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Safeguarding policy


  • Appendix 1: Contact details for Sunnybank Trust safeguarding officers

  • Appendix 2: Contact Details for Surrey Multi-Agency Safeguarding Hub (MASH) & Link to Alert Form

  • Appendix 3: Additional Information and Useful Links

  • Appendix 4: Additional Information and Useful Links

  • Appendix 5: Link to Easy Read Information for Vulnerable Adults




Sunnybank safeguarding contacts

1. Introduction – Purpose of this Policy

Our mission is to enrich the lives of adults with learning disabilities by promoting inclusion, fostering meaningful friendships, and enabling people to achieve equality and justice through the services and activities we offer.

Central to this mission is the need to ensure that the people we work with are able to live with dignity, treated with respect and free from fear and abuse of any kind. Through this policy, we acknowledge our duty to respond appropriately to any allegations, reports or suspicions of abuse, and to foster an environment in which everyone who is a part of the Sunnybank Trust feels valued and accepted and able to respond to any abuse issues that arise.

The policy is intended to assist staff, volunteers, service users, members and trustees, individual and collectively, to understand their responsibilities and duties, prevent or reduce the risk of abuse and act speedily and appropriately when abuse is suspected or encountered.

2. Adult Safeguarding within the Trust: Governance, Policy Review & Amendment and Communicating the Policy to Staff and Volunteers


It is the responsibility of the Board of Trustees to formally review and approve the Safeguarding Policy and subsequent amendments and to nominate a Safeguarding Trustee with direct oversight of the safeguarding process within the Trust.

The Board of Trustees will appoint a Lead Safeguarding Officer (LSO), whose duties are to oversee and manage the safeguarding process within the Trust, ensuring compliance with all national and local procedures, updating of the Trust’s safeguarding policy and procedures, and the provision of relevant safeguarding training.

The Lead Safeguarding Officer will appoint a Deputy Safeguarding Officer (DSO) to assist in the oversight and management of the safeguarding process.  (Note: The names and contact details of the Trust’s Safeguarding Officers and Safeguarding Trustee, together with contact information for Surrey Council’s Multi-Agency Safeguarding Hub (MASH) are provided in Appendices 1 and 2.)

Review and Amendment

This policy will be formally reviewed at 12 monthly intervals, and may be amended to reflect new guidance, legislation or relevant procedures at any time. Simple amendments (e.g. changes in contact details) may be made without reference to the Board.

All stakeholders within the Trust should provide feedback on the effectiveness of the policy and procedures and any issues that arise from their implementation, so that they may be refined and improved as needed.


Throughout this policy, the term ‘staff’ is used to refer to trustees, permanent and temporary employees, agency workers, contractors and consultants, volunteers (including, advocates, buddies, and supported volunteers), and students on placement within the Trust.

Communicating the Safeguarding Policy and Procedures

All staff working on behalf of the Trust, must read the policy as part of their induction, and when it has been amended. They must sign a register to confirm that they have read and understood it.

The Safeguarding Policy and related procedures will be referenced in Safeguarding Training provided by the Trust.

The Policy will be accessible to staff on the Sunnybank One Drive and to volunteers via the Sunnybank website or distributed in hard copy.

A ‘quick guide’ for employees and an easy-read version summarising this policy will also be available.

3. Context and Guiding Principles

The Sunnybank Safeguarding of Adults policy is part of a wider framework of national and local legislation procedures and guidance, which everyone at the Trust must comply with, as well as internal policies and procedures which complement each other to provide the highest level of protection possible.

