This policy outlines the procedures when any employee, volunteer, service user, visitor to the  agency or contractor has an accident, near miss or when a dangerous occurrence occurs on agency  premises or as a result of work-related activities. 

For the purposes of this policy, the following definitions apply. 

• • An accident is an unplanned event that causes injury to persons, damage to property or a  combination of both. 

• • A near miss is an incident that could have caused an accident or injury, but in the event did not  — near misses may be warning signs of problems and should be reported and recorded so that  proactive action can be taken to investigate the causes and prevent a more serious accident from  occurring. 

• • Work-related activities include any activities that are related to the provision of care.

This policy covers reporting and recording procedures for managers, employees and non employees. Suitable information and training will be given to all personnel regarding accident  reporting. 

The service recognises that keeping records of accidents and safety incidents at work is required by  law and is an important part of any health and safety risk management process. The analysis of  comprehensive accident records is a valuable management tool that can be used to aid risk  assessment and put in place safety actions to prevent accidents in the future. 

On a larger scale, the collection of reports about serious incidents that may endanger the public is  an essential role for an enforcing authority such as the HSE, local authorities and regulators.

Legal Requirements 

This care provider complies with the requirements of the Health and Social Care Act (2014)  (Regulated Activities) Regulations 2014 in respect of service user care, particularly 12: Safe Care and  Treatment and the following regulations relating to accident management, reporting and  investigation.

• • It is a requirement of the Social Security (Claims and Payments) Regulations 1979, as amended,  that organisations with 10 or more employees must keep records of all workplace accidents  resulting in personal injury in an appropriate accident book. 

• • Reporting certain types of serious work-related accidents to the Health and Safety Executive  (HSE) is a legal requirement under the Reporting of Injuries, Diseases and Dangerous Occurrences  Regulations 2013 (RIDDOR). 

• • The Safety Representatives and Safety Committees Regulations 1977 require an employer to  inform any appointed union safety representative of a notifiable accident to allow them to conduct  an investigation.

The following HSE guidance will be followed: 

• • INDG453 Reporting Accidents and Incidents at Work. A Brief Guide to the Reporting of Injuries,  Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR) 

• • HSG245 Investigating Accidents and Incidents: A Workbook for Employers, Unions, Safety  Representatives and Safety Professionals.

• • HSIS1 (rev3) Reporting Injuries, Diseases and Dangerous Occurrences in Health and Social Care.

In this care service, the following policies and procedures will apply.

This policy intends to safeguard the people who use our services from suffering any  form of abuse or improper treatment while receiving care and treatment. This policy shows how All  Carer Services Ltd protects its service users from abuse or harm in line with its legal requirements  and best safeguarding practice guidance. It reflects in particular: 

• • Regulation 13: Safeguarding Service Users from Abuse and Improper Treatment of the Health  and Social Care Act 2008  

• • the statutory guidance for the Care Act 2014 (Chapter 14: Safeguarding), which describes the  duties and responsibilities of local authorities and its partner organisations to protect adults with  care and support needs from abuse, neglect and other sources of harm, and to make enquiries if  they suspect or have evidence of people being abused.

More specifically, it also reflects the (local safeguarding adults’ authority) policies and procedures. 

All Carer Services Ltd shares and is committed to the vision of the local safeguarding authority,  which is to empower and protect adults who are at risk of abuse and neglect, as defined in  legislation and statutory guidance. 

All Carer Services Ltd understands that local safeguarding arrangements and developments follow a  government strategy based on. All adult safeguarding should reflect the following principles: 

• • empowerment – supporting people to make decisions and have a say in their care > protection – support and representation for those in greatest need

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

• • proportionality – safeguarding must be built on proportionality and a consideration of people’s  human rights

• • partnership – local solutions through services working with their communities

• • accountability – safeguarding practice and arrangements should be accountable and  transparent. 

Improper treatment includes discrimination or unlawful restraint, which includes inappropriate  deprivation of liberty under the Mental Capacity act 2005. We take a zero-tolerance approach to  abuse, unlawful discrimination and restraint which includes:  

• • Neglect

• •  Subjecting people to degrading treatment

• • Unnecessary or disproportionate restraint

• • Deprivation of liberty 

We recognise that safeguarding involves a range of responses to different forms of abuse and  potential sources of harm and the different contexts in which abuse occurs. Accordingly, this policy  should be read and used in association with a suite of policies all designed to make sure that users  are safe from abuse and the risks of their coming to harm are kept to the minimum and well  managed.

Policy Aims 
The central aim of this safeguarding policy is to set out: 

• • principles and values underlying this service’s approach to the safeguarding of its service users

• • steps taken to avoid abuse/harm taking place

• • actions taken to deal with abuse/harm if it occurs

• • how it learns from incidents of abuse to prevent reoccurrence. 

All Carer Services Ltd works on the principle that it is the right of vulnerable service users to be kept  safe from all forms of abuse/harm. Being and feeling safe will contribute a great deal to their  wellbeing and quality of life. It therefore recognises that it must always protect its service users and  identify and deal with specific instances of abuse/harm if they occur, following the required  procedures and best practice guidance. All Carer Services Ltd is always aiming for the very best  quality of care and will not be satisfied with anything that falls short of this. It takes every possible  action to prevent abuse/harm and associated risks and to deal with the issues as promptly and  effectively as possible when they arise. 

All Carer Services Ltd seeks to work in line with local safeguarding adults’ authority policies and  procedures (or, in relation to services to children and families, to work in line with local  safeguarding children authority policies and procedures) . It recognises the importance of government and national guidance and seeks to  comply in all respects with current safeguarding legislation and regulations. 

All Carer Services Ltd recognises that service users who lack mental capacity are particularly  exposed to abuse/harm and exploitation. It is accordingly mindful of the need to follow the  principles and practice guidance that has accompanied the Mental Capacity Act 2005. These apply  particularly to investigations of possible abuse/harm in which it is important to seek means of  ascertaining the experiences and views of any victim or indeed alleged perpetrator who might lack  capacity, eg through the services of independent advocates. 

All Carer Services Ltd recognises that anyone who might need the help of an independent advocate  when engaged in safeguarding enquiries and plans is entitled to one (as legislated for by the Care  Act 2014). It will always support a person to have advocacy help where required in line with its  (separate) advocacy policy. 

All Carer Services Ltd has all required systems in place to track and monitor incidents, accidents,  disciplinary action, complaints and safeguarding concerns, and to identify patterns of potential  abuse/harm to its service users. 

