Safeguarding policy

If you are worried about somebody right now

If somebody is in immediate danger, call 999. Do not use a form, do not email, and do not wait to speak to us first.

An adult you are worried about

Call the adult safeguarding team at the council for the area they live in. The council leads safeguarding enquiries for adults — that is its job in law, not ours — and it can act whether or not the person is anything to do with Bluebell. Every council publishes the number for its own team, and most have an out-of-hours number too.

A child

Call the children’s services or safeguarding team at the council for the area the child lives in, or the police. We do not house children, but children live in and visit the households around us, and a concern about one is dealt with exactly as urgently.

A concern about a member of our staff or a contractor

Tell the council’s adult safeguarding team. You can do that without telling us, you do not need our permission, and you do not have to be sure.

TBD — the councils we work in. The local authorities Bluebell operates in, so this page can name each adult safeguarding team and link to it directly. Until then a reader has to search, which is a step too many for somebody who is frightened. Operations has to supply the list. Until then, searching for the council’s name with “adult safeguarding” reaches the right team.

You can also tell us, and we would rather you did — through any route on our contact page, or by telling any member of staff. But our enquiry form is not monitored around the clock, so it must never be the only place a concern goes.

What we are, and what that means here

Bluebell Housing is a supported housing provider. We source and manage homes and we provide housing-related support: help to keep a home, to manage money and benefits, to get to appointments, to live alongside other people, to move on.

We do not provide personal care. Nobody here washes, dresses, feeds or gives medication to a resident. Personal care is a regulated activity and has to be delivered by an organisation registered to do it; where somebody needs it, it comes from a provider commissioned separately, and we work alongside them.

That boundary matters for safeguarding in a specific way. Our staff are in people’s homes, often alone, often with the only regular sight of how somebody is actually living. A support worker, a housing officer or a repairs operative is frequently the first person to notice that something is wrong — and the first person a resident tells. So every one of them is expected to recognise abuse and to act on it, whatever their job title.

The principles we work to

Six principles govern adult safeguarding. They are not slogans; each one constrains what we may do.

Empowerment

People lead decisions about their own lives, and are asked what they want to happen.

Prevention

Acting before harm happens is better than responding after.

Proportionality

The least intrusive response that meets the risk. Overreacting takes away somebody’s life as surely as underreacting fails to protect it — and in housing, overreacting often means somebody loses their home.

Protection

Support and representation for those in greatest need.

Partnership

Working with councils, health services, the police and communities.

Accountability

Being answerable for what we did and did not do.

In practice this means making safeguarding personal: we start from what the person wants to happen, not from a process. We would only override that where they lack the capacity to make the decision, or where somebody else is at risk.

The ten kinds of abuse we look for

All ten are named because a list that stops at the obvious ones trains people to miss the rest. In supported housing, financial abuse, self-neglect and exploitation by people who have got into somebody’s home are the three most often missed.

Physical abuse

Hitting, restraining, misusing somebody’s medication, or withholding help.

Domestic abuse

Including coercive control, and including abuse by a partner, an ex-partner or a family member who does not live there.

Sexual abuse

Any sexual act without consent, or where consent cannot be given.

Psychological or emotional abuse

Threats, humiliation, controlling somebody, cutting them off from other people.

Financial or material abuse

Theft, fraud, pressure over money or property, somebody else taking control of benefits or a bank card, or a “friend” who is only there on payday.

Modern slavery

Forced labour, servitude, trafficking. Our modern slavery statement sets out what we do about it.

Discriminatory abuse

Harassment or ill-treatment because of race, religion, disability, sexuality, sex, gender identity or age.

Organisational abuse

Neglect and poor practice arising from how a service is run — rigid rules, a closed culture, doing things for the rota’s convenience rather than the person’s. This is the one a provider must be most willing to see in itself.

Neglect and acts of omission

Failing to act on somebody’s needs, ignoring medical needs, leaving somebody without heating, food or help they were promised.