These include: –

National Policies and Guidance

  • The Care Act 2014

  • The Mental Capacity Act 2005


The Deprivation of Liberty Safeguards (amendment to the Mental Capacity Act 2005)

  • The Human Rights Act 1998

  • Data Protection Acts 1998 and 2018

  • Safeguarding Vulnerable Groups Act (SVGA) 2006

  • Public Interest Disclosure Act 2013


Local Guidance and Procedures

  • Surrey Safeguarding Adults Multi-agency Procedures, Information and Guidance

(Note: links to further information and resources on National and Local Guidance are available in Appendix)

Sunnybank Internal Policies and Guidance

  • The Sunnybank Trust Safeguarding Children Policy

  • Equal opportunities policy

  • Code of Conduct for volunteers

  • Confidentiality Policy

  • Complaints Policy

  • Lone Working Policy

  • Anti-bullying and harassment

  • Whistleblowing Policy

Guiding Principles

In particular, the Trust’s Safeguarding Policy is founded upon the 6 key principles of safeguarding identified in the Care Act 2014. These are: –

  • Empowerment – presumption of person-led decisions and informed consent

  • Prevention – it is better to take action before harm occurs

  • Proportionality – proportionate and least intrusive response appropriate to the risk presented

  • Protection – support and representation for those in greatest need

  • Partnerships – local solutions through services working with their communities

  • Accountability – accountability and transparency in delivering safeguarding

4. Scope – Who and What is covered by the policy?

Who is the policy intended to safeguard?

The policy is intended to protect vulnerable adults. The Care Act defines a vulnerable adult as an adult at risk of abuse and neglect who may require safeguarding. The safeguarding duties apply to an adult (someone aged 18 or over) who: –

  • has needs for care and support (whether or not the local authority or the Sunnybank Trust is meeting any of those needs)

  • is experiencing, or at risk of, abuse or neglect; and

  • is, as a result of those care and support needs, unable to protect themselves from either the risk of, or the experience of abuse or neglect.

Who could be a source of abuse?

 The source of abuse or suspected abuse could be: –

  • A staff member of the Trust

  • A volunteer (including a supported volunteer) in any capacity within the trust

  • A person acting on behalf of the trust, such as an agency worker, a contractor, or a work experience student on a placement within the Trust

  • A member of staff or volunteer of another organisation, such as a care home, college or other charitable organisation

  • Another vulnerable adult, whether or not a member of the Trust

  • A friend, acquaintance or family member of a vulnerable adult

  • A member of the public

Who in the Sunnybank Trust must comply with the policy?

Every staff member, paid or unpaid, in any capacity, working on behalf of the Sunnybank Trust must comply with this policy, and take action in accordance with it.

5 Safeguarding in Recruitment

The Trust will make every effort to ensure that all staff whether paid or volunteer recruited, are suitable and present no risk to vulnerable adults. The recruitment process will include: –

  1. For employees:

The requirement for candidates to submit a comprehensive CV, covering all employment and including dates and explanations for gaps and periods of unemployment. Any gaps or discrepancies may be explored further in an interview or before a contract is offered

  • A formal interview with the minimum of two interviewers

  • A minimum of 2 satisfactory written references, upon which any offer of employment depends

  • An Enhanced DBS check for any staff member recruited to work directly with vulnerable adults

  • Induction training, covering adult and child safeguarding, codes of conduct and other relevant policies

  • A probationary period of six months for staff

  • For volunteers:

  • A formal interview with the Operations Coordinator

  • A minimum of 2 satisfactory written references, upon which any offer of employment depends

  • An Enhanced DBS check for any volunteer recruited to work directly with vulnerable adults

  • Induction training, covering adult and child safeguarding, codes of conduct and other relevant policies

  • A six monthly settling-in review

6. Safeguarding – Managing and Supporting Staff and members


All employees will receive Safeguarding Adults training within the first year of employment, which will be refreshed or renewed at 2 yearly intervals. This may be through attendance at courses or via e-learning.

Staff (including volunteers) supervision

Staff and volunteers will receive regular supervision (at a minimum of 6 weekly intervals) which will include health and safety, risk and safeguarding as a standing agenda item. A written record of supervision will be kept on Lamplight. For volunteers, this supervision may be face-to-face or by telephone.

Staff meetings

The agendas for all Sunnybank staff meetings will include safeguarding issues and concerns.

Raising awareness in vulnerable adults about safeguarding

The Sunnybank Trust will empower people to respond to the risk of abuse by providing information and regularly promoting awareness on these issues through its activities, talks, advocacy, self-advocacy group sessions, and via easy read materials provided by the Trust, Surrey Council and other sources.

