) or institutionalised (practice based) in nature.
Staff should make full use of the Whistleblowing Policy and/or address their concerns
directly, in confidence, to the Home Manager, (DSO and registered Manager)
5.
6. Staff will be aware that the young person may be bullied outside of the young people’s
home e.g., school, youth club, on the street and be bringing this behaviour into the
home, victim or perpetrator. In all cases the staff have a duty to respond and inform all
parties where this is taking place.
7. Identification of bullying:
All staff working at This home will look for the following signs as an indication of a young person
being the victim of bullying:
a. Significant changes in known attitudes and behaviours to fit in with others.
b. Unhappiness, the young person appearing withdrawn and depressed or more
aggressive or disruptive.
c. Running unacceptable errands for others.
d. Showing signs of physical hurt.
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e. Looking tired, stops eating, cries/flares up easily.

f. Money/possessions going missing or being damaged.
g. Refusing to go to school or join in the Home’s activities.
h. Running away.
i. Being afraid or intimidated.
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8. Managing bullying:
a. Incidences of bullying will be managed in the following ways:
b. Staff will create an atmosphere and environment within This home where
young people feel confident to confide in staff.
c. Staff will be vigilant towards the behaviour of young people towards each other and
act pro-actively.
d. Staff will establish the facts in any incidents.
e. Staff will establish whether any patterns of bullying exist either with regard to the
victim(s) or the perpetrator(s).
f. Staff will ensure positive rather than punitive responses to bullying. Strategies and
sanctions will be designed to enable young people to think about their misbehaviour
rather than responses that are seen to depend on force or punishment.
g. Staff will address incidents of bullying with the young people concerned individually
in the first instance.
h. Staff will act inclusively by taking the matter to the Residents Meeting in order to
bring about open discussion, joint ownership, clarify This home position regarding
this form of behaviour and develop solutions.
i. A further meeting will take place involving all adults involved in the care of the
young people involved to review the management of the incident, agree a formal
resolution, review the current Care Plans and set a date for reviewing the decisions
made.
9. Staff will always consider the following when managing situations of bullying:
a. Whether or not the incident was bullying. Whether the incident was the young
person’s usual behaviour and whether there is a risk of over reaction by
staff/staff pursuing their own agendas.
b. The victim’s participation in the incident and whether they invited bullying, are
making himself or herself a continual victim.
c. Protection of the victim(s) in managing the incident and confronting the
perpetrator(s).
d. The victim’s perception of the handling of the event and whether they feel safe.
e. The perpetrator’s understanding of their actions.
f. The use and abuse of ‘power’ by staff in resolving the incident and the effects of
their actions in reinforcing, acknowledging or rewarding such behaviours.
g. How This home might take steps to stamp out further incidences of bullying
before it could become a sub-culture. e.g., engage young people in the making
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of posters, project work, review staff practices that might give

opportunity/permission for this behaviour.
h. When this incident might become a young person protection matter.
i. Use of specialist help to eradicate such behaviour from within the Home.
e.g., psychiatric or psychological help, specialist group work.
j. Whether identified behaviour requires an internal formal warning from staff to the
young person identified as the bully.
k. Whether a criminal offence has taken place assault, threatening behaviour and
consideration given as to whether charges should be pressed.
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Measures to be considered
o In supporting the victim
o Call a meeting and review Care Plans.
o Undertake specific Key Work to explore why the person is being bullied.
o Develop practical confidence-building measures with the young person e.g.,
practicing eye contact, walking tall, decisiveness, developing answers to taunts,
strategising to reduce contact with perpetrator or change nature of the contact.
o Encourage the young person to keep a note of what is happening, when and by
whom.
o Provide a higher level of support and security e.g., named staff on shift to
oversee young person.
o Initiate support from trusted adults e.g., teacher, independent visitor, advocate,
social worker, favourite staff member or from specialist agencies such as Kidscape
(0207 730 3300), Childline (0800 1111), many other agencies which can be found
on-line.
o In sanctioning the perpetrator

a. Call a meeting and review Care Plans.
b. Do not allow the issue of bullying to remain “a secret” in the Home. Open it up to
the Resident Group for discussion, project work etc.
c. Undertake educative and insightful key work with the perpetrator to explore the
nature of their aggression and the feelings they generate in others.
d. Shadow the perpetrator to offer support, prevent reoccurrence and encourage
change.
e. Encourage an apology from the perpetrator that is meant.
f. Encourage reparation towards victim.
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11. LOG BOOKS AND STATUTORY RECORDING

There are a number of Log Books which we are required to be kept. All staff must record in the relevant
log Books and associated recording documents whilst on duty or as is required. They are as follows;
1. A detailed record of the history of each young person, including social, educational, medical
and accommodation history. This information is contained in the LAC materials that will be
made available to the young people’s home prior to the young person’s admission. This
information will be retained in the young person’s file. It is the Key Worker and senior
RSW’s responsibility to ensure these documents are kept up to date.
o A record of all admissions and discharges to the Home. This is in the form of an
electronic matrix titled “Admissions and Discharge”. Recording in this log is self-
explanatory.
o A record of all staff. This is in the form of personnel records at the Home and is the.
o A record of all other person’s resident at the young people’s home.
o A record of all accidents. It is the responsibility of individual staff members to
record in the young person’s case file/ care plan.
o A record of all medical products administered to any young person at the Home.
This information is recorded on individual medication sheets for all medicines. This
includes homely remedies and it is the responsibility of each staff member to record
information as soon as any medication is given to a young person.
o A record of every fire drill and/or alarm test conducted. This information is stored in
the “fire folder” ether hard copy or on clear care electronically. It is the
responsibility of the senior RSW to ensure that drills are carried out and the correct
information is recorded in this log.
o A record of all money deposited by young people for safekeeping is kept. It is the
responsibility of young people’s key workers to record this information and to
ensure the monies are deposited for safe keeping with the senior staff.
o A record of valuables deposited by the young person for safekeeping. This record is
kept in the same manner as “Money Deposited”.
o A record of all accounts kept in the Home. This will include “Petty Cash” records
which will detail credit and debits from the weekly petty cash float. It is the
responsibility of the senior RSW to ensure that this is recorded in the log.
o A record of all menus. This information will be recorded on the Weekly Menu Sheet
on clear care online. A record of what is actually eaten by the young person should
46
be recorded in each young person’s Daily Support log.

o A record of every disciplinary measure imposed. This information is recorded in
clear care and it is the responsibility of individual staff members to complete the log
and to have each entry endorsed by the young person the sanction relates to and by
the Manager.
o A record of all duty rosters. This information is recorded online in the form of Roster
Sheets, once the roster has expired each copy, with any amendments, will be saved
online.
o A daily log of events. This information is recorded in the clear care system. The
recording is primarily used to record comings and goings of young people at the
Home, brief information in relation to information received about young people, a
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brief view of young people’s behaviour, actions and demeanour and a chronological log of general
occurrences in the Home. More detailed information on young people should be recorded on
individual recording sheets and cross-referencing noted in the log. It is the responsibility of all staff to
record in this log whilst on shift.
o A log of night stays and any absent or missing of young people, is recorded in clear
care. This is to record any absence of young people from the home. It is the
responsibility of all staff to complete this log.
2. Recordings must take place as soon as is practicably possibly. They must be legible, and
each staff member must sign their entries with their full name. All sections of logs must be
completed.
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12. CONFIDENTIALITY
Matters relating to young people.
3. All young people resident at This home are entitled to privacy and the right to have
information about them kept confidential. Access to any information pertaining to young
people is restricted. This requires that, at all times, written information of this nature is
securely maintained within Clear Care and/or the appropriate locked filing cabinets and
secure staff offices and not be available for unauthorised viewing.
4. As a general principle, information about a young person is only available to the individual
and with whom they choose to share this with. Additionally, workers at the Home and the
Placing Authority staff will have access to this information. Wherever possible it is both
courteous and respectful to request young people’s permission to share information held about them
and will also engender a greater sense of control of their own lives if permission is sought. It is
important for staff to remember that information held on young people is not the property of their
parent(s)/carer(s) and they do not automatically have the right to see a young person’s file.
5. Both private information (that which is not in the public domain), and sensitive information
(restricted information in the young person’s interest) must not be shared with other young
people unless it affects others directly or has a serious negative impact on good order
and/or discipline. If the sharing of this information is deemed pertinent the young person
must be consulted beforehand. Thought will need to be given about how, and in what
context this information is shared.
6. Young people at the Home have access to a private phone to use for contact with their
families/key kin, social worker and young people’s rights organisations such as the Young people’s
Rights Commissioner (02077838330).
7. As detailed in the recording, Key Work and Care Planning procedural documents, young
people should be encouraged to read and contribute to the records kept about them. They
should be encouraged to endorse individual records and/or record dissent where
appropriate.
8. Staff must also uphold young people’s right to privacy in respect of their individual rooms,
knocking and announcing whom they are prior to being given permission to enter. In
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exceptional circumstances, where staff are genuinely concerned for a young person’s safety,
they may not wait for permission to enter; however, this must be the exception.
9. Staff will also respect young people’s need for privacy by not entering bathrooms/toilets or
harass young people who are using these facilities. There are arrangements for young
people to undertake the laundering of their clothes in relative privacy. All young people will
be afforded privacy in matters relating to contraception but if they wish for staff/adult
advice on such matters this will be forthcoming via the Family Planning Association and/or
50
Key Worker or member of staff to whom they are able to relax with.
10. Young people have the right to privacy in relation to their health and medical matters unless
there are serious concerns in relation to what viewing this information might do to their
health. Such decision to withhold information can only be made with the support of the
child’s network.
Matters relating to This home.

1. As a general principle all matters relating to This home are confidential and must not be
discussed with external parties. The exceptions to this are; HMCI (OFSTED inspectors),
Placing Authorities, Social Workers, relevant professionals, parents (in some circumstances)
and those carrying out Regulation 44 Inspections.
2. Nothing in this guidance should prevent the reporting of criminal acts or conspiracies,
professional misconduct or acts contrary to the welfare of young people; physical, sexual or
emotional abuse; racist, sexist or homophobic comments or behaviour; breaches of the
Young people’s Homes Regulations or any other applicable regulations; and any other activity,
action or circumstance which jeopardises the welfare of the resident young people or the
reputation of the Home.
3. Such matters should be reported initially to the Registered Manager,

4. Any requests for information from the media must be referred to the Responsible Individual.
Under no circumstances must staff release any information written or verbal to the media.
Staff should refer to the Whistleblowing Policy in this matter.
Matters relating to colleagues.

Generally, all matters relating to colleagues are confidential to them. Staff should not discuss
information about individual colleagues amongst themselves or in front of young people – this can
seriously undermine the individual’s professional stance and teamwork. If a member of staff has
concerns relating to a colleague this should first be addressed between the two staff in a sensitive
manner away from young people and other staff. If the issue cannot be resolved between the two it
should be referred to the Manager or Responsible Individual for assistance.
o If staff have concerns about issues pertaining to a colleague’s private life and this clearly
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impinges on their work at the Home, again they should follow the steps outlined above.
Staff members private details; telephone numbers, addresses etc are only available to the
Registered Manager, Directors, members of the staff team and Responsible Individual. They
will not be disclosed to young people. The rota is confidential to the Home and any request
from those outside of the Home for information pertaining to this will be declined.
o Staff are reminded that they are in a place of work whilst at the young people’s Home. It is
not acceptable for staff’s family members to come to the Home nor is it acceptable for staff
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to give young people personal details about themselves such as their home address,
telephone number etc.
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13. ADMINISTRATION OF FINANCE

1. The petty cash tin will be kept in a locked drawer in a locked Office at all times.
2. Petty cash returns will be recorded. Receipts will be recorded on a petty cash form and a
chronological record of the young people’s home’s expenditure will be held in Petty Cash
Logs.
3. On a day-to-day basis the shift handover will balance and sign at the beginning and end of
each shift as to the amount of money in the tin. This measure will act as acceptance of the
figure in the tin.
4. In all cases, a receipt should be sought against expenditure. Receipts should be stapled to a
petty cash voucher and if a receipt was not possible, two members of staff should sign a
petty cash voucher.
5. It is considered good practice that the Manager, or any Senior from This home may
undertake a spot check of the petty cash system at any time.
6. A record of all money deposited by young people for safe keeping will be recorded in the log
book “Young People’s Finances”. It is the responsibility of the key workers to record
information in this log and to ensure the monies are deposited for safe keeping with the
Manager.
7. Where appropriate residents may have bank accounts open in their name with the support
of This home staff member. This staff will always be a permanent member of staff, and
these records will be overseen and monitored by this home Manager.
8. Some named staff members may have purchase order cards, these will only be used as per
the agreement for these cards on appropriate products for the service and evidence for
these will be submitted using the on-line portal monthly as per the agreement. Only the
named card holder may use each card.
9. Any irregularities in any finance must be reported to a senior member of staff and will be
addressed via the finance team and Human resource if required.
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14. REPAIRS AND MAINTENANCE

1 It is the intention of the Manager at This home to run and maintain the Home as much like
a family home as is feasible.
2 Additionally, the importance of order and structure in the lives of young people with
complex needs and histories is also recognised as an important factor in helping young
people to develop.
3 With this in mind, staff at This home seek to keep the Home in peak physical condition
at all times. To achieve this:
 Physical checks of the building are undertaken at least weekly and a Health and
Safety Checklist completed.
 Any deterioration or damage to the building is then transferred to the Maintenance
Book. A copy of these most recent entries is then sent to the Responsible Individual
and the Bursar for their attention and action.
4 Where the repair is minor, often staff will attempt put this right themselves. Where a young
person has caused the damage, staff will often include the young person in putting right the
damage caused in the form of reparation.
5 Where the damage is serious or in need of urgent repair, the maintenance team will be
contacted and will complete the repair of use regular contractors who can be called at short
notice.
6 The Manager oversees this system and regular meetings are held with the Responsible
Individual to ensure this process is working and the young people’s homes are in a condition
in which staff themselves would be happy to live.
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15. FIRE AND EMERGENCY PROCEDURES

1 It is company policy that, in the case of a fire being discovered, everyone should leave the
building immediately, without panic, and gather at the designated Fire Assembly Point. Staff
and young people are instructed not to attempt to fight the fire but to leave the building and
contact the Fire Brigade.
2 Staff will alert everyone in the Home. A member of staff will tour the building, rounding up
everyone, closing all doors on the way out and escorting everyone to the Fire Assembly
Point (car park). The member of staff will, if possible, collect the Visitors Book, Logbook and
Register, telephone the Fire Brigade and meet the group at the Fire Assembly Point (care
park). The Manager and Responsible Individual will be contacted. Everyone will remain
together until it has been advised that it is safe to return to the building by the Fire Brigade
or alternative arrangements have been made.
3 A nominated person is responsible for Fire equipment and procedures. However, all staff
must be vigilant in their responsibilities regarding fire safety. Regular monthly checks on fire
extinguishers, fire blankets, smoke detectors and emergency lighting. Monthly House
evacuations are practiced. Fire notices are in the appropriate places.
4 Evacuations will be risk assessed to ensure that residents are not asked to evacuate on a day
when they are already dysregulated, and the risks outweigh the benefits of the drill.
5 These checks are recorded in the Fire evacuation forms. Any faults identified are reported
promptly and repaired as a matter of urgency. Poor responses received from the young
people in carrying through evacuations are picked up and discussed in House Meetings with
a view to improving exiting.
6 Staff are trained in fire safety techniques and talk to young people at induction and House
Meetings about the need to respond quickly and safely to fire alarms. Young people are
spoken to about fire safety issues including what to do in the case of a fire being discovered
and where to assemble in the event of a fire.
7 Annual maintenance checks are made to fire extinguishers, emergency lighting, smoke
alarms and electrical equipment by an external contractor. Fire risk assessments are
completed in- house on a regular basis. Annual visits by external professionals are carried
out to assess and advise whether current fire precautions are satisfactory and what needs to
be undertaken to upgrade the systems. These external visits will only be required when
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there are changes to the building (use, fabric); or if there are changes to the legislation.
8 Annual checks are carried out on all electrical equipment in the Home. Any faulty equipment
is discarded and replaced.
9 Annual checks on gas appliances are carried out by a registered company.
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16. COUNTERING RISKS ASSOCIATED WITH SIZE

1 This home is a 4-bedded young people’s home. The Home is run as close to a family
home as is feasible.
2 The house has 4 bedrooms, a communal sitting room, 1 kitchen, 1 dining room, 2
bathrooms. It has an enclosed garden at the back and a car parking area at the front. The
size and location of the house allows for easy supervision of the young people.
3 It is not the policy of This home to lock internal doors, except for the staff office where
confidential information, money and medication are stored and areas where there are
hazardous substances such as the laundry and COSSH cupboard. However, as some young
people have challenges and young people are supported with high staff ratios some
bedrooms may be secured to prevent other young people from entering bedrooms that
are not their own. No young person will ever be prevented from entering their own
bedroom.
4 Young People can always gain access to garden and communal spaces.
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17. HEALTH AND SAFETY POLICY

The Manager of This home advises staff that this policy is organised as follows:
 General introduction to responsibilities under current legislation and how these

responsibilities are undertaken and discharged.
 Risk Assessment at This home
 The position of This home to COSHH.
 The position of This home to RIDDOR
General
1 This home commits to following legislation:
a. The Health and Safety at Work Act 1974.
b. The Management of Health and Safety at Work Regulations 1999.
c. The Young people’s Homes (England) Regulations 2015
2 Under this legislation, the Manager and Responsible Individual accepts the duty they have to
ensure, as far as is practicable, the health, safety and welfare at work of:
a. All employees,
b. Anyone outside the employ of the company but who might be affected by their
business activity e.g., authorised visitors, contractors, parents and carers.
3 Within the spirit of this legislation, adequate arrangements are in place with for planning,
organising and monitoring health and safety matters within the Home. This measure
includes the purchase and display of appropriate health and safety posters.
4 To ensure these arrangements are successful at operational level, we will provide:

a. Training for all staff within their induction period and subsequently. This training will
enable all staff to take responsibility for their own health and safety whilst at work
and provide channels of communication to enable staff to advise the Manager of the
Home of any perceived shortcomings in health and safety provision.
b. Recorded, formal meetings for staff to raise any health and safety issues that affect
them or others. This may take place in Team Meetings, Shift Handovers, and
individual Supervisions. An agenda slot will be made available for this purpose.
c. Places to record health and safety concerns. The Registered Manager will provide a
Communication Book and a Repairs Book to incorporate this need.
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d. Representatives on the staff team to whom individuals can report their health and
safety concerns. The Manager and delegated health and safety representative from
the staff team for this purpose. The name(s) of representatives with this delegated
responsibility will be placed on the staff notice board/ H&S poster in the staff office.
e. Opportunities to review current health and safety provision annually. This will
include the effectiveness of all measures contained within this policy as they are
working in practice and will form a consultation exercise with the entire staff team.
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5 Staff are reminded that, within The Health and Safety at Work Act 1974, a legal
responsibility is placed on each member of staff to take care of themselves and anyone else
who may be affected by their work. All employees of the company should:
a. Comply with the measures outlined above.
b. Cooperate with seniors and The Manager on health and safety matters.
c. Not interfere with anything provided to safeguard their health and safety.
d. Take reasonable care of their own health and safety.
e. Report all health and safety concerns to the appropriate person.
6 Within the context of the Young people’s Homes (England) Regulations 2015, The Manager
commits to:
a. Ensuring the location, physical design and layout of premises are fit for the task for
which they are intended as per the Statement of Purpose and Function for that
Home.
b. That the Home will be:
i. Adequately lit, heated and ventilated.
ii. Secure from unauthorised access.
iii. Suitably furnished and equipped.
iv. Of secure construction and kept in good structural repair externally and
internally.
v. Kept clean and reasonably decorated and maintained.
vi. Equipped with what is reasonably necessary and adapted to meet the needs
of the residents.
vii. Kept free from offensive odours and have suitable arrangements for
disposal of general and clinical waste.
viii. Providing sufficient washbasins, baths, showers with hot (maximum 60F)
and cold water and sufficient lavatories for the number age and gender of
the residents.
ix. Providing sufficient and suitable kitchen equipment, crockery and utensils
and adequate facilities for the preparation of food for staff and residents.
x. Providing adequate facilities for laundering, washing, drying and ironing
clothes for staff and residents.
xi. Ensuring adequate communal space for sitting, recreation and dining.
xii. Providing facilities for private study appropriate to the educational needs of
the residents.
xiii. Ensuring sleeping accommodation is suitable to the individual’s needs
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including privacy, equipped with furniture, storage facilities, lighting,

bedding, windows and floor coverings. That any bedroom sharing is confined
to siblings where previously agreed with the Placing Authority.
xiv. Able to provide staff with facilities for sleeping overnight and other facilities
for the purpose of changing and storage.
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7 In summary, we seek to:

 Provide adequate control of the health and safety risks arising from the home’s work
activities.
 Consult with employees of the home on matters affecting their health and safety.
 Provide and maintain safe plant and equipment within young people’s homes run by
the company.
 Ensure safe handling and use of substances.
 Provide information, instruction, and supervision for employees.
 Ensure all employees are competent to do their tasks, and to give them adequate
training.
 Prevent accidents and cases of work-related ill health.
 Maintain safe and healthy working conditions.
 Review and revise this policy as necessary at regular intervals.
Risk Assessment
1 The Manager and Responsible Individual take seriously their legal responsibilities to assess
the risks to health and safety of all employees and anyone outside the employ of the
company but who might be affected by their business activity e.g., authorised visitors,
contractors, parents and carers. The purpose of this risk assessment is to identify hazards
and evaluate risks arising from them in order to establish any preventative or protective
measures necessary. Within this home such risks may extend to areas including:
a. Control of infection.
b. Aggression and violence to staff.
c. Lone working.
d. Work related stress.
2 A general risk assessment for the Home will be conducted on a risk assessment sheet. This
sheet will be reviewed a minimum of annually, and more frequently as required, in
consultation with the staff team to ensure risks assessed are still relevant. Any new risks
assessed will be included on this risk assessment. From this sheet more specific risk
assessment forms will be drawn for regular weekly checks on the young people’s home.
3 The Manager and Responsible Individual commit to ensuring all electrical equipment is PAT
tested in line with current regulations.
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4 The Manager and Responsible Individual commit to the Home undergoing a complete
electrical wiring test at least every five years.
5 The Manager and Responsible Individual commit to ensuring all gas appliances within the
Home are inspected regularly and made safe by an approved Gas Safe contractor.
6 The Home commits to undertaking regular fire risk assessments by a competent person
within the Home through the Registered Manager or delegated representative. The name of
the delegated representative for this task will be placed on the staff notice board in the staff
office. These duties will comprise:
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a. Fire systems e.g., fire alarm panels are maintained in working order.
b. Checking escape routes are free from obstruction.
c. Checking fire extinguishers are operationally maintained.
d. Regular checking of fire points/ emergency lighting and fire alarms.
e. Ensuring emergency evacuations take place.
The frequency of these checks can be found within the policy “Fire precautions and emergency
procedures”.
COSHH (Control of Substances Hazardous to Health)

1 We will make suitable and sufficient assessment of any potentially hazardous substances
held within the Home and evaluate the risks associated with holding such materials on the
premises (Control Of Substances Hazardous to Health Regulations 2002). These products can
be identified by the yellow warning triangle on the packaging.
2 Data Sheets are obtained for all chemicals used in the home and are kept in the home, all
staff will read and sign them. These will be reviewed annually or more frequently should the
need arise.
3 This task will be delegated to the Registered Manager or appointed representative within
the Home. The name of this person will be displayed on the staff notice board in the staff
office. This person will decide upon and implement the action required to remove the risks
associated with each substance.
4 Wherever possible staff will use the safest chemicals that are least dangerous to health. All
relevant safety information in the form of “Hazard or Safety Data Sheets” will be obtained
from the supplying company and be kept in the Health and Safety File for staff perusal.
5 Within these COSHH regulations each employee of This home has a responsibility to:
a. Report actual and potential hazards to the Manager or delegated representative.

This includes any actual or potentially hazardous actions by members of staff,
members of the public or neighbours.
b. Avoid creating conditions for young people living in the Home that mirror the
damage and neglect that the young person has experienced previously.
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c. Ensure the upkeep of the fabric of the Home by carrying out any maintenance tasks
they can safely carry out, enter in the Maintenance Book any tasks beyond their
scope for prompt repair.
d. Report any accidents immediately to the senior staff member of duty and complete
an entry in the Accident Book provided.
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6 This home instruct all employees:

a. Not to mix chemicals and not to decant chemicals into other containers.
b. To wear protective clothing, goggles and/or rubber gloves, read all instructions fully
and follow the manufacturer’s instructions when working with household agents.
c. To ensure adequate ventilation is available when working with chemicals.
d. To store materials in a dry, safe, lockable place immediately after use.
e. Not to use any equipment they have not been shown how to operate or any
equipment that they do not feel fully safe with.
f. To keep prescribed medicines in a locked cabinet.
RIDDOR (Reporting of Injuries, Diseases and Dangerous Occurrences

Regulations)
1 The Manager is required to hold an Accident Log for both young people living in the Home
and a separated book for all adults working in and visitors to the Home.
2 Staff are advised that it is a requirement to enter all accidents in the appropriate Accident
Log. The Manager is to ensure these records are filled in correctly and harmonize with other
records within the young people’s home and will monitor the Accident Books regularly.
3 The Manager is required to make a report to the local Environmental Health Department
and The Incident Contact Centre Incident Contact Centre when:
a. There is a death or major injury connected with work. Such examples may include
fractures (other than fingers, thumbs and toes); amputations; dislocation of the
shoulder, hip, knee or spine; loss of sight (temporary or permanent); chemical or hot
metal burn to the eye or any penetrating injury to the eye; injury resulting from
electrical shock or electrical burn leading to unconsciousness or requiring
resuscitation or admittance to hospital for more than 24 hours; any other injury
leading to hypothermia, heat induced illness or unconsciousness, or requiring
resuscitation or requiring admittance to hospital for more than twenty-four hours;
unconsciousness caused by asphyxia or exposure to harmful substance or biological
agent; acute illness requiring medical treatment, or loss of consciousness arising
from absorption of any substance by inhalation, ingestion or through the skin, acute
illness requiring medical treatment where there is reason to believe that this has
resulted from exposure to a biological agent or its toxins or infected material. This
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must be done immediately by phone and followed by relevant form F2508 within
ten days.
b. There is an accident or injury at work that requires staff to be off sick longer than
three days or unable to undertake the full range of duties (not including the day of
the injury or rest days). This includes physical attack. A completed form must be sent
off within ten days.
c. A Doctor reports that a staff member has a reportable, work-related disease.