Self-neglect

Somebody not looking after their own health, hygiene or surroundings, or hoarding to a point that makes the home unsafe. It is safeguarding, and it needs the most careful proportionality judgement of the ten — a home that is difficult to live in is not the same as somebody who has to be rescued from their own choices.

Two patterns specific to this cohort sit across those categories and are named so nobody waits for a better fit. Cuckooing — somebody taking over a resident’s home to deal drugs or to exploit them — is abuse, a crime, and a housing matter at the same time. It is never treated only as anti-social behaviour, though our anti-social behaviour policy deals with the housing side of it alongside this one. Mate crime — somebody befriending a person in order to take their money or their home — is financial abuse however friendly it looks from outside.

Who investigates, and how the law works

The duty to make enquiries belongs to the local authority, not to us. Where a council has reasonable cause to suspect that an adult in its area has needs for care and support, is experiencing or at risk of abuse or neglect, and because of those needs cannot protect themselves, it must make — or cause to be made — whatever enquiries it thinks necessary.

“Cause to be made” is the part that involves us. A council frequently asks the provider to carry out the enquiry and report back, and when it does, we do it and we do it properly. But the duty, and the decision about what happens next, stay with the council. We will not investigate first and refer afterwards, and we will not decide between ourselves that something did not meet a threshold.

Every council must also have a safeguarding adults board, made up of the council, the NHS and the police, which sets the multi-agency procedures everybody in the area works to. We are not a member of a board — providers are not — and we follow the procedures of the board for each area we work in. Where an adult dies or is seriously harmed and there are concerns about how agencies worked together, the board may hold a safeguarding adults review, and we take part in one fully, including when the findings are about us.

What happens when a concern reaches us

1. Make the person safe. Before anything is recorded or reported. If there is immediate danger, 999.
2. Record what was actually said, in the words used, on the day. Not a summary written later, and not tidied up.
3. Tell the council. The adult safeguarding team for the area, without delay, and without waiting to find out whether it is true. We do not need to be sure.
4. Ask the person what they want to happen, and tell them what we have done — unless doing so would put them or somebody else at greater risk, in which case we record why.
5. Co-operate with the enquiry, including carrying it out where the council asks us to, and giving the council and the police whatever they need.
6. Tell the commissioner, where somebody’s placement was arranged by a council or another body that needs to know.
7. Be open about it. Where something has gone wrong in something we did, we say so to the person affected, as soon as we reasonably can, truthfully, and we apologise. An apology is not an admission of liability and is never a reason to delay one. That is our own commitment; we are not a registered care provider and the statutory duty of candour that binds one does not bind us.
8. Learn from it. Take part in any review, and change what we do rather than filing the finding.

Where a concern is about a member of our staff, they are removed from contact with the person while it is looked at. That is a neutral act and it is not a finding against anybody.

If you think we did not deal with a concern properly, say so. Our complaints policy has two stages and time limits, and complaining will not put anybody’s home at risk. It does not replace telling the council: do both.

Mental capacity, and being kept somewhere

We start from the assumption that an adult can make their own decisions. Somebody is not lacking capacity because they make a decision we would not make. Where somebody cannot make a particular decision at the time it needs making, anything decided for them must be the least restrictive option available and in their best interests, and they must be helped to take part as far as they can.

The five principles of the Act apply to our staff directly, in ordinary decisions — whether to let somebody into a home, whether to share information, what to do when somebody refuses help. Ill-treating or wilfully neglecting somebody who lacks capacity is a criminal offence under the Act.

On deprivation of liberty, be clear what does and does not apply here. The Deprivation of Liberty Safeguards operate in care homes and hospitals only. Supported housing is neither. Where arrangements in somebody’s home would amount to depriving them of their liberty — locked doors, constant supervision, not being free to leave — that has to be authorised by the Court of Protection, and it is the responsibility of the body arranging the care to apply. We will raise it with the council rather than let an arrangement run unauthorised.