This will include information on where and to whom abuse may be reported

7. Recognising abuse

It is vital for employees and members of the Trust to be able to recognise potential abuse in all its forms. The main types of abuse are listed below. (Note: links to further information and resources are on indicators and signs of each type of abuse are detailed in Appendix)

Types of abuse

  • Physical abuse – including assault hitting, slapping, pushing, misuse of medication, restraint or inappropriate physical sanctions.

  • Sexual abuse – including rape and sexual assault or sexual acts to which the adult has not consented or was pressured into consenting.

  • Psychological abuse – including emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, isolation or unreasonable and unjustified withdrawal of services or supportive networks.

  • Modern slavery – including forced labour, bonder slavery (based on debts that cannot be repaid), human trafficking, descent-based slavery, child slavery, and forced or early marriage

  • Financial or material abuse – including theft, fraud, exploitation, coercion in relation to an adult’s financial affairs or arrangements, including in connection with wills, property, inheritance or financial transactions, or the misuse or misappropriation of property, possessions or benefits.

  • Neglect and acts of omission – including ignoring medical or physical care needs, failure to provide access to appropriate health, care and support or educational services, the withholding of the necessities of life, such as medication, adequate nutrition and heating.

  • Self-neglect – this covers a wide range of behaviour neglecting to care for one’s personal hygiene, health or surrounding and includes behaviour such as hoarding. It is important to consider capacity when self-neglect is suspected. Also consider how it may impact on other family members and whether this gives rise to a safeguarding concern.

  • Domestic violence – psychological, physical, sexual, financial, emotional, and ‘honour’- based violence

  • Discriminatory abuse – including discrimination on grounds of race, gender and gender identity, disability, sexual orientation, religion, and other forms of harassment, slurs or similar treatment.

  • Organisational abuse – including neglect and poor care practice within an institution or specific care setting like a hospital or care home, e.g. this may range from isolated incidents to continuing ill-treatment.

  • Radicalisation – the process by which a person is led to support extremist and sometimes terrorist  ideologies

8. Responding to and recording concerns or suspicions about abuse

Any suspicion, witnessing, allegation or disclosure of the abuse of a vulnerable adult, whether or not that person has any relationship with the Sunnybank Trust, must be reported immediately in line with the escalation procedures below, and Surrey Council’s Safeguarding guidance, and a detailed record made.

In all cases whether or not the circumstances amount to abuse, the issue must be reported immediately to either the Lead or Deputy Safeguarding Officer, or to the Safeguarding Trustee if neither is available. This must be done whether or not the individual has consented to it.

The Safeguarding Officer or Trustee will make a decision as to whether the issue amounts to possible abuse, and, if it does, decide whether to report it to MASH. Reporting possible abuse to MASH must be done even if the individual has not consented, if any of the following circumstances apply: –

  • The person lacks the mental capacity to make that decision – this must be properly explored and recorded in line with the Mental Capacity Act

  • Other people are, or may be, at risk, including children

  • Sharing the information could prevent a crime

  • The alleged abuser has care and support needs and may also be at risk 

  • A serious crime has been committed

  • Staff are implicated

  • The person has the mental capacity to make that decision but they may be under duress or being coerced

  • The risk is unreasonably high and meets the criteria for a multi-agency risk assessment conference referral

  • A court order or other legal authority has requested the information.

How to respond when a vulnerable adult discloses a concern of abuse

If a vulnerable adult discloses possible abuse to you, you should respond sensitively and calmly to the person making the disclosure, making time for them, encouraging and supporting them to explain what their concerns are. Briefly, you should

  • Contact emergency services on 999 if you believe they are at immediate risk of harm or danger.

  • Be encouraging and reassuring that they have done the right thing in telling you

  • Let them know that you will have to inform a manager, and that the manager may have to report the issue to the Council’s Safeguarding Team.

  • Make detailed notes about the vulnerable person, including age, contact details,

  • Record whether they have consented, and whether, in your view, they have capacity to decide whether to consent.