Reportable diseases are certain poisonings; some skin diseases such as occupational
dermatitis, skin cancer, chrome ulcer, oil folliculitis/acne; lung diseases including
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occupational asthma, farmer’s lung, pneumoconiosis, asbestosis, mesothelioma; infections such

as leptospirosis, hepatitis, tuberculosis, anthrax, legionellosis, tetanus; other conditions such as
occupational cancer, certain musculoskeletal disorders, decompression illness and hand-arm
vibration syndrome. A completed disease report form F2508A must be sent when this diagnosis is
confirmed.
d. There is a dangerous occurrence. This is described as something, which happens

which does not result in a reportable injury but which, clearly could have done. This
must be reported on form F2508 within ten days.
4 All accidents that fall within the scope of the RIDDOR regulations will be reported to the
Incident Contact Centre on the required prescribed forms F2508 and F2508A. Contact details
for the Incident Centre are:
The Incident Contact Centre
Caerphilly Business Park Caerphilly
CF83 3GG
Telephone: 0845 300 9923 (Monday to Friday 08.30 – 17.30) E-mail:
riddor@natbrit.com
5 The Manager of the Home is required to keep archive records of all reportable injuries,
diseases or dangerous occurrences for three years from the date of the incident. Such
records will include:
a. The date and method of reporting.
b. The date, time and place of the event.
c. Personal details of those involved.
d. A brief description of the nature of the event or disease.
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18. ROOM SEARCHES

1 Staff working at This home are aware of the traumatic effects and the effect on trusting
relationships caused to young people by invasions of privacy and violation of private space.
It is therefore instructed that room searches take place only under the following guidelines.
2 Staff must uphold the child’s right to privacy in respect of their individual rooms by knocking,
announcing who they are and waiting permission to enter. It is only in exceptional
circumstances where staff are genuinely concerned for a young person’s safety that they may not
wait for permission to enter.
3 Staff may only search a child’s room or possessions if they have clear grounds for doing so
(suspicion of stolen goods, hoarding food or other items, offensive weapons, drugs,
grooming etc) and where failure to carry out a search would endanger the welfare of
themselves or others.
4 The grounds for the search should be clearly explained to the child, if possible before the
search is carried out, the search if possible, should take place with the young person
present.
5 All searches will be documented showing the time, date and reason for the search and
noting what, if anything was found, who carried out the search and who was present at the
time. This record should be signed by all those present.
6 This home reserves the right to confiscate or remove any items that they may consider
an offensive weapon and to inform the Police.
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19. SAFEGUARDING POLICY & PROCEDURES

Policy
Introduction
We aim to ensure that all young people and young people are welcomed into This home, a safe,
caring and trusted environment where safeguarding is taken seriously, and any concerns or
issues are dealt with appropriately.
All young people and young people have the right to be protected from abuse and neglect
regardless of their age, gender, disability, culture, language, racial origin, religious beliefs, sexual
identity, personality or lifestyle.
We are committed to:
 Ensuring that the welfare of the young person or young person is paramount and that all
those who work directly with or have regular access to young people and young people are
familiar with the contents of this policy and are offered support and on-going training
 Appropriately screening all staff and volunteers who work with young people and young
people
 Ensuring that full consideration is given to the appropriateness of venues and locations to
carry out safe and enjoyable activities
 Working with appropriate statutory agencies where there are allegations or suspicions of
abuse
 Treating all suspicions and allegations of abuse seriously
 Implementing, maintaining and regularly reviewing procedures and guidelines
 Providing a range of high quality and safe provisions for young people and young people
Purpose of this Policy and Procedure
 To set out the principles underpinning our approach to the safeguarding of young people
 To assist staff and volunteers through the process of safeguarding young people
 To define the different types of abuse and identify associated signs, recognising that this will
not include every potential area of abuse
 To set out a clear procedure for employees and volunteers who suspect possible abuse
 To set out a clear procedure for dealing with staff or volunteers who are suspected of
harming a child
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 To provide a framework for vetting, training and supporting those who work with young
people
 To ensure we meet our legal obligations in terms of The Counter Terrorism and Security Act
2015, the Mental Capacity Act 2005, The Young people Act 1989 and 2004.
Principles
Our core values are those of caring, honesty respect and responsibility and we believe that everyone
is entitled to live free from abuse. We also recognise that young people, particularly young people
with disabilities are at particular risk of abuse and exploitation.
Working Together to Safeguard Young people (2018) aims to help professionals understand what
they are expected to do and what they can expect from each other in relation to safeguarding and
promoting the welfare of young people. This statutory guidance defines;
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Everyone who works with young people has a responsibility for keeping them safe. All staff and
volunteers have a duty to protect young people and report suspicions or disclosures of abuse. Service
users should be made aware, prior to the commencement of any service, that staff / volunteers have
a duty to report any concerns, allegations or suspicions of abuse and will not be able to 'keep secrets'
of this nature. All confidentiality clauses must clearly state that confidentiality cannot be maintained
where there is an allegation of abuse although clearly any investigations, reporting will be done only
to appropriate bodies / persons.
This means individual staff must understand that they cannot singularly, on their own, meet the
complex needs of our young people, which means that they must work together to ensure that
that are young people remain safe from harm.
In order that organisations and practitioners collaborate effectively, it is vital that every individual
working with young people and families’ is aware of the role that they play and the role of other
professionals
Staff must be clear that effective safeguarding systems are young person-centred.
We have a clear legal duty to consider the views, wishes and feelings of young people placed in
This home, particularly in relation to matters affecting their care, welfare and their live. Young
people want to be respected, for their views to be heard and to have stable relationships· with
professionals
The Young people Act 1989 and 2004 places a duty on Local Authorities and other
agencies for safeguarding and promotes the welfare of young people
When sharing information, it should be necessary and proportionate; relevant, accurate and always
shared with confidentiality in mind.
The Mental Capacity Act 2005 protects the rights of people aged 16 and over to make their own
decisions as far as they are able and provide a network for supporting and involving people in
making decisions on their own about their treatment.
Recruitment and Selection

Applications for employment or volunteering in roles working directly with young people must be
made via a completed application form or comprehensive CV. All shortlisted applicants will be
interviewed by at least two staff or managers and job / volunteering offers will be subject to 2
satisfactory, verified references and a satisfactory DBS disclosure. At least one of the interview panel
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must be trained on Safer Recruitment Practice and questions must cover safeguarding, motivation
for working with young people, any gaps in employment / education, forming appropriate
relationships and professional boundaries. Any potential concerns arising at any stage during the
process will be discussed with applicant, investigated and documented before any final decision is
made.
Safeguarding Young people and Young People Against Radicalisation

and Extremism
In accordance with the Counter Terrorism and Security Act 2015, our organisation has a
responsibility to prevent those accessing our services from being drawn into terrorism. "Prevent" is
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one of the strands of the Governments counter terrorism strategy and its aim is to stop people being
drawn into terrorism.
PROCEDURES
Staff Selection and Vetting
All applicants for roles working with young people will be subject to a thorough recruitment process
including completion of an application form (or a comprehensive CV), shortlisting by at least two
staff I managers and interviewing by at least two staff I managers of which at least one must be
trained in Safer Recruitment and with questions covering safeguarding, motivation for working with
young people, forming appropriate relationships and professional boundaries, gaps in employment
or education. Questions should cover emotional resilience, motivation; integrity and values;
authority; accountability; ethical standards and team work will also be covered as part of the
recruitment process.
Thorough notes of all responses given is vital to ensure we have adequate evidence to make a
balanced recruitment decision.
Once offered a role or during the recruitment process, all staff, volunteers will be required to have
two refences taken up and verified. At least one of the references should be from the most recent
setting where the applicant worked with young people. Where concerns are raised on a reference I
declaration these will be discussed with the applicant, fully documented and could lead to the
withdrawal of the offer.
An Enhanced Disclosure and Barring Service (DBS) Disclosure with a Check of the Barred List for
Young people and Young People or a check via DBS Update Service will be undertaken for all staff
and volunteers. It is a criminal offence to allow someone to work with young people and young
people if they are barred from doing so.
As appropriate, DBS disclosures I checks of the DBS will be repeated during employment on a three-
yearly basis. Refusal to comply could be grounds for dismissal.
Barring, Criminal Offences and Staff Suitability

Employees / volunteers who, whilst employed or volunteering with us in any capacity, become barred
from working with young people arid I or adults at risk must inform their manager and HR
immediately so that appropriate action (which may include redeployment or dismissal) can be taken.
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Failure to inform will result in dismissal.
If an employee or volunteer is facing criminal charges or is convicted of a criminal offence, they must
inform their manager and HR immediately so that appropriate action (which may include
redeployment or dismissal) can be taken. Failure to inform will result in dismissal.
Employees / volunteers should also inform managers of any other concerns about themselves that
could impact on their suitability to work with young people/young people. For example, if they are
subject to young person protection or safeguarding enquiries in relation to their own young people.
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Induction and Training

All staff and volunteers in their induction will receive basic information about safeguarding young
people from a senior member of this home team, they will be given the safeguarding policy and
procedure which they will sign to shown read and understood. They will be enrolled on face-to-face
safeguarding training within 6 months, this training is renewed every year. Other specialist
safeguarding training will be provided as appropriate to the role.
Safeguarding will be a focus of this organisation; safeguarding will be discussed as a standing item on
team meeting minutes and supervision meetings.
All staff and volunteers can access the Local Safeguarding Young People Board (LSCB) website or
speak to the Designated Safeguarding Lead Officer or LADO for general advice and information
regarding safeguarding young people. Contacts at the end of this document.
Staff Conduct
All staff have a responsibility to maintain public confidence in their ability to safeguard the welfare
and best interests of young people. They should adopt high standards of personal conduct in order
to maintain confidence and respect of the general public and those with whom they work.
There may be times where an individual's actions in their personal life come under scrutiny from the
community, the media or public authorities, including about their own young people, or young people
or adults in the community. Staff should be aware that their behaviour, either in or out of the
workplace, could compromise their position within the work setting in relation to the protection of
young people, loss of trust and confidence, or bringing the employer into disrepute.
The Childcare (Disqualification) Regulations 2018 set out grounds for disqualification under the
Childcare Act 2006 where the person meets certain criteria set out in the Regulations. For example,
an individual will be disqualified where they have committed a relevant offence against a child; been
subject to a specified order relating to the care of a child; committed certain serious sexual or
physical offences against an adult; been included on the DBS young people's barred list; been made
subject to a disqualification order by the court; previously been refused registration as a childcare
provider or provider or manager of a young people's home or had such registration cancelled. A
disqualified person is prohibited from providing relevant early or later years childcare as defined in
the Childcare Act 2006 or being directly concerned in the management of such childcare. Schools and
private childcare settings are also prohibited from employing a disqualified person in respect of
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relevant early or later years childcare.
Members of staff and volunteers must always;

 Maintain professionalism in their conversations, language and conduct
 Maintain appropriate dress and personal appearance when working with young people and
young people (this includes not getting changed in front of young people or young people)
 Not undertake other work e.g., babysitting services, childminding etc for young people /
young people who are receiving services from us or attending our provisions.
 Never disclose their home address or personal phone numbers, share information about
their personal lives, arrange to meet young people·, young people or their parents
socially or allow access to their personal social networking sites, on-line messaging
systems etc.
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 Never start a personal relationship with a young person or young person receiving our
services or accessing our schemes. In posts working directly with young people and
young people any potential relationship with a young person who has previously
accessed our provisions should be discussed with the line manager and formally
declared.
 In the interests of transparency, all pre-existing relationships must be declared to the line
manager and on a declaration of interest form;
 Pre-existing on-line relationships e.g.: Facebook friends with individuals and families
of individuals using the service must be declared and ended. A separation between
professional and personal relationships must be maintained
 Not accept personal gifts from the young people or give gifts to them.
Individual support and maintaining boundaries with young people and

young people
In a situation with a young person or young person where privacy and confidentiality are important
ensure that any meeting that takes place in a private setting, involves at least one other adult in
proximity who is aware that additional support is necessary.
You should treat all young people and young people with respect and dignity befitting their age
and always be sure to be mindful of your own language, tone of voice, body language and
dress.
You should never encourage the use of alcohol, drugs or tobacco or the watching /playing of violent
films, games and you must never smoke or drink alcohol in front of the young people or young
people in your care and you must be prepared to actively intervene to stop any inappropriate
games / activities / conversations etc.
Staff I volunteers must not use their own cars to transport young people or young people except in
very exceptional circumstances and only with the approval of their line manager or a senior officer.
All destinations, stops, and areas where the vehicle is stopped for long periods of time must be pre-
planned and approved by the employees' line-manager. Any emergency / unplanned departures from
the pre-approved travel itinerary should be reported to the line manager as soon as it is safe to do so.
Participants must never travel to, enter, or know the location of private dwellings that are related to
staff members or volunteers.
Those working with young people and young people should never:
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 participation in rough, physical or sexually provocative games

 use inappropriate and intrusive touching of any form
 tell inappropriate jokes.
 use bad language
 scapegoat, intimidate, ridicule or reject a young person or young person
 Disturb the privacy of young people when they are showering or toileting unless personal
care is required and included in care plans and risk assessments
 Make sexually suggestive comments about a young person, even in 'fun'.
 Let young people or young people involve you in excessive attention seeking,
especially that which is overtly sexual or physical in nature.
 Invite a young person or young person to your home or communicate with them via
personal social media
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 Use corporal, physical, verbal or psychological punishment in dealing with young

people and young people.
Allegations and Suspicions of Abuse - Reporting Concerns

Grounds for suspecting that abuse is occurring may also be based on personal knowledge of the
child/ young person and observations of changes in their mood, behaviour or personal presentation,
as well as evidence of injury or disclosure. The worker must document their observation and attach
body chart if required.
A child, a young person; a colleague, relative or member of the public could disclose to a member of
staff or volunteer, information about an incident or incidents that could be construed as abuse. They
must listen to and record exactly what is said, allowing them to speak without asking questions, other
than clarifying basic factual details about the incident itself. They may ask if the person injured in case
immediate medical treatment is required. Every allegation must be recorded and reported to a
designated officer, whether the staff member/ volunteer hearing the allegation believes it or not.
If a member of staff or volunteer suspects abuse, it is their responsibility to report their concerns to
the most senior officer on shift. They should give as much detail as possible about the nature of their
concerns and the time, place, content and nature of any discussions with anyone else involved.
The senior staff will ensure that the young person or young person is protected from any further
harm while the appropriate authorities are informed. They will also notify the DSL who is currently
also the RM as soon as possible. Where risk of harm is suspected, further steps to protect that
child/young person may be taken.
If there is not an immediate explanation, or there is a suspicion that abuse has occurred this must be
referred to the Short Breaks Service Manager who will discuss it with the Young people's Social Care
Social Work Team manager in the appropriate placing borough.
Staff and Volunteers are able to report concerns outside of This home irrelevant of the direction by
the manager.
If staff/ volunteers believe that a child/young person has injuries or requires medical attention they
should be supported in gaining access to emergency treatment. The clinical staff should be informed
of the nature of the suspicions about the source of the injury so that they can take steps to ensure
that potential evidence is not destroyed or compromised.
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Concerns regarding employees or volunteers

An allegation against an employee / volunteer could come from several sources including a report
from a child, a concern from a colleague or a complaint by a parent. It may also arise from the
volunteers' / employee's life outside work.
If any concerns or allegations relate to an employee or volunteer, the most senior staff on shift must
be informed immediately and they will inform the DSL. The DSL will inform the Local Authority
Designated Officer (LADO) prior to any action and before the employee/ volunteer is informed. This is
to ensure that young person protection processes and any criminal investigations are not
compromised. If such an allegation is received out of office hours that requires immediate attention,
then the DSL should consult the on-call manager and the out of hours emergency duty team (EDT).
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Ofsted will be informed of the nature of the allegations and the action we are taking. Once the
investigation / hearing is concluded they will also be advised of the outcome. Notification to Ofsted
will be completed by the Registered Manager.
When informed of a concern or allegation against an employee / volunteer some discrete enquiries
can be made but they must not investigate the matter with the child, parent, volunteer, employee,
witness etc. They must obtain written details of the concern/ allegation, signed and dated by the
person receiving or making the allegation. The LADO must then be contacted, and the allegations
discussed with them. The LADO and reporting officer will consider how much information can be
shared with the employee, whether a police investigation may be required, whether the young
person needs additional support, if anyone else needs to be informed and what the next steps will
be. Where the allegation is about a member of staff or volunteer, the accused may be asked to work
elsewhere or be suspended during the period of investigation, this is for the safety of young people
and the staff member and to ensure the investigation is not compromised.
We want to encourage staff and volunteers to feel confident about raising concerns about the actions
and attitudes of colleagues and want to create an atmosphere of transparency, openness, shared
good practice and professionalism. If a concern is raised but the individual does not believe it is being
dealt with appropriately then the individual should speak to a senior officer and, if still not satisfied,
should use our Whistleblowing Procedure or contact the LADO directly.
Staff and volunteers can also report anonymously to the NSPCC whistleblowing advice line on
help@nspcc.org.uk or Telephone 0800 028 0285.
Receiving A Disclosure
General Points:
 Show acceptance / belief of what the young person says (however unlikely the story may
sound)
 Keep calm
 Look at the young person directly
 Tell the young person you will need to let someone else - don't promise confidentiality
 Young people are never blamed for any abuse they are victim to
 Be aware that the young person may have been threatened or bribed not to tell
 Never push. If the young person decides not to tell you, then accept that and let them
know you are always ready to listen. Record what they did say immediately
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Helpful things you may say or show:
 I believe you (or showing acceptance of what the young person says)
 Thank you for telling me
 It's not your fault
 I will help you
Don't
 Say "Why didn't you tell anyone before? '

 Say "I can't believe it"
 Say "Are you sure this is true?"
 Ask "Why? How? When? Who? Where?"
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 Don’t make fake promises

 Probe or ask questions other than to clarify points made
 Say you won't tell anyone else
Concluding:
 Reassure the young person that they were right to tell you and show acceptance
 Let the young person know what you are going to do next and that you will let them
know what happens
 Contact the most senior staff on shift as soon as possible and inform the RM and DSL
 Consider your own feelings and seek appropriate pastoral support if needed whilst
maintaining confidentiality
Follow Up
 Make notes as soon as possible (preferably within one hour of being told), writing down
exactly what the young person said and when, and what you said in reply and what was
happening immediately beforehand (e.g.; description of activity)
 Record dates and times of these events and when you made the record. Keep all
hand• written notes securely, even if these have been typed subsequently
 Report the discussion most senior staff on shift as soon as possible and inform the RM and
DSL as soon as possible.
 You must not discuss your suspicions, allegations or any disclosure with anyone other than
the most senior staff on shift, RM, DSL and LADO. If any of these individuals were involved
do not inform them, go above to the next level of staff.
Use of Camera, Recording Equipment and Mobile Phones

Please remember that only the communications team are authorised to publish photos,
images or moving images on behalf of the council, and only with explicit consent of the young people
and the person(s)/ bodies with parental responsibility.
Parents/ carers/ young people and young people must provide written consent using the consent
form to publish any images. Consent must also be sought for the taking and use of images within this
home, this might be for local photo albums for example.
Care must be taken to ensure that images are never sexual or exploitative in nature, nor open to
misinterpretation and misuse.
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If we use external photographers as agreed by parents and carers, the family will be advised of our
safeguarding and other pertinent polices and will sign to acknowledge that they have read,
understand and will abide by them.
No photographs or video at an event/activity will be authorised of any child, other than the parents/
carers own child. Visitors must be told of our expectations and wherever' possible written notices to
this effect will be displayed. Any concerns regarding inappropriate or intrusive photography / filming
should be reported to the manager and dealt with in the same manner as any other safeguarding
concern.
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Under no circumstances must cameras of any kind be taken into the bathrooms without prior
consultation with the Manager.
Mobile Phones/ Tablets etc. Our staff and volunteers should be completely attentive during their
hours of work to ensure all young people and young people are properly looked after. For those
working directly with young people and young people, personal mobile devices must not be used
during working hours and must be kept on silent or switched off and placed with staff belongings.
Work mobiles must be used on outings. However, in the unlikely event that this is not available, staff
may use mobiles on outings for emergency use only with explicit permission. Personal mobiles must
never be used to take photographs of any of the young people. It is the responsibility of all members
of staff to be vigilant and report any concerns to a Manager or designated officer.
Staff should not allow young people / young people to use council phones without supervision. Staff
must never allow young people / young people in our provisions to use the staff member’s personal
phone.
Concerns will be taken seriously, logged and investigated appropriately and thoroughly.
The Manager or another senior staff manager, in their absence, reserves the right to check the
image contents of a member of staff's personal mobile phone or similar device should there be any
cause for concern over its use, and can request immediate return of any council devices held by
named staff.
Should inappropriate material be found on any personally owned or council owned device then the
most senior officer on duty, the RM and DSL will be informed. A LADO referral will be made, and HR
contacted, the staff may be removed from duty whilst this is investigated.
All parents/carers that enter This home are asked to ensure their mobile phones are not used. If
they need to use their phones, they are asked to wait until they leave the setting. This is to
safeguard against risk. Staff must remain vigilant and will remind any parents/carers and visitors if
they observe anyone not adhering to this policy.
Deprivation of Liberty Safeguards (DOLS)

The homes manager and the DSL will continually monitor practice in the home to ensure that young
people over the age of 16 are not subjected to deprivation of liberty unless necessary to safeguard
them I their own interest. If necessary, Mental capacity Assessments (MCAs) will be completed, best
interested meetings arrange with relent stakeholders and the home will request the social worker
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will make an application for DOLS around the specific situations required.
Responsibilities summary
It is the responsibility of
 All to be familiar with this Policy and Procedure, to reread it annually and to also be aware of
the Whistleblowing Policy and procedure
 All to ensure the wellbeing of the young people and young people with whom they work
 All who receive an allegation or disclosure of abuse from any source, or who suspect abuse,
to report their concerns to the senior on shift and to the DSL. If an allegation or suspicion of
abuse involves or implicates these individuals the staff member must report their concern to
a more senior staff or the LADO directly.
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 All staff to be aware of contextual safeguarding in recognising that young people are
exposed to many influences outside of their family and that professionals working with
young people need to be proactive and alert to these influences and ensure that their own
professional influence is positive and wholesome ·
 All to refer allegations to the appropriate bodies, informing the Registered Manager and DSL
 All to maintain confidential records
 Manager to ensure that safeguarding is a standing item at team meetings and supervision
meetings and to create a culture where concerns are raised early and openly, where
safeguarding is always considered, and staff and volunteers can learn good practice from
each other.
 Manager to ensure that staff and volunteers are aware of and comply with this Policy and
procedures and that they receive training appropriate to their role
 The Registered Manager and DSL to report safeguarding concerns to the service manager or
above within 24 hours
 The Registered Manager and DSL to liaise with the Local Authority Designated Officer (LADO)
if allegations relate to staff or volunteers before progressing the issue
 The Registered Manager and DSL to liaise with social work teams as appropriate to
investigate any issues
 The Registered Manager and DSL discuss with HR and required referrals to the Disclosure
and Barring Service (DBS)
 The Registered Manager complete any required notifications to Ofsted within timescale-
Appendix A - Behaviour Management Guidelines

This home recognises the importance of positive and effective behaviour management strategies in
promoting young people's welfare, learning and enjoyment. Parents/ carers and others in the child’s
network are encouraged to contribute to these strategies, raising any concerns or suggestions.
This home team will manage behaviour according to clear, consistent and positive strategies,
guidelines and working practices relating to behaviour management that they must adhere to.
Encouraging Positive behaviour
This will be reinforced with praise and encouragement. In the first instance of negative behaviour,
staff will try to re-direct young people's energies by offering them alternative and positive options.
Staff will be open in stating and explaining non-negotiable issues.
Staff will always communicate in a clear, calm and positive manner.

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Staff will make every effort to set a positive example to young people by behaving in a friendly and
tolerant manner themselves, promoting an atmosphere where young people and adults respect and
value one another.
Staff will work as a team by discussing incidents and resolving to act collectively and consistently.
Staff will encourage and facilitate mediation between young people to try to resolve
conflicts by discussion and negotiation.
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Activities will be varied, well planned and structured, so that young people are not easily
bored or distracted.
Staff will work on each child's positives: and will not compare them with each other but encourage
them individually.
Staff will ensure that quieter and well-behaved young people get attention too.
Staff will aim to be consistent in what they say and ensure that other team members know what has
been said - this avoids manipulation.
Staff will consider individual motivation and needs when deciding why a young person is behaving in a
certain way.
Staff will take a young person aside to talk to them about their behaviour, encourage them to
change and encourage them on their strengths.
Staff will help young people to develop a range of social skills and help them learn what
constitutes acceptable behaviour.
Dealing with Negative Behaviour
Staff will try to discuss concerns with parents/carers at the earliest possible opportunity in an
attempt to help identify the causes of negative behaviour and share strategies for dealing with it.
When confronted with negative behaviour, staff will be clear to distinguish between 'disengaged',
'disruptive' and 'unacceptable' behaviour.
'Disengaged' behaviour may indicate that a young person is bored, unsettled or unhappy. With
sensitive interventions, staff will often be able to re-engage a young person in purposeful
activity.
'Disruptive' behaviour describes a young person whose behaviour prevents other young people
from enjoying themselves. Staff will collectively discuss incidents and agree on the best way to
deal with them.
'Unacceptable' behaviour refers to non-negotiable actions and may include discriminatory remarks,
violence, bullying or destruction of equipment. Staff will be clear that consequences will follow from
such behaviour, e.g., temporarily removing a young person from the activity if appropriate
When an incidence of negative behaviour occurs, staff will listen to the young person or young
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people concerned and hear their reasons for their actions. Staff will then explain to the young
person or young people what was negative about their behaviour and that such actions have
consequences for both themselves and for other people.
Staff will make every attempt to ensure that young people understand what is being said to them.
Young people will always be given the opportunity to make amends for their behaviour and, unless
it is judged inappropriate, be able to re-join the activity.
At all times, young people will have explained to them the potential consequences of their actions.
Staff will NEVER smack or hit a young person and will try not to shout but will change their voice
tone where necessary. Breaches of this are likely to result in disciplinary action.
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Use of Physical Interventions
Staff will use physical restraint interventions only as a very last resort and only then if they have
reasonable grounds for believing that immediate action is necessary to prevent a young person
from significantly injuring themselves or others or to prevent serious damage to property.
Before reaching this stage, staff must have used all possible non-physical actions, such as dialogue,
de-escalation and diversion, to deal with the behaviour. The young person or young people
concerned will be warned verbally that physical intervention will have to be used if they do not
stop.
A dialogue will always be maintained with the young person or young people, so that the member
of staff can explain what they are doing and why they are doing it. Staff will make every effort to
avoid the use of physical interventions.
Only the required, least impactful intervention to prevent injury or damage should be applied. For
example, by diverting a young person or young people by leading them away by a hand or by an arm
around their shoulders.
Staff will use physical intervention as an act of care and control and never punishment. Physical
interventions will not be used purely to force a young person to do what they have been told and
when there is no immediate risk to people or property.
As soon as it is safe, the physical intervention should be gradually relaxed to allow the young person
or young people to regain self-control. The use of the physical intervention will always be
appropriate to the age, size and strength of the young person or young people involved and in
accordance with the training received.
Only staff trained in the approved Physical intervention techniques are to use physical intervention
at This home. If staff are not confident about their ability to contain a _particular situation or type
of behaviour, they should call for the help of a colleague or manager immediately or, in extreme
cases, the police.
Where a member of staff has had to intervene physically to restrain a child/young person, the
incident must be recorded on the appropriate form by the lead staff involved in the incident by the
end of the shift, parents and social workers must be informed and the incident form must be passed
to the RM for review. The form is not shared with the network until the RM has signed it off. Young
person and staff to receive debriefs within the allotted timescales
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If a staff member commits any act of violence, inappropriate restraint or abuse towards a child,
disciplinary action will be implemented, according to the provisions of the Disciplinary Procedure
following consultation with the LADO.
Appendix B – Types and Indicators of Abuse

Physical abuse
The deliberate infliction of pain, physical harm or injury and includes withholding or misuse of
medication.
Indicators include:
 Any injuries not consistent with the explanation given for them
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 Injuries which occur to the body in places which are not normally exposed to falls, bumps,
etc
 Injuries which have not received medical attention
 Reluctance to change for, or participate in, games or swimming
 Finger marks or multiple bruising
 Bruises, bites, cuts, scratches, bums, fractures, etc. which do not have an accidental
explanation
 Flinching or evidence of pain/discomfort during normal activity
Emotional abuse
The emotional ill treatment of a young person such as to cause severe and persistent adverse
effects on the child's emotional development. Some forms of cyber bullying may fall into this
category. It may involve conveying to young people that they are worthless, unloved or inadequate
or causing young people frequently to feel frightened or in danger, or the exploitation or corruption
of young people. It may feature age or developmentally inappropriate expectations Some level of
emotional abuse is involved in all types of ill treatment of a child, though it may occur alone.
Indicators include:
 changes or regression in mood or behaviour,

 a young person becoming withdrawn or becomes clingy
 nervousness, frozen watchfulness
 obsessions or phobias
 sudden under-achievement or lack of concentration
 Inappropriate relationships with peers and/or adults
 Attention seeking behaviour
 Running away/stealing/lying
Sexual abuse
Involves forcing or enticing a young person or young person to take part in sexual activities, whether
or not they are aware what is happening. This may involve physical contact, including penetrative
(e.g., rape, buggery) or non-penetrative acts or non-contact activities, such as involving young people
in looking at, or the production of, pornographic material or watching sexual activities, or
encouraging young people to behave in sexually inappropriate ways. Sexual violence and sexual
harassment can also occur between young people of any age or through a group of young people
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sexually assaulting or sexually harassing a single young person or group of young people
Indicators include:
excessive preoccupation with sexual matters
detailed knowledge of adult sexual behaviour
young person who is sexually provocative or seductive
with-adults inappropriate bed sharing arrangements
unexplained bruising around or bleeding from the rectal or genital area
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stained or bloody underclothing
unexplained difficulties in-walking
sexual activity through words, play or drawing
Neglect
The persistent failure to meet a child's basic physical and/or physiologic needs which results in the
serious impairment of the child's health or development. It may involve a parent or carer failing to
provide adequate food, shelter or clothing. Failure to protect a young person from physical harm or
danger or failure to ensure access to appropriate medical care or treatment.
Indicators include
 Persistent hunger
 Weight-loss
 Poor hygiene
 Dress which is inappropriate to weather or activities
 Physical problems
 medical needs unaddressed
 medical appointments not attended
Organised or multiple abuse

This may be defined· as abuse involving one or more abuser and a number of related or non-related
abused young people and young people. The abusers concerned may be acting in concert to abuse
young people, sometimes acting in isolation/ or may be using an institutional framework or position
of authority to reach or recruit young people for abuse. Social media may be used to orchestrate
organised abuse
Indicators include:
 complaints from different people about the same staff/ situations or issues
 records regularly being mislaid/
 Poor or incomplete record keeping
 controlling relationships
 young people/ activities being visited regularly by "associates" of staff
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Female Genital Mutilation (FGM)