The Liberty Protection Safeguards, legislated in 2019 to replace the existing scheme, have never been brought into force. Any policy citing them as current law is citing something that does not exist.

Sharing information when somebody is at risk

Data protection law is not a reason to leave somebody at risk, and it has never been one. There is a specific condition allowing us to share information to protect an adult at risk of neglect or physical, mental or emotional harm — including without their consent, where asking for consent would get in the way of protecting them.

So: we will share a safeguarding concern with the council and the police, and we will usually do it whether or not everybody agrees. We share what is needed and no more, we record what we shared and why, and we tell the person unless telling them would increase the risk.

What we hold about you, and everything you can ask us to do with it, is in our privacy policy.

The people we employ, and the checks behind them

Safeguarding starts at recruitment, before anybody meets anybody.

• A criminal record check at the level the role is eligible for. Eligibility is decided by what the role actually involves, not by where it happens, and it is unlawful to ask for a check at a level a role does not qualify for. Some housing-support work does sit within regulated activity with adults — helping somebody with cash, bills or shopping because of age, illness or disability, or assisting with their affairs — and those roles are eligible for an enhanced check with a check of the adults’ barred list. We assess role by role and record the decision. We will not publish a blanket claim that every member of staff has the highest level of check, because that claim is usually untrue and is sometimes unlawful.
• Regulated activity for criminal record purposes is not the same test as regulated activity for care purposes. A role being eligible for an enhanced check does not mean the organisation carries on a regulated activity requiring registration, and the two are routinely confused. Bluebell does not deliver personal care and holds no such registration.
• Right to work, identity and qualifications verified before anybody starts.
• Full employment history, with any gap explained, and references taken up directly from the referee rather than accepted as a letter.
• TBD — safeguarding training. The safeguarding training every member of staff completes before working unsupervised, the level required for each role, and how often it is refreshed. No regulation sets an interval for a housing provider, so this is a commitment Bluebell makes rather than one it inherits, and it should be a real interval rather than the word "regularly". Operations has to set it.
• Regular supervision, so that practice is seen rather than assumed.

TBD — the named safeguarding lead. The job title of the named safeguarding lead for Bluebell Housing and of the deputy who covers when they are away, plus the internal route for reaching them out of hours. A policy with no named role in it leaves everybody assuming somebody else is dealing with it. Operations has to name both roles and the out-of-hours route.

Staff and contractors carry identification and will show it without being asked. Nobody should be let into a home by somebody who cannot prove who they are — if in doubt, do not open the door, and check with us first.

If you work here and something is wrong

The law protects you. Report something in the public interest — abuse, neglect, a danger to people, a cover-up, a falsified record — and you are protected from being dismissed or treated badly for it, from your first day, with the right to go to an employment tribunal if you are.

Inside Bluebell: tell your manager, or go above them, or use the route that sits outside your own line of management. You do not have to be sure, and you do not have to have proof.

Outside Bluebell, and without telling us first: the council’s adult safeguarding team, the police, the commissioner who placed the resident, or the Health and Safety Executive where it is a safety matter. Protect, the independent whistleblowing charity, gives free confidential advice to workers.

TBD — the internal contact outside the line of management, and the current advice line numbers taken from those organisations’ own published material. We have deliberately not printed a number we could not verify: a wrong number on this page is not an inaccuracy, it is somebody in a crisis reaching nothing.

About this policy

This page is the public summary. The full policy, with procedures, forms and internal contacts, is held by us and is available on request — commissioners and safeguarding boards can have the whole thing.

If you live in one of our homes, the residents page gathers this route and the others — repairs, safety, support and complaints — in one place.

TBD — the version, the owner, when it was last reviewed and when it is next due. No single rule sets a review interval for a housing provider, so we will state our own, and review sooner after any serious incident, any safeguarding adults review we take part in, and any change in the law.