Guidelines for staff on how to respond to allegations or suspicions of abuse or harm
General Principles
Imperial College is committed to providing a safe and secure environment which is respectful and collaborative and has a zero tolerance approach to bullying, discrimination, victimisation and harassment.
Imperial College expects all individuals to act responsibly and appropriately at all times and to contribute to maintaining an inclusive and non-threatening environment by treating all members of the staff and student community with respect and dignity. respect.
All individuals should ensure safe work practices to help reduce the risk of abuse by being sensitive to individual and cultural needs and providing an environment which lessens any imbalance of power.
Whilst all individuals must be treated with respect, where children, young people and vulnerable adults are involved, all are expected to conduct themselves in line with the particular responsibilities outlined in the Guidelines for Staff, Students and Volunteers
This Code of Practice operates in conjunction with the , harassment support provisions and Active Bystander training by providing a mechanism through which behaviour or actions to the contrary can be addressed.
There are many forms of abuse and harm, indicated as may include:
1. Abuse includes acts of both omission and commission that have caused, or are likely to cause, harm.
2. Harm means ill-treatment or impairment of health or development including, for example, impairment suffered from seeing or hearing the ill-treatment of another. ‘Development’ means physical, intellectual, emotional, social or behavioural development. ‘Health’ means physical or mental health; and ‘ill-treatment’ includes sexual abuse and forms of ill-treatment which are not physical.
3. For the purposes of this section the word “abuse” includes reference to harm and the word “harm” includes reference to abuse.
Indicators of abuse and harm
There are different forms of abuse and they include:
Neglect may be indicated by constant hunger, weight loss, constant fatigue, inappropriate or uncharacteristic dress/clothing; isolated /unable to socialise.
Physical abuse and non-accidental injury may be indicated by unexplained bruising, scalds, broken bones etc, fear of parents/carers/others, flinching when approached, or concealing injuries.
Emotional abuse could be indicated by unusual behaviour, developmental delay, lack of self-esteem, unprecedented violent outbursts.
Sexual abuse may be indicated by sexually transmitted infections, fear of being left alone with perpetrator, sexual knowledge far beyond developmental level or inappropriate sexualised/risky behaviour.
Financial abuse may be indicated by difficulty in purchasing everyday items, lack of essential resources, regularly borrowing money, or old/inadequate clothing.
Abuse can also include domestic abuse, forced marriage, female genital mutilation and exposure to extremist ideology (as outlined below in next section):
Exposure to extremist ideology
The Counter Terrorism and Security Act 2015 places a duty on universities to have ‘due regard to the need to prevent people from being drawn into terrorism’ (‘the Prevent duty’). Concerns that a child, or vulnerable adult, has been, or may be exposed to inappropriate/ extremist material or activities should be acted upon in accordance with the appropriate procedure below. Where a Prevent-related concern is established, Imperial College’s Referral of Concerns Policy and Procedure (http://www.imperial.ac.uk/admin-services/secretariat/secretariat/what-we-do/prevent/referral-of-concerns/) should be followed.
Recognising abuse
Concerns may arise because a child or vulnerable adult alleges abuse;
Someone discloses that a child or vulnerable adult has alleged abuse to them or that they strongly believe a child or vulnerable adult has been or is being abused
Someone witnesses something which constitutes abuse
There are suspicions or indicators that a child or vulnerable adult is being abused
There are observable changes in a child’s or vulnerable adult’s behaviour that may be related to abuse; and/or
The behaviour of a member of staff towards children or vulnerable adults causes concern or there is suspicion that a member of staff is abusing a child or vulnerable adult.
Basic premise of a child protection and safeguarding procedure
The basic premise of a child protection and safeguarding procedure is to ensure that those who are suffering from harm, abuse and neglect are identified, and that information is shared appropriately to afford them protection and ensure access to requisite services. Policy and Code of Practice
Safeguarding is everyone’s responsibility
It is the duty of any staff working with children or vulnerable adults to report disclosures of abuse to their Local Safeguarding Officer or a Lead Safeguarding Officer Safeguarding referrals flowchart [pdf]. It is not for staff to decide whether or not a suspicion or allegation is true. All suspicions or allegations must be taken seriously and dealt with according to this Policy and Code of Practice. Investigation of and action taken in relation to any alleged malpractice or wrongdoing will be undertaken in line with Ordinance 18 – Investigation of Public Interest Disclosures.
The following sections provides step-by-step guidance on how to respond to a concern about a child’s or vulnerable adult’s welfare.
Guidelines for staff on how to respond to a concern about a child or young person's welfare
Definition
A child or young person refers to anyone under the age of 18 years.
How to deal with allegations of child abuse
If a child alleges abuse, staff should:
a. Stay calm, listen and re-assure the child;
b. Limit any questioning to the minimum necessary to seek clarification only and avoid leading questions;
c. Check with the child that they have their consent to share the information. If consent is withheld then be clear to them why their wishes may need to be overridden. Do not promise confidentiality;
d. Record information, using the child's own words if possible, and confirm with them that what has been recorded accords with what they have said;
e. Discuss with the child any steps which could be taken immediately to protect them from harm, and what the child will do after the discussion;
f. Invite the child to participate in any discussion with a safeguarding officer
h. One of the Lead Safeguarding Officers should decide upon next steps: seeking further advice, informing parents, informing children’s social care, informing the Disclosure & Barring Service (DBS) and/or the Police;
i. Advise the child what is going to happen and seek their consent wherever possible; and
j. Advise the child of the outcome of any conversations with outside agencies and what will happen next.