FGM is defined as: A procedure where the female genital organs are injured or changed and there is
no medical reason for this. It is frequently a very traumatic and violent act for the victim and can
cause harm in many ways. Women and young girls are considered to be at greater risk of undergoing
FGM during the extended summer break as this time allows for healing time thus reducing the risk of
detection by professionals. FGM affects girls of all ages, however, in half of the countries where FGM
is practiced the majority were cut under the age of 5.
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Indicators include:
 A female young person is born to a woman who has undergone FGM or into a family where
an older sibling or cousin has undergone FGM
 Family comes from a community known to practice FGM
 A female family elder is very influential within the family and involved in the care or has
started/ is planning to stay with the family
 The family have limited contact with people outside of the immediate family
 A young person or family indicate a 'special procedure'/ 'special event' to become a woman
 A girl or her family talk about a long holiday to her country of origin or another country
where the practice is prevalent
 A planned trip out of the country for a prolonged period (with or without parents)
 A girl has attended a travel clinic or equivalent for vaccinations/ antimalarials
Fabricated or induced illness

This is a condition whereby a young person has suffered, or is likely to suffer, significant harm
through the deliberate action of their parent and which is attributed by the parent to another
cause. There are three main ways of the parent fabricating (making up or lying about) or inducing
illness in a child:
Fabrication of signs and symptoms, including fabrication of past medical history;
Fabrication of signs and symptoms and falsification of hospital charts, records, letters and
documents and specimens of bodily fluid;
Induction of illness by a variety of means
Indicators include:
1. Young person being sick only when in care of the family

2. Inconsistent views between medical test and medical professionals and parents/ carers
3. Family being overly focused on health issues
Young person Sexual Exploitation (CSE)

CSE is a form of young person sexual abuse. It occurs where an in individual or group takes
advantage of an imbalance of power to coerce, manipulate or deceive a young person or young
person under the age of 18 into sexual activity
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1. in exchange for something the victim needs or wants, and/or

2. for the financial advantage or increased status of the perpetrator or facilitator. The victim
may have been sexually exploited even if the ·sexual activity appears consensual. Young
person sexual exploitation does not always involve physical contact; it can also occur
through technology.
Indicators include:
 Having goods or gifts from strangers/ unknown sources

 Secrecy especially about whereabouts and contacts
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Appendix C – Other definitions

Young person– a person who has not yet reached their 18th birthday.
Safeguarding and promoting the welfare of young people - protecting young people from
maltreatment, preventing impairment of young people's health or development, ensuring that
young people grow up in circumstances consistent with the provision of safe and effective care,
taking action to enable all young people to have the best outcomes
Young person protection – Part of safeguarding and promoting welfare., the activity that is
undertaken to protect specific young people who are suffering or are likely to suffer significant
harm.
Contextual safeguarding - an approach to understanding, and responding to, young people's

experiences of significant harm beyond their families. It recognises that the different relationships
that young people form in their neighbourhoods, schools and online can feature violence and
abuse. Parents and carers can have little influence over these contexts, and young people's
experiences of extra-familial abuse can undermine parent-young person relationships. It expands
the objectives of young person protection systems in recognition that young people are vulnerable
to abuse in a range of social contexts.
Abuse - A form of maltreatment of a child. Somebody may abuse or neglect a young person by
inflicting harm, or by failing to act to prevent harm. Young people may be abused in a family or in
an institutional or community setting by those known to them or, more rarely, by others. Abuse can
take place wholly online, or technology may be used to facilitate offline abuse. Young people may
be abused by an adult or adults, or another young person or young people.
Extremism – Extremism goes beyond terrorism and includes people who target the vulnerable,
including the young, by seeking to sow division between a community’s basis of race, faith or
denomination; persuade others that minorities are inferior; or argue against democracy arid the rule
of law in our society. Extremism is defined in the Counter Extremism Strategy as a vocal or active
opposition to our fundamental values, including the rule of law, individual liberty and the respect and
tolerance of different faiths and beliefs.
Young Carer - A young carer is a person under 18 who provides or intends to provide care for
another person (of any age, except generally where that care is provided for payment, pursuant to a
contract or as voluntary work).
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Parent Carer: - A person aged 18 or over who provides or intends to provide care for a disabled
young person for whom the person has parental responsibility.
Local Authority Designated Officer (LADO) - County level and unitary local authorities should ensure
that allegations against people who work with young people are not dealt with in isolation. Any
action necessary to address corresponding welfare concerns in relation to the young person or young
people involved should be taken without delay and in a coordinated manner. Local authorities should
have designated a particular officer, or team of officers (either as part of multi-agency arrangements
or otherwise), to be involved in the management and oversight of allegations against people who
work with young people. Arrangements should be put in place to ensure that any allegations about
those who work with young people are passed to the designated officer, or team of officers, without
delay.
Safeguarding partners - A safeguarding partner in relation to a local authority area in England is

defined under the Young people Act 2004 as: (a) the local authority, (b) a clinical commissioning
group for
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an area any part of which falls within the local authority area, and (c) the chief officer of police for an
area any part of which falls within the local authority area. The three safeguarding partners should
agree on ways to co-ordinate their safeguarding services; act as a strategic leadership group in
supporting and engaging others; and implement local and national learning including from serious
young person safeguarding incidents.
Young person death review partners A young person death review partner in relation to a local
authority area in England is defined under the Young people Act 2004 as (a) the local authority, and
(b) any clinical - commissioning group for an area any part of which falls within the local authority
area. The two partners must make arrangements for the review of each death of a young person
normally resident in the area and may also, if they consider it appropriate, make arrangements for
the review of a death in their area of a young person not normally resident there. The purposes of
a review or analysis are (a) to identify any matters relating to the death or deaths that are relevant
to the welfare of young people in the area or to public health and safety, and (b) to consider
whether it would be appropriate for anyone to take action in relation to any matters identified.
County Lines - As set out in the Serious Violence Strategy, published by the Home Office, a term
used to describe gangs and organised criminal networks involved in exporting illegal drugs into one
or more importing areas within the UK, using dedicated mobile phone lines or other form of 'deal
line'. They are likely to exploit young people and vulnerable adults to move and store the drugs and
money, and they will often use coercion, intimidation, violence (including sexual violence) and
weapons
Young person criminal exploitation - As set out in the Serious Violence Strategy where an individual
or group takes advantage of an imbalance of power to coerce, control, manipulate or deceive a young
person or young person under the age of 18 into any criminal activity (a) in exchange for something
the victim .needs or wants, and/or (b) for the financial or other advantage of the perpetrator or
facilitator and/or (c) through violence or the threat of violence. The victim may have been criminally
exploited even if the activity appears consensual. Young person criminal exploitation does not always
involve physical contact; it can also occur through the use of technology.
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Appendix D – The Prevent Strategy

The Prevent Strategy: Overview and Contact details
Prevent is one of the four elements of CONTEST, the government’s counter-terrorism strategy. It
aims to stop people becoming terrorists or supporting terrorism. The Home Office works with local
authorities and a wide range of government departments, and community organisations to deliver
the Prevent strategy.
The Prevent strategy
 Responds to the ideological challenge we face from terrorism and aspects of extremism, and
the threat we face from those who promote these views.
 Provides practical help to prevent individuals from being drawn into terrorism and ensure
they are given appropriate advice and support.
 Works with a wide range of institutions (including education, criminal justice, faith, charities,
online and health) where there are risks of radicalisation that we need to deal with. The
strategy covers all forms of terrorism, including far right extremism and some aspects of
non-violent extremism.
The Prevent Delivery Team delivers work including;
 Training for frontline staff in recognising, referring and responding to radicalisation

Workshop to Raise Awareness of Prevent (WRAP)
 A variety of projects to build capacity, increase resilience and improve understanding of
extremism and radicalisation with partners such as schools, colleges, frontline staff,
community groups, venues and parents
 A referral service for concerns called Channel which acts as an early intervention service to
safeguard vulnerable individuals from radicalisation
Prevent Safeguarding
Prevent works to safeguard vulnerable individuals from being drawn into radicalisation. Individuals
referred to the Prevent team are discussed on the Prevent Safeguarding Board in order to assess
their vulnerabilities.
Individuals deemed at risk may then be discussed as part of the Channel Panel. Channel is an early
intervention multi-agency panel designed to safeguard vulnerable individuals from being drawn into
extremist or terrorist behaviour. Channel works in a similar way to existing multi-agency partnerships
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for vulnerable individuals, delivering tailored support packages to individuals deemed to be at risk.
Channel is voluntary, confidential and non-criminal.
Any concerns about an individual can be referred to the Prevent team who will consider the case
and identify any necessary support for the individual.
Disruption of extremist events
Alongside the police, the Prevent team provide community and business engagement in order to
limit the risk or disruption of events attended by extremists or which feature extremist narratives
and aims.
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Prevent contact information
For further information on Prevent, and the work done to stop people becoming terrorists or
supporting terrorism, please contact;
Useful documents
Prevent Strategy
Prevent Duty
Counter-Extremism Strategy
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Appendix E – LADO workflow (relevant for This home) LADO-ASV

Flow Chart for Schools and other Organisations
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Appendix F – This home reporting workflow
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Appendix G - Key Safeguarding Contacts and information

Registered Manager and Designated Safeguarding Lead (DSL)
LADO
NSPCC
Whistleblowing advice line help@nspcc.org.uk or Telephone 0800 028 0285
London safeguarding procedures
https://www.londoncp.co.uk/ version 5 2017, updated 30 September 2019
Ofsted
0300 1231231
Ofsted enquiries and notifications to enquiries@ofsted.gov.uk
DFE Quality Standards (2015) relevant to this Policy:
Regulation 5- Engaging with the wider system to ensure young people’s needs are met
The protection of young people standard
The leadership and Management standard
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20. ARRANGEMENTS FOR REGULATING AND VETTING

VISITORS
1. Most visitors to This home visit on a pre-arranged basis, enabling staff and young people to
prepare for their arrival. Such visitors must sign the Visitors Book on arrival and, if
necessary, provide proof of identity. This is particularly pertinent when utility workmen are
undertaking work within the Home. Placing social workers should provide information on
any person who is not authorised to have contact with young people and the reasons why in
order that staff can uphold this. Family members/key kin will also be asked to sign the
Visitors Book.
2.
Should staff have any concerns relating to a visitor, these must be reported immediately to the
Manager clearly outlining the concerns. The Home is a private establishment and, as such, has the
right to refuse entry to anyone it does not wish to admit to its premises.
3. Young people will be encouraged to have family, key kin and significant others visit them at
the Home. However, this must be arranged in advance and risk assessed because of the
challenging needs of some residents. It may be necessary to make arrangements to keep
visitors safe and enable young people to manage changes in their routines prior to the visitor’s
arrival, such as social stories for young people about visitors or other young people going out
while visitors are on site.
4. Planned visits will be put in the Home diary in order that all staff are aware. However, it is
acknowledged that some young people will have visitors who arrive without prior
notification; in such cases staff will try to accommodate such visits if possible.
5. No person who is thought to be under the influence of alcohol or drugs will be admitted to
the premises. Individuals who disrupt the running of the young people’s home by making the
young people feel unsafe will be asked to leave.
6. This home is a place of safety for some young people and if this is the case families may
not be admitted, detail about who may not have access is detailed in young person care
plans.
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21. HIV, AIDS, HEPATITIS B AND SERIOUS INFECTIONS

1. Staff are advised that the HIV (Human Immunodeficiency Virus) infection may not produce
any symptoms for long periods. Therefore, it is possible for some people, and those around
them, to be completely unaware that they have the infection. Staff are advised that it is
good practice for everyone to assume and act at all times as if everyone is potentially
infectious.
2. AIDS (Acquired Immune Deficiency Syndrome) is defined as a condition in which the body’s
ability to resist infection has been damaged by the HIV virus.
3. The HIV virus may be transmitted through the body fluids and tissues (blood and blood
products, semen, vaginal and cervical fluids and transplanted organs). The virus cannot be
caught in the same way a person might contract flu or measles. There are three main ways
in which the virus can be passed from person to person: 1) Sexual Transmission i.e.,
vaginal, anal and oral sex. 2) Injecting drugs. Infection can be transmitted by sharing
needles and syringes contaminated with infected blood. 3) From mother to baby during
pregnancy and birth.
4. Staff do not have the right to take a young person in their care for an HIV test (there is no
test for AIDS) without permission. The decision to test can only be made by the parents or
people with parental responsibility for the young person, or the young person themselves if
they are over sixteen years of age. A test for HIV should be made only with the informed
consent of the person concerned. Informed consent involves a thorough understanding of
the nature and consequence of the test. This understanding is gained through pre-test
counselling.
5. Although other young people are at no risk of contracting HIV in ordinary daily life from a
young person who is HIV positive, the young person with HIV may be put at risk by
contracting common infections from others. It is good practice therefore for staff:
a. To contact the doctor or specialist concerned should the young person not recover
within normal time-scales if the young person with symptomatic HIV has any illness,
contact the doctor immediately.
b. Keep the young person with HIV infection away from others who have common viral
infections such as measles, rubella, chicken pox, whooping cough or mumps, even if
they have been vaccinated against these illnesses, as the efficacy of the vaccine may
be reduced.
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c. Keep the young person away from school or other young people if you are aware
that these infections are going around or if there is an outbreak of any infection
causing diarrhoea.
6. Staff are expected, at all times, to demonstrate a positive attitude in response to the futures
of a young person with HIV. Within the Home’s basic philosophy, it is accepted that a young
person with HIV will have special needs, but as far as possible, they will be cared for and
treated like any other child.
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7. Any social worker and Social Services Department placing a young person at This home
will be expected to fully inform the Manager of the HIV status and medical history of that
child. Staff are fully committed to caring for such young people on the basis of full
understanding and knowledge of the child’s background and antibody status, where known.
8. Staff working with young people with HIV should routinely take the following precautions:
a. Wash your hands regularly. Always wash your hands after handling bodily
secretions.
b. Cover all cuts or abrasions on your skin with clean waterproof plasters.
c. Take simple protective measures to avoid contaminating yourself or you’re
clothing with blood, i.e., wear rubber gloves and apron in the presence of blood.
d. Take care to avoid damaging your skin with cuts or abrasions in the present of blood.
e. Clear up spillages of blood promptly and disinfect surfaces. Cover the spillage with
disposable household towels and pour on diluted bleach (in parts 9 to 10). Leave for
a few minutes and then clear. The person clearing up the spillage must wear rubber
gloves and an apron. Surfaces should then be wiped with diluted household bleach.
When cleaning up blood spillages, care should be taken not to splash.
f. Disposable towels, gloves and aprons which have been stained with blood should be
double bagged, using plastic bags, and put with the other household waste for
collections. Non-disposable items can be washed by hand, wearing rubber gloves, or
in the washing machine.
g. Disposable and other waste items contaminated with blood which is infected with
HIV should be double bagged, preferably in yellow plastic bags and the local Clinical
Nurse Specialist be asked to arrange for collection and incineration.
9. With regard to first aid:

a. Accidents:
i. If a young person has an accident where there is a loss of blood:
1. Wash the wound immediately with soap and warm water and a
relevant cleaning agent. Dry with a disposable kitchen towel
(dispose of in a plastic bag, in a bin).
2. Apply a waterproof dressing
3. Wash your hands (and rubber gloves).
b. If blood has been spilt on to someone else:
i. Wash off immediately with soap and warm water
ii. Wash off any blood splashes in the eyes or mouth with plenty of water.
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c. If you think you may have been exposed, through damaged skin, to body fluids from
someone with HIV infection, you should immediately:
i. Wash your cut or abrasion liberally with soap and water but without
scrubbing. If your skin has been punctured, free bleeding should be
encouraged but the wound should not be sucked.
ii. Report the incident to the Manager / Responsible Individual.
iii. Complete a full accident record.
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10. Staff may feel it is appropriate to over-protect a young person who is HIV positive. This is
not This home policy. The young person should be encouraged and helped to live a normal
life. Should the young person experience avoidance or hostility from other young people
and/or adults, staff will assist the young person to overcome this prejudice and will
challenge the other party to take a positive understanding of the situation.
11. The National AIDS Helpline is available at any time, 24 hours, free and entirely confidential
to carers and those with HIV on 0800 567 123.
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22. SAFER RECRUITMENT PRACTICES POLICY

This home takes the recruitment of staff and associated safeguarding procedures very seriously. All
staff undergo a series of checks as outlined below and employment will not begin until the Principal is
satisfied that the person is suitable to work with young people and is fully committed to the
safeguarding of young people in our care. The following policy applied to all staff employed by the
Group to work in the Home.
1. Pre-Interview Planning:
a. Timetable decided.
b. Job Specification prepared.
2. Vacancy Advertised:
a. Advert includes paragraph about This home being committed to promoting
the welfare of young people.
b. The successful applicant will be advised that he / she will need an enhanced DBS.
3. Applications Received:
a. Any gaps in employment, anomalies or discrepancies are explored with the candidate and, if
necessary, previous employers contacted to confirm employment dates and reasons for leaving.
Applications are only accepted on official Application Forms. Any previous convictions will be
checked, and the candidate will be asked for further information if necessary. If the previous
convictions are considered to not pose any safeguarding concerns for young people, the Responsible
Individual will be asked to allow the candidate to be invited to interview. If any previous convictions
are of a young person protection nature, the candidate will not be invited to interview, and the Police
and DBS will be advised.
4. Short-List Prepared and Candidates advised that References will be Taken Up:
a. At least two references are requested using the covering letter to ask specific
questions and including a statement about the need for accuracy. However, where
a candidate has worked with young people, young people or vulnerable adults in
the past, every attempt will be made to contact these employers to ensure that
there were no concerns regarding the employee prior to their departure.
b. Every request will include:
i. Referee’s relationship with candidate, how long known to them and in what
capacity.
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ii. Whether satisfied the applicant has ability and is suitable to perform the job
in question and has demonstrated ability to meet the Person Specification.
iii. Specific comments about the person’s suitability for the post and how he /
she has demonstrated his / her ability to meet the Person Specification.
iv. Whether referee is completely satisfied that the candidate is suitable to
work with young people and, if not, to provide specific details of
concerns and reasons why.
v. Confirmation of details of applicant’s current post, salary and sick record.
vi. Specific verifiable comments on applicant’s performance history and
conduct.
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vii. Details of any disciplinary procedures the applicant has been subject to
which have involved issues relating to safety and welfare of young people,
including anywhere the disciplinary sanction has expired, and the outcomes
of those.
viii. Details of any allegations or concerns that have been raised about the
applicant that relate to the safety or welfare of young people or young
people or behaviour towards young people, and the outcomes of those
concerns i.e., whether allegations or concerns were investigated, the
conclusion reached and how the matter was resolved.
ix. Reminding referees that they have a responsibility to ensure the reference is
accurate and does not contain any material misstatement or omission. They
should provide relevant factual content that could be discussed with the
individuals.
5. Receive References (either before or after interview):

a. Check against information on Application Form and note any concern or discrepancy
to take up with candidate at interview.
b. References should be followed up with a telephone call to verify.
c. References addressed ‘To whom it may concern’ will not be accepted.
6. Invitation to Interview:
Include itinerary for the day and any other relevant information. All Interview Panels to have a
minimum of two interviewers. At least one person on the Interview Panel will be trained in safer
recruitment
a. All interviews are face-to-face even if there is only one candidate. Phone interviews
are not allowed.
b. Notes are made and destroyed after 6 months; successful candidate’s notes are held
indefinitely.
c. Interviews should include the following questions that would probe candidates
about their:
i. Personal life including the candidate’s mental and physical fitness to carry
out their work.
ii. Attitudes and motivations.
iii. Suitability to work with the client group.
7. Conditional Offer of Appointment:

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a. Offer of appointment is made conditional on satisfactory completion of the

following:
i. References (if not already obtained).
ii. Identity – only photographic evidence - a passport or driving licence - is
acceptable. In addition, evidence of current address must be seen (utility
bill, bank statement or similar).
iii. Where appropriate, verify qualifications.
iv. Enhanced DBS. All staff working with young people will be required to
apply for an Enhanced DBS (with barred list information for people
working with young people and adults.) Where appropriate, if the
applicant has subscribed to
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the DBS Update Service, and with the individual’s consent, this can be
checked on-line.
v. Health Questionnaire (Medical Fitness).
vi. Right to work in the UK.
vii. If the person has been living outside the UK, checks will be made to establish
his / her suitability to work with young people, having regard to any
guidance published by the Home Office on the government website
(gov.uk).
8. Should a DBS show any past convictions / concerns these will be checked against the
application form to ensure they were notified at the initial recruitment stage. If they have
not been notified, and if they are of a young person protection nature, the DBS and police
will be immediately informed, and the candidate will be advised that their application can go
no further. For previous convictions that are not of a young person– protection nature and
that have been notified prior to interview, these will be checked for factual accuracy, a risk
assessment completed, and the Responsible Individual will make the final decision as to
whether or not the post will be offered. This home does not allow any staff to work with the
young people without full checks having been carried out.
9. An induction period takes place when staff are monitored and shadowed by an experienced
member of staff and copies of all policies and procedures are read. Staff members are
expected to read this through and are invited to discuss any areas of uncertainty with the
Manager. Induction will include training as identified in the training matrix
10. Contractors who come into contact with young people at the Home will be supervised at all
times.
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23. THE SUPPORT OF YOUNG PEOPLE WHO HAVE

BEEN ABUSED
1. The staff at This home recognise that some of the young resident people may have been
abused and so may have a distorted view of adults and their motives. It may be more
difficult to build trusting relationships with these young people and so it is essential that
staff approach them in an open and honest manner. It is important that staff maintain clear
boundaries and ensure that they are reliable, warm and respectful.
2. Staff should be aware of the possibility that any physical affection towards young people
could be misconstrued by the individual as a sexual overture, or that it may make them feel
uncomfortable. Whilst physical affection is invaluable in boosting a young person’s sense of
self-esteem, it must never be imposed upon them. The ‘lead’ should come from the young
person. Young people who have been physically abused or neglected may also respond
differently to touch or support, staff must be aware of this, reassure young people and go
slowly when providing care to ensure the young person is in as much control as possible and
appropriate. Any observations of unusual behaviours or concerns must be recorded.
3. Staff will discuss at Staff Meetings at regular intervals, what they think is appropriate
touching. This will depend upon the age of the young person, their personal history and
emotional development.
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24. ROSTERING / SHIFT HANDOVERS

1. Staff will come on duty at 0700 (weekdays) 0700 (weekends) (whilst the young people are
asleep) and 1500 (weekdays) 1500 (weekends.) If the young people are present, then one
member of staff on duty will chair the handover, (usually shift leader) and the other staff
member supervise the young people. Otherwise, all staff should attend the handover
meeting.
2. When staff arrive on shift, they are expected to read:

a. Log Book & Daily Recording. Twice a day, morning and evening, a daily log of the
young person’s activities, general behaviour and emotional and physical state will be
recorded on their Daily Support Plans. Telephone calls concerning the young person
will also be recorded here. Should there be matters of a young person protection or
sensitive nature
the ‘recorder’ should refer the reader to the closed file and this information should be recorded
there in detail. Copies should be made and placed in the Confidential Young person Protection File.
b. Incident Reports. Any ‘incidents’ such as episodes of aggressive behaviour, bullying,
disciplinary measures, restraint, absconding, should be reported in detail on an
incident form and placed in the appropriate section of the young person’s case file.
Copies of these incidents may have to be filed elsewhere also e.g., disciplinary
measures etc…
c. The Communications Book is to be used for staff to share information concerning
the general running of the house, and for information not directly concerning an
individual child. Telephone calls made or received, questions/answers to staff that
are not on shift, or for general information all should know.
d. The Diary should record all appointments and plans for everyone in the building.
e. Petty Cash is kept in a tin in the office and staff will balance and sign at the
beginning and end of each shift as to the amount of money in the tin. Receipts
should be stapled to a petty cash voucher, and if a receipt was not possible, two
members of staff should sign the voucher. The Petty Cash tin should always be kept
locked in the office.
3. Each of the above should be completed, checked and read before handover so as discussion
might take place at handover.
4. There is a Shift Plan Allocation sheet for each shift that should record who is on duty, the
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plans for the shift and the outcome of each shift. It should also include tasks to be
completed by the end of the shift and if these tasks are not completed, they should be
passed onto the next shift planner. Accompanying the shift planner there is also a tick list of
chores that have to be completed each shift.
5. All staff leaving shift are required to complete all outstanding paperwork before leaving, it is
the responsibility of the shift leader to ensure this has happened.
6. All of these documents/ records should be discussed, decided and completed at handover.
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25. STAFFING POLICY

Young people are best safeguarded in the residential setting by vibrant and enthusiastic staff. Caring
for young people at This home is demanding and can be a stressful and isolating experience. It is
essential that staff are properly supported by means of written guidance, staff supervision, staff
meetings, training and where appropriate, external consultancy.
The following provision is in place within This home:
Recruitment. Staff are recruited within the procedures laid down in Safeguarding Young people and
Safer Recruitment in Education. Informal and formal interviews are held and at least one member of
the Panel will have been trained in Safer Recruitment procedures. DBS clearances are sought
(Enhanced status) and references are required from previous employers. References will be sought
from all employers where the employee has worked in the past with young people. No member of staff
will start working at the Home until their DBS clearance and references have been received.
Staff Induction. All staff will receive an induction course (see below) relevant to the tasks and aims of
the Home and this will include background information about the young people the Home is caring
for. It is vital that, during this induction, staff understand the contribution that they are expected to
make, understand how their work fits in with the Home and the team, and are provided with
information and training they need to settle quickly and effectively into their role.
Induction. During the induction period staff will have an induction supervisor to assist them in their
learning and fulfilment of their role. The induction supervisor will carry out some of the practical
aspects of the induction. The induction will take place in 4 stages:
a. Pre-arrival. This will entail providing information pertaining to contract employee

conduct, conditions of service and administration.
b. First day. This will involve introduction to the Home’s staff, health and safety issues,
location of sleeping accommodation, security issues, fire and emergency procedures
and client confidentiality declaration.
c. The first week. New staff will have access to copies of relevant policies and
procedures, compliments and complaints procedure, dates for staff meetings and
supervision sessions. Read care plans and Behaviour Management Plans.
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d. The first month. Staff will have had their first supervision, the logs will have been
discussed and discussions will have taken place with regard Policies and Procedures,
Young People’s files.
e. The third month. Staff will have had regular supervisions and all policies will have
been read and understood. ID badges to be complete.
f. The sixth month. Staff will be advised if they have completed their probation, all
training will have been completed, confirmation of post will have been given in
writing and all the policies and procedures read.
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Supervision. All staff at the Home will receive individual supervision from an identified supervisor.
Staff will receive a supervision every month. Supervision will comprise of the following:
 Responses to and methods of working with young people.

 Work with any young person for whom the staff member is key worker.
 Staff member’s role, including accountability in fulfilling the young people’s home’s Statement
of
Purpose.
 Staff members work in fulfilling the placement plan for individual young people.
 Degree of personal involvement, feelings, concerns and stress.
 Staff development and training.
 Feedback on performance.
 Guidance on current and new tasks, including the setting and maintenance of standards.
 Personal issues that may impinge upon the staff member’s ability to carry out their duties
effectively.
Casual or bank staff will receive supervision monthly or following 6 shifts, if they work infrequently
Supervision will be perceived as the normal means by which staff are able to raise with their
supervisor any concern(s) about the welfare or treatment of a young person.
Additionally, staff have access to advice about young people outside of the supervisory session
through line Managers and colleagues.
Team Meetings. Staffing rotas will be organised in such a way as to enable the staff, or as many as
possible, to meet together for staff meetings. Such meetings are important for the cohesion of the
staff as a group and for group supervision and to help combat the fragmenting experience the young
people can have on the staff group as a result of staff working shifts. There will be regular meetings
for all staff who engage with young people at least monthly. This will allow staff members to
contribute to decisions affecting the running of the Home and encourage the development of a
common awareness of the needs of the young people collectively and individually. Meetings will be
timed so that, as far as possible, part-time staff may attend. There will also be a forum for mutual
support through the sharing of experience.
There are 3 fundamental aspects to the staff meeting, these are:
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Young person Care Matters. This will include modification of individual internal care/placement plans
dependent upon need and circumstance, and management of the key worker role. These areas will
enhance the consistency of approach when working with young people.
Staffing Matters. This will include changes to the rota and staff absenteeism, administration and
regulation of systems within the home.
Training and Development. This will include sharing of available training. Feedback from staff
members who have undertaken training. External speakers and short training/information events.
De-briefing of Staff. De-briefing/counselling and group support will be provided as necessary to

members of staff, following crisis intervention, work of a difficult or distressing nature, or work
which places the worker at risk. A formal de-briefing process will apply to all incidents involving
trauma. Where the incident does not include the Manager, the Manager will undertake this de-
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briefing in the first instance, the purpose being to support the individual, discover the true nature of
the incident and draw from it any relevant practice issues. Where it is deemed necessary or in the
best interests of the staff member external support will be offered.
Staff Training. To enable staff to achieve the necessary skills and competence all staff need ongoing
training. This training needs to be appropriate to the aims, objectives and methods as outlined in the
Statement of Purpose and Function and to the individual needs of staff. Staff will be expected to
develop a range of techniques for working with young people as well as specific skills required by
the Homes aims and methods.
Core training will comprise:
 Restrictive Physical Interventions.