References

This Policy will also be consistent with and mindful of a range of legislation and guidance. Notably  including: 

Adults at Risk 

 Modern Slavery Act 2015 

 Care Act 2014 

 Domestic Violence Crime and Victims (Amendment) Act 2012 

 Human Rights Act 2008 

 Mental Capacity Act 2005

Defining Abuse 

Adults at Risk 

Aged 18 years or over; Who may be in need of community care services by reason of mental or  other disability, age or illness; and who is or may be unable to take care of him or herself, or unable  to protect him or herself against significant harm or exploitation. 

Safeguarding 

Safeguarding and promoting the welfare of vulnerable individuals can be defined as: Protecting vulnerable individuals from maltreatment 

Preventing impairment of vulnerable individuals health or care 

Ensuring that vulnerable individuals are living in circumstances consistent with the  provision of safe and effective care 

Taking action to enable all vulnerable individuals to have the best outcomes 

Types of abuse 

Types of abuse that can given rise to safeguarding concern can be described as: Physical abuse 

Domestic abuse 

Sexual abuse 

Psychological abuse 

Financial or material abuse 

Modern slavery 

Discriminatory abuse 

Organisational abuse 

Neglect and acts of omission 

Self neglect 

Safeguarding Commitment 

All of our employees who are in contact with our commercial clients, service users and their families  members have a responsibility to: 

Protect the welfare of children, young people and adults at risk; 

Safeguard any child, young person or adult at risk; and 

Be able to recognise and respond appropriately to any potential or actual threat to the  wellbeing of the child, young person or adult at risk.

Protect from abuse and improper treatment in accordance with this policy 

Establish and effectively operate within the processes to investigate, immediately upon  becoming aware of any allegation of such abuse.  

Where appropriate we will follow national and local safeguarding arrangements.  

We will ensure that: 

All front-line employees are trained to recognize the signs of a person who could be at risk  / suffering neglect and/or abuse 

We know our customers and hold up to date customer data 

We are assertive in working with statutory agencies 

We have and will continue to implement and update robust process and procedures that  make sure service users and all parties involved are protected  

Induct new staff members with safeguarding training that is suitable and relevant for their  role, with continual CPD and training for all staff members  

Train staff to be aware of their individual responsibilities to prevent, identify and report  abuse when providing care and treatment  

Review incidents and complaints to identify potential abuse, take preventative action, and  escalate where appropriate  

Work within the requirements of the Mental Capacity Act 2005 when working with people  who may lack the mental capacity to make certain decisions 

We will know, understand and internally update local safeguarding arrangements so that all  staff are aware and can act appropriately  

We will the right people into the business to ensure that we mitigate any risk of  safeguarding incidents, this is covered within our recruitment policy. Management has the  responsibility to ensure that all staff members have the correct experience, qualifications,  DBS checks and references in place prior to any employment contract offers made.  

We will ensure that when creating or reviewing care plans for service users, that the risk  assessments include safeguarding factors such are money management, manual handling  and their ability to consent. 

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Identifying Abusers 

All Carer Services Ltd accepts that abuse/harm can be committed by a range of possible people. It  therefore accepts its responsibility to protect its service users from possible abuse from all sources,  which include: 

> the staff and management of All Carer Services Ltd 

> volunteers working in All Carer Services Ltd 

> visiting health and social care practitioners and other official visitors to the person’s home > service users’ relatives and friends 

> people who have contact with service users while they are temporarily outside > neighbours, people on their social network or living in the community at large. 

The Role and Accountability of Staff

All Carer Services Ltd insists that all its staff have a responsibility to: 

Report any incidents of abuse or potential abuse to an appropriate manager. If the person  

● you are concerned about or is involved is a manager and you do not feel comfortable  raising your concerns to another manager.

● Respect people’s privacy, dignity and human rights always, and treat people with  sensitivity, respect and thoughtfulness, adhering to individual care programmes 

● Understand their individual responsibilities in preventing discrimination in relation to  protecting the protected characteristics set out in the Equality Act 2010.  

● Regularly monitor and review the approach to restraint and restrictive practices.  

● Take all reasonable steps to make sure service users are not subject to any degradation or  treated in a manner that may be viewed in a degrading way.  

● Always deliver care and treatment that enables all services users’ needs to be met in  accordance with their set needs and preferences  

● _{Act in accordance with the Mental Capacity Act 2005 Deprivation of Liberty safeguards}

● _{Wherever possible support people’s independence and freedom of choice}

● _{Comply with and implement the organisation’s policies and procedures}

● _{Act within the limits of their training at all times} 

Whistleblowing 

Staff members who wish to report a safeguarding concern anonymously can do so by using an  anonymous reporting form. The business will ensure that the anonymity of the whistleblower is  protected throughout the process. The reporting form will require as much detail about the incident  as possible including the following: 

– Service user name, date and time of the findings 

– The category of safeguarding concern 

– Any conversations had with the service user that is relevant to this concern – What actions have been taken to ensure they are not in any immediate danger – Names and details of any other parties involved. 

We actively encourage all staff members to come forward and have a discussion with any of the  management team or the registered manager directly regarding safeguarding concerns. We will look  to protect the identity of those who report incidents and take all information and reporting  seriously. If the report is regarding a manager within the business, to ensure that there is an  impartial and fair way of investigating the matter you can do one of three things: 

– Report the manager/ supervisor/ Director to another Director of the business to enable  them to then investigate accordingly.

All Carer Services Ltd requires it’s Managers have a responsibility to: 

● Develop the systems and structures within which it is possible to deliver the best possible  care. To measure consistency internal auditing will be completed to ensure that procedures  are being followed and that safeguarding incidents have been followed up correctly with  the right outcomes.  

Regular staff observations will be conducted to ensure that not only are they following the  regulations as they should and not displaying any concerning behaviors towards our service  users, but also that they are aware of being able to spot the signs of safeguarding concerns  whilst caring for our service users. 

● Encourage a culture and ethos that is hostile to any sort of abuse/harm 

● Produce and regularly revising the policies and procedures to prevent and deal with abuse/harm 

● Operate personnel policies which identify, appropriately deal with and, if necessary,  exclude from practice potential or actual abusers 

Provide training for staff in all aspects of safeguarding, abuse/harm and protection. This  

● will include role play of safeguarding scenarios and testing their knowledge of how to deal  with them and what they would do if an incident occurred.