How to deal with suspicions of child abuse
If there are genuine suspicions that a staff member is abusing a child, staff should:
a. Maintain confidentiality but alert one of the Lead Safeguarding Officers in the first instance.
b. The Lead Safeguarding Officer should take such steps as they considers necessary to ensure the safety of the child in question and any other child who might be at risk. The Lead Safeguarding Officer should speak to the child about any actions taken and offer support and advice about what will happen next.
c. The Lead Safeguarding Officer shall keep the person who reported the original concern informed of how the matter is progressing to the extent that this is appropriate.
Further advice is available from the government’s What to do if you’re worried a child is being abused guidance.
A member of staff who has any concerns regarding the welfare of a child who is involved in Imperial College activities must report their concerns to their local safeguarding officer as set out in the referrals flowchart . The Local Safeguarding Officer will escalate to a Lead Safeguarding Officer who may then refer the case as appropriate to the DBS, to children’s social services where they have concluded that someone may have caused harm or abuse or poses a risk of harm or abuse to a child, to the Local Authority Designated Officer where there are concerns that that a member of staff may be abusing a child, and/or to the Police where there is a concern that a crime may have been committed.
Staff who are worried about sharing concerns about abuse are encouraged to speak with an appropriate agency such as the NSPCC helpline for further advice.
Where the individual of concern is a member of staff, the Director of Safeguarding will take any relevant action, such as suspension or commencing disciplinary proceedings, if necessary (and if such action has been approved by the Police and/or the Local Authority Designated Officer, where such external agencies are involved).
Imperial College will make a referral to the DBS when a member of staff is dismissed or leaves following safeguarding allegations and where the DBS harm criteria is met.
In the event there is a risk of immediate serious harm to a child the emergency services should be contacted via 4444 if on campus or 999 if off campus or the police via the 101 service. Anybody can make a referral in these circumstances. The Lead Safeguarding Officer should then be notified of the case.
Recording information
The member of staff who raises the initial concern must record what the child disclosed or what they have observed, and speak with a Safeguarding Officer about the case as soon as reasonably possible.
The record should detail what the person said or the incident they witnessed or details of any significant marks or behaviour which were observed, noting any names and contact details (yours and those of the child and any witnesses), dates and times. Staff must bear in mind that this record could become disclosable evidence in the event of a prosecution or other proceedings.
The Safeguarding Officer should record any subsequent actions, decisions or conversations.
A Lead Safeguarding Officer is responsible for forwarding referrals to the DBS.
Safeguarding Officers are responsible for storing information in a secure area and ensuring that only authorised staff have access to this.
Confidentiality
It is impossible to promise complete confidentiality when a concern is raised or an accusation made. Imperial College owes a legal duty of care to its staff, students or visitors that cannot be fulfilled unless it takes action on the basis of information that may have been provided in confidence. The duty of confidentiality must be weighed against the duty of care, in case of potential or actual harm of an individual. Where issues arise via Counselling, Occupational Health, etc alternative specific professional guidelines may need to be followed. At all stages, only those people who need to be made aware of an incident or concern, whether internal or external to Imperial College, should be informed on a ‘need to know’ basis.
Any enquiries made by the media about possible allegations of abuse should be referred to the Communications and Public Affairs immediately.
Guidelines for staff on how to respond to a concern about a vulnerable adult's welfare
Definition
The definitions of a "vulnerable adult" and an "adult at risk" are complex and depend not just on the characteristics of the individual but also the context and environment in which they are interacting with others.
A vulnerable adult is defined as anyone aged 18 years or over who is:
Dependent on others for care or support in their everyday life At risk of or currently experiencing neglect or abuse Unable to protect themselves from significant harm or exploitation Generally speaking, if staff suspect that an adult may be unable to take care of him or herself or protect him or herself from significant harm or exploitation, or if an adult is in need of community care services because of disability, age or illness then it is sensible to proceed on the basis that they may be a vulnerable adult.
It is also important to consider whether or not an adult is vulnerable at a particular moment in time since individuals may move in and out of the scope of the definition, for example, as a consequence of being affected temporarily or permanently by health and/or personal issues. To some extent staff may therefore be dependent on individuals notifying them of such issues.
How to deal with allegations of abuse of a vulnerable adult
If a vulnerable adult alleges abuse, staff should:
a. Stay calm, listen and re-assure the vulnerable adult;
b. Limit any questioning to the minimum necessary to seek clarification only and avoid leading questions;
c. Check with the vulnerable adult that they have their consent to share the information. If consent is withheld then be clear to them why their wishes may need to be overridden. Do not promise confidentiality;
d. Record information, using the vulnerable adult’s own words if possible, and confirm with them that what has been recorded accords