 First Aid.
 Food Hygiene.
 Fire Safety.
 Health and Safety.
 Young person Protection.
 Administration, storage and disposal of medication.
 NVQ Level 3 in Caring for Young people and Young People.
1 The following minimum standards will apply to every member of staff:

a. All staff will have an annual appraisal.
b. Following the appraisal all staff will have an annual training plan.
c. The training plan may be periodically reviewed.
d. The Manager will periodically join a supervision session. The Manager will also be
available to discuss any disagreements or disciplinary issues, as well as exemplary
practice. Furthermore, the Manager will actively engage in each staff member’s annual
appraisal and subsequent action plan.
e. The nature, content and frequency of meetings will vary according to the nature of the
work undertaken.
f. Meetings will be planned, regular and given priority.
g. Meetings will be uninterrupted.
h. Meetings will be recorded, and records kept by both parties.
i. Meetings will take place in an environment, and in a manner appropriate to meet the
needs of the staff member and the supervisor.
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j. During the meetings supervisors should be clear about issues of confidentiality.

k. All staff should understand how to access the training and development processes.
2 Staff employed at the Home will be actively encouraged to be involved in the design,
implementation and evaluation of the mechanism for their appraisal, supervision and how their
performance is reviewed. It will be necessary through observation, comment and review of
written work to enlist the views of young people to gain the most comprehensive assessment of
each staff member.
3 Should any disagreement arise out of the supervision or appraisal process that cannot be
resolved with the supervisor, staff may seek the intervention and advice of the Manager or
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Responsible Individual. Additionally, staff may wish to seek advice from their union
representative or support from another work place individual.
4 When staff leave employment in the Home the manager will ensure that they hand in their key,
fob and ID card. The manager will conduct an exit interview to determine the reason for the
staff’s decision to leave and in this interview will remind staff that they are still obliged to follow
the confidentiality policy.
DF
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26. SLEEPING-IN, BED-TIME AND NIGHT SUPERVISION

Staff are aware that night time is often a time of anxiety for young people. It may be that they have
memories that make them feel vulnerable at this time; it may be that this is the first opportunity in
the day that they have had the space to think. This may cause them to ‘act out’ their worries.
Therefore, bedtime and night routines are extremely important in order to help the young person
develop a sense of security.
1 There is a minimum one sleep-in each night at This home. In addition, it may be necessary
from time- to-time to employ additional sleep in or waking night staff according to the needs
of the young people.
2 The settling down time for the young people will start at a time identified in the Placement
Plan. All areas of the building will be shut at 22.30. Staff taking the young people off
premises for activities should be back by this time.
3 Young people will go to bed at a time appropriate to their age and will have been agreed as
part of the Placement Plan. Staff will make every effort not to be drawn into confrontations
with young people at bedtime but concentrate on the settling of the young people. Poor
behaviour can be dealt with the next day.
4 In line with the ethos of running the Home as much like a family home as is feasible, staff
will adopt good parenting role models and be calm and quiet and remind the young people
that it is settling down/sleep time.
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27. PHYSICAL CONTACT BETWEEN STAFF AND YOUNG

PEOPLE
1 Staff are advised to read this policy in conjunction with This home policy on
“treatment of young people who have been abused” (Policy number 23)
2 Staff are to be aware, at all times, of the possibility that any physical contact with young
people could be misconstrued by the young person as a sexual overture, or that it may make
them feel uncomfortable.
3 Whilst physical contact is invaluable in boosting a child’s sense of self-esteem, it must never
be imposed upon a child. The ‘lead’ should come from the child.
4 Staff will discuss at staff meetings at regular intervals, what they think is appropriate
touching. This will depend upon the age of the child, their personal history and emotional
development.
5 Staff are instructed to never engage in acts of physical contact in the child’s bedroom or
when they are on their own. They will also be aware of the possibility of allegations that
they favour one young person over another.
6 Under no circumstances is kissing deemed to be acceptable. Additionally, massage should

only be performed on feet and hands in the company of another member of staff.
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28. SPENDING ONE-TO-ONE TIME ALONE WITH

YOUNG PEOPLE
1. Staff at the Home are committed to the basic tenet of young person care: that in order to
progress a young person developmentally, staff need to invest in him/her and spend time
with the young person individually and in group situations.
2. From the young person’s perspective there is a high level of risk in beginning to trust in an
adult. Generally, their past experiences have led them to feel that not all adults can be
trusted to keep them safe or act appropriately towards them.
3. The Manager acknowledges that, in requiring staff to invest in the young person on a
meaningful level, there is potential risk to staff of allegation/complaint from the young
person. The Manager advises staff that this risk is symptomatic of working with young
people with additional needs.
4. For some young people, the nature of how to behave in a relationship with an adult is
unclear as is their expectations towards and from the adult. The possibility of boundary-
testing behaviours and transference from the young person is likely to be high due to the
nature of their past histories and the subsequent level of damage and disturbance.
5. Staff will be supported through a complaint from the young person providing the member of
staff has worked within policy guidelines and the support does not compromise the Home’s
greater responsibility to the welfare of the young person.
6. The Manager acknowledges the possibility of abuse to the young person by staff who are
engaged in one-to-one activities. Staff who present risk to young people or are abusive
towards young people shall be deemed to have committed gross misconduct and will be
dismissed under the company’s disciplinary procedures. If proven and dismissed the staff
member’s details will be referred to DBS as appropriate.
7. In order to manage these risks to staff and to support them, staff will be monitored and
supervised in their professional practice through supervision, team meetings and discussion
with colleagues, Managers and consultants as well as by the provision of a comprehensive
policy file to which they will have contributed and regular training.
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8. Young people will be supported through a named Key Worker, access to other staff including
the Manager, Independent Visitor, counsellor, consultants, social workers (detailed in
Young people’s Guide) and access to confidential help lines. They will be made aware of policies in
place and organisations that exist to support them and their rights e.g., Complaints Policy. Young
people will be advised of this during their induction to the Home.
9. In order to promote best practice for staff and safeguard the welfare of the young person,
the following guidance will be followed when undertaking one to one work with young
people:
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a. The activity has been agreed as part of the care plan/placement plan for the young
person.
b. The young person’s social worker and any other significant adult in the young
person’s life have been consulted regarding the activity, where appropriate.
c. The young person has expressed willingness to undertake the activity with a staff
member.
d. The member of staff is willing to undertake the event with the young person.
e. A risk assessment has been carried out in relation to the activity.
f. The activity is planned, and other staff are aware where the activity is taking place,
what time the young person and staff member will be departing and what time they
are due back.
g. The member of staff is provided with a means of being able to contact the young
people’s
home, and the home them, in case of emergency. e.g., mobile phone.
h. The young person is observed/debriefed on their return to the Home and any
abnormal behaviour noted, the young person spoken to if necessary.
i. The member of staff, before going off duty, provides a written record of the activity.
This record is then made available for the young person to read and sign as with
other records in the Home.
j. Under no circumstances will staff have young people visit them in the staff members
own home.
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29. CARE PRACTICES TOWARDS YOUNG PEOPLE OF

THE OPPOSITE SEX
1. It is acknowledged that there will be times when staff will need to work alone with a young
person or young person of the opposite sex, e.g., driving the young person, activities.
2. Consideration should always be given to the needs of the young person when Key Work
allocation is arranged and when planning shifts. Staff should ensure that any staffing
arrangements aim to meet the gender needs of the young person.
3. Even when there are no clear historical or gender indicators of difficulty, staff need to
consider the potential risk issues of lone working with young people of the opposite sex and
should carefully consider these needs and individual care planning for that young person.
4. Where possible, gender-to-gender care should be provided, particularly as young people

enter adolescence. Therefore, staff should consider and assess the personal care needs of a
young person they are working with, particularly when planning activities outside the unit
e.g., swimming etc…
5. Staff should always maintain a professional approach to the young people that respects their
individuality, privacy and rights. These aims will support appropriate relationships. Staff
should develop sensitive strategies that support these aims through their day-to-day
practice
e.g., closing door when providing personal care, not entering a space where personal care is being
given, knocking on bedroom or bathroom doors before entering; supporting and encouraging young
people to discuss their feelings and working in an open and honest way, which supports and
encourages discussion and reflections of professional practice.
6. It is important to recognise that, for many young people, adolescence by its very nature is
characterised by confusing emotions and sexual development. Whilst these feelings are
appropriate, they may on occasion lead to inappropriate behaviours from young people such
as ‘a crush’ on an adult. It is the responsibility of the worker to manage these situations,
both through their action and reactions to any presenting behaviours, as well as reporting
any concerns to the Manager, ensuring any areas of concern or difficulty for either the staff
or the young person are discussed.
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7. It is acknowledged that some staff can find it difficult to manage these behaviours
appropriately or may find them intimidating, embarrassing or culturally inappropriate. Staff
should discuss any concerns the have through supervision or with senior staff in order to
receive appropriate support.
8. It is also acknowledged that staff may find it difficult to recognise that a young person may
have sexual feelings for them, and it is the role of all staff to discuss or raise their
observations of interaction between staff and young people.
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9. Staff should always maintain a professional approach to the young people in their care, and
sensitively reinforce appropriate behaviour. There are many strategies that can be
employed, such as:
a. Substitution of particular words for more appropriate words.
b. Using side hugs.
c. Greeting people using handshakes.
d. Thinking about seating arrangements.
e. Discussions of personal space and boundaries etc…
10. When working with young people of the opposite sex, staff should be aware of the
following:
a. The Young Person. What are their care needs? How are these needs best
addressed? Am I the best person to be working with this young person?
b. The Environment. Staff should consider physical space; not isolating themselves or
the young person; the appropriateness of the venue, working outside the unit etc…
c. Support. Do other members of staff share my concerns? Do they know my
concerns? Do they know where I am? What time will I return? Do I need to discuss
my concerns in supervision? Etc…
d. Recording. All records need to be clear and accurate. Have you recorded you?
actions/concerns? What has the young person said or done to evidence them? Etc…
11. Key Workers should ensure that care plans are regularly updated to ensure that information
regarding interpersonal relationships and strategies to support the young person are
included and reviewed. However, it is important that all staff are sensitive to the young
person’s feelings.
12. All staff members working at This home will have contact with the young people placed
there. It is vital that, at all times, staff are aware of the young person’s needs, vulnerabilities
and characteristics and adopt a model of interaction which promotes mutual respect,
dignity, self-worth, sensitivity, valuing diversity and care. Staff should be mindful of the
language they use; this must not be discriminatory, offensive or demeaning to others. It is
reasonable that on some occasions staff will need to assert themselves vocally by way of
disciplining young people or averting them from danger. This is acceptable practice. A good
benchmark is to question if you yourself would like to be treated in a respectful way, and
acknowledge how it feels when others are rude, abusive or insensitive to you.
13. Young people who are ‘looked after’ in public care face many difficulties that their
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counterparts in the community and families do not. Unfortunately, there continues to be

stigma attached to being ‘looked after’; good family and individual attachments are often
absent, young people may have had negative role models, both adult and within their peer
group. They may have adopted learnt abusive behaviours in their dealings with others or
present as victims as a result of abuse. It is the responsibility of staff to actively role-model
good human interaction and self-worth. Staff relationships are crucial to the promotion of
young people’s well-being and feelings of being valued. We should always strive to be
ambitious and have clear aspirations for and with these young people, celebrating them
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successes and assisting them humanely and professionally through difficult times.
14. The conduct of staff in the work setting should reflect the position and role of the care
worker as an adult carer with professional and ethical obligations towards vulnerable and
impressionable young people. Conduct must always be directed towards developing and
maintaining professional standing and reputation. It must not be collusive, anarchic or such
as to undermine the work or purpose of the Home.
15. In the work setting, staff should conduct themselves in a manner that is consistent with
promoting and safeguarding the welfare and interests of young people, their safety and
security, and which seeks to mitigate the negative and damaging effects of their previous
experience.
16. It is not permissible for staff to shout at, verbally abuse or otherwise intimidate young
people. Language should reflect the professional role of the carer but this is not to say that
we banish the colloquial or vernacular. Staff should draw a distinction between the creative
application of a colourful expression and bad language, which intentionally disrespect. Staff
should also ensure that they do not engage with colleagues or young people in a manner
that perpetuates discrimination in any form.
17. It is vitally important that we set boundaries for, and with, the young people we work with
and that we ourselves, as staff, maintain professional boundaries. Boundaries are there
primarily to serve as safeguards for young people but also to help them to live successfully in
the community. Boundaries that are appropriate in terms of age, emotional and physical
development also assist in developing emotional security and a sense of well-being. A good,
balanced daily routine that allows young people education/employment access, regular
meals, leisure time, privacy and respect, interaction with others, self-help and growth all aid
a young person’s development. There are occasions when young people will need to be
sanctioned for negative behaviours – it is vital that when applying sanctions that young
people are fully aware of the reason for the sanction and helped to find mechanisms to
manage their behaviour more successfully. Young people need help to evaluate their
interaction with others and this should be done in a sensitive manner to enable them to take
on new ways of dealing with others.
18. Given the nature of the residential task and the time young people spend in placement, it is
perfectly acceptable for staff to continue professional relationships with young people once
the young person has left the Home, so long as the Responsible Individual is informed prior
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to this taking place and appropriate boundaries, negotiations and notifications have been
managed.
19. Young people should always:

a. Be offered choice. Primarily through knowledge of what is available and an
understanding of the consequence of any choice.
b. Have their rights upheld through opportunity irrespective of gender, race, culture,
disability or sexual orientation. Young people will need to acknowledge the rights of
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others and be encouraged to embrace diversity in order that they do not infringe on other peoples’
rights.
c. Be entitled to achieve fulfilment in their lives, realising their potential and being
assisted and/or supported in reaching their goals.
d. Have the right to achieve independence both in their lives and decision making as is
appropriate for their development. This will include a proportionate approach.
e. Be given privacy within the Home away from others living in the group and staff
when it is safe and appropriate to do so. This also applies to the young person’s right to have any
information held about them, by the Home, to be always treated as confidential.
f. Be treated with dignity that signifies an awareness of the individuals needs and
characteristics and their ability to exercise choice and have control over their own
lives as far as is practicably possible.
20. In their day-to-day dealings with young people, staff should adopt a non-competitive stance
and attitude, always giving the young person a ‘back door’ in times of stress or conflict. This
will encourage and enable the young person to develop skills reasoning, negotiation and
compromise whilst not ‘losing face’. Staff should always be honest and trustworthy in their dealings
with young people. If there is difficult information/news to impart this should be done in a sensitive
and caring manner. Whenever possible always explain the reason for actions and decisions that
affect the young person and be prepared to discuss these and, if appropriate, re-negotiate or
compromise.
21. Staff must remember that they need to maintain professional boundaries. This means being
mindful of touching young people and respecting their personal space. It is acceptable to
place an arm round young people in times of distress if this is acceptable to young people,
but touching should never be sexual or intimate in nature, nor should it invade the others
personal space. Contact must not be intrusive, it should be appropriate to the context, time
and place and not cause embarrassment either to the giver or receiver, or any other person
who is present.
22. Staff will need to exercise discretion, judgement and common sense in determining whether
physical contact is appropriate, welcome and not likely to be misinterpreted before engaging
in it. As a further precaution, such contact should always be public and immediately
desisted from if it begins to feel uncomfortable or generates an inappropriate response.
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23. Staff will not:

a. Lend or give money to young people.
b. Receive gifts from young people and/or their families/key kin but may accept cards
and letters, which should be shared with their supervisor. Staff must not buy gifts for
young people unless the cost is agreed by the Manager and funded by the Home.
c. Give young people cigarettes, nor encourage them to smoke.
d. Wear inappropriate or provocative attire in the company of young people but
ensure it is practical and appropriate for the task.
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e. Take risks with young people’s health and will follow reasonable health and safety
guidance in food preparation and cooking, self-care, use of potentially harmful
products i.e., bleach and cleaning materials.
f. Encourage young people towards drug and alcohol consumption and must
encourage them to adopt a healthy diet and lifestyle.
g. Give keys belonging to the young people’s Home and held by staff to any young
person.
Staff will be assisted in the building of appropriate relationships with young people through
supervision sessions by use of observation, assessment and evaluation of young people’s files,
attendance at meetings and feedback from the staff group and young people.
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30. NEEDS OF YOUNG PEOPLE FROM MINORITY

ETHNIC GROUPS
1. All young people placed at the Home are unique individuals. Each young person has personal
past histories and difficulties specific to themselves.
2. Special attention is required when working with young people from minority ethnic groups
in order to ensure that they are not further disadvantaged by their placement. Their
particular needs associated with their ethnicity may necessitate additional planning and
resourcing.
3. Staff must pay special attention to ensure that the young person’s cultural heritage needs
are met e.g.: private space to practice their religion, specialist clothing, customs, decoration
of rooms as well as paying attention to any particular health need, they may have e.g.,
foods, creams for hair and body.
4. Staff will be alert to the emotions generated in other young people by what they may
perceive as “special treatment” and be alert to any jealousies and racist behaviours metered out. It is
essential that staff include all young people in learning about and understanding different cultural
needs. This can take place by celebrating together different festivals, trying favourite meals of the
young person etc.
5. Staff will be open to methods that might assist the young person remain in touch with their
ethnic and cultural heritage. Staff will not make assumptions regarding the young person’s
needs but will clarify their intentions with the young person before acting.
6. Where appropriate links with groups in the community will be established with the
permission of the young person. This connection may not be as a link for the young person
but may serve as a means by which staff can understand cultural significance and develop
knowledge of dress, music, art and customs.
7. This home provides for special diets, this currently includes Halal, vegetarian, thickened
liquid and soft consistency and restricted choice diets. Any individuals needing or wanting
specific foods have their choices included in the meal plans which are created with
residents.
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31. PRACTICES IN THE HOME TO COMBAT RACISM

1. Staff acknowledges and actively promote the rights of every individual regardless of their
race, colour, nationality, ethnic or social origin, language, culture, age, religion, political or
other opinion, birth or status. This principle applies to all people involved with the Home,
whether they are a young person for whom the Home has a duty of care, a carer associated
with the young person, visitor or an employee.
2. We define “harassment” as “conduct which is unreasonable, unwelcome and offensive,

which creates an intimidating, hostile or humiliating environment, affecting the individual’s
dignity”. Staff understand and accept that the nature of harassment is determined by the
individual who is experiencing the unacceptable behaviour rather than by the perpetrator or
circumstances.
3. Every individual with whom the Home has professional contact is encouraged to challenge
vigorously any attitudes or behaviours, exhibited by staff at the Home, or people cared for
by the Home, that are seen to be, or may be, construed as racist. Staff are committed to
advocating on behalf of those who need support to do this.
4. A climate will be created within the Home where issues such as racism can be regularly and
openly discussed within the staff team meetings and supervision. Staff are advised to read
complimentary policies such as the Whistleblowing Policy.
5. Any form of racial harassment will not be tolerated, and The Manager will act swiftly to
eliminate such behaviours. The Manager will carry out all investigations. Should the
complaint be against the Registered Manager, the Responsible Individual or Regulation 44
Inspectors will carry out the investigation
If an allegation of racial harassment is received against a client, for the duration of the
investigation, the alleged perpetrator will be subject to a twenty-four-hour management
programme. The alleged victim will not be subject to further discomfort.
If an allegation of racial harassment is received against a staff member, suspension or an

alternative working environment will be considered.
6. Should the investigation prove that the alleged perpetrator is guilty of racial harassment the
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Responsible Individual will decide as to whether the incident was non-deliberate or wilful on
the part of the perpetrator.
a. In the case of a non-deliberate incident an educative solution will be pursued.
b. In the case of a wilful incident:
i. In the case of a client perpetrator, termination of placement will be
considered. A Disruption Meeting will be called for this purpose; the views
of the victim will be central in the discussion around the perpetrator
remaining.
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ii. In the case of a staff member perpetrator, summary dismissal on the

grounds of Gross Misconduct will follow.
7. The Management team at This home commit to reviewing the practices of the Home
through regular training and regular policy reviews to ensure any elements of direct or
institutional racism are eliminated.
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32. INFORMATION COMMUNICATION TECHNOLOGY

(ICT) ACCEPTABLE USAGE POLICY
This Acceptable Usage Policy covers the security and use of all This home information and IT
equipment. It also includes the use of email, internet, voice and mobile IT equipment. This policy
applies to all This home employees, contractors and agents (hereafter referred to as
‘staff’).
This policy applies to all information, in whatever form, relating to This home business activities
worldwide, and to all information handled by This home relating to other organisations with
whom it deals. It also covers all IT and information communications facilities operated by This
home or on its behalf.
Computer Access Control – Individual’s Responsibility Access to This home IT systems is controlled
by the use of User IDs and passwords. All User IDs and passwords are to be uniquely assigned to
named Staff and consequently, Staff are accountable for all actions on This home IT systems.
Staff must not:
 Allow anyone else to use their user ID/token and password on any This home IT system.
 Leave their user accounts logged in at an unattended and unlocked computer.
 Use someone else’s user ID and password to access This home IT systems.
 Leave their password unprotected (for example writing it down).
 Perform any unauthorised changes to This home IT systems or information.
 Attempt to access data that they are not authorised to use or access.
 Exceed the limits of their authorisation or specific business need to interrogate the system
or data.
 Connect any non-This home authorised device to This home network or IT systems.
 Store this home data on any non-authorised This home equipment.
 Give or transfer This home data or software to any person or organisation. outside
This home without the authority of This home.
 Line managers must ensure that Staff are given clear direction on the extent and limits of
their authority regarding IT systems and data.
Internet and email Conditions of Use

Use of This home internet and email is intended for business use. All Staff are accountable for
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their actions on the internet and email systems.
Staff must not:
 Use the internet or email for the purposes of harassment or abuse.

 Use profanity, obscenities, or derogatory remarks in communications.
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 Access, download, send or receive any data (including images), which This home considers
offensive in any way, including sexually explicit, discriminatory, defamatory or libellous
material.
 Use the internet or email to make personal gains or conduct a personal business.
 Use the internet or email to gamble.
 Use the email systems in a way that could affect its reliability or effectiveness, for example
distributing chain letters or spam.
 Place any information on the Internet that relates to This home, alter any information
about it, or express any opinion about This home unless they are specifically authorised
to do this.
 Send unprotected sensitive or confidential information externally.
 Forward this home mail to personal non- This home email accounts (for example a
personal Hotmail account).
 Make official commitments through the internet or email on behalf of This home unless
authorised to do so.
 Download copyrighted material such as music media (MP3) files, film and video files (not an
exhaustive list) without appropriate approval.
 In any way infringe any copyright, database rights, trademarks or other intellectual property.
 Download any software from the internet without prior approval of the IT Department.
 Connect this home devices to the internet using non-standard connections.
Clear Desk and Clear Screen Policy

In order to reduce the risk of unauthorised access or loss of information, this home enforces a
clear desk and screen policy as follows:
1. Personal or confidential business information must be protected using security features

provided for example secure print on printers.
2. Computers must be logged off/locked or protected with a screen locking mechanism
controlled by a password when unattended.
3. Care must be taken to not leave confidential material on printers or photocopiers.
4. All business-related printed matter must be disposed of using confidential waste bins or
shredders.
Working Off-site
It is accepted that laptops and mobile devices will be taken off-site. The following controls must be
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applied:
1. Equipment and media taken off-site must not be left unattended in public places and not left
in sight in a car.
2. Laptops must be carried as hand luggage when travelling.
3. Information should be protected against loss or compromise when working remotely (for
example at home or in public places). Laptop encryption must be used.
4. Particular care should be taken with the use of mobile devices such as laptops, mobile
phones, smartphones and tablets. They must be protected at least by a password or a PIN
and, where available, encryption.
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Staff must not: Store personal files such as music, video, photographs or games on This home IT
equipment.
Viruses
The IT department has implemented centralised, automated virus detection and virus software
updates within the This home. All PCs have antivirus software installed to detect and remove any
virus automatically.
Staff must not:
1. Remove or disable anti-virus software.

2. Attempt to remove virus-infected files or clean up an infection, other than by the use of
approved This home anti-virus software and procedures.
Telephony (Voice) Equipment Conditions of Use

Use of This home voice equipment is intended for business use. Staff must not use This home voice
facilities for sending or receiving private communications on personal matters, except in
exceptional circumstances. All non-urgent personal communications should be made at an
individual’s own expense using alternative means of communications
Staff must not:
1. Use this home voice for conducting private business.

2. Make hoax or threatening calls to internal or external destinations.
3. Accept reverse charge calls from domestic or International operators, unless it is for business
use.
Actions upon Termination of Contract

1. All this home equipment and data, for example laptops and mobile devices including
telephones, smartphones, USB memory devices and CDs/DVDs, must be returned to This
home at termination of contract- this is ensured through the staff leavers checklist. All This
home data or intellectual property developed or gained during the period of employment
remains the property of This home and must not be retained beyond termination or reused
for any other purpose.
2. Monitoring and Filtering
All data that is created and stored on This home computers is the property of This home and there is
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no official provision for individual data privacy, however wherever possible This home will avoid
opening personal emails. IT system logging will take place where appropriate, and investigations will
be commenced where reasonable suspicion exists of a breach of this or any other policy.
3. This home has the right (under certain conditions) to monitor activity on its systems,
including internet and email use, in order to ensure systems security and effective
operation, and to protect against misuse. Any monitoring will be carried out in accordance
with audited, controlled internal processes, the UK Data Protection Act 1998, the Regulation
of Investigatory Powers Act 2000 and the Telecommunications (Lawful Business Practice
Interception of Communications) Regulations 2000.
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4. This policy must be read in conjunction with: • Computer Misuse Act 1990 • Data Protection
Act 2018
5. It is your responsibility to report suspected breaches of security policy without delay to your
line management, the ICT department, or the DSL staff.
6. All breaches of information security policies will be investigated. Where investigations reveal
misconduct, disciplinary action may follow in line with This home Disciplinary procedures.
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33. DELEGATED AUTHORITY, NOTIFICATIONS AND

ON-CALL PROCEDURE
1 There are issues that all staff have a duty to report to either the Manager or senior person
on call who will then inform the Responsible Individual if required. This will ensure that the
duty of care to both young people and employees is appropriately discharged.
2 Should staff be in any doubt about reporting matters not listed below it is advisable to err on
the side of caution and report the issue to those listed above.
Absences
a. The unauthorised absence of any young person from the Home.

b. The failure of any young person to return as planned to the Home
Serious Accidents and Serious Injuries
a. To either a member of staff or to a young person.

b. To a member of the public at the home.
c. To a member of the public caused by a resident.
d. To a member of the public caused by staff whilst on duty.
e. Suffered by a young person requiring medical treatment.
f. Resulting in a young person requiring hospitalisation.
g. Resulting in the death of a young person, or member of staff whilst on duty.
Incidents
a. Involving a member of the public (including young peoples’ parents).

b. Resulting in serious damage to the fabric of the building.
c. Resulting in damage to property of member of the public.
d. Giving rise to a complaint from a member of the public.
e. Involving damage to the minibus.
f. Involving theft of property or money
Road Traffic Accidents
a. Involving young people at the Home.

b. Involving staff whilst on duty
Assaults and Sexual Activity

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a. Any serious assault by a young person on another young person or staff member
b. Any serious assault by a member of staff on a young person or staff member
c. Any incidents involving sexual activity by, or between young people
Substance Misuse
a. By young people where it is intended to report to the police

b. By young people resulting in their requiring medical attention
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Staffing Matters
a. The failure of any member of staff to report for duty

b. The failure of any member of staff to carry out reasonable instructions (including medication
error)
c. The departure of any member of staff from duty without authority or agreement
d. Racist, sexist or discriminatory behaviour by a member of staff either towards a young
person, staff member or visitor to the Home
e. Should staff feel that a situation warrants the need to invoke young person protection
procedures or to initiate police involvement with a young person staff are instructed they
must contact the Manager / Responsible Individual before either action is initiated. Only in
an emergency, when the immediate safety of staff or young people is an issue may the
police be called without this notification.
On-call procedure for This home
On call support is the arrangement of support from senior staff off site to support staff working on
shift. The support may be over the phone or in person in extreme circumstances (as described
above), however it should only be used as an emergency not for general enquires as it is important
that all staff have equal opportunity to have a positive work life balance.
Procedure for contacting on-call senior
 Check the rota for who is on-call

 Contact them on their work phone number, if no answer on their personal number. On-call
numbers at are the front of the diary.
 Be clear about the issue, what has happened, what you need support with, and any
questions related to the issue you have.
 Follow the direction of the on-call person, making clear notes in the log of what was
discussed, and direction given, and what you did
 If the on-call/ senior staff needs to escalate the matter, they will do that
 Only re-contact the on-call if essential or directed to do so.
Do’s
 Contact on call if there is a significant event, incident or injury such described above (and the
senior on duty feels they need to escalate)
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Don’ts
 Do not contact other managers who are not on-call outside their rota hours
 Do not continue to contact on-call with updates – unless directed to or the situations
changes, and more direction is needed
 Do not contact on-call for general information/ updates - only emergencies or significant
events
 Do not contact on-call to administering PRN medication – follow the care plan
 No not contact on call about rota requests, do that by email or during office hours
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34. REVIEWS
1 Each young person who is “looked after” is subject to Statutory Review. The initial Statutory
Review takes place 4 weeks after the young person becoming looked after; subsequent
review is at 3 months and further reviews after at 6 monthly intervals. In the event of an
emergency placement, the first Review will take place within 72 hours, then three months
and then six-monthly. The review dates are set by the social worker.
2 The purpose of the Statutory Review is to set a LAC (Looked after Young people) Care Plan
for the continuation of holistic care of the young person, to promote their welfare and to
routinely evaluate this plan through using the LAC Review of Arrangements Form and LAC
Review
Recommendations. The young people’s home’s Placement Plan should mirror the objectives set out
in the LAC Care Plan and LAC Review Recommendations and be updated at the same intervals. The
Placement Plan provides the detail of how this plan will be managed by staff at the young people’s
home on a day-to-day basis.
3 It is the responsibility of the allocated social worker to set up Statutory Reviews for the
young person and to invite the relevant people to attend. Young people must be asked who
they wish to attend the review and this must be considered by the social worker. It is usual
practice that the social worker, education representative, residential young person care
officers, senior care workers, keyworkers, manager, parent(s) and significant others and the
young person are invited.
4 It is also the social worker’s responsibility to provide the young person and carer/residential
unit with consultation documents to be completed prior to the review to inform the review
meeting. It may be that some young people need assistance in completing the consultation
form and this is the task of the key worker.
5 Key Workers must also complete a report to be presented to the Statutory Reviewing Officer
and all others present. It is important that this report is shared fully with the young person
prior to the review and changes that are felt pertinent made or, disagreement noted. The
Key Workers report must be shared with the Manager for endorsement.
6 Statutory Reviews can feel quite daunting for some young people, particularly if there are a
considerable number of people attending. They should have support of their Key Worker,
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advocate or mentor at the meeting to enable them to participate as fully as possible.