● Investigate any evidence of abuse/harm speedily and sympathetically 

● Implement improvements to procedures if an enquiry into abuse/harm reveals deficiencies  in the way in which the service operates 

● All safeguarding incidents will be reviewed by the Registered manager in team meetings  with other members of the management teams to discuss lessons learned, policy and  procedure reviews to integrate preventative actions moving forward.  

● All incidents will be shared with care staff to educate them in how to deal with these  scenarios moving forward. This is integral to the continuous improvement within the  service and form part of ongoing training for the staff.  

● Collaborate with all other relevant agencies in combating abuse/harm and improving the  safeguarding and protection of service users 

Liase with the relevant safeguarding adults/children authority teams and following their  

● guidance and instructions where applicable, including the issues arising from multi-agency  involvement 

Recruitment Practices

All Carer Services Ltd takes great care in the recruitment of staff, carries out all possible checks on  recruits to ensure that they are of a high standard and co-operates in all initiatives regarding the  sharing of information on care workers who are found to be unsuitable to work with people at risk. 

The agency ensures that new employees employed in regulated activity have been checked against  the Disclosure and Barring Service (DBS) criminal records and barred lists in line with the current  requirements. 

Preventing Abuse from Occurring

All Carer Services Ltd is committed to taking all possible steps to prevent abuse or harm of service  users from occurring, including: 

● Setting out and making widely known the procedures for responding to suspicions or  evidence of abuse/harm 

● Operating personnel policies which ensure that all potential staff in regulated activity are  rigorously checked, by the taking up of references and clearance through DBS criminal  records and barred list checks, with equivalent checks for staff employed from overseas 

● Incorporating material relevant to abuse/harm into staff training at all levels 

● Maintaining vigilance concerning the possibility of abuse/harm of service users from  whatever source 

● Encouraging among staff, service users and all other stakeholders a climate of openness  and awareness that makes it possible to pass on concerns about behaviour that might be  abusive or that might lead to abuse/harm 

● Maintaining effective procedures for regulating any contact that care workers need to have  with service users’ property, money or financial affairs 

● Communicating concerns to the local Adults’ Safeguarding Board or, where applicable,  Safeguarding Children Board 

● Helping service users as far as possible to avoid or control situations or relationships that  would make them vulnerable to abuse/harm. 

Identifying Actual or Possible Abuse 

All Carer Services Ltd will identify any instances of actual or possible abuse/harm involving our  service users by all possible means including: 

● Fostering an open and trusting communication structure so that staff, service users and  others feel able to discuss their concerns with someone authorised to take action 

● Ensuring that all staff and service users know whom they may turn to for advice and action  if they become aware or suspect that abuse/harm is occurring 

● Encouraging staff to recognise that a commitment to the highest possible standards of care  must, when necessary, overrule loyalty to colleagues individually or corporately 

● Making it clear to staff that failing to report incidents or suspicions of abuse is itself  abusive and may lead to disciplinary or criminal proceedings 

● Operating systems of management, supervision, internal inspection and quality control that  have the potential to reveal abuse/harm where it exists. 

Procedures for when Abuse Has Occurred

If abuse/harm is clearly occurring or is alleged to have occurred, the agency takes swift action to  limit the damage to service users and to deal with the abuse, as follows. 

Initial procedures 

A staff member who witnesses a situation in which a service user is in actual or imminent danger  must use their judgment as to the best way to stop what is happening without further damage to  anyone involved including themselves, either by immediately intervening personally or by  summoning help, which could include phoning the police on 999. 

Any staff to whom actual or suspected abuse/harm is reported — usually the manager or a senior  staff member — must immediately act to protect, support or arrange additional care to a service  user who has been harmed. 

The manager will discuss with the known or suspected abused/harmed person what actions they  consider to be appropriate. In some circumstances, the person might not wish any action to be  taken or agree to a referral being made on their behalf (though this would not apply to children). 

In such cases, the manager will consider whether there are reasons for overriding the person’s  wishes, eg because it is in the public interest and to prevent further harm or because the harmed  individual is a child. This could include seeking advice from the Safeguarding Adults’ Authority or  Safeguarding Children Authority. 

Any adult “victim” whom it is thought might lack mental capacity to give their consent for the  abuse/harm to be reported will be assessed for their capacity to decide and a “best interests”  decision will be taken in line with Mental Capacity Act procedures. 

Once a person has consented to further action being taken, or for someone unable to give their  consent, it has been decided that it is in their best interests to do so, the senior staff member or  manager (or whoever has authority at the time) will then alert the local Safeguarding Adults’  Authority or Safeguarding Children Authority and follow its procedures and guidance from that  point on. This could involve a strategy meeting and a safeguarding plan to be implemented from  the strategy meeting. 

The specific procedures to be followed and referral forms are those available on the local SAB  website. 

In some instances, the registered manager/person responsible for safeguarding might need to  report the matter directly to the police and take guidance from them on the measures to be taken. 

The registered manager must ensure that there is no further risk of the victim being  abused/harmed by the alleged or suspected perpetrator. 

The registered manager must address the needs of the alleged victim of the abuse/harm for any  special or additional care, support or protection or for checks on health or wellbeing as set out in  the person’s safeguarding plan. 

If the alleged abuser is a staff member and there is sufficient evidence that abuse/harm has or  might have occurred, the manager will suspend the person from duty pending the outcome of a  disciplinary investigation. The manager will receive guidance on the steps to be taken following the  local safeguarding adults/children authority strategy meeting, which will be held following the  reporting of the abuse or suspected abuse/harm. 

If the evidence is insufficiently strong to warrant suspension, the staff member against whom the  allegation has been made will be instructed not to have further unsupervised contact with any  service users until the matter is resolved. 

However, it should be noted that in the event of a referral being made to the police because a  criminal offence might have been committed the police investigation will take precedence and no  action should be taken that might jeopardise its enquiries, which might contaminate the evidence it  is seeking and collecting.

Investigating Alledged Abuse 

Investigations are based on a person-centred approach in which the wellbeing of the victim or  alleged victim is the central focus of all the activities involved. In many cases, enquiries will be  carried out or led by a member of an external agency in line with the action plan determined by the  initial strategy meeting convened by the local SAB or Safeguarding Children Authority. If a staff  member is expected to carry out an enquiry of its own, it will proceed as follows. 