  • Make notes about what occurred times, dates, places, whether there were witnesses, etc. Be objective, and record what they have said as far as possible in their own words. If they have communication difficulties, record where you have had to interpret what they are communicating.

  • Make detailed notes about the identity, age, location, etc. of the alleged perpetrator

  • Provide any other relevant information.

  • Report to a Safeguarding Officer within the Trust within 4 hours

9. Reporting of abuse originating or believed to originate within the Trust, including any of the following: employees, volunteers, adult students and others related to the Trust

What you need to do

When a suspicion, allegation or disclosure of abuse within the Trust arises, you must: –

  • Notify the police or emergency services immediately by calling 999 if the vulnerable adult is in imminent danger or may need immediate medical treatment

  • Within four hours you must contact the Lead Safeguarding Officer,   the Deputy Safeguarding Officer or the Safeguarding Trustee and notify them of the full details. If one of these is the subject of the concerns, you should notify the other Safeguarding Officer or the Safeguarding Trustee. Let them know whether or not the person has given consent.

  • Make a detailed record of the allegations, disclosure or observations of abuse (as indicated above in general guidance) and send this by password-protected email to the manager. (Identify the person by initials and confirm name separately by additional email or text). Do not enter the details in the Lamplight database.

  • Do not  discuss with anyone except a Safeguarding Officer of the Trust

10. What should the Sunnybank safeguarding lead or deputy do in the event of suspected abuse by a staff member or volunteer?

The Trust’s Safeguarding Manager must make a decision as to whether the issue constitutes abuse, and if so, it must be reported to the Surrey Council’s Safeguarding Team via MASH on the same day about the possibility of abuse on the same day that the abuse occurs,

The relevant manager should also consult with the Safeguarding Trustee (or in their absence, the Chair of the Board of Trustees) and agree immediate action to remove or minimise the risk of possible further abuse. This might include: –

  • Instructing the alleged or suspected abuser to refrain from contacting or meeting any vulnerable person or responding to contact initiated by a vulnerable person

  • Requesting the return of Sunnybank phones and relevant passwords,  and suspending email accounts and access to the Lamplight database

  • Suspending the suspected staff member/volunteer from work without prejudice  in accordance with relevant HR or disciplinary procedures

Once reported, it is for Surrey Council’s Safeguarding Team to decide whether an investigation is to be conducted and whether the Sunnybank Management team should carry this out.

Any further action taken will be in line with the Safeguarding Team’s instructions and procedures (see Appendix 5a).

11. Internal reporting procedure where suspicion, allegation or disclosure of abuse originates outside the Trust

If the abuse issue concerns individuals or organisations other than the Trust (such as a residential home, day centre or within a family), you must:-

  • Within 4 hours, notify the Lead or Deputy Safeguarding Officer of the Trust or the Safeguarding Trustee in their absence, who will decide whether the issue may constitute abuse, and whether to report the to the Safeguarding Team, with or without the consent of the vulnerable person.

  • Record the details of the allegation, suspicion or disclosure in the Lamplight database. The manager should enter the details if the employee does not have access to Lamplight).

  • Do not notify or share the disclosure with any the management or any member of an organisation, such as a care home, where the abuse may have originated, as this may endanger an investigation’s ability to capture or preserve evidence – this is for the Council’s Safeguarding team to do if they judge it appropriate.

  • If the Safeguarding Officer’s decision is that the issue must be reported, this must be done on the same day that the report has been received.

12. Further Action

Any further action will be decided by the Council’s Safeguarding Team, in line with their Council’s Safeguarding Policies and Procedures.

Any member of the Sunnybank Team or management who responded to or disclosed the safeguarding issue may be required: –

  • To give evidence to the Police

  • To give evidence in a Coroner’s Court

  • To be interviewed as part of a disciplinary investigation

  • To participate in a section 42 safeguarding enquiry

13. Support for all staff (paid and voluntary)

The Sunnybank Trust recognises that staff who must deal with or witness abuse may suffer from distress or feelings of guilt or anxiety, whether from the initial disclosure or from participating in any formal investigation. The Sunnybank Trust will make every effort to support and assist anyone in this position, through supervision, and counselling where necessary.

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