Participants should avoid the use of jargon to ensure that everybody is clear on what is being
said and decided. The Statutory Review is for, and about, the young person and every
encouragement and support should be given to them to enable their attendance and full
participation in decision-making affecting their lives.
7 The Review Meeting and subsequent documentation concentrates on making plans within
given timescales and identifying those individuals responsible for undertaking specific tasks.
The structure of each plan should be appropriate to each young person’s level of ability,
developmental level and consider the young person’s attainments and areas of
development. Management of risk should be developed in such a way that it ensures
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maximum opportunity for the young person whilst minimising the potential of the risk. The young
person must be fully aware of the plan and its objectives and should also actively contribute to its
construction.
8 Following each Statutory Review, the LAC Care Plan, LAC Review of Arrangement and LAC
Review Recommendations must be appraised and evaluated by the Key Worker and young
person and any relevant changes to the Placement Plan should be agreed and documented
and endorsed by both. The plan should have clear and measurable and achievable
outcomes. There should be clear evidence of participation of the young person in setting out
the plan and its objectives.
9 Once this has been completed the document should also be shared with the Manager and
endorsed by the same. It may occasionally be necessary for the placement plan to be
altered between Statutory Reviews. If this is the case, changes should be endorsed by the
young person, Key Worker and Manager and forwarded to the placing social worker.
10 The Home submit their own review reports to the Statutory Review.
11 The Home will ensure that the Local Authority will be contacted to request a review if this is
overdue.
12 The Home will also ensure that if a young person has not been visited by their social
worker within the time limits detailed in the Regulations, this will be raised at the next
review.
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35. DEALING WITH AGGRESSION AND VIOLENCE
1 The Manager and staff strive to create a positive, caring and appropriate environment for
the resident young people. Staff, through positive role modelling, training, supervision and
growing experience will convey a sense of wanting to form constructive relationships with
young people, and of wanting to care for them.
2 Generally, young people will behave within a setting they value and respect. Some young
people will seek to jeopardise positive relationships, either to test them out, through low
self-esteem, or lack trust in adults/those in authority. The whole staff group will strive to
create a positive ethos in which to care for young people drawing on their professionalism,
expertise and literature/training on the subject.
3 The young people will be involved in discussing the implications of negative behaviours
which demand staff intervention and methods of curtailing this behaviour thereby allowing
young people to make choices and have increased control over their life’s whist managing
any risk appropriately. This will take place both in groups and individually, informally and
formally. Individual discussion of behaviours will take place within the key work session and
as and when the need arises by all staff.
4 On arrival, young people placed at This home will be given a Welcome Pack, which
includes the house rules, sanctions and rewards. It is important that staff and young
people clearly understand which behaviours are acceptable and those which are not.
5 Group discussions allow young people and staff an opportunity to discuss values and define
what acceptable and unacceptable behaviour is and examine the consequences of both.
This will take place primarily at House Meetings. The young people will be encouraged to
take responsibility for their actions and behaviours as part of their emotional development.
Compromise and negotiation should be key factors in managing behaviour where
management of risk allows this to be the case.
6 It is imperative that the staff are aware of the histories of the young people they are caring
for and in turn this should influence their behaviour, attitude and responses to individual
young people. They should also be aware of any care plan issues that deal with the care and
control of young people who present particular behavioural difficulties. Also, staff meetings
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and handover meetings will discuss individual and group behaviour by the young people and
develop strategies for the management of such behaviour.
7 Staff, through training, literature and knowledge of young people should be encouraged to
detect early signs of tension in the young people which may lead to disruption or negative
behaviours.
8 Staff should work as a team to ensure good communication and understanding of specific
roles to gain confidence in working alongside one another. Staff should, as a team, discuss
methods of diffusing potentially difficult situations which may include diversionary tactics,
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group meetings, privacy for young people, one to one attention of staff, explanation of
certain situations, giving young people choice, upholding young people’s dignity.
9 In a situation where a child’s behaviour requires staff intervention, where possible the initial
response should be through dialogue. It is important that the member of staff remain calm,
do not shout and reassure the young person that they are listening and taking the,
seriously. Staff may feel it necessary to reinforce this dialogue through actions such as
adopting a particular non-confrontational stance, standing in the way of the young person
(to prevent them
leaving), placing a hand on the child’s arm in a non-threatening manner, or in extreme cases the use
of restraint if the child, staff member or other young person is in immediate physical danger, or
where there is a serious risk to property. All of these are acceptable if their use is persuasive rather
than coercive.
10 On many occasions, staff presence is enough to deter continued difficult behaviour

accompanied by an appropriate look or statement this can encourage young people to
manage their behaviour within acceptable limits. Alternatively, it may encourage the young
person to discuss their behaviour or distress. On occasion, the young person may require a
period of time to ‘cool down’ and staff members should enable this. Staff will always try to
give a young person choice to manage their behaviour, and so retain control and dignity.
11 The application and maintenance of safe, consistent, understandable and predictable

boundaries will assist young people in managing their own lives more successfully &
encourage appropriate behaviours. There will always be occasions when boundaries are
temporarily disregarded such as an extension of bedtime, and additional excursion etc…
However, when they are disregarded, it should always be explained fully to the young
people why this is and that it is a temporary measure.
12 The staff team should differentiate between ‘one off’ interventions and repeated methods
of care and control. They must be able to show that the method of interventions is in
keeping with the incident. Staff should avoid tactics that will potentially escalate the
situations and be mindful of the child’s age and level of understanding when dealing with
conflict. Remember, you want the behaviour to stop, not to punish the child. Staff will
always work towards rewarding and/ or encouraging positive behaviours to minimise
negative and difficult behaviours.
13 It is essential that after an aggressive or violent incident that the young person and the staff
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member be given the opportunity to discuss what has happened – a debrief session, in
order to express their anxieties, discuss alternative options and to achieve closure on the
incident.
The leadership and management standard
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36. RISK-TAKING
1 It is essential for young people placed at This home, as with anyone else in society, to take
calculated risks in order that they might move forward developmentally and grow in self-
awareness, self-confidence and self-worth.
2 It is the role of the staff team, collectively and through Key Work, to manage this risk safely
in consultation and partnership with the young person so as to not jeopardise the stability
and security of the young person or other young people in placement.
3 The management of the level of risk is further complicated as, for some young people, their
dysfunctional and disrupted histories have led to a distorted view of people and situations
and poor decision-making skills.
4 To this end, staff are required to analyse potential situations systemically in order to
minimise risk to staff and resident young people. A five-system approach has been adopted.
Identification of the risks.
 Who is at risk?
 What is the risk being presented?
 Describe the worst that can happen.
 When is it most likely to happen?
 How often is it likely to happen?
 Describe why the outcome is unacceptable?
 Who else is involved?
 Why and to what extent are they involved?
Assessment of the risks.
 What are the advantages to the young person taking the risk?
 What are the disadvantages of taking the risk?
 For whom is the risk advantageous/disadvantageous?
 What is the capability of the service provision (the Home) / the organisation?
Assessment of what is required to minimise the risks and maximise the opportunities.
 Do the advantages outweigh the disadvantages?

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 How can the advantages be increased?

 How can the disadvantages be decreased?
Agreement of how the risk taking will be supported.
 What resources will be needed to support the risk taking?

 How do these need to be organised?
 What are the behaviours required by staff?
 Who is going to communicate these required behaviours?
 Who has the authority to change the plan?
 What difficulties can be anticipated?
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 How are these going to be managed?
A review of what has happened
 When will the progress be reviewed?

 Who needs to be there?
 How will staff behaviour, collective or individual, attitude and assumptions be actively
challenged?
 Who and how will feedback be given to the young person?
 Who will update the risk assessment?
Risk assessment is on-going from the start of the young person’s placement and covers every aspect
of the young person’s placement. An assessment of risk informs the level, depth and speed of Care
Planning and Placement Planning. Risk Assessment will have a higher probability of success for the
young person if it is undertaken in partnership, if each risk is manageable and achievable.
The above process can be utilised by staff and young people to develop risk assessment strategies on
any level of projected undertaking
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37. DEALING WITH SEXUALITY AND PERSONAL

RELATIONSHIPS
1 Staff are advised that there are a number of factors related to working within a small
young people’s home that will have a bearing on the development of relationships with other
staff and with young people resident in the home.
a. Staff work closely together in a pressurised atmosphere. Staff rely totally on each
other in situations specific to this environment.
b. Young people placed within young people’s homes often have distorted experiences
of
what constitutes a caring relationship with adults?
c. Young people placed at This home are in often in their teenage years and,
regardless of any other difficulties, will be experiencing the rigours of
adolescence.
2 It is therefore essential that staff carefully consider the messages, verbal and non-verbal,
that they give to young people and clarify with the young person exactly what message has
been received. It is also essential that staff be particularly aware of the messages young
people are giving to each other.
3 With regard to managing sexuality and personal relationships, staff are advised to be very
clear and straightforward in their conversations with young people. This does not mean that
there is a need to be rude or distant, simply that there should be no margin for
misunderstanding. Staff will keep conversation on a professional level.
4 Staff will need to observe boundaries in their conversations with young people and not
provide the young person with too much detail regarding their personal lives, their
addresses or their telephone numbers. This is one area where young people can mistake
kindness for encouragement.
5 It is possible that a young person may develop a ‘crush’ on a staff member. Should this be
the case, it is essential that the staff member does not become defensive to this observation
but attempts to speak to the young person directly about the unfeasibility of the situation at
an early stage. The Manager will be made aware and a strategy put into place should the
situation develop further.
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6 It is not generally acceptable for young people to enter into relationships with one another
within the young people’s home on the basis that neither young person will have the
emotional maturity to either manage the relationship or the break-up of the relationship.
It is likely that the conduct of the relationship will be ultimately damaging for both
individuals.
7 Should a relationship between two young people within the Home develop, both placing
authorities will be informed and a Strategy Meeting will be called. The outcome of this may
be a Young person Protection referral, removal of one of the young people or perhaps, in
some cases approval. In any event, staff will need to prepare a direction to be taken so that
consistency and a professional approach be developed.
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8 Personal relationships between staff within the Home will be referred to the Responsible
Individual. As a rule, husband and wife/partner working is not encouraged but individual
circumstances will be reviewed by the Responsible Individual and the Manager.
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38. WORKING WITH PARENTS/CARERS

1 The Manager and Staff at This home are aware of the need for young people placed in the
Home to have regular contact with other adults and other young people in the best
interests of their social and emotional development.
2 Staff are reminded of the nature of the client group with whom they are working and are
advised that best practice in relation to the young people requires careful planning
surrounding the visit to ensure a positive outcome. Where appropriate, other young people
resident in the Home will be advised of the visit to alleviate anxieties regarding the presence
of strangers. Where appropriate, other young people resident will be introduced to the
visitor.
3 Staff are also aware of the damage that can be caused to the young person by visits that are
not permitted or the disruption and damage that can be caused to other young people by
visits that are not planned or that affect the running of the home.
4 In order to ensure this process runs smoothly;

a. All visits will take place in the downstairs communal areas of the house unless
previously agreed by the Manager.
b. All visitors are required to sign the Visitors Book.
c. All visitors will need proof of identity. In the case of school friends and other young
people visiting the child, parental permission for the visit on that particular day will
need to be given by the parent of the visiting young person in advance of the visit.
d. The duration of the visit and the level of staff support required and who will be
supporting the young person will be recorded in the diary.
e. In consultation with the senior member of staff on duty, staff have the right to turn
away visitors should they feel that it is not in the best interests of the young
person to receive a visitor at that time. Reasons might include the emotional
condition of the young person receiving the visitor, events in the Home at the time
of the visit or the condition of the visitor on arrival.
f. Similarly, staff are responsible for intervening in visits to the young person or
terminating the visit should the young person appear to be distressed. Staff will
monitor the visit as required to ensure both the young person and the visitor are
comfortable.
g. Staff may make notes if appropriate of the visit and the behaviour of the
young person following the visit.
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h. Staff will treat visitors courteously. Staff will not let any personal feelings towards
the visitor encroach on the visit. Staff will keep in mind that the visitor is important
in the life of the young person and his/her development.
5 Staff are advised that failure to follow the above protocols may lead to the safety and
security of the young person and other young people in the home being compromised.
Should this be the case individual staff may be subject to disciplinary action.
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39. MEDICATION STORAGE AND ADMINISTRATION

POLICY
1. Introduction and relevant other guidance
This home is a young people’s home, registered with Ofsted. The home provides support to young
people and young adults with disabilities many of who have medication but do not have the
understanding or skills to self-medicate so are supported in this by residential staff.
The following list of guidance has influenced the writing of this policy and related procedures.
 The Residential Care Homes Regulations 1984

 National Health Service Act 1977
 The Medicines Act 1968
 Misuse of Drugs Act (s 5[4]) 1971
 The Young people’s Homes Regulations 2001/2011/2015
 Boarding out Regulations 1988
 National Care Standards 2001
 Fostering Service Regulations 2000
 Mental Health Act 1983 and 2001
 Mental Capacity Act 2005
Medication includes prescribed medication, as well as over the counter remedies such as Calpol or
itch cream.
Prescription medication needs to be taken in accordance with the general practitioner’s instructions
as written on the prescription label. It is the responsibility of the staff member to ensure that
medications are administered appropriately.
For non-prescribed medication such as Calpol, this can be given based on guidance and consent from
parents/ guardians. However, if the young person uses other medications it is advised to also consult
the GP is case of the medications do not work well together.
Some medications may also require specialist advice and/or training prior to staff being able to
administer them. It is the responsibility of the Registered Manager to ensure appropriate numbers
of staff are trained on each shift.
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2. Training and competence of staff to administer medication

The Home as the staff member’s employer is responsible for making sure that staff has the
appropriate training to support young people with medical needs. Ideally this will be arranged in
conjunction with the Health Authority or other health professionals. Details of training required are
in the service training matrix and workforce plan. Detail of staff training compliance is also
maintained.
The Registered Manager shall ensure that all staff administering medication understand how to
record medication details and are confident in administering. Medication should be administered by
permanent staff where possible. Agency staff who have had the relevant training and understand
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the procedures can administer medication under a permanent staff’s supervision.
Staff Members need to be competent and aware of any allergies or any contraindications that could
affect a young person when medication has been administered. Staff must be prepared to follow
emergency protocols if required following any adverse reactions to medication, especially with newly
prescribed medication.
3. Signing in/ out of medication

When a young person comes to this home with medication, the duty senior member of staff (shift
leader) will ensure that they are checked and recorded against the medication log/record. They will
check and record in the medication signing in/ out book the following:
 the details on the medication are correct on the prescription label and match the young
person’s name, and the box/ bottle as required
 count the number of tablets or estimate how much liquid is in the bottle
 strength and dosage
 that the medication is in date
 signatures of members of staff sign and date medication receipt book
 staff check/ create a MARS chart for the medication
 details of any new medication are communicated to all staff
 registered manager to ensure prior to new young people starting if any medication
needs specialist training or storage
The senior staff on duty is responsible for ensuring that all medicines received onto the premises are
in good condition and not damaged in anyway. Where staff find a fault or are concerned, then this
must be brought to the attention of the appropriate manager (if not on duty then on call person)
If staff are unsure about any medication they must check immediately with the young person’s
parent/ guardian and senior on shift. If unable to contact any of the above, they must contact the
senior manager on duty and potentially the GP for clarification.
No medication is to be kept on site once a young person has left the home. When a young person is
going home or returning from a home visit, it is important that an accurate account is made of
medicine. This will include:
 counting tablets and/or how much liquid/cream is left

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 signatures of members of staff

This record must then be signed as correct.
4. Medication audits
Audits of medication will be completed regularly to ensure that medication is in date, stored
appropriately and that there are the expected levels of medication in place for young people.
Audits also ensure that enough medication is always on hand to give as required.
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Medication that has been prescribed for one young person must not be used for any other young
people.
Any issues identified during audit will be investigated by the Registered Manager.
5. Changes to medication
Only the young persons’ GP or Consultant can vary, cancel or change prescribed medication or its
dosage. Any change must be recorded, and a new prescription and label issued. Staff must not alter
labels on medicine containers.
Where the contact with the medical practitioner has been indirect, e.g., by telephone, the GP or
consultant must send written confirmation before the change is put into effect.
Any cancellation of medication must be clearly identified on the Medication Administration Record
Chart by drawing a line through the original entry so that it is still legible. The discontinuation date
must be recorded and initialled by the member of staff making the change.
6. Storage of medication
Medication is to be stored in the locked medicine cabinet or locked medicine fridge both in the staff
office. Some restricted medication will be kept in a separate locked medication cabinet with an
internal locked compartment also in this home office. The decision of which place is suitable is as per
individual storage guidance for each medication.
The cupboard/ fridge is exclusively used for medication and will always remain locked when not
being directly accessed. Every member of staff has access to the key to the office and medication
cupboard/fridge.
Medication will be kept separately for each young person in the medication cabinet. All medication
will be kept in its original packaging with prescription label. All medication is to be kept under
hygienic conditions, in a manner that protects it from loss, damage, theft and improper use or
deterioration.
7. Consent and capacity

Under the Mental Capacity Act 2005 the setting is required assess capacity before administering of
medication age 16 and over as they are considered to be capable of giving consent to medical
treatment and have the right to do so. This right cannot be overridden by a parent or person who
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has parental responsibility but can be overridden by the Court.
A consent form signed by the parent or guardian is required for medication to be given for young
people and young adults without capacity. This must be placed in the child’s file. This applies to all
medication, prescribed or homeopathic, daily and PRN (PRO RE NATA – or “when required”)
medication.
8. Encouraging young people to take medication

It is the right of any individual to refuse medication. Where a young person is not old enough or does
not have the level of understanding to reach such a decision, the consent of the child’s parent or
person with parental responsibility and relevant medical professionals must be sought about how to
encourage the young person to comply.
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Some young person may initially refuse medication but accept it on a second attempt or with
encouragement or coaxing. In these cases, it is acceptable to keep trying. If, however there is
significant delay from the time stated on the medication administration chart, this should be
recorded as refused.
In some cases, consent may be given from the GP and person with parental capacity to disguise
essential medication in food or drink. Where this is approved it must be clearly recorded in the
child’s file and on the medication, administration records (MARs chart). Wherever possible the young
person must be informed that medication is being administered within the food or drink.
It is important young people and young people are encouraged to take medication as the
consequences of not taking it could be serious;
 the young person may have physical discomfort

 the young person may experience anxiety or distress
 the young person may be a danger to themselves and others
 the young person may become unmanageable due to behaviour
 the young person may experience avoidable seizures
 many other potential issues
Some oral medication can be more easily administered through a plastic syringe without a needle
instead of a spoon. The best method for each young person needs to be specified in young
person’s care plan.
If the doctor prescribes a PRN medication, they must specify the circumstances under which it is to
be given. For example, is it for pain? Anxiety? Distress? or other circumstances? If in doubt, care
staff should consult the senior member of staff on duty.
9. Self-administration of medicines
Where there is a young person who normally self-medicates at home and school, to continue with
this level of independence a risk assessment will be completed with the young person, parent/
guardian.
Young people with capacity should know where their own medication is stored and who is
responsible for it. Medicines, such as asthma inhalers, must be readily accessible to young people.
Even if self-administering medication, the medicines will be stored in the medication cupboard/
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medication fridge and when self-administered will be witnessed and signed for by a member of staff.
10. Administration
Medication is to be administered by a trained, confident member of staff who has adequate time to
complete the task without distraction. The shift leader will be the person to administer medication,
with the witness being the child’s allocated staff member.
The shift leader will wear a red tabard whilst administering medication to ensure they are not
disturbed.
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The medication administration will:
 Give medication will be given to each young person in turn as prescribed

 They will identify a child
 Check the chart for what medication is to be given to that child
 They will take the relevant medication containers for the named young person and the
MARS charts from the medication cabinet to the child, they will lock the cabinet between
each journey.
 They will check the medication name, dosage and time of administration is the same on the
container and MAR charts for the named child
 The witness will also review the information
 If correct and due to administer, the medication will be dispensed as required
 If in tablet form it will be shaken from the bottle or pushed out from blister pack into a
medication cup and passed to the young person to take. If liquid use a clean syringe to
draw the appropriate amount, both staff check the drawn amount is correct.
 Do not touch the medication any more than essential i.e., to position in cutter
 If instructions are to conceal in food that will happen at this point as directed on the MARS
chart
 Both the administrator and witness observe the young person to see that the medication is
swallowed.
 This can be helped by offering a drink of water to assist the swallowing process and asking
the person to open their mouth to check if in doubt.
 Once taken, both staff sign the MARs chart, noting time of administration and code if i.e.,
if refuse
 This procedure of checking and administering is completed for all that child’s medication due
to be administered.
 The medicines administrator then returns all that child’s medicine to the locked storage
 Then the processes are started again for the next child.
PRN medication follows the same procedure, except that it may not be part of a medicines round as
it could be at any time.
11. Record Keeping

Each young person who requires the administration of medication, shall have a Medication
Administration Records (MARs) chart per medication showing the following;
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 Child’s full name

 D.O.B
 Address
 Any drug sensitivities
 Name of medication, Strength and form (tablet, liquid etc.)
 Dosage to be taken - written as e.g., 20mg and not in number of tablets
 Method of administration – oral, rectal, applied to skin, or in eye
 Frequency and the time of administration (am, lunch, dinnertime, pm).
 Date of prescribing.
 Any special requirements (e.g., to take with food, hidden in yoghurt etc)
 Space for record the time given.
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 The initials of the member of staff administering the medication and the member of staff
witnessing the medication
 Record key for Vomit, Refuse, Omitted, Hospital, Leave, (given in parental home)
This system will ensure that other members know why the medication was not administered and will
be essential in case of referral to a GP and also allow monitoring of the situation.
12. Errors in administration and or recording

If there has been an error in the administration of medication the member of staff must take
immediate action to minimise risk to the young person and to inform parents/ guardian of the issue
and the senior manager on call.
As soon as possible contact the lead doctor for advice, if there is any delay contact N.H.S. Direct 111
and follow their direction.
Staff must also have the following information to hand when contacting health professionals for
direction;
a. This home telephone number

b. This home addresses
c. Young person name
d. Young personhood
e. Detail of the medication error, type of meds how much was given/ missed, and when
f. Detail of any symptoms i.e., restless, sick etc
g. List of all medications prescribed
If a young person needs to attend A&E a member of staff must accompany the young person or young
person taken to hospital and must remain until other arrangements are agreed. Following the error,
the staff will complete a detailed incident report and make a note in the daily log.
The report must include the full record of the error taken place and the actions taken thereafter. The
Registered Manager will review the incident report and any learning coming from the incident and
where required complete a notification to the social worker, commissioner, health lead and to Ofsted.
The manager shall carry out regular checks to ensure the records and procedures are followed. If
there are errors in administration or recording, this will be investigated and addressed with the staff
member and the shift leader on duty. Repeated errors will be addressed through supervisions and
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ultimately disciplinary procedures.
13. Disposal of medication

Medication for disposal should not be kept on any premises for longer than is necessary it must be
return to a pharmacy for disposal. A record must be made in the medication in/ out book of any
expired medication disposal.
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This home Consent and Agreement for Medication Administration

The following section is to be signed by the parent/ carer/ guardian.
I authorise This home to administer medication as prescribed/ agreed with me to
(young person name) on my behalf.
I understand that I must take medicine from and return medication to This home if my young
person returns home for any period.
Name Signed:
Relationship to child: Date:
Emergency Phone numbers
The following section is to be signed by the Manager or Deputy Manager
I agree shall receive the medication as prescribed / agreed as per

This home medication storage and administration policy.
This agreement will continue until instructed by parents/guardian or young person over 16, where
they have capacity.
Where the service is instructed to discontinue administering medication, this is to be updated by

signing the section below.
Name Signed:
Role: Date:
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Consent removed instruction
I remove consent for This home to administer medication as prescribed/ agreed to
(young person name) on my behalf.
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Name Signed:
Relationship to child: Date:
Contact phone numbers
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MEDICATION LIST (EXAMPLE)

Medication name LAMOTRIGINE (Lamictal)
What for Anticonvulsant (Epilepsy)
Side effect Rash, blurred or double vision, headache, tremor or in coordination

(common)
Nausea, flu like symptoms, sore throat, bruising, swelling around face,
(rare)
Missed doses Take as soon as possible after missed time. If not taken until within 2
hours of next dose take the missing dose and miss the next dose.
Exceeding dose One unintentional extra dose is unlikely to cause ill health or side effects.
Large overdoses may cause sedation, double vision, loss of muscle

coordination, nausea, and vomiting. Call a doctor if a large overdose is
taken even if not side effects are seen.
Storage Keep in closed container in cool dry place (in medication cabinet)
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40. FIRST AID POLICY

1 The Manager and staff at This home are committed to ensuring a safe living and working
environment for those accommodated and employed at the Home. The Manager will
ensure that enough staff with first-aid training are available, with sufficient facilities, to
effectively manage accidents and injuries at work and to meet its statutory requirements.
This policy should be read in conjunction with the Health and Safety Policy. Staff should also
be familiar with the accident record books.
2 Equipment
This home has a first-aid box that is suitable and sufficient for the number of people using the Home
and the hazards they are exposed to. Only specified items will be kept in the first-aid box, i.e., no
creams, antiseptics, lotions or drugs. In addition, each vehicle attached to the Home must have a
suitable first-aid box. There should be verifiable arrangements for checking the maintenance of each
box. Containers should contain the following:
a. A general guidance leaflet on first aid
b. 20 individual sterile adhesive dressings (assorted sizes), detectable dressings (blue)
for the kitchen
c. sterile eye pads
d. sterile triangular bandages
e. safety pins
f. medium-size sterile unmediated dressings
g. large-size sterile unmediated dressings
h. disposable gloves and other personal protective equipment
The contents should be checked regularly for out-of-date items and replenished where
necessary.
3 Training
a. It is the responsibility of the Manager to ensure that enough numbers of staff
receive the relevant training.
b. First-aiders are defined as personnel who have received 3-days training, have passed
an examination in accordance with HSE requirements, and hold a current first aid
certificate.
c. Appointed persons are those who have undergone a 1-day emergency first-aid
course. Staff will be retrained as required and records of training will be maintained
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on personnel files.
d. All staff should be aware of their responsibilities and limitations, and when and how
to summon assistance. All staff should know the whereabouts of the first-aid box.
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4 Record keeping
a. All accidents, however minor, must be recorded in the Home’s Accident Book, of
which one will be for staff and one for young people. It is the responsibility of the
injured person or, in the case of a young person, a member of staff, to complete the
Accident Book as soon as practicably possible after the accident. If this is not
possible, it is the responsibility of the person in charge at the time.
b. Where relevant, accidents must also be recorded and reported under RIDDOR
regulations. If such an accident occurs, it must be reported to the Manager or Senior
member of staff on duty.
c. The Manager should be informed of all accidents occurring in their absence. The
Manager will decide if an investigation into the accident is required. A record should
be maintained of first-aid box checks and any action taken.
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41. COMPLAINTS PROCEDURE