The person appointed to make the enquiries will usually consult the person who may have been  abused/harmed to hear their account of what has occurred and their views about what actions  should be taken, involving service users’ relatives, friends or representatives if that is appropriate  and in line with the wishes of the service user. 

The enquiries should take into account: 

> the fears and sensitivity of the abused/harmed person 

> any risks of intimidation or reprisals 

> the need to protect and support witnesses 

> any confidentiality or data protection issues 

> the obligation to keep the abused/harmed person and, in specific instances, the alleged  perpetrator informed on the progress of the investigation. 

It will be important to assure the person who may have been abused/harmed that they will be taken  seriously, that their comments will as far possible be treated confidentially, that they will be  protected from reprisals and intimidation, and that they will be kept informed of actions taken and  of the outcome. 

It is important to consider if the service user needs independent help or representation, including  the services of an independent advocate, in presenting their evidence. The care service manager  will, if necessary, arrange for the appropriate help or support to be made available. 

If the abused/harmed person expressly states a wish that no further action should be taken, the  safeguarding enquiry will consider if: 

> a danger to others exists from not investigating further 

> in the light of that assessment it is possible to follow the person’s wishes 

> in any case precautionary measures should be taken to protect others from the possibility of  abuse from the same source 

> the person will be informed of what is to happen. 

Once decided that enquiries should proceed, they will look into all aspects of the situation discreetly  and respecting their sensitive and confident nature. 

The enquiry could include interviewing the staff involved in the incident or circumstances up to that  point, hearing and assessing evidence from any others who might be in a position to supply  information, exploring every other possible source of evidence, maintaining appropriate contact  with any other agencies involved, and if necessary seeking expert advice on any technical aspects of  the situation which are outside the knowledge or expertise available within the care service. 

Any staff from whom evidence is taken will be assured that they will be dealt with in a fair and  equitable manner and informed of their employment, legal and procedural rights. 

The alleged victim of the abuse/harm, and where appropriate their relatives, friends or  representatives, will at all times be kept as fully informed as possible of what is happening  regarding the suspected abuse/harm. 

The enquiry will be carried out within an agreed timescale. 

The findings will usually be presented to the local safeguarding adults/children strategy group,  which will then decide what further action to take, eg that a safeguarding plan should be developed  and implemented. 

If it is found that a member of the Senior management team or Director is reported for  safeguarding concerns, a different approach to investigation will have to be conducted to ensure a  fair, impartial and ethical approach to the matter is taken. If there are other Directors or senior  management above the accused Manager/ Director, they will need to conduct the investigation and  manage the disciplinary process.

If the accusation is made about the only Director of the business, then reporting to a regulatory  board is the best course of action to ensure that a fair and robust investigation is conducted  accordingly. 

Following the Investigation 

If it seems from the enquiries that on the balance of probabilities abuse/harm did indeed take place,  the manager will, if the abuser is a staff member, initiate and carry through proceedings according  to the agency’s disciplinary policy or, if the abuser is not a member of staff, take action to involve  other responsible bodies. 

If abuse/harm is proved against a care staff member, the manager will initiate appropriate action,  which most likely will be dismissal and referral to the DBS to prevent them from being employed  further in regulated activity. 

Other employment sanctions could apply depending on whether there might have been mitigating  or extenuating circumstances. In some cases, retraining could be appropriate. 

The service user or representatives will be informed of the outcome of the investigation and any  further action and will be consulted about whether any redress or apology would be appropriate and  helpful to them in line with the service’s duty of candour. 

The manager will take appropriate steps to inform the DBS for possible inclusion of the person on  its barring lists as someone who is unsuitable to work again in regulated activity with at risk adults  and/or children. 

At all stages of the process, a careful record will be kept of all actions taken, paying particular  attention to the sensitivity of the abused/harmed person. 

Where relevant to the resolution of the situation, a plan will be drawn up to address the issues with  the alleged or known perpetrator(s), particularly if they will be continuing to form part of the  victim’s life, directly or indirectly.

Planning Further Action 

At the end of an incident involving possible or actual abuse/harm, managers should review what has  happened with a view to assessing whether the agency or its management has been in any way  culpable, ineffective or negligent, learning lessons for the way the agency should operate in the  future, and passing on any appropriate information to other agencies. 

If necessary, the care service will review and revise its policies, procedures and training  arrangements in response to any material that has emerged from the incident or the investigation. 

The care service could carry this out with advice and guidance from the local Safeguarding Adults’  Authority or Safeguarding Children Authority. 

Record Keeping 

All Carer Services Ltd will record all details associated with allegations of abuse/harm clearly and  accurately. The records are kept securely and the agency’s rules on confidentiality are carefully  followed. 

Record Keeping 

All Carer Services Ltd will comply with its legal requirement to refer a care worker, where it has  evidence that the staff member in question has been guilty of misconduct by harming or putting at  risk of harm a service user or other person at risk, during the course of their work, to the DBS  barred lists following the procedures issued by the DBS.

Training 

All staff receive training in recognising abuse or harm and carrying out their responsibilities under  this policy as part of their induction programme and further training in line with their training  needs as identified from their supervision and appraisals and policy developments and changes. The  training is updated on a regular scheduled basis at least annually. 

All training, including induction training, is in line with the guidance and standards produced by the  relevant social and healthcare workforce development organisations and the local safeguarding  authority training policies and guidance. 

Examples of a Safeguarding Training Strategy (to be amended as required by individual  circumstances and local requirements). 

Staff new to care work must achieve Standard 10: Safeguarding Adults and Standard 11:  Safeguarding Children to achieve the Care Certificate. 

Other new staff will have a baseline training level, which is at least the equivalent of the Care  Certificate Standards 10 and 11 from previous or current induction training. 

All Carer Services Ltd will check their knowledge and competencies to ensure it meets the required  standard and provide additional training if needed (see the Training Factsheet). 

All staff receive training to ensure that they are familiar with local Safeguarding Adults’ Boards  policies and procedures. 

All staff following induction are expected to proceed to at least a Foundation Level 2 award and a  Multi-agency (Level 3) training in safeguarding. 

Managers and staff responsible for safeguarding are required to receive Specialist Safeguarding  Training (Level 4) and, where appropriate, to their roles and responsibilities, achieve the Multi Agency Safeguarding Leaders Development Programme (Level 5). 

The registered manager will include the Safeguarding unit (LMAC5C/S) in their Level 5 Diploma in  Leading and Managing Adult Care Service. 