The complaints procedure is available to all young people, their families and significant others. A
synopsis of the policy is included in the Welcome Booklet in an abbreviated form to ensure all young
people are aware of its existence. However, staff are fully aware of the policy and can explain this to
young people in a way they can understand. All complaints will be recorded on a Complaints Form
and a record will be held in the Central Complaints Log. In all cases where the member of staff is
subject to a complaint or investigation they are not permitted to investigate or consider the
complaint, incident or outcome.
1 The Manager and staff pride themselves on the quality care and support given to its young
people. However, if they do have a complaint, they can expect to be treated by the Home in
accordance with this policy.
2 Young people may at times have cause to complain regarding:

a. Bullying/violence from other young people.
b. Inappropriate behaviour by other young people.
c. Racial or sexual discrimination.
d. Theft of property.
e. Unfair treatment by staff.
f. Damage to facilities for young people.
g. Lack of consultation for young people/families/significant others.
h. Lack of agreed support by staff.
i. Inappropriate sanctions/restraint.
3 If young people, their families or significant others encounter any of the above or, if there is
any other issue, they feel warrants the making of a complaint, they will be encouraged to
follow the following procedure:
 Stage 1. Informal Resolution

We will encourage the young person to speak to a member of staff at the Home about the problem
and we hope that we will be able to resolve it as this early stage. At this stage, the person who is the
subject of the complaint may take part in its consideration. Whatever the outcome, the staff member
will record the complaint on a Complaints Form to be held on the young person’s file along with the
outcome and request that the young person endorses the recording and writes any comments that
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are applicable on the reverse of the form. The recording must then be shared with the Manager and
a copy placed in the personal file of the young person in order that analysis of complaints and any
appropriate changes can be monitored.
 Stage 2. If the complaint cannot be resolved at Stage 1, the complainant will be

encouraged to discuss the issue with their Key Worker or the Manager
This will be formally recorded on the reverse of the complaints form. If resolution can be found the
complainant will be required to endorse the recording and comment in if appropriate and the
recording placed in the case file.
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 Stage 3. Formal Resolution

If the complaint cannot be resolved at Stage 1 or 2 the complaint should be put in writing (with the
assistance of the Key Worker or Manager as appropriate) and should be sent to the Responsible
Individual, who will investigate the complaint and will speak, if necessary, to the complainant and
any other staff as deemed necessary. The Responsible Individual will reply, in writing, within 5
working days to the complainant and will, if appropriate, speak to the young person concerned to
explain his decision.
The Responsible Individual will keep a full record of the complaint and the outcome of his findings
on a Complaints Form and will ask the young person to endorse the recording and comment in if
appropriate and the recording placed in the case file. If appropriate, the Responsible Individual will
take advice from LADO
 If the young person has a complaint about the Manager, this should be made directly to
the Responsible Individual who will make the necessary investigations as at Stage 3.
 If the young person has a complaint about the Responsible Individual, this should be
made directly to the Manager who will investigate as appropriate and will take advice
from outside agencies as appropriate.
 If the young person, their social worker, parent or other significant person is not
satisfied with the outcome of a complaint made, they may, at any time or process of the
complaint, take this to HMCI. All complainants are free to contact HMCI at any stage of
the complaints process, however we would like to have the opportunity to look into it
thoroughly and resolve complaints as we take all complaints very seriously. A member of
staff or the Independent Visitor will be able to assist the young person in contacting
HMCI either in writing to:
a. Ofsted, Piccadilly Gate, Store Street, Manchester. M1 2WD or by telephone: 0300
123 1231
4 At no time will a young person be penalised for making a complaint in good faith, regardless
of whether or not that complaint is upheld.
5 Where appropriate, young people will always be encouraged to discuss their complaint with
parents / guardians / social workers or advocate. Staff in the Home or the Independent
Visitor who will assist the young person throughout.
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6 Following the resolution of a complaint, young people will be offered support, regardless of
whether the complaint has been substantiated.
7 A written record of complaints will be retained within the Home and will be regularly
reviewed to ensure that any patterns are readily identified, and any necessary action taken.
These records will be made available to the Regulation 44 Inspectors and HMCI upon
request.
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8 Anyone wishing to make a complaint can find the relevant contact details for the manager
and responsible individual on the first page of this document and these are also in the
Young people’s guide.
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42. SMOKING POLICY AND ALCOHOL POLICY

1 In respect of the law regarding tobacco, it is illegal to sell tobacco products to anyone under
the age of 18.
2 In respect of alcohol the law is more complex. Generally, under the Licensing Act 1964, it is
an offence for a young person under the age of 18 to purchase, or attempt to purchase
alcohol, or consume alcohol on licensed premises.
3 All staff at This home will be aware of the health risks around the use of alcohol and
tobacco. In the case of tobacco, the risks are from smoking-related diseases although there
is clearly an evidenced risk through passive smoking for those who do not smoke. In the case
of alcohol there are, again, a number of alcohol-related diseases and the issue of
dependency as well as uncontrolled, disorderly and dangerous behaviour that are associated
with intoxication at high levels.
4 There is a clear responsibility on staff to discourage young people from use of both tobacco
and alcohol use, particularly where dependence is an issue. Some young people resident at
the Home will already have established a pattern of tobacco and alcohol use which may also
be a significant means of their way of coping with stressful and difficult situations. It is
appropriate to consider changing this pattern of behaviour, but this has to be done in
conjunction with recognition of the impact on the individual. Staff should help young people
develop alternative strategies for coping and support them fully in minimising or ceasing
their use of both substances.
5 Additionally, support, help and guidance can be gained from health professionals in assisting
young people in reducing or ceasing their intake. Staff will accept the responsibility of
supporting young people in developing healthy life styles and encouraging a responsible
attitude to alcohol and tobacco use. Additionally, it must be pointed out to all young people
that everyone has the right to live and/or work in a smoke free environment.
6 Where young people insist on smoking, or have difficulty in minimising/ceasing their intake,
the Home will provide a space for the exclusive use of smoking. In all cases, young people
who smoke should be encouraged in ensuring that disposal of cigarette/tobacco packets is
done and that they ensure ashtrays are emptied and cigarette butts are appropriately
discarded and cleared away at the end of each evening with the assistance of staff
supervision.
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7 Staff should act in a positive manner discouraging young people from smoking and alcohol
consumption. They should also, where appropriate, point out the health risks to young
people of use of both substances.
8 Young people with an established pattern of alcohol or tobacco use will receive guidance
from their Key Worker, health professionals and staff on the reduction of their intake. These
plans will be incorporated in the young person’s internal Care Plan.
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9 Under no circumstances will staff smoke in the presence of young people whilst on duty.
Staff may only smoke during breaks, and not on the premises.
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43. DRUGS AND SUBSTANCE ABUSE POLICY

1 The Manager and staff strive to create a safe, warm and emotionally secure environment
within the Home. In order for staff to be able to achieve this and develop a family
environment within the home all anti-social behaviours from young people will be
challenged.
2 In line with this tenet, it is the policy of This home that there should be no drugs (except
prescribed drugs), alcohol or illegal substances on any premises owned, run or managed by
the company, whether consumed by young people, visitors or staff.
3 The Manager and staff are aware that ensuring drugs are not allowed on the premises only
goes someway to assisting young people in managing any difficulties they may have with
drugs. The Home is pro-active in providing solutions to assist young people manage any drug
problems they may have. These are listed below.
4 To ensure this policy is carried out in practice, all staff will be alert to the signs and
symptoms that young people are using and abusing drugs, alcohol and other substances.
5 Staff will aim to encourage positive attitudes among young people to help them resist
experimentation with drugs, alcohol or toxic substances. Staff will act as appropriate role
models. They will show disapproval and will provide, through Key Work, clarity about the
consequences for the young person’s future health.
6 Where young people are admitted who already use and abuse drugs, alcohol or other
substances, referral for professional help will be arranged in consultation with the young
person and any desired support to help them give up the practice will be forthcoming.
7 Young people with drugs on the premises: If the substances involved are not illegal but are
being used inappropriately, then the young person will be asked to hand them in. The
relevant Social Worker will be informed.
8 If a pattern of substance abuse or persistent abuse of alcohol is identified and where the
health of the young person is deemed to be at risk, the following action will be taken:
a. The Social Worker and parents / significant others (as appropriate) will be informed.
This will include details of the action taken or proposed.
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b. Support and guidance will be offered to the young person(s) involved.

c. A referral to counselling and relevant health awareness bodies will be arranged in
consultation with the young person.
d. A Planning Meeting will be held to discuss causes of the problem and the way
forward.
9 Should the substance abuse involve the use of drugs then the following procedures will
apply:
a. The young person would be asked to hand in any cannabis thought to be in their
possession.
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b. If they do so, the drugs will be confiscated, witnessed by two members of staff, if
possible, in the presence of the young person.
c. Advice will be sought from the Responsible Individual as to the proper disposal of
the drugs.
d. The local police will be contacted on each occasion.
10 Should the young person refuse to comply with reasonable requests to hand in illegal
substances, or if it is suspected that there are amounts on the premises:
a. A room search will be instigated in line with the policy of the Home.
b. After consultation with the Responsible Individual, the Police will be informed and
asked to intervene if deemed appropriate.
c. An Incident Form will be completed.
d. The young person will have the opportunity for de-brief.
e. OFSTED may be informed if deemed as ‘serious’ by the Manager.
f. The Social Worker will be informed.
11 In the event of serious drug, alcohol or substance misuse where the young person
is obviously unwell, then the following procedure will apply:
a. Staff will try to ascertain the substance and amount taken by the young person.
b. The hospital, GP or NHS Direct (111 /999) will be contacted and advice sought
having detailed what has been taken and how much.
c. The Manager and Responsible Individual will be notified.
d. The social worker and parents will be informed, if necessary, by contacting the out
of hour’s service.
12 Accurate and complete documentation are always maintained.
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44. GIFTS POLICY

1 The Manager and staff at the Home are aware of the conflicting issues of the need for staff
to build close interpersonal relationships with young people and issues of perceived
favouritism towards the staff member and the young person by other staff, residents and
visitors to the Home when gifts are exchanged between staff and young people.
2 The Manager and staff are also aware of the potential risks to staff that Key Work young
people in the misunderstandings that can come about for the young person receiving gifts
from a member of staff.
3 Therefore, in the best interests of the young people looked after at This home, and in the
best interests of staff employed at the Home, it is necessary to regulate the practices
surrounding the giving of gifts so that the same rules apply to everyone equally.
4 In this way we seek to avoid embarrassment and possible rejection as well as any issues of
probity and equity that may be levelled.
5 Staff are instructed to follow the guidelines below regarding staff giving gifts to young
people:
 Gifts will be purchased and given only by the Manager or Key Worker to the young
person.
 Gifts will be presented from the entire staff team and not any individual.
 Gifts will only be given for the following special occasions:
i. The young person’s birthday.
ii. Christmas or equivalent religious celebration.
iii. On leaving the Home for another placement.
 An agreed sum of money to be spent on gifts for young people will be decided by
The Responsible Individual of This home. The amount will be dependent upon age
and the nature of the event for which the gift is to be bought. This figure will be
reviewed annually and circulated to the Manager to inform staff.
 Gifts will be purchased with company monies. There will be no personal contribution
from staff. The agreed budget for gifts will be stuck to rigidly.
6 The guidelines regarding staff receiving gifts are thus:

 Receiving of gifts by staff is only acceptable:
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i. At Christmas or the gift-givers equivalent religious celebration.

ii. When the young person is leaving the Home for another placement.
iii. Staff will only accept gifts if their total value is less than £5.
iv. Any gifts received by staff will be declared to the Manager who will make a
dated entry on the personnel file of the member of staff.
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45. WHISTLE- BLOWING BY STAFF

1 This home is a professional service provider to social services departments countrywide.
The company provides childcare services to some of the most vulnerable young people.
The staff at This home seek to provide the best services to young people and their Placing
Authorities.
2 Staff are required to work to the highest professional standards. This is in order to protect
and promote the welfare of the young people cared for at the Home and also to promote
the best interests of the company within the social work field.
3 In order to achieve these aims, staff are charged with the responsibility to appropriately
challenge any and all other staff working within the resource if they feel that standards are
not being maintained and that young people are not receiving the highest DFE Quality
Standards (2015) relevant to this Policy. This may be in any area of service provision.
4 Normally, systems within the resource are sufficient to resolve any matters relating to staff
concerns. These include informal discussion, supervision, team meetings, and formal
meetings with the Manager and training days.
5 However, under no circumstances should any member of staff feel that their voice would
not be heard. For whatever reason, if a member of staff feels that they are not being heard,
or that they are unable to voice their concerns within the Home, they have an absolute right
(and will be encouraged) to contact any member of the Senior Management Team or the
Responsible Individual to discuss these concerns.
6 Should the staff member feel they are not able to talk to the Home Manager the Manager
will advise them accordingly and, if appropriate, support or advocate for the member of
staff.
7 At all times, personnel employed by This home will be mindful that the needs of the young
person are paramount and override any other concerns. Staff will remember that they are
employed to provide professional care; it is their professional responsibility to speak out on
behalf of disadvantaged young people.
8 Staff should only consider speaking to the HMCI- OFSTED Inspector (0300 123 1231) once
they have exhausted all avenues of speaking to the Manager, Responsible Individual,
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Independent Visitor or other Managers within the Group and given enough time and
opportunity for the matter raised to be resolved.
9 Staff have one further opportunity to report their concerns, to the placing authority and the
young person’s social worker. This option should only be considered once all avenues above
have been exhausted.
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10 Under no circumstances are staff employed by This home permitted to speak directly to
national or local press, press agencies or radio or television stations in connection with their
work, nor should they give interviews if approached by such bodies. This will be viewed as a
breach of company confidentiality and a breach of the confidentiality afforded
to young people living in the young people’s home. Any such breaches will be viewed as gross
misconduct under the disciplinary procedures.
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46. TRANSPORT POLICY

The Manager and staff at This home are fully committed to positively discharging their
responsibilities in respect of safe and secure transportation of young people and staff.
The Driving Staff
The following procedures will be/ are in place and maintained to provide safe transportation for
young people:
 On appointment staff will present management with originals of their driving licence. This
will be copied and held on personnel file. This will be renewed yearly.
 If staff receive any points or cautions on their licence, they are to inform Manager
immediately. A decision will then be made of the competency of that person to transport
young people, if they do not inform the Manager, it will then become a disciplinary action.
 All young people carried in vehicles will have their behaviours risk assessed.
The Vehicle
For safe and secure transportation of young people at This home, the following procedures
have been put in place:
 All vehicles will be maintained to high standard, this will involve regular servicing and checks
as well as ensuring cleanliness.
 If staff find vehicles have a defect, they are not to use the vehicle but must inform
management as soon as possible and the vehicle is to be repaired by professional garage
and work warranted.
 Any vehicle over 3 years old will have a yearly MOT.
 All vehicles will have safety belts /harnesses fitted, any special restraints will be itemized in
the young person’s care plan.
 Staff will not be required to use their own vehicles for the transport of young people.
Staff are to report any accidents in the vehicles to management as soon as possible. They are to
complete Accident Report Forms and, if necessary, Personal Accident Forms. These, together with
Incident Reports (if a young person is involved), are to be forwarded to the young person’s social
worker.
School and other transport (without This home staff)
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When young people are collected for school, they will be handed over to a known person, along
with any medication and personal items they require for the day. A home school contact book will
also be handed over. Any communications need to be verbally as well as written in the book. The
same happens on return to the home, a handover is received. Comings and goings are noted in the
log book.
Public transport
As part of our commitment to preparation for adulthood young people are support where
possible to use public transport. Risk assessment and care planning is in place to make this a
positive and valuable experience.
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47. Running Away or Missing from Home or Care

(RMFHC)
Staff at This home is proactive in assisting young people find other solutions to difficulties they are
experiencing rather than absenting themselves. Staff are concerned that vulnerable young people are
making themselves more vulnerable through these actions and thus adding to their difficulties. Young
people are offered key work sessions specifically about absconding in an attempt to channel their
anxieties into behaviours that are potentially less dangerous.
Notwithstanding this approach, for some young people, absconding is the only way that they can
manage their overwhelming problems initially. For these young people, staff attempt will to
minimise the risks associated with this behaviour by ensuring the young person knows the
difficulties and the consequences associated with absconding.
There may be occasions where the young person may attempt to run away to become missing, if staff
are to follow a young person, they must be aware of their environment and dangers, visible or
hidden, that potentially lurk. They must be aware of putting themselves in danger if they are near a
road or having to cross uneven ground such as a field.
In terms of staff managing absences the following procedure is in place and this has been drawn up
with reference to the RMFHC Guidelines outlined in the document ‘Statutory guidance on young
people who run away or go missing from home or care – June 2013’.
 As part of the admissions process a Missing Person’s Form will have been completed along
with a recent photograph of the young person. These will be placed on the young person’s
file ready for such an eventuality.
 A Placement Plan will have identified the risk management strategy for known behaviour
such as absconding. Within this plan the time-scale within which the young person must be
reported missing will be identified. Known addresses where the young person runs to will
also be identified along with contact numbers for all parties with a legitimate interest in the
welfare of the young person.
 The attitude and mood of the young person along with their dress for the day will have been
recorded in the young person’s Daily Support Plan
 When it is known the young person is absent without permission, an immediate search of
the premises and surrounding area will be undertaken. Other young people in the Home will
be questioned as to the missing young person’s whereabouts and possible ‘contacts’ will be
telephoned.
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 Staff will consult the prepared documents and follow the agreed plan as to whom to contact
and when. This will include The Police and those with parental responsibility (Social Services
and parent(s)) and the Manager on call at This home.
On the young person’s return, they will not be sanctioned for absenting themselves.
 Staff will ensure the young person is safe and comfortable and they will be offered hot food
and drinks, a bath and so on.
 A debrief with staff will be offered and a key work session will be set up sensitively. Also, a
“Return interview” for those “missing” young people (absent for longer than 12 hours) will
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offered and will be completed within 72 hours. (RMFHC protocol) taking into account the young
person’s needs with regards communication.
 All parties identified will be contacted regarding the young person’s return.
 The Police and social worker will be contacted with a view to visiting the young person.
 All information will be recorded on an Incident Form and emailed to the local authority with
care for the young person, parents if appropriate, within 24 hours.
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48. EQUALITY AND DIVERSITY POLICY

The Manager and staff at This home are committed to providing opportunity and anti-
discriminatory practice for all young people, their careers and families.
We aim to:
 Provide a secure environment in which all our young people can flourish and in which all
contributions are valid;
 Include and value the contribution of all carers / families to our understanding of equality
and diversity;
 Provide positive non-stereotyping information about different ethnic groups and people
with disabilities;
 Improve our knowledge and understanding of issues of equality and diversity; and make
inclusion a thread which runs through all of the activities in the Home
The legal framework for this policy
 DFE Quality Standards (2015) relevant to this Policy: Equality Act 2010
 Young people Act 1989 (amended 2013)
Methods
Admissions
 We advertise our service widely to Local Authorities.

 We provide information in clear, concise language, whether in spoken or written form.
 We will endeavour to provide information in other formats or in another language if needed.
 We base our admissions policies on fair system which is based on the needs of the
young person applying and of those already in our community.
 We do not discriminate against a young person with a disability or refuse a young person
entry to the Home because of any disability.
 We ensure that Social Workers, families and carers are made aware of our equal
opportunities policy.
 We develop action plans to ensure that all young people with disabilities can participate
successfully in the services offered by the Home.
Employment
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 Posts are advertised and all applicants are judged against explicit and fair criteria.
 The applicant who best meets the criteria is offered the post, subject to references and
checks by the DBS. This ensures fairness in the selection process.
 All job descriptions from the date of this policy will include a statement which specifically
requires a commitment to equality and diversity as part of their specifications.
 We monitor our application process to ensure that it is fair and accessible.
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Training
 We seek out training opportunities for staff to enable them to develop practices which
enable all young people to flourish.
 We review our practices to ensure that we are fully implementing our policy for equality and
diversity.
Activities
 The Home’s ethos and activities programmes encourage young people to develop positive
attitudes to people who are different from themselves. We will work to encourage young
people to empathise with others.
We do this by:
 Ensuring that young people have access to learning, taking into account their
communication and individual learning needs.
 Reflecting the widest possible range of communities in the choice of resources;
 Avoiding stereotypes or derogatory images in the selection of materials;
 Celebrating a wide range of festivals;
 Making young people feel valued and good about themselves;
 Creating an environment of mutual respect and tolerance;
 Helping young people to understand that discriminatory behaviour and remarks are
unacceptable;
 Ensuring that the activities offered are inclusive of young people with special educational
needs and young people with disabilities; and
 Ensuring that young people whose first language is not English have full access to the
activities and are supported in their learning and play.
Valuing Diversity in Families
 We welcome the diversity of family life and work with all families, carers and social workers.
 We encourage parents/carers / social workers to take part in the life of the Home and to
contribute fully.
 For families who have a first language other than English, we value the contribution their
culture and language offer.
Food
 We work in partnership with young people, families, carers and social workers to ensure that
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the medical, cultural and dietary needs of young people are met.
 We help young people to learn about a range of food, cultural approaches to mealtimes and
eating and to respect the differences among them.
Meetings
 Meetings are arranged to ensure that all families, carers and social workers can contribute
their views to the life of the Home.
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 Information about meetings can be communicated in a variety of ways – written, verbal and
in translation – to ensure that all parents, carers and social workers have information about
access to the meetings.
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49. THIS HOME DATA PROTECTION POLICY

This home collects and uses personal information (referred to in the Data Protection Act as personal
data) about staff, pupils, parents and other individuals who come into contact with the Home. This
information is gathered in order to enable the provision of care and other associated functions. In
addition, the Home may be required by law to collect, use and share certain information.
The Group is registered as a Data Controller, with the Information Commissioner’s Office (ICO).
Details are available on the ICO website.
Purpose
This policy sets out how the Group deals with personal information correctly and securely and in
accordance with the Data Protection Act 2018 and other related legislation.
This policy applies to all personal information, however it is collected, used, recorded and stored and
whether it is held on paper or electronically.
All staff involved with the collection, use, processing or disclosure of personal data will be aware of
their duties and responsibilities and will adhere to this policy.
What is Personal Information/ data?
Personal information or data is information which relates to a living individual who can be identified
from that data, or from that data in addition to other information available to them. Personal data
includes (but is not limited to) an individual’s, name, address, date of birth, photograph, bank details
and other information that identifies them.
Data Protection Principles
1 The Data Protection Act 2018 establishes eight principles that must be adhered to at all
times:
2 Personal data shall be processed fairly and lawfully;
3 Personal data shall be obtained only for one or more specified and lawful purposes;
4 Personal data shall be adequate, relevant and not excessive;
5 Personal data shall be accurate and, where necessary, kept up to date;
6 Personal data processed for any purpose shall not be kept for longer than is necessary for
that purpose or those purposes;
7 Personal data shall be processed in accordance with the rights of individuals under the Data
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Protection Act 1998;

8 Personal data shall be kept secure i.e., protected by an appropriate degree of security;
9 Personal data shall not be transferred to a country or territory outside the
10 European Economic Area, unless that country or territory ensures an adequate level of data
protection.
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Commitment
This home is committed to maintaining the above principles at all times. Therefore, we will:
 Inform individuals why personal information is being collected.

 Inform individuals when their information is shared, and why and with whom unless the
Data Protection Act provides a reason not to do this.
 Check the accuracy of the information it holds and review it at regular intervals.
 Ensure that only authorised personnel have access to the personal information whatever
medium (paper or electronic) it is stored in.
 Ensure that clear and robust safeguards are in place to ensure personal information is kept
securely and to protect personal information from loss, theft and unauthorised disclosure,
irrespective of the format in which it is recorded.
 Ensure that personal information is not retained longer than it is needed.
 Ensure that, when information is destroyed, it is done so appropriately and securely.
 Share personal information with others only when it is legally appropriate to do so.
 Comply with the duty to respond to requests for access to personal information, known as
Subject Access Requests.
 Ensure that personal information is not transferred outside the EEA without the appropriate
safeguards.
 Ensure all staff are aware of, and understand, these policies and procedures.
Complaints
Complaints will be dealt with in accordance with the Home’s Complaints Policy. Complaints relating
to the handling of personal information may be referred to the Information Commissioner
Review
This policy will be reviewed as it is deemed appropriate, but no less frequently than every year. The
policy review will be undertaken by the Responsible Individual or nominated representative.
Contacts
If you have any enquires in relation to this policy, please contact Colonel Keith Boulter, who will also
act as the contact point for any data requests.
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50. YOUNG PEOPLE’S RIGHTS POLICY

At This home, we believe that every young person has the right to be heard and to have a voice,
regardless of their ability to vocalise their thoughts and feelings. They have the right to an education,
to be healthy and to grow up in a safe and nurturing environment. These rights are enshrined in the
UN Convention on the Rights of the Young person which is a legally-binding international agreement
which sets out the political, economic, social and cultural rights of every child, regardless of their
race, religion or abilities. These basic, fundamental rights include:
 The right to life

 The right to his or her own name and identity
 The right to be protected from abuse or exploitation
 The right to an education
 The right to having their privacy protected
 The right to be raised, or to have a relationship with their parents
 The right to express their opinions and have these listened to and, where appropriate, acted
upon
 The right not to be forcibly recruited into the Armed Forces under the age of 18
 The right not to be sold into slavery
 The prohibition of young person sexual exploitation and pornography
We work with young people, their parents and carers, social services and other professionals to
ensure that the best interests of the young person are at the heart of everything we do. For non-
verbal young people, we use PECS and Makaton as a form of communication, and we will arrange for
a native speaker to be available should we have a young person with no English.
All young people are allocated a Key Worker who works closely with them and liaises with other
members of staff in the Home as well as with interested professionals. An Independent Visitor will
see each young person monthly and will act as an intermediary with the Home and at LAC Reviews
if required.
All young people within This home are automatically enrolled into the This home School or another
School or College if this is not appropriate for them. For those whose disability makes formal education
more difficult, a programme of ASDAN which promotes life skills, whilst also teaching basic numeracy
and literacy, is followed. Every young person has an IEP which is tailored to meet his specific
requirements and to ensure he achieves to the maximum of his ability.
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This home promotes and encourages relationships between the young person and his immediate
and extended family. We facilitate this by providing escorted transport to and from home and
supervised / supported contact. Parents, carers and other professionals are always welcome at
the Home and are encouraged to visit as often as they wish, either announced or unannounced.
Every young person in This home has the right to feel safe. They are cared for by caring and
dedicated staff who are well trained and supervised. If a young person needs to be restrained for
their own, or others safety, only NAPPI (Non-Aggressive Psychological and Physical Intervention) will
be used and staff are trained to use this technique and are updated regularly on its use.
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The Home, together with the placing Local Authority, will, at the outset, agree on the level of care
that each young person requires, and this will be monitored and updated as required. However, the
Home will not wait for a change of contract if it believes that a young person is not safe with the level
of care it is contracted to provide and will increase this, at its own expense, immediately if it is felt
that the young person no longer remains safe. A meeting with the LA will then be called to discuss
the continued use of this additional support.
Young people or young people are able to access additional support from the Young people’s
Commissioner
and information about this service is advertised within the Home.
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51. E-Safety Policy

Context
It is our duty to protect our residents against any form of abuse or exploitation. However, we are
challenged to do so whilst offering plentiful opportunities for our residents to use technology to
support them to become more independent, communicative, successful and active citizens.
In the main our residents have Autism that co-exists with other complex needs. This means that our
approach to the use of technology differs from some other Young people’s Homes as the level of
support our residents require to access technology is significantly greater in some cases.
There has been much in the national news around those with autism either ‘hacking into’
government websites all over the world precipitating legal action against them or radicalisation of
those with Autism towards terrorist/ other groups, therefore it is critical that staff are aware of their
responsibilities in this area.
Aims
 To ensure our residents have access to suitable technology and learn how to use it
effectively.
 To ensure that we support our residents to remain safe when using technology, especially
when accessing online spaces that enable information exchange, communication and social
media.
 To ensure that residents who have capacity to do so, adequately safeguard themselves when
using technology.
Supporting our residents to use technology safely

For those residents who have greater autonomy in using technology we must consider the following:
Sharing appropriate websites and materials
It is critical that any staff or volunteers thoroughly check any online materials they wish to share
with residents. This applies to all areas of the internet, but particularly those showing digital images
and videos that may carry inappropriate advertising or content.
Staff should always preview such resources to ensure they are appropriate for their audience.
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 Using the internet

Residents should be encouraged and taught to use the internet to find information or entertainment
resources and trained to search effectively. Awareness should also be raised regarding safe
searching, and discussions on reliable and unreliable information online should be regular.
 Search engines
Some common Internet search options carry risk, and residents should be taught to use these
resources (e.g., image searches) in a safe, appropriate way. This is also further
protected by the ‘firewall’ that protects both wired and wireless devices online.
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 Collaborative technologies
There are a number of Internet technologies that make interactive collaborative
environments available. Often the terms ‘Social networking’ or ‘social media’ are used. Examples
include blogs, wikis and podcasting. Using these technologies for activities can be helpful, can
develop communication skills, and can help residents build networks of their own. However, they
are high risk environments and it is essential that staff use them carefully and ensure that residents
understand the risks that they present.
 Webcam based activities

Webcams and iPad can be used to provide a ‘window onto the world’ to see what it is like
somewhere else. The value of this in terms of seeing activity/life in otherwise unreachable locations
is clear, however staff should always preview websites to ensure that webcam feeds and similar
resources are suitable. The highest risks lie with streaming webcams and often those linked to online
gaming, that residents use or access outside of the school environment. Whilst these are rarely used
by our residents, those who have autonomy need to be aware of the dangers.
 Social networking sites

These are a popular aspect of the web for residents. For residents who have a good level of
cognisance but may be non-verbal or physically limited this can expand their world significantly and
give them equity with their peers. Sites allow users to share and post web sites, videos, images, etc.
It is important for our more autonomous residents to fully understand that these sites are public
spaces with adult users. They are environments that should be used with extreme caution. Some of
these sites are blocked by our security settings, however residents need to be taught safe behaviour
as they may well be able to readily access them outside of the school day.
 Podcasts
Podcasts are essentially audio files published online, often in the form of a radio show, but can also
contain video. Users can subscribe to have regular podcasts sent to them and simple software now
enables young people to create their own radio broadcast and post this onto the web. These could
provide a valuable outlet for residents, but they must be treated with caution and residents must
understand their risks and how to report inappropriate use.
 Chat rooms
Many sites allow for ‘real-time’ online chat. Again, residents should only be given access to
educational, moderated chat rooms. The moderator (or referee) checks what users are saying and
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ensures that the rules of the chat room (no bad language, propositions or other inappropriate
behaviour) are observed. Residents should be taught to understand the importance of safety within
any chat room because they are most likely at risk out of school where they may access chatrooms.
 Digital photography and sharing platforms

These online platforms allow the sharing of digital images. It is vital that our staff and residents
fully understand that these are often public domains from where images can be taken, altered
and/or re-shared. They are also often platforms that allow/enable
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communication with strangers with no prior checking. These are not used in the school to any
extend, but residents may access them out of school on their own devices or in their family homes.
It is therefore critical that they understand the risks they present and how to report any concerns
they may have.
 Email
Email can be a significant aid to non-verbal residents and residents who are looked after. It can give a
voice to residents and can enable them to maintain communication with family and friends. Any
email received or sent onsite is subject to our security filter settings and is therefore safeguarded to a
degree for all users. However, residents who are able may set up e-mail accounts of their own and
therefore must know how to do so safely and how to report any concerns that may arise.
 Cyber bullying
We hope that our high levels of supervision would enable us to quickly identify and protect our
residents against cyberbullying. However, this may not always be the case and we must
acknowledge this fact. Cyber bullying is bullying through communication technology like mobile
phone text messages, e-mails or websites. This can take many forms e.g.
o Sending threatening or abusive text messages or emails, personally or anonymously.
o Making insulting comments about someone on a website, social networking site
(e.g., Facebook) or online journal (blog).
o Making or sharing derogatory or embarrassing videos of someone via mobile phone
or email.
In some cases, this practice may be illegal and should be reported as they may be covered under the
auspices of either the Harassment Act 1997 or the Telecommunications Act 1984 for example.
Responses to cyberbullying with autonomous residents
If a bullying incident directed at a young person occurs using email or mobile phone technology
either inside or outside of school time:
 Advise the individual not to respond to the message.

 Secure and preserve any evidence.
 Inform the sender’s e-mail service provider or social media provider if possible and request
the comments be removed if the site is administered externally.
 Notify Social Workers/ Parents of those involved, if it is residents in our care.
 Consider informing LADO and/or police.
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 Send all the evidence to CEOP at ww.ceop.gov.uk/contact_us.html.

 Endeavour to trace the origin and inform police as appropriate if possible.
Our use of digital images of our residents
Our website is subject to stringent content controls to respect both privacy and dignity of our
residents. Content to be submitted by staff to members of the marketing and web team, then
sanctioned by senior staff before going ‘live’.
 Residents’ images may only appear on the Home’s website if permission to use their
photograph online has been granted.
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 When showcasing examples of residents work in online, in displays or published formats use
only first names.
 Only use images of residents in suitable dress and situations to protect the dignity of all
residents.
 Links to any external websites are thoroughly checked before inclusion on website to ensure
that the content is appropriate.
 The Home has mobile phones/ cameras that can be used for trips offsite. Staff are directed
not to use their personal phone or camera without prior permission e.g., an activity day or
to record evidence offsite.
Roles and Responsibilities
This home has responsibility to provide the appropriate solutions for access to technology. This
includes the provision of hardware, software and appropriate security to safeguard users across the
Homes. The ICT team are also responsible for informing the leadership team of any suspected
breaches or inappropriate use or security affecting anyone on site that are identified by the system
and its associated monitoring.
Responsible Managers
It is the role of the responsible managers (Registered Manager) or their delegated officers, to ensure
that processes for investigating any allegations or suspicions of abuse of technology by staff or
residents is completed and dealt with as appropriately.
Designated Safeguarding Leaders
This home Designated Safeguarding Leader (DSL) is: Registered Manager
It is their role to ensure staff are trained on safeguarding matters, including e-safety and to be a first
point of contact for anyone wishing to raise a concern. It is then their responsibility to notify relevant
officials, professionals and/or families and decide upon next steps according to our process.
Responsibilities of All Staff and Residents

 All staff are responsible for promoting and supporting safe behaviours in their roles and
interactions with our residents and following E-Safety procedures.
 Staff are required to attend e-safety training.
 Safe use of the internet at school and home is discussed in classes and in the young people’s
home.
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 All staff should be familiar with the This home Acceptable Use and e-safety policies
including and be aware of:
 Safe use of e-mail.
 Safe use of Internet including use of internet-based communication services, such as instant
messaging and social networking.
 Safe use of the network, equipment and data.
 Safe use of digital images and digital technologies, such as mobile phones and digital
cameras.
 Publication of resident’s information/photographs and use of websites.
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 Cyber bullying procedures.

 Their role in providing e-Safety education or advice for residents.
 Their responsibility to report any misconduct or inappropriate use of the internet or related
technology amongst colleagues and visitors in line with This home Safeguarding and
Whistleblowing policy.
Dealing with Complaints
All complaints received regarding e-safety concerns or infringements will be dealt with initially in line
with our safeguarding policy and investigated thoroughly as a safeguarding concern. This may include
referrals being made to outside agencies including LADO and the police where appropriate.
Depending on the outcome of this investigation the following will be considered:
In the case of conscious inappropriate use by a young person, appropriate sanctions will be
considered such as removal of devices, further learning regarding e-safety or discussion and
agreement of sanctions with their family or local authority parent.
In the case of inappropriate use by an adult volunteer or employee this will then be considered
against This home Disciplinary policy for further action or investigation.
Where appropriate complainants will receive some feedback, but this may not always be
appropriate or possible.
DFE Quality Standards (2015) relevant to this Policy:
Regulation 5- Engaging with the wider system to ensure young people’s needs are
met he enjoyment and achievement standard
The protection of young people standard
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52. CODE OF CONDUCT (STAFF)

All staff will behave in a mature, professional manner towards clients, visitors, young people and
colleagues.
Differences in race, religion, sex, sexuality, culture etc... will be respected and derogatory remarks
are not acceptable.
Staff will be supportive towards one another and sensitive towards each other’s needs.
Staff will challenge any breach of the ‘Code of Conduct’ and will be supported be management and
colleagues as required.
Staff will listen to the viewpoints of all colleagues before deciding on any course of action.
In all decision making, the emphasis will be placed on knowledge, evidence, professional skills and
experience.
Discussions will not be contaminated with ego, power or personality issues. It is acceptable to
challenge the views and beliefs of others in a professional manner.
The outcomes of the decision-making process will be accepted and respected by all concerned and
will become the status quo at least until the date for review.
Staff will share their skills and knowledge and offer each other support and understanding especially
when difficult situations and challenges arise.
Staff will accept the responsibility and challenge of playing a ‘full’ part in the team.
Staff will be expected to attend and contribute to staff meetings. These meetings will be recorded the
individual not in attendance will be required to read and sign the produced minutes. It is the
responsibility of staff member to sign and date the minute upon reading the minutes when returning
back to their normal shifts.
Staff will accept responsibility for their own professional development and for updating their skills
and knowledge as required.
Staff will accept areas of delegated management as and when required and will willingly take part in
arrangements made for supervision.
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Staff with designated roles of key and co-worker will work in close liaison with each other and with
their key child, but NOT to the sole exclusion of other staff.
Staff are expected to adhere to the policies and procedures of the unit which are held in the
designated file and will take responsibility of updating themselves when amendments of additions
are added.
Staff are expected to read all correspondence in the Communication Book, and to sign next to what
they have read.
Requests for holidays will be made in the appropriate manner and with respect to the needs of their
colleagues and unit.
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Staff are expected to arrive at and leave work punctually, having given a clear and comprehensive
shift handover, making use of both verbal and written communication.
Any inability to work on shift due to illness or for any other reason will be reported to the Unit
Manager as soon as possible and every effort must be made to return to work as soon as possible –
your attendance matters.
Staff will assume responsibility for protecting their own health and wellbeing whilst at work with
regard to safety, hygiene etc...
Any staff member who is unsure as to what is required of them must accept responsibility for finding
out – if in doubt, ASK.
Never walk past bad practice:
 All people who work with young people are in a very responsible position which demands a
great deal of faith and trust being placed in their practice.
 Our clients are very vulnerable young people who may find it hard to complain about
issues that may affect their lives.
 It is vital, therefore, that we constantly question out own practice and the actions of our
colleagues in order to ensure that best practice is always promoted.
 Staff may act in a way that they believe to be right simply because that is the way it has
always been done and no-one has ever questioned why!
It may be appropriate initially to address the issue with the person concerned.
Every member of staff has an obligation to report any concerns regarding practice to their line
manager and, if they do not feel that the appropriate response has been made, to take the matter
further. For more information, please refer to the Whistleblowing Policy.
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SCHEDULE OF MATTERS RESERVED FOR APPROVAL

BY THE BOARD OF DIRECTORS
Stepping Stones Care Ltd (the “Company”)
Board of Directors (the “Board”)
Strategy and risk management
 Approval of SSC’s strategy and monitoring the delivery of this strategy.

 Approval of SSC’s risk management and internal control framework.
Structure and capital
 Acquisition or disposal of corporate entities or assets which are material in the context of
SSC.
 Issues of debt or equity to be undertaken by the Company.
 Material changes relating to the Company’s capital structure.
 Material changes to SSC’s corporate structure.
 Recommendation to shareholders for approval of any changes to the Company’s Articles of
Association.
 Approval of all circulars and prospectuses issued by the Company.
Financial reporting and controls
 Approval of interim and final results (including preliminary statements).

 Approval of the annual report and financial statements.
 Approval of any significant change in accounting policies or practices.
 Monitoring the decisions and processes designed to ensure the integrity of financial
reporting and sound systems of internal control and risk management.
 Approval of the annual operating budget and monitoring performance against budget.
 Appointment or removal of the external and internal auditors and determination of the
external and internal auditors’ remuneration.
 Approval of material changes to SSC Standing Orders.
Governance
 Determine the size, structure and composition of the Board.

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 Appointment and removal of any director of the Company.

 Executive succession planning.
 Approval of the membership of the Board committees.
 Approval of the terms of reference of the Board committees.
 Oversight of the annual Board and committee performance evaluation.
 Appointment and removal of the Company Secretary of SSC Ltd.
Policies
 Approval of SSC’s code of conduct.

 Approval of material policies relating to:
o safety, health and environmental issues relating to SSC;
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o anti-bribery and corruption;

o competition law;
o whistleblowing;
o the business ethics by which SSC expects to conduct itself.
Material tenders or potential contract awards
The following paragraphs provide details of material tenders or potential contract awards (each a
“contract”) which will be subject to a review of the Board.
 Contracts with a total award value to SSC of equal to or greater than £1m, whether on a
standalone basis or via a joint venture share; and
 Any other “high profile” contract (for example, a national project or a contract with a
potentially high reputational risk).
Other matters
 Notification and, where required, oversight of matters with significant safety, financial,
operational, commercial, reputational, legal, social or environmental implications.
 Notification and, where required, oversight of significant issues affecting SSC’s pension
scheme.
 Notification and, where required, oversight of the prosecution, defence or settlement of
litigation which is material in the context of SSC.
 Notification of insurance claims made or received which may be material in the context of
SSC.
 Any change to the matters included in this schedule.
Notes
(a) The above schedule indicates those matters which the Board specifically reserves to itself for
approval. The schedule is not, however, exclusive and does not derogate from the Board’s overall
duties and responsibilities.
(b) The Board may, at its discretion, delegate consideration and/or approval of any of the above
matters to a committee of the Board specifically constituted for that purpose.
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Modern Slavery Act 2015 Statement

August 2019
Introduction
SSC is a leading provider of residential young people’s homes. We operate under Ofsted registration
and care for young people on behalf of Local Authority clients. A full description of the business and
services we offer can be found on our website.
We have relationships with a number of sub-contractors and, every day, a significant number of
their employees will be working on our behalf, in addition to our own employees. We also rely on a
number of, suppliers and distributors which, in turn, will source products from their respective
supply chains.
Our policies
We have a number of policies that are designed to manage the risks relating to modern slavery and
human trafficking issues, including our Employee Code of Conduct, Responsible Procurement Policy
and Anti-slavery and Human Trafficking Policy. These set out our position of zero tolerance of
modern slavery and human trafficking in any form in our business and supply chain. We are
committed to acting ethically and with integrity in our business dealings and relationships and to
maintaining systems and controls designed to ensure modern slavery and human trafficking are not
taking place in our business or across our supply chain. Our Whistleblowing Policy provides a
mechanism for our employees and others working in our supply chain to report suspected breaches
of these policies.
We are aware that risks arising from modern slavery and human trafficking can apply anywhere in
our operations, whether through direct employment, sub-contracted employees or the supply of
materials. We expect our suppliers and subcontractors to ensure that there is no slavery or human
trafficking in their supply chain. Where issues are identified (including through our audit process) that
are not resolved to our satisfaction, we review the on-going nature of the relationship with that
relevant organisation.
Our approach to assessing and managing risk
1 We have a policy confirming our zero tolerance of modern slavery and human trafficking.
2 Our policies require that our sub-contractors and suppliers acknowledge their responsibility
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for adhering to our policies.

3 We have undertaken risk assessments to identify the key risks in our supply chain and
review those risk assessments regularly.
4 We have issued minimum procurement standards for certain, high risk categories of
materials and products. We keep these standards under review.
5 Our contractual terms include obligations on our sub-contractors and suppliers to comply
with our policies, including our Anti-slavery and Human Trafficking Policy.
6 Our policies require our subcontractors and suppliers to complete an assessment to confirm
that they comply with SSC’s zero tolerance policy.
7 We undertake checks on new recruits to ensure that they are eligible to work in the relevant
country of employment.
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8 We continue to deliver training to key employees on the risks of modern slavery and human
trafficking and our processes to mitigate these.
9 We continue to monitor the effectiveness of our actions against the risk of modern slavery
and human trafficking. This includes reviewing our policies and our procurement standards
and implementing an audit programme (see below).
10 We undertake audits of certain key supply chain partners to understand and validate the
controls in their organisations and provide an opportunity to learn from best practice.
Next steps
We will continue to monitor the effectiveness of our actions against modern slavery and human
trafficking.
Next steps will include:
1 Continuing to develop further standards to support our Anti-slavery and Human Trafficking
Policy (and related policies).
2 Keeping our pre-qualification standards for the appointment of new suppliers and
subcontractors under review.
3 Continuing to train employees on identifying any potential issues within our operations and
supply chain.
4 Updating the assessment of risks of modern slavery in our business and our supply chain.
This statement is made in accordance with section 54(1) of the UK Modern Slavery Act 2015.
Signed on behalf of the board of directors by:
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Business Ethics Policy

Introduction
Ethical business practice is one of the guiding principles of Stepping Stones Care Young People’s
Home (SSC). The SSC Board is committed to ethical business conduct and expects the highest
standards of integrity to be followed by all employees in each of its businesses wherever services
are delivered.
This Business Ethics Policy (“this Policy”) specifies the standard of behaviour SSC expects from its
employees, and others acting on its behalf, when conducting business on behalf of SSC. It applies in
addition to the other policies, procedures, codes and statements that have been issued by SSC
and/or its operating companies.
Business ethics and legal compliance
SSC requires all employees to conduct business with honesty and integrity. It is SSC policy to comply
with this requirement in all aspects of its business, and to ensure compliance by its employees and
agents with all applicable legal and ethical standards of each country, state, province or local
jurisdiction in which SSC business is conducted.
Duty to report non-compliance
If employees have knowledge of any activities which they have reason to believe may violate this
Policy, they must report such activities immediately. SSC relies on its employees’ vigilance to notify it
when something isn’t quite right.
Employees are able to raise their concerns with their line managers or business director. In addition,
SSC has a whistleblowing policy that provides details of external independent “hotlines” that can be
called to report concerns anonymously.
Conflicts of interest
The integrity of all employees must be capable of scrutiny at all times. While SSC respects the right
of employees to privacy in their personal activities and financial affairs, employees must not have
personal interests which conflict, or could conflict, with those of SSC.
Gifts and hospitality
All gifts and hospitality given or received by an employee must comply with SSC Gifts and Hospitality
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policy.
Improper payments
No employee may offer, pay, promise or authorise the payment of money or anything of value to
any other person where (s)he knows or believes that the money or thing of value will be improperly
given or promised in order to obtain, retain, facilitate or expedite business for SSC. No payments
may be made for the purpose of improperly influencing the action or decision of the recipient,
inducing the recipient to do or refrain from doing any act in breach of his or her lawful duty, or
inducing the recipient to exert influence on any foreign government or its department or agency.
SSC has a zero-tolerance policy to bribery and corruption.
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Compliance with laws prohibiting anti-competitive activity
SSC complies with all aspects of competition law. SSC policy and procedure to ensure no anti-
competitive contact takes place is available to all employees and rigorous training is undertaken
throughout the business. Potentially anticompetitive contact is reported.
Political contributions and activities
SSC makes no political contributions and is not affiliated to any political party.
Supplier relations
Our relationships with the people and organisations that supply goods or services to SSC are of
paramount importance. Suppliers are selected impartially, on the basis of price, quality,
performance and suitability of product or services.
Health, safety and environmental protection
Employees are responsible for conducting SSC business in a manner that protects the health and
safety of SSC employees and the public, as well as the environment. They should act at all times in a
manner that ensures SSC complies with all applicable health, safety and environmental
requirements. Please refer to SSC Health and Safety, and Environmental Policies.
Equality, diversity and inclusion
SSC values the diversity provided by gender, race, colour, ethnic or national origin, sexual
orientation, religion, or marital status. The principles and practices of equal employment
opportunity and workforce diversity contribute to the achievement of SSC business objectives.
Please refer to SSC Equality and Diversity Policy.
SSC expects its employees to maintain a workplace that is free from any form of discrimination,
harassment or bullying.
Human rights
SSC business activities are pursued with respect for human rights. As such, it needs to ensure and to
demonstrate that it treats all employees and contractors fairly, legally, with respect and with dignity.
SSC endeavours to operate in a manner consistent with the principles of the United Nations Universal
Declaration of Human Rights and the core International Labour Organisation Convention areas
(freedom of association, collective bargaining, non-discrimination, prohibition of young person labour
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and of forced labour).
We will not participate in, contribute to or obtain information from any blacklist or other similar
service which undermines these principles and as part of this obligation we will ensure that
compliance with our Equality and Diversity Policy, as well as this Business Ethics Policy, will form part
of the selection process for appointing subcontractors and other members of our supply chain.
Confidentiality
During the course of employment, employees may acquire information not generally known to the
public, including knowledge of a commercially sensitive nature, business plans or outlook, marketing
or sales programmes, customer lists, significant new services or price changes, mergers and
acquisitions, changes in management and other proprietary and confidential information.
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Employees must not disclose, during or after their employment by SSC, any non-public information
regarding SSC business or operations to any outsider unless disclosure is authorised in writing by
Senior Management.
Whenever possible, authorised third party recipients of SSC confidential information should be
required in advance to execute agreements acknowledging their confidentiality obligations to SSC.
The terms and conditions of employment for all employees make it clear that all information which
becomes available as a direct result of their employment is confidential to SSC and should not be
disclosed except as required in order to achieve SSC business objectives.
SSC undertakes to protect the personal data of all persons with whom it holds a record in
accordance with the Data Protection Act 1998.
Corporate governance
The SSC Board recognises the importance of high standards of corporate conduct and is committed
to managing SSC operations in accordance with the best principles of corporate governance as
contained within The UK Corporate Governance Code. The SSC corporate governance statement is
available on the SSC website.
Personal conduct outside the work place
SSC’s reputation depends largely upon its people and how they interact with stakeholders within and
outside the organisation as well as how they behave in the public domain outside their place of work.
Communications – government inquiries, investigations, consultations and lobbying
From time to time, SSC may be obliged to permit various government agencies to review certain of its
policies and practices. It is SSC policy to ensure that inquiries from government agencies are properly
handled to minimise SSC exposure and liability. In the event that copies of specific Group procedures
or practices are requested by representatives of government agencies or interviews with SSC staff are
requested; such requests should be handled in a manner consistent with such procedures or
practices. For non-routine requests by government representatives, that any such request be referred
immediately to the SSC Managing Director, Company Secretary and Compliance Director without any
further discussions with such contact.
From time-to-time SSC may present its position on a particular topic to government, or other official
bodies, whether during a review of policies/legislation, part of a consultation process or because of
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its expertise in a particular area. Consultation of this type may also occur through any of the trade
organisations to which it is a party. On other occasions, SSC may lobby on a particular issue to ensure
that the policy makers understand the issues fully and are therefore able to develop appropriate
policies.
In any of these circumstances, SSC and its employees will:
 Ensure that views put forward are fair, true and accurate and free from any personal bias
and that they represent the Company’s views;
 Not bring the Company into disrepute;
 Comply with the wider requirements of this Business Ethics Policy to report any conflicts of
interest and to act with honesty and integrity.
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 Communications – news media relations
It is important that inquiries from the news media are properly handled in order to maintain effective
public relations and to protect SSC competitive position and propriety information. Employees must
not discuss SSC business with any member of the news media, even on an informal basis. This will
minimise news stories based on rumour or unofficial “tips” which can be damaging to SSC best
interest. All requests for information from the news media (including, in particular, those relating to
financial or commercial matters) must be referred to SSC Company Secretary.
Communications – email, internet and social media
Employees are required to follow the provisions detailed in SSC Use of Business Systems Policy (and
related guidelines), as well as SSC Social Media Usage Policy (and related guidelines), when using
email and the internet.
Management has responsibility on a day-to-day basis for ensuring that access to the business
systems is used prudently. Managers must ensure that contract or temporary staff are informed and
familiar with these policies and that they agree to be bound by the terms listed.
Key issues with regard to the use of these IT facilities are:
 Misuse of email, internet or social media for personal communications;

 Risk of defamation by an individual or organisation;
 Bringing into the workplace via email, the internet or social media material of a racist,
pornographic, sexist, obscene, abusive, defamatory or other inappropriate nature or
material that may be in breach of copyright;
 Unwittingly creating a binding contract with a supplier, client, etc.;
 Knowingly introducing a virus to company equipment or forwarding a virus.
Other policies etc.
Elements of ethical business practices are referred to in many other SSC publications and several of
the topics raised in this Policy also appear in more detailed and defined policies, procedures, codes
and/or statements already in place within SSC. In this context, where any questions or doubts arise
over the interpretation of this Policy, please refer in the first instance to the appropriate subject-
specific policy (or procedure guidance, if applicable). Employees should also contact the SSC Legal
Department.
Other affiliated SSC policies and statements, all of which are available through the appropriate
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Departments, include the following:
 Whistleblowing Policy (and procedures)

 Gifts and Hospitality Policy
 Competition Law Policy and Procedures
 Counter-Fraud Policy
 Safety and Health Policy Statement
 Environmental Policy Statement
 Equality and Diversity Policy
 Information Security Policy – All Users
 Responsible Procurement Policy
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 Use of Social Media Usage Policy (and related guidelines)

 Anti-Slavery and Human Trafficking Policy
Further Information
If you have any questions concerning this policy or would like further guidance, please refer to SSC's
Code of Conduct.
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Anti-Bribery and Corruption Policy

Foreword
A good reputation is a hard-won asset which we must protect. Our ability to tender for new business
and our relationship with the full range of our stakeholders depends a great deal upon the good
reputation that we have established. This means all of us acting to the highest personal, ethical and
corporate standards in everything we do. It means making sure all our actions and decisions support
Stepping Stones Care’s (SSC) vision and values.
This policy is designed to help you understand not just the legislation relevant to bribery and
corruption but also to provide you with details of further help and training which you may need. I
encourage you to seek further guidance or assistance if feel you need it in any way. Your personal
contribution to protecting and enhancing our reputation by complying with this policy is important
to me and the SSC Board. It is only by each one of us individually being aware of the law and
complying with it that we can be sure we protect and enhance the reputation of SSC.
I am committed to this policy and would ask you to show your commitment too by reading it and, if
you have any queries or concerns at all, getting in touch as set out at the end of the policy.
Gurpreet Singh
Managing Director
For and on behalf of Stepping Stones Care Young People’s Home
Introduction
Our vision is “to be the provider of choice for local authorities in the sector”, and our success in this
endeavour is dependent upon how all employees behave. It is also our policy to comply with the law
wherever we operate.
In the UK, it is a criminal offence to offer, promise or provide – or request or accept - a bribe.
In the UK it is also an offence for a commercial organisation to fail to prevent an incident of bribery
being committed either by the company or by someone associated with it in order to obtain or
retain a business advantage.
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This means that bribery and corruption have absolutely no place at SSC – and why we operate a
strict no tolerance policy towards bribery in all its forms whether directly or through third parties.
This anti-bribery and corruption policy apply to all members of SSC – full and part-time employees
and temporary staff wherever we are based. It also applies to business partners who supply services
to SSC including agents and intermediaries.
We also rely on the services of contractors, sub-contractors and consultants, and here we only want
to do business with those who accept the terms of our policy or whose own policy sets standards to
match our own.
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This policy sets out our anti-bribery and corruption rules and explains what is expected of all SSC
personnel and associated persons – but we ask you all to do more than follow the rules. We want
you to act according to the spirit and the values they represent in whatever you do for SSC.
In this way we can achieve our vision together and help drive up standards throughout the sector.
Legislation
The Bribery Act 2010 (the ‘Act’) reformed the criminal law providing a new, modern and
comprehensive scheme of bribery offences that enable courts and prosecutors to respond more
effectively to bribery at home or abroad.
Key elements of the Act are:
 two general criminal offences which cover the offering, promising or giving of an advantage,
and requesting, agreeing to receive or accepting of an advantage
 a separate offence of bribery of a foreign public official
 an offence of failure by a commercial organisation to prevent a bribe being paid for or on its
behalf (the only defence is if the organisation can show it has adequate procedures in place
to prevent bribery).
You can find out more via https://www.gov.uk/government/publications/bribery-act- 2010-
guidance. Because SSC is a UK registered company, its subsidiaries, its directors and employees are
subject to the Act wherever you are located.
Throughout this policy “our”, “us” or “we” are references to SSC and its subsidiaries, unless the
context indicates otherwise.
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Anti-Bribery and Corruption Policy