Policy Statement 

All Carer Services Ltd is fully committed to the principles and values of equality, diversity, social  inclusion and protection of human rights. We aim through this policy to communicate this  commitment to everyone who uses our service and who help us to deliver it. 

The policy should always be referred to wherever there are differences of views based on lack of  understanding or prejudice about diversity, equality and human rights. 

All Carer Services Ltd shows its commitment to equality, diversity and protection of human rights in  its statement of purpose and all information produced for the people who use its services. This  enables us to provide responsive services to meet people’s diverse needs for care and support. 

We show the same commitment to equality, diversity and protection of human rights in our staff  recruitment, deployment and human resources policies 

Policy Statement

Our commitment to equality, diversity and human rights guarantees everyone receiving a service  from us will have their needs comprehensively addressed and they will be treated without  discrimination. This is regardless of an individual’s ethnic background, language, culture, faith,  gender, age, sexual orientation or any other aspect that could result in their being socially  stigmatised and discriminated against purely because they have such characteristics; or who could  be vulnerable to acts of hate crime as a result. 

We follow the same principles when assessing and meeting the needs of people who lack decision  making capacity by treating them with respect, developing person-centred care and treatment and  by following all mental capacity act best interests’ assessment and decision-making procedures. 

In implementing its equality, diversity and human rights policy, we do not accept that there can be  any hierarchy of protected characteristics, but aims to celebrate all individual differences, regardless  of being caused by ethnic backgrounds, religion, sexual or gender diversity. 

We will treat everyone equally. We recognise that treating people unequally can result in their losing  their dignity, respect, self-esteem and self-worth and ability to make choices, and is in breach of  their human rights. 

We do not assume that equality, diversity and inclusion principles and policies apply only to staff  treatment of people using the service. People using our service must also respect the ethnicity,  

Legal Compliance 

All Carer Services Ltd fully understands its legal responsibilities under the Equality Act 2010 and the  Social Care Act 2008 (Regulated Activities) Regulations 2014 which underpin commitment to  equality, diversity and protection of human rights. 

We refer in particular to the following. 

Regulation 9: Person-centred Care — requires service providers to ensure that the care and  treatment of people using services must be appropriate, must meet their needs, and must reflect  their preferences. 

Regulation 10: Dignity and Respect — requires that people using services must always be treated  with dignity and respect, including respect for personal preferences, lifestyle choices, diversity and  culture. 

Regulation 14: Meeting Nutritional and Hydration Needs — requires service providers (where  involved in the provision of food and drink) to ensure that the nutritional and hydration needs of  the people using services are met, including the meeting of any reasonable requirements of a  person for food and hydration arising from the person’s preferences or their religious or cultural  background. 

Regulation 15: Premises and Equipment — requires that people using services can easily access a  care service’s premises and use its equipment safely and effectively, and where they cannot because  of their disabilities, reasonable adjustments are made in line with the Equality Act 2010 and other  relevant legislation and guidance. 

Our commitment to equality, diversity, and human rights runs through everything that this care  service stands for and practices. The care service will always have evidence of “good” or  “outstanding” practice in relation to the Care Quality Commission quality statements that reflect  equality issues, particularly the following. 

Caring 

 Treating people as individuals. 

Responsive 

 Care provision, integration, and continuity. 

 Equity in access. 

 Equity in experiences and outcomes. 

Well-led 

 Shared direction and culture. 

 Workforce equality, diversity and inclusion.

We will protect everyone from bullying, harassment, avoidable harm and abuse that may breach  their human rights, including that which is associated with a person’s race and ethnicity, culture  and religion, sexual orientation and preferred gender, physical and neurological disabilities and  sensory impairments.

Our Approach to Equality, Diversity and Human Rights 

All Carer Services Ltd will: 

Never refuse anyone requiring care and support based on discriminatory grounds such as ethnicity,  sexual orientation, religion, or other protected characteristics as defined by the Equality Act 2010  and human rights laws, provided they meet all other admission criteria. 

Never provide inferior or substandard services based on a person’s ethnicity, sexual orientation, or  any grounds on which discrimination can occur. 

Always assess the need for additional “reasonable adjustments” in line with the Equality Act 2010  for any person receiving care who has protected characteristics, in addition to their other assessed  care and support needs. 

Always address a person’s communication needs arising from sensory, cognitive, neurological, and  other impairments, acting in accordance with our separate policy on achieving the Accessible  Information Standard. 

Act decisively if anyone receiving our services experiences offensive or abusive treatment based on  their ethnicity, religion, or sexual orientation, including those who identify as gay, lesbian, bisexual,  transgender, or their preferred gender. 

Work with each person using our service to determine their wants and needs, and how they will be  provided with the required service. This process will consider the person’s gender, sexual  orientation, culture, personal choices, and other characteristics, avoiding assumptions that everyone  wants the same thing. 

Encourage people receiving our care and staff to relate to one another based on equality and respect  for individual differences and chosen lifestyles, including those who identify within the LGBTQ+  spectrum. 

Develop self-awareness among staff and service users to report, challenge, or complain about any  form of discriminatory behavior, including offensive or abusive language directed at a person’s  disability, ethnicity, preferred gender, sexual orientation, or religion. 

Ensure that people using our service and staff are continuously aware of the procedures for dealing  with complaints and allegations of discriminatory or oppressive language or behavior, including our  safeguarding policies. 

Promptly and properly address all reports, complaints, allegations, and incidents of abuse that  breach our approach to equality, diversity, and protection of human rights. 

Develop non-discriminatory recording practices that reflect and are consistent with equality  principles through the careful use of language and terms, in which staff will be trained and  expected to use. 

How We Practise Equality and Diversity and Protect Human  Rights

All Carer Services Ltd expresses its commitment to equality, diversity and inclusion by: 

Respecting people’s ethnic, cultural, and religious practices, and individual sexual identities, and  reassuring the people who use our services that their diverse backgrounds and individual  preferences enhance the quality of experience of the service. 

Accepting people who use our services as individuals, not as cases or stereotypes, and making  reasonable adjustments which, if not made, would result in their being treated unequally and  unfairly; including the use of communication and digital aides and equipment. 

Adapting and using equipment and devices that people can competently use and are always  accessible to them when they need them. 

Involving people who use the service to express their individuality and to follow their preferred  lifestyle irrespective of any LGBTQ+ status, and helping them celebrate events, anniversaries, or  festivals which are important to them as individuals and in relation to their sexual orientation or  gender identity. 