Penalties for engaging in bribery and corruption
As befits a serious criminal offence, the penalties for engaging in bribery or corruption are severe.
Companies can face punitive fines and individuals can be fined and/or imprisoned.
As noted above, in the UK, the legislation incorporates a specific criminal offence for a company of
failing to prevent bribery committed on its behalf. We take this responsibility very seriously and this
is why we want to be associated only with those whose standards match our own.
A conviction for a bribery or corruption related offence could have severe penalties for our
reputation including exclusion from tender lists or being overlooked when bidding; loss of business;
or a decrease in investor confidence, all of which could have severe financial consequences for our
business.
Understanding and recognising bribery and corruption
Bribery and corruption can occur in many forms; so, understanding them and recognising when they
might occur is a key step in guarding against them.
Bribery is when a person offers, promises or gives a financial (or other) advantage to another person
with the intention of inducing or rewarding that person to act improperly (active bribery), or when a
person requests, agrees to receive or accepts a financial (or other) advantage to act improperly
(passive bribery).
Corruption is any form of illegal, dishonest or bad behaviour, especially by people in positions of
power.
In our industry, bribery could occur in situations such as tendering, appointing preferred suppliers,
contractors and agents, awarding licences and so on. Bribery and corruption can be found at all
levels from governments and government officials through to site operatives.
Wherever we work in the world – even where bribery may be seen as the norm - we must be clear
that we will not participate in or condone any form of bribery in our dealings whether with the
public or private sectors.
Bribes are not always a matter of handing over cash. Gifts, hospitality and entertainment can be
bribes as well as offers of employment or gifts to charities if they are intended to influence a
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business decision.
Transparency and openness are effective weapons against bribery, so be ready to challenge any
arrangements that compromise them. Even political contributions, charitable donations and
sponsorship arrangements can be used as a subterfuge for bribery.
Preventing bribery
Our ‘no tolerance’ of bribery relies on every person at SSC and our associated persons always
choosing to do the right thing. All this take is a few simple commitments:
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We will always:
 Comply with this Anti-Bribery and Corruption Policy

 Comply with company policies on gifts and hospitality, political contributions and charitable
donations
 Comply with our requirements concerning any conflicts of interest
 Record all activities and transactions accurately, completely and transparently
 Follow appropriate due diligence and risk mitigation procedures before proceeding with any
contract or other arrangement
 Seek advice if unsure how to proceed
 Report any suspected or actual breaches of this policy promptly and accurately to the
relevant SSC line manager or via the Speak Up Helpline
 Be alert to ‘red flags’ and immediately report or seek guidance about them
 Complete a bribery and approach record
We will never:
 Participate in any form of corrupt behaviour

 Use company funds, in the form of payments or gifts and hospitality for any unlawful,
unethical or improper purpose
 Authorise, make, tolerate or encourage, or invite or accept, any improper payments to
obtain, retain or improve business
 Permit anyone to offer or pay bribes or make facilitation payments on our behalf, or do
anything else we would not be permitted to do ourselves
 Offer or give anything of value to a public official (or their representative) to induce or
reward them for acting improperly in the course of their public responsibilities
 Offer or accept gifts or hospitality, if we think this might impair objective judgement,
improperly influence a decision or create a sense of obligation, or if there’s a risk it could be
misconstrued or misinterpreted by others
Understanding specific areas of risk
While high profile cases of bribery, involving large sums of cash and senior executives, are most
likely to hit the headlines, bribery can be a risk in many areas of our industry. It might take the form
of:
 Facilitation payments
 Kickbacks and reciprocal agreements
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 Corrupt third parties (including agents, consultants, contractors or sub- contractors)

 Excessive gifts and hospitality
 Inadequate financial controls or record keeping.
Facilitation payments are usually small payments (or gifts) made to public officials in order to speed
up or ‘facilitate’ actions the officials are already duty-bound to perform. We make no distinction
between facilitation payments and bribes, regardless of their size or the local culture.
The only exception is where a payment is extorted from an employee. If an employee feels coerced
or that their personal safety (or that of family or colleagues) is at risk, then they should make the
payment but report it immediately to their SSC line manager.
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Kickbacks and reciprocal agreements or any other form of ‘quid pro quo’ are never acceptable. We
will not participate in cartels, cover pricing, bid-rigging or any form of collusion. We will neither
accept nor make improper payments to obtain new business, retain existing business, or secure any
improper advantage.
Corrupt third parties can include a range of people acting on our behalf such as agents, consultants,
contractors or sub-contractors. We wish to work only with those who are committed to our
standards and will undertake due diligence to ensure this. We will engage a third party only when
there is a clear business rationale for doing so and with an appropriate contract. We will ensure all
payments made to third parties are properly authorised and recorded.
Excessive gifts and hospitality can be used to exert improper influence on decision makers. We will
only accept gifts and hospitality in accordance with our Gifts and Hospitality policy. We will ensure
any gifts or hospitality we offer are reasonable in terms of value and frequency. We will never offer
or accept gifts or hospitality if we feel it could influence a business decision or give the appearance
of doing so.
Inadequate financial controls or record keeping can be exploited to hide bribes or corrupt practices.
We will ensure we have robust controls in place so that our financial and other records are accurate
and complete and never misleading.
Disciplinary action
Bribery is a criminal offence which can lead to criminal penalties. But in addition, you have a duty to
SSC and breaches of this policy will result in prompt disciplinary action, up to and including
dismissal/termination of contract.
Statement of commitment
We will not tolerate any form of bribery or corruption.
This policy demonstrates the SSC Board’s no-tolerance approach to bribery and corruption. It will be
regularly reviewed and updated if necessary, as new threats appear.
This policy applies to the whole of SSC and as such should be seen as setting the broad rules and
guidance for all.
Further information
If you have a concern or suspect a violation of this policy, we want you to speak up immediately.
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Speaking up can be a difficult thing to do, so be reassured that all information received will be
treated seriously and investigated appropriately. If you act in good faith, believing your information is
accurate, we will protect you even if you are wrong. Some concerns can be addressed by speaking to
the person whose conduct is the cause for concern. We understand that this is not always possible,
so we suggest that you speak to your line manager. If, for whatever reason, you do not feel
comfortable doing this, you can contact any member of the Human Resources, Compliance or Legal
departments.
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Prevention of Fraud
Policy Statement
SSC does not tolerate fraud in any form or at any level. Employees who are proven to be involved
with fraud may be subject to the Company’s disciplinary process up to and including dismissal.
Introduction
The Board, have specific corporate responsibilities in relation to the prevention, detection and
investigation of fraud. However, they rely on the honesty and integrity of SSC’s employees to assist
them and, in particular, the active support of managers at all levels throughout the business.
This policy does not form part of any employee's contract of employment and we may amend it at
any time.
The ability to report concerns under this policy is open to use by staff, agency workers,
subcontractors, clients, other members of SSC’s supply chain and the general public.
Objectives
This Counter-Fraud policy outlines what fraud is, the measures that should be taken to prevent it
and how to report a suspected fraud.
Definition of Fraud
Fraud covers a number of areas but is essentially theft of company property by different means
including by use of deception.
This theft can be explicit, in terms of stealing cash, taking small tools, office stationery or scrap
materials. However, it can also be implicit such as:
 Agreeing inappropriate variation orders thus reducing profit to SSC for personal gain.
 Receiving personal payments or benefits from suppliers or sub-contractors in return for
preferential treatment.
 Theft of data, whether developed by someone in company time or proprietary data.
 Misuse of company credit, procurement or fuel cards.
Attempted thefts or frauds are treated in the same way as actual thefts and fraud and fall under this
policy. In addition, unexplained financial irregularities, particularly those in excess of £1K or
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anywhere misconduct is a possible cause also fall under this policy and need to be escalated
accordingly.”
This policy covers any fraud that could potentially affect SSC’s operations or put it at risk, including
those committed by:
 Employees, including consultants, contractors, agency workers and temps.

 Sub-contractors.
 Clients.
 Members of the public.
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Internal control
SSC maintain effective controls to prevent fraud and to aid prompt detection. These include:
 clearly defined operating guidelines and procedures including:

 segregation of duties
 robust procurement procedures
 appropriate levels of authorisation and approval
 objective tender assessment;
 assignment of tasks to specific roles/individuals
 clear communication of responsibilities
 physical and system access controls;
 regular review of actual results against latest forecast;
 a system of self-examination and self-certification of internal controls; and
 procedures and guidance issued with regard to the screening of new employees.
 A suite of policy, procedure, guidance and training on expected behaviour, including
induction training that covers this policy, whistleblowing, anti-bribery and corruption,
conflicts of interest, gifts and hospitality, corporate ethics, competition law etc.
The Board has responsibility for overseeing the effectiveness of the systems of internal control. The
Finance Director has responsibility for providing assurance with regard to the soundness and
adequacy of the system of internal control and risk management systems, and to recommend
improved measures where appropriate. Such assurance is partly based upon ensuring compliance
with the SSC finance procedures, applicable to all businesses and developed and maintained by the
Finance Director.
Locally, senior management and home managers are responsible for implementing and enforcing
these control mechanisms, providing annual assurance that the controls included within SSC’s
control self-assessment process are operating effectively. Employees are required to play their part
in identifying and reporting any control failures, for resolution whether or not a fraud has occurred.
Raising a concern
If you have a concern or a suspicion about the conduct of any company or individual, whether a
customer, competitor or member of SSC, you should speak up immediately.
Please don’t ignore it. Identifying an issue before it becomes a breach of law or before it is discovered
by others could help save SSC from severe penalties, further financial loss or reputational damage.
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There are 3 options available for reporting concerns, as follows:
 Reporting it to a member of SSC Compliance team is usually a good place to start, as this
team has a level of independence from the business.
 Raising the issue directly with line management or HR. However, the line manager or HR are
then required to report the matter to Group Compliance immediately.
 If you wish to report it anonymously, you can use the Whistleblowing facility operated on
SSC’s behalf by an independent third-party service provider. However, you should be aware
that remaining anonymous may make it more difficult to fully investigate matters without
the ability to clarify details with you. Thus, we would recommend that, wherever possible,
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concerns are raised directly with SSC Compliance instead. If you decide to use the helpline then
you can call any of the following numbers, free of charge (unless stated otherwise below) and in
complete confidence, any time of the day or night.
 If you are calling from the UK the number is 0808 915 1571
You can also make a report via the website: www.safecall.co.uk/report Where requested, you will
need to enter the alpha numeric code for SSC (5437).
Investigating Reported Concerns
Once concerns of this nature have been reported to SSC, they are considered, escalated and
investigated in line with the protocols set out in the organisation’s Whistleblowing Policy.
Predominantly, this involves Senior Management in the business, taking overall responsibility for
each investigation and ensuring they are completed appropriately in compliance with group policy
and the law.
The Whistleblowing Policy and other related information can be found at the end of this document
under the Further Information section.
Once concerns of this nature have been reported to SSC, the person who initially receives the
information is also responsible for immediately informing the relevant Finance Director in line with
SSC Standing Orders regarding financial irregularity.
Consequences
SSC takes fraud very seriously. If an investigation identifies sufficient evidence indicating fraud or
other wrongdoing by anyone working for SSC, a supplier or subcontractor, the matter will be
escalated for further appropriate action to be taken. For an employee, this is likely to lead to a
formal disciplinary case and, if wrongdoing is proved, the outcome is likely to be gross misconduct,
which normally results in summary dismissal. SSC may also seek formal recovery of any losses
incurred from any individuals or organisations who have committed fraud against SSC. Where
criminal activity is involved, the matter may be reported to the police.
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Supplier privacy notice policy

SSC is committed to maintaining the privacy of our suppliers. We comply with data protection laws
that are applicable in respect of data processing within the UK. SSC determines the purposes and the
manner in which personal data is processed.
This privacy notice sets out how we collect, use and protect your personal information and your
rights in relation to your information.
What type of data do we collect?
As part of our On-Boarding process it is necessary for us to collect and process personal data about
you.
 Categories of personal data that we collect include:

 personal details (for example, your name)
 your bank details and national insurance number
 your contact details (for example, your address, phone number and e-mail address)
How will we use your data?
Your personal data will be stored, processed and used by us in the following ways:
 To complete and improve the supplier On-Boarding process

 To send your data to third parties where appropriate (see details below)
 To administer payment processes
 To administer processes relating to the CIS scheme
 To answer your questions and enquiries
 To communicate with you and provide information about working with SSC
 To contact your emergency contacts when necessary
 To perform any investigations where required
Do we pass data to third parties?
We (or an agent working on our behalf) may pass your personal data to third parties for the purpose
of assisting with your On-Boarding and ongoing relationship with us. These third parties may include,
where applicable:
 Companies that perform background checks for us

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 Insurance brokers, insurance providers, loss adjusters and legal representatives

 Other organisations where we are required by law or where we are contractually required or
otherwise obligated to pass your information (such as HMRC or the Health and Safety
Executive)
We may pass your personal data to government bodies, regulators, law enforcement agencies,
courts/tribunals and insurers where we are required to do so, or to other organisations for the
purpose of making an assessment regarding any fraud matters.
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How is my data safeguarded?
The security of your data is important to us. Access to the data is only provided to our staff and
other third parties who need access for the On-Boarding, supplier compliance, management and
payment processes.
We have in place appropriate security measures to protect the security of your personal information
and keep it confidential. We review these measures regularly to make sure they remain appropriate.
We cannot guarantee the security of any third-party application you may use to transmit your data
(for example, internet browsers).
We may transfer and process your data outside of the UK. Where your personal information is to be
transferred outside the UK, we will take reasonable steps to ensure that there are appropriate
safeguards to protect your information.
We will keep your personal information for at least as long as we have a relationship with you or
anyone whose personal information you have provided. When deciding how long to keep your
personal information after our relationship with you has ended, we will keep your information for a
period of time taking into account our legal, professional and regulatory obligations as well as any
investigations that may arise.
On what grounds will you process my personal data?
We must have a legal reason to process your personal information. The information you provide will
be processed:
 to meet our contractual obligations to you (such as paying your salary into your bank
account)
 to meet our legal obligations (such as compliance with employment law or health and safety
law)
 to meet our legitimate interests to effectively maintain your services to us
 to assess your working capacity and, in some cases, for the provision of health treatment
Your information
You have rights regarding your personal information, including the right to access and correct your
information and, in certain limited circumstances, restrict or object to our use of it and to request
erasure of your information. We may need extra information from you to deal with any request. If
you would like to discuss or exercise these rights, please contact us.
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We encourage you to let us know of any changes to the information you have provided to us. If you
do not want us to process your data, then it may have an impact on our service arrangement and, in
some cases, remove your eligibility to work with SSC.
Should you have cause for complaint, please contact us and we will follow up to resolve this. If you
have a data privacy related complaint, you also have the option to direct your complaint to the
Information Commissioner’s Office (ICO).
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GDPR: GENERAL DATA PROTECTION REGULATION

POLICY
Retention of Personal Data (Policy)
1.0 INTRODUCTION
1.1 The GDPR defines “personal data” as any information relating to an identified or identifiable
natural person (a “data subject”). An identifiable natural person is one who can be identified,
directly or indirectly, in particular by reference to an identifier such as a name, an identification
number, location data, an online identifier, or to one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural, or social identity of that natural person.
1.2 The GDPR also addresses “special category” personal data (also known as “sensitive” personal
data). Such data includes, but is not necessarily limited to data concerning the data subject’s race,
ethnicity, religion, trade union membership, health, sex life, or sexual orientation.
2.0 POLICY
2.1 This Policy is designed to ensure that our Service sets out the specific purposes for which we hold
personal data on Service Users Staff and volunteers. The periods for which the data is to be retained,
the criteria for establishing and reviewing such periods and when and how it is to be deleted or
otherwise disposed of.
3.0 RETENTION OF PERSONAL DATA
3.1 The Service shall not keep personal data for any longer than is necessary in light of the purpose or
purposes for which that personal data was originally collected, held, and processed.
3.2 Different types of personal data, used for different purposes, will necessarily be retained for
different periods and its retention periodically reviewed.
3.3 When establishing and/or reviewing retention periods, the following shall be taken into account:
• The type of personal data in question;
• The purpose(s) for which the data in question is collected, held, and processed;
• The Services legal basis for collecting, holding, and processing that data;
• The category or categories of data subject to whom the data relates;

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• The retention periods stipulated by Ofsted.
3.4 If a precise retention period cannot be fixed for a particular type of data, criteria shall be
established by which the retention of the data will be determined, thereby ensuring that the data in
question, and the retention of that data, can be regularly reviewed against those criteria.
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3.5 In addition, the following defined retention periods, certain personal data may be deleted or
otherwise disposed of prior to the expiry of its defined retention period where a decision is made
within the Service to do so (whether in response to a request by a data subject or otherwise).
3.6 We will specify the retention period of personal data records and carry out disposal of data which
exceed the retention period in accordance with data protection. When any personal data has
served its purpose, it will be disposed of accordingly.
3.7 In limited circumstances, it may also be necessary to retain personal data for longer periods
where such retention is required by Ofsted, or other regulators or in the public interest. All such
retention will be subject to the implementation of appropriate technical and organisational
measures to protect the rights and freedoms of data subjects, as required by the GDPR.
4.0 RIGHT TO ERASURE (the "right to be forgotten")
4.1 Data subjects are entitled to require a controller to delete their personal data if the continued
processing of those data is not justified
4.2 Data subjects have the right to erasure of personal data (the "right to be forgotten") if:
• The data are no longer needed for their original purpose (and no new lawful purpose exists);
• The lawful basis for the processing is the data subject's consent, the data subject withdraws that
consent, and no other lawful ground exists;
• The data subject exercises the right to object, and the controller has no overriding grounds for
continuing the processing;
• The data have been processed unlawfully; or
• Erasure is necessary for compliance with EU law or the national law of the relevant Member State.
• In the event that any personal data that is to be erased in response to a data subject’s request has
been disclosed to third parties, those parties shall be informed of the erasure (unless it is
impossible or would require disproportionate effort to do so).
5.0 DISPOSAL OF PERSONAL DATA
5.1 When any personal data is to be erased or otherwise disposed of for any reason (including where
copies have been made and are no longer needed), it should be securely deleted and disposed of.
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PRIVACY NOTICE FOR EMPLOYEES/WORKERS

In accordance with the General Data Protection Regulation (GDPR), we have implemented this
privacy notice to inform you, our employees, of the types of data we process about you. We also
include within this notice the reasons for processing your data, the lawful basis that permits us to
process it, how long we keep your data for and your rights regarding your data.
This notice applies to current and former employees and workers.
A) DATA PROTECTION PRINCIPLES
Under GDPR, all personal data obtained and held by us must be processed according to a set of core
principles. In accordance with these principles, we will ensure that:
a) processing is fair, lawful and transparent
b) data is collected for specific, explicit, and legitimate purposes
c) data collected is adequate, relevant and limited to what is necessary for the purposes of
processing
d) data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased
without delay
e) data is not kept for longer than is necessary for its given purpose
f) data is processed in a manner that ensures appropriate security of personal data including
protection against unauthorised or unlawful processing, accidental loss, destruction or damage by
using appropriate technical or organisation measures
g) we comply with the relevant GDPR procedures for international transferring of personal data
B) TYPES OF DATA HELD
We keep several categories of personal data on our employees in order to carry out effective and
efficient processes. We keep this data in a personnel file relating to each employee and we also hold
the data within our computer systems, for example, our holiday booking system.
Specifically, we hold the following types of data, as appropriate to your status:
a) personal details such as name, address, phone numbers
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b) name and contact details of your next of kin
c) your photograph
d) your gender, marital status, information of any disability you have or other medical
information
e) right to work documentation
f) information on your race and religion for equality monitoring purposes
g) information gathered via the recruitment process such as that entered into a CV or included in a CV
cover letter
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h) references from former employers
i) details on your education and employment history etc
j) National Insurance numbers
k) bank account details
l) tax codes
m) driving licence
n) criminal convictions
o) information relating to your employment with us, including:
i) job title and job descriptions
ii) your salary
iii) your wider terms and conditions of employment
iv) details of formal and informal proceedings involving you such as letters of concern,
disciplinary and grievance proceedings, your annual leave records, appraisal and
performance information
v) internal and external training modules undertaken
vi) information on time off from work including sickness absence, family related leave etc
p) CCTV footage
q) building access card records
r) IT equipment use including telephones and internet access.
C) COLLECTING YOUR DATA
You provide several pieces of data to us directly during the recruitment period and subsequently
upon the start of your employment.
In some cases, we will collect data about you from third parties, such as employment agencies,
former employers when gathering references or credit reference agencies.
281
Personal data is kept in files or within the Company’s HR and IT systems.
D) LAWFUL BASIS FOR PROCESSING
The law on data protection allows us to process your data for certain reasons only. In the main, we
process your data in order to comply with a legal requirement or in order to effectively manage the
employment contract we have with you, including ensuring you are paid correctly.
The information below categorises the types of data processing, appropriate to your status, we
undertake and the lawful basis we rely on.
282
Activity requiring your data Lawful basis

Carry out the employment contract that we have Performance of the contract
entered into with you e.g., using your name, contact
details, education history, information on any
disciplinary, grievance procedures involving you
Ensuring you are paid Performance of the contract
Ensuring tax and National Insurance is paid Legal obligation
Carrying out checks in relation to your right to work Legal obligation
in the UK
Making reasonable adjustments for disabled Legal obligation
employees
Making recruitment decisions in relation to both Our legitimate interests
initial and subsequent employment e.g., promotion
Making decisions about salary and other benefits Our legitimate interests
Ensuring efficient administration of contractual Our legitimate interests
benefits to you
Effectively monitoring both your conduct, including Our legitimate interests
timekeeping and attendance, and your performance
and to undertake procedures where necessary
Maintaining comprehensive up to date personnel Our legitimate interests
records about you to ensure, amongst other things,
effective correspondence can be achieved and
appropriate contact points in the event of an
emergency is maintained
Implementing grievance procedures Our legitimate interests
Assessing training needs Our legitimate interests
Implementing an effective sickness absence Our legitimate interests
management system including monitoring the
amount of leave and subsequent actions to be taken
including the making of reasonable adjustments
Gaining expert medical opinion when making Our legitimate interests
decisions about your fitness for work
Managing statutory leave and pay systems such as Our legitimate interests
maternity leave and pay etc
Business planning and restructuring exercises Our legitimate interests
Dealing with legal claims made against us Our legitimate interests
Preventing fraud Our legitimate interests
283
Ensuring our administrative and IT systems are secure Our legitimate interests
and robust against unauthorised access
Providing employment references to prospective Legitimate interest of the prospective
employers, when our name has been put forward by employer
the employee/ex-employee, to assist with them
effective recruitment decisions
284
E) SPECIAL CATEGORIES OF DATA
Special categories of data are data relating to your:
a) health
b) sex life
c) sexual orientation
d) race
e) ethnic origin
f) political opinion
g) religion
h) trade union membership
i) genetic and biometric data.
We carry out processing activities using special category data:
a) for the purposes of equal opportunities monitoring
b) in our sickness absence management procedures
c) to determine reasonable adjustments
Most commonly, we will process special categories of data when the following applies:
a) you have given explicit consent to the processing
b) we must process the data in order to carry out our legal obligations
c) we must process data for reasons of substantial public interest
d) you have already made the data public.
F) FAILURE TO PROVIDE DATA
Your failure to provide us with data may mean that we are unable to fulfil our requirements for
285
entering into a contract of employment with you. This could include being unable to offer you
employment, or administer contractual benefits.
G) CRIMINAL CONVICTION DATA
We will only collect criminal conviction data where it is appropriate given the nature of your role and
where the law permits us. This data will usually be collected at the recruitment stage, however, may
also be collected during your employment. We use criminal conviction data to determine your
suitability, or your continued suitability for the role. We rely on the lawful basis of protection and
safeguarding of vulnerable young people to process this data.
286
H) WHO WE SHARE YOUR DATA WITH?
Employees within our company who have responsibility for recruitment, administration of payment
and contractual benefits and the carrying out performance related procedures will have access to
your data which is relevant to their function. All employees with such responsibility have been
trained in ensuring data is processed in line with GDPR.
Data is shared with third parties for the following reasons: for the administration of payroll, I.T.
maintenance and compliance in relation to maintaining registration of the young people’s home
with Ofsted.
We may also share your data with third parties as part of a Company sale or restructure, or for other
reasons to comply with a legal obligation upon us. We have a data processing agreement in place
with such third parties to ensure data is not compromised. Third parties must implement appropriate
technical and organisational measures to ensure the security of your data.
We do not share your data with bodies outside of the European Economic Area.
I) PROTECTING YOUR DATA
We are aware of the requirement to ensure your data is protected against accidental loss or
disclosure, destruction and abuse. We have implemented processes to guard against such.
J) RETENTION PERIODS
We only keep your data for as long as we need it for, which will be at least for the duration of your
employment with us though in some cases we will keep your data for a period after your
employment has ended. Some data retention periods are set by the law. Our retention periods are:
Retention periods can vary depending on why we need your data, as set out below:
76 years
K) AUTOMATED DECISION MAKING
Automated decision-making means making decision about you using no human involvement e.g.,
using computerised filtering equipment. No decision will be made about you solely on the basis of
automated decision making (where a decision is taken about you using an electronic system without
human involvement) which has a significant impact on you.
L) EMPLOYEE RIGHTS
287
You have the following rights in relation to the personal data we hold on you:
a) the right to be informed about the data we hold on you and what we do with it;
b) the right of access to the data we hold on you. More information on this can be found in our
separate policy on Subject Access Requests;
c) the right for any inaccuracies in the data we hold on you, however they come to light, to be
corrected. This is also known as ‘rectification’;
d) the right to have data deleted in certain circumstances. This is also known as ‘erasure’;
e) the right to restrict the processing of the data;
288
f) the right to transfer the data we hold on you to another party. This is also known as
‘portability’;
g) the right to object to the inclusion of any information;
h) the right to regulate any automated decision-making and profiling of personal data.
More information can be found on each of these rights in our separate policy on employee
rights under GDPR.
M) CONSENT
Where you have provided consent to our use of your data, you also have the right to withdraw
that consent at any time. This means that we will stop processing your data.
N) MAKING A COMPLAINT
If you think your data rights have been breached, you are able to raise a complaint with the
Information Commissioner (ICO). You can contact the ICO at Information Commissioner's Office,
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113
(local rate) or 01625 545 745.
O) DATA PROTECTION COMPLIANCE
Our Data Protection and compliance officer in respect of our data protection activities is:
289

Draft Safe Home-Shaping Lives - Policy and Procedures 27-02-2023

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Policies & Procedures

Semi-Independent Home Policies and Procedures

Allegations and Suspicions of Abuse - Reporting Concerns...................................................................55

23. THE SUPPORT OF YOUNG PEOPLE WHO HAVE BEEN ABUSED......................................................79

3. Signing in/ out of medication.................................................................................................116

Semi-independent provision - Key Principles

Semi-independent provision should foster positive relationships, encouraging strong bonds

Semi-independent provision should be attentive to young people’s need, supporting emotional,

Semi-independent provision should have high expectations of staff as committed members of a

Semi-independent provision should provide a safe and stimulating environment in high-quality

Other central HR policies and procedures

1. ADMISSION AND MOVING ON PROCEDURES

With regard to the administration of the young person’s admission:

With regard to the administration of a young person moving on:

2. Behaviour Management Policy

 Bullying or other similar behaviours

of tobacco, alcohol and drugs.

5. PERMITTED DISCIPLINARY MEASURES

3. The following are acceptable sanctions within the Home;

8. A Central Sanctions Log Book is held in addition to individual Sanctions Sheets.

6. RESTRICTIVE PHYSICAL INTERVENTION POLICY

4 Restrictive Physical Intervention should avert danger by preventing or deflecting a young

7. RECORDING OF FILES PERTAINING TO YOUNG

must record information as soon as is practicably possible. Recordings should be typed

8. CARE AND PLACEMENT PLANNING

4. The initial assessment will focus, broadly, on the following areas:

o Family and Social Relationships. This will comment on observations of interaction

9. USE OF EACH YOUNG PERSON’S PLACEMENT PLAN

10. COUNTERING BULLYING

4. Staff have an individual (personal) and collective (organisational) responsibility to challenge

e. Looking tired, stops eating, cries/flares up easily.

of posters, project work, review staff practices that might give

o In sanctioning the perpetrator

11. LOG BOOKS AND STATUTORY RECORDING

be recorded in each young person’s Daily Support log.

Matters relating to This home.

3. Such matters should be reported initially to the Registered Manager,

Matters relating to colleagues.

13. ADMINISTRATION OF FINANCE

14. REPAIRS AND MAINTENANCE

15. FIRE AND EMERGENCY PROCEDURES

9 Annual checks on gas appliances are carried out by a registered company.

16. COUNTERING RISKS ASSOCIATED WITH SIZE

17. HEALTH AND SAFETY POLICY

 General introduction to responsibilities under current legislation and how these

4 To ensure these arrangements are successful at operational level, we will provide:

including privacy, equipped with furniture, storage facilities, lighting,

7 In summary, we seek to:

COSHH (Control of Substances Hazardous to Health)

a. Report actual and potential hazards to the Manager or delegated representative.

6 This home instruct all employees:

RIDDOR (Reporting of Injuries, Diseases and Dangerous Occurrences

c. A Doctor reports that a staff member has a reportable, work-related disease.

occupational asthma, farmer’s lung, pneumoconiosis, asbestosis, mesothelioma; infections such

d. There is a dangerous occurrence. This is described as something, which happens

18. ROOM SEARCHES

19. SAFEGUARDING POLICY & PROCEDURES

We are committed to:

Purpose of this Policy and Procedure

Recruitment and Selection

Safeguarding Young people and Young People Against Radicalisation

Barring, Criminal Offences and Staff Suitability