Only sharing sensitive information with third parties with a person’s consent and with regards to  our policy on confidentiality, in line with data protection requirements. 

Showing positive leadership and having management and human resources practices that actively  demonstrate a commitment to equality, diversity, and the protection of human rights. 

Developing an ethos throughout the care service that reflects these values and principles and  expecting all staff to work to equality, diversity, and human rights principles and policies and to  behave at all times in non-discriminatory ways. 

Having a code of conduct that makes any form of discriminatory behaviour unacceptable, which  applies to staff and people receiving care; this is rigorously observed and monitored accordingly. 

Providing training, supervision, and support to enable staff to carry out care in line with our  expectations on equality, diversity, and human rights. 

Addressing rigorously and fully, in line with the service’s complaints procedure, any complaint  which a person using the service or someone acting on their behalf might make about the  behaviour of another or others that is causing them offence because it potentially breaches the  service’s policy on equality, diversity, and human rights. 

Addressing any acts of abuse or hate crime towards an individual because of their ethnicity,  religion, or LGBTQ+ spectrum characteristics through the service’s safeguarding policy and  procedures, involving and co-operating with the local safeguarding authority as required. 

Encouraging people who are vulnerable or at risk from experiencing abuse because of their  ethnicity, religion, gender, sexual orientation, and LGBTQ+ spectrum identities to obtain support  through local or national support groups, organizations, and advocacy schemes. 

Carrying out regular assessments of the impact of our approach and policies on equality, diversity,  and human rights on people who use the service and our service provision generally. 

Specific Practice Toward Religious and Cultural Beliefs 

We recognise that contacts with places of worship and fellow believers are for many people an  important element of their continued integration with the community, and we will take steps to  make such continued contacts possible and meaningful. 

We acknowledge that at the time of dying and death, religious belief and practice may assume a  particular significance, and if our workers are involved at such times we will try to observe any  requests for special treatment, ritual, or family and community contacts which are requested, for  anyone receiving care who is close to death and after, and for their friends and relatives. 

We recognise that for some people the expression of personal and spiritual values takes forms  outside a structure of religious belief and practice, and in such instances we will do everything  possible to facilitate that expression in ways appropriate to individuals in order to make possible  their maximum personal fulfilment. 

We know that some people with severe disabilities, communication difficulties, mental disorders or  terminal illnesses retain a sense of the importance of their personal faith; we will respect and try to  respond to this need in any appropriate way. 

We will take vigorous steps to ensure that no one is the subject of discrimination because of their  religious beliefs or practices. A lack of respect for religious needs on the part of any member of  staff will be the subject of disciplinary action. 

We will seek in the makeup of the staff group to reflect the diversity of faiths and cultures among  people living in the home and in the local community as a way of helping people to feel accepted  and respected. We will not discriminate on grounds of religion against applicants for posts in the  care service, and we will attempt to accommodate staff whose personal religious beliefs require  them to be away from work at certain times or on specified days.

We see our efforts to promote appropriate responses to people’s religious needs as a part of all our  efforts to provide each person living in the home with as fulfilling and participative a lifestyle as is  possible according to their personal preferences, needs and choices.

Achieving the Accessible Information Standard 

The Accessible Information Standard requires all health and care providers to carry out specific  actions to ensure that their users’ communication needs are fully and adequately addressed  throughout their care, treatment, and support. 

We are legally required to carry out the following: 

Find out if an individual has any communication or information needs relating to a disability or  sensory loss, and if so, what they are. 

Record those needs clearly and in a standard way on all of an individual’s care records and  documents. 

Highlight them in their care records so everyone who has to communicate with that person and has  access to their records can address their communication needs in line with the individual’s  communication plan. 

Where required and relevant, pass on to others an individual’s information or communication needs  and how they should be addressed. 

Ensure that each individual receives information they can access and understand and receives  communication support if they need it throughout their care, support, and treatment. 

We understand that communication and the provision of information is a fundamental part of  treating people with dignity and respect and in providing good, compassionate care. Furthermore,  we recognize that effective communication can be affected by conditions such as dementia, stroke,  hearing conditions, sight loss, or cases where the person lacks the capacity to make decisions.

The Accessible Information Standard requires all health and care providers to carry out specific  actions to ensure that their users’ communication needs are fully and adequately addressed  throughout their care, treatment, and support. 

All Carer Services Ltd is legally required to carry out the following: 

Find out if an individual has any communication or information needs relating to a disability or  sensory loss, and if so, what they are. 

Record those needs clearly and in a standard way on all of an individual’s care records and  documents. 

Highlight them in their care records so everyone who has to communicate with that person and has  access to their records can address their communication needs in line with the individual’s  communication plan. 

Where required and relevant, pass on to others an individual’s information or communication needs  and how they should be addressed. 

Ensure that each individual receives information they can access and understand and receives  communication support if they need it throughout their care, support, and treatment. 

All Carer Services Ltd understands that communication and the provision of information is a  fundamental part of treating people with dignity and respect and in providing good, compassionate  care. 

Furthermore,All Carer Services Ltd recognizes that effective communication can be affected by  conditions such as dementia, stroke, hearing conditions, sight loss, or cases where the person lacks  the capacity to make decisions. 

Procedures 

Step 1 of the Accessible Information Standard 

To find out if an individual has any communication or information needs relating to a disability or sensory  loss and, if so, what they are. 

People who use services have the right to be communicated with and receive sufficient information  about their care and treatment so that they can make a balanced judgment on whether or not to  give their consent. 

To be responsive to individuals’ communication needs, we adopt a “whole person” approach by  identifying the most effective means of communicating with that individual, where necessary, with  specialist help, which is also based on their views and preferred ways of communicating. The results  are written into their plan of care and highlighted, particularly where other than standard means of  communication are required. 

People who use services who have difficulty communicating their needs because of their difficulties  or impairments will be offered or recommended access to specialist support. This may be in the  form of assessments by speech and language therapists, psychological assessments, and advisers  from organizations specializing in disabilities and sensory impairments. 

It is possible that new people’s communication needs will already have been identified by other  health and care agencies involved, but we will always check that these needs have been accurately  assessed and addressed so that we can communicate effectively with the person about their care  needs and deliver the appropriate care. 

Steps 2 and 3 of the Accessible Information Standard 

(2) To record the person’s communication needs clearly and in a standard way on all of an  individual’s care records and documents. 

(3) To highlight a person’s communication needs on their care records so everyone who has to  communicate with that person and has access to their records can address their communication  needs in line with the individual’s communication plan. 

We will clearly record in a highlighted separate section of the person’s care records the relevant  information. Everyone involved in the person’s care and support will know how to communicate  effectively with that person. 

We will discuss with the person as part of the care planning process (and, if necessary, in  consultation with other professionals and agencies) what adjustments and interventions are needed  to improve communication with that person. 

Agreed methods of communication and interventions will be recorded in the person’s care plan in a  prominent and consistent way so that all care staff know exactly what has been agreed to meet the  needs of people using the service, their relatives and carers. 

Step 4 of the Accessible Information Standard 

To pass on where it is required and relevant to others an individual’s information/communication needs and  how they should be addressed . 

All staff who have access to a user’s care records will be aware from the records of that person’s  communication needs and support plan. They are also expected to impart and share the facts of a  person’s specific communication needs and support plans with others involved in that person’s care,  support and treatment, but who might not have authorised access to the person’s care records. 

Where someone transfers to another service or receives care from another service, we will, with the  person’s permission, share information that we are requested to provide about their communication  and information needs (along with other information sharing) with the receiving service. 

Where it is suspected that a person does not have the mental capacity to communicate, or in any  other way has no ability to communicate, then the provisions of the Mental Capacity Act 2005 will  be implemented and best interests’ decisions made with the involvement of people close to the  person using the service, such as relatives, carers or advocates. 

Step 5 of the Accessible Information Standard 

To ensure that individuals receive information which they can access and understand, and receive  communication support if they need it throughout their care, support and treatment. 

All reasonable adjustments will be made to meet the communication needs of people with sensory  difficulties, including people with visual and hearing difficulties. 

Where required and appropriate to the role of the care service, we will provide or facilitate the  sourcing and provision of resources and assistive technology such as Braille books and magazines,  large print/easy read copies of literature, British Sign Language interpreters for deaf people, Braille  or talking telephones and mobile phones, hearing aids, text phones, loop hearing systems, etc. 

For any person using the services, family member or carer who might require it, advocacy will be  provided or sought to help meet their communication and information needs. 

All staff are responsible for helping to deliver this policy by communicating in a way that is  accessible to every user of this service. 

Training 

All care staff will receive training as relevant to their roles and responsibilities in the care of people  with hearing and sight problems and disabilities, which will include learning about communication  techniques and providing accessible information. 

Care staff: 

 receive initial training based on the Care Certificate Standard 6: Communication and develop  their communication skills from there 

 will receive training in the five steps of the Accessible Information Standard so that they can  communicate effectively with all users with special communication needs. 

All Carer Services Ltd is committed to providing the highest possible quality of service to the people  who use our services, the organisations who purchase services on their behalf and all other  customers and stakeholders and we believe that, no matter how good our present service, there is  always room for improvement. 

The high standard of service we aim for is achieved through the implementation of a plan of  continuous improvement, which covers all of our operational functions from delivery of care and  support through to our internal management systems. Staff at all levels of the organisation are  involved in this process of improvement and this commitment to staff involvement is reflected in  our on going support and reward for staff.

We provide evidence-based and continually improving services, which promote both good outcomes  and best value, which includes: 

Ensuring a person centred approach to the care and support for each individual. 

Enabling the people we support to set Customer Standards and involving them in the  auditing process. 

Internal Quality Monitoring Audits, identifying recommendations and requirements to  ensure the improvement and development of the service, as well as identifying  commendations for good practice and achievements. 

Obtaining feedback from others who are involved with our services, such as healthcare  professionals and relatives. 

Policies, procedures and guidelines, which detail how these agreed levels of service are to  be achieved. 

Auditing of our systems to ensure that our high quality standards are maintained and to  highlight areas for improvement. 

Quality Assurance Audits 

The organisation works within a number of externally imposed quality frameworks that define  standards. The most important of these include: 

Health and Social Care Act 2008 (Regulated Activities) Regulations 2015 

Other regulatory standards, e.g. Health & Safety Executive, Fire Authority, Environmental  Department

Contracts compliance as set by the placing authority 

In general these external quality frameworks all aim to ensure that quality is built into services  through setting and implementation of standards, through processes for review, and through  monitoring to ensure that services meet the needs of service users and other stakeholders. 

Internal Audits 

We aware that other key aspects of quality assurance include mechanisms for the monitoring or  auditing of services to ensure they are being delivered as originally intended. 

These include: 

Monitoring Visits- Unannounced spots checks to observe staff performance in a real world  setting) 

Monthly Managers check – Monthly audit of Essential Standards of Quality & Safety,  examination of buildings, fixtures, fittings, risk assessments, equipment, policies,  procedures, records, reports 

Complaints monitoring and effective “open door” policy 

Policies, Procedures & Practices – Review of policies, procedures and practices in light of  changing legislation and reflection of good practice as advised by appropriate authorities or  multidisciplinary body 

Satisfaction surveys – collection of service users’ questionnaires, family/advocates  questionnaires, stakeholder questionnaires to gain insight directly from those benefiting  from the services provided. To be handled without prejudice, discrimination or  recrimination. 

Service User Involvement – Quality assurance begins and ends with the service  users – the key customer. In order for any quality assurance programme to be  successful, their views must be sought on a regular basis and action taken if a  service no longer appears to be meeting their needs. 

Participation & Consultation 

Service user meetings – Meetings will be held at least every six months to enable  service users to have a forum to share and discuss issues concerning the running  of the business and its activities. 

Family meetings – to enable families to work in partnership with staff and  service user.

Key working meetings – to ensure all aspects of the key working contract is  fulfilled. 

One-off meetings – Where there are specific important issues or changes on  which service users should be consulted. 

Care plan review meetings – to be held monthly for each service user, the  service user is to attend if at all possible and the meeting recorded in the care  plan. 

Continuous Improvement Plan 

The service will have a continuous development plan for quality improvement, based upon feedback  from service users, staff and others. The improvement plan will become part of an agreed ‘live’  ongoing commitment to continuous improvement. The plan becomes ‘live’ because it is regularly  reviewed, amended and added to. 

The files which may be in situ for continuous improvement may be: 

Discovered – complaints, suggestions, and compliments, good and innovative practice. 

Health & Safety – risk assessments 

Management – budgets, procedures, guidelines, codes of practice. 

Service users – surveys, meetings and individual comments. 

Staff – meetings & individual comments, training, conferences.  

All Carer Services Ltd has a duty of confidentiality to its individuals. All Carer Services Ltd regards  this as being of the utmost importance and key to building trusting, caring relationships, where  people who use the service are safe in the knowledge that their confidences will be kept and where  information about them will be protected. 

The service’s policy is that all the information we receive about or from people using the service is  confidential, and that only those people who need to know the information will have access to it.  All Carer Services Ltd will always seek the written permission of its users prior to sharing personal  information about them with anyone else. 

The care service seeks to comply with the following requirements.

To have effective systems for keeping confidential information safe and secure (Regulation  

● 17(1)(a)). 

● To keep all sensitive information confidential such as in the handling of complaints,  (Regulation 16(2)) and in the exercise of a duty of candour (Regulation 20(2)). 

To share information with people and agencies outside the service on a strict “need-to 

● know” basis. 

● To have information governance systems that comply fully with data protection laws  (Regulation 17(2)(c)). 

Values and Principles 

All Carer Services Ltd adopts the Caldicott principles of confidentiality, which were developed for  health services and are equally applicable to social care. These are: 

● the purpose(s) for using confidential information must be justified

● confidential information should only be used when absolutely necessary

● the minimum information that is required should be used  

● access to confidential information should be on a strict need-to-know basis

● everyone must understand their responsibilities to treat information confidentially

● everyone must understand and comply with the laws, particularly those on data protection 

● the duty to share personal information can be as important as the duty to have regard for  patient confidentiality.

In applying these principles, the care service will follow these rules. 

● We treat all information about people who use the service confidentially and respectfully.

● We share our information when needed so that the person receives safe and effective care.

● If we publish information about people who use the service it will be on an anonymous basis.

● We will respect the right of people to object to any sharing of their personal information. 

We apply these rules and rights to people without capacity to give their consent to any  

● sharing or disclosure of their personal information for whom best interests decisions might  need to be taken. 

Procedures 

To comply with this policy staff must: 

● store securely all files or written information of a confidential nature (eg in a locked filing  cabinet or using strong password protected computer files) 

●  _{only access this information if they have a need and a right to access it} 

● wherever practical or reasonable, fill in all care records and individual’s notes in the  presence of and with the co-operation of the individual concerned 

● ensure that all care records and individual’s notes, including care plans, are signed and dated. 

Situations can arise which give rise to exceptions to this duty, where confidential information may  relate to harm to other people who use the service or harm to the person sharing the confidence. In  such circumstances, the service expects staff to report the information to a senior member of staff  for further consideration. 

In such circumstances: 

● the relevant person will be informed of the service’s position and full details will be  discussed with the person who uses the service 

● appropriate notes will be made in the individual’s plan, and these notes will be open to  inspection by the person using the service 

● the information will only be given to those who absolutely need to know and wider issues  of confidentiality of that information will still apply 

● the individual will be free to make a complaint through the service’s complaints procedure  if they consider that the information held about them has not been treated in the  confidential manner they should expect. 

Initial Assessment Policy

New people to the service or people considering using the service are shown a copy of the  statement below, and have it explained to them and their representatives so that they can  understand it as fully as possible and sign it. 

Every effort is made by staff to ensure that people who use the service fully understand the  implications of the policy. The member of staff carrying out the assessment will ensure that the  new people to the service understand and have read the following statement. 

“To help us make an assessment of your needs, we will need to ask you for personal  information about your circumstances and to record this information. We will not share  this information with anyone, including friends and relatives, without your agreement  (unless they have legal authority as guardian or attorney) and it will be kept in a  confidential file which will be kept securely. 

Only care staff with permission to see the file will be able to access it. Care staff will record  in the file on a daily basis information relevant to your care and will pass on information  relevant to your day-to-day care to your key worker or to whoever is in charge of each  shift. 

You may have access to your notes at any time to see what is actually being recorded. It is  the care service’s policy that all the information we receive about or from people who use  the service is confidential and that only those people who need to know the information  will have access to it. 

The care service will always ask your permission before we share with anyone else the  information you have given us. 

In certain circumstances, however, we may need to share information in your best interests  and may do so to fulfil our duty of care to you to keep you safe from risk of harm by  following the procedures that are set out in the service’s safeguarding policy.” 

Requests for Information 

All Carer Services Ltd will not provide information to relatives, spouses, friends or advocates  without the consent of the individual concerned. If the person is unable to give their consent, a  decision will be taken in line with “best interests” procedures set by the Mental Capacity Act 2005. 

All enquiries for information, even if they are from close relatives, should be referred back to the  person using the service, or their permission sought before disclosure. If the relative or person who  seeks to have access to this information objects to the decision, they will be asked to make a formal  written complaint, which will be addressed through the service’s complaints procedure. 

The service is also often asked for reports by insurance companies, solicitors, employers, etc. Before  providing these reports, we shall require written consent from the individual concerned and will  never divulge information without consent unless obliged to by law.

Recording Keeping 

We keep files on all our people who use the service but only keep relevant information to ensure  that the care we offer as an organisation is of the highest quality. The files are only available to  staff who need to use them. We keep very personal letters or notes securely. 

This service makes sure that: 

● records required for the protection of people who use the service, and for the effective and  efficient running of the service are maintained, are up to date and are accurate 

● people who use the service have access to their records and information about them held  by the service, as well as opportunities to help maintain their personal records 

● individual records and care service records are kept in a secure fashion, are up to date and  in good order, and are constructed, maintained and used in line with the General Data  Protection Regulation and the Data Protection Act 2018 and other statutory requirements. 

All Carer Services Ltd adheres fully to the current standards on record keeping, while recognising  the importance of responsible information sharing to enable a person to receive safe and effective  care from the responsible sharing of information, particularly in emergencies such as occurred  during the Covid-19 pandemic. 

The service considers that access to information and security and privacy of data is an absolute  right of every person who uses the service, and that they are entitled to see a copy of all personal  information held about them and to correct any error or omission in it. 

The care service will ensure the confidentiality of all information covered by the GDPR and Data  Protection Act 2018.

Training 

New staff are required to read and understand the policies on data protection and confidentiality as  part of their induction. All staff receive training on confidentiality, data protection and access to  records’ policies. 

Training in the correct method for entering information in individual’s records is given to all care  staff. The nominated data user/data controller for the service is trained appropriately in the GDPR  and Data Protection Act 2018. 

All staff who use the computer system are thoroughly trained in its use, including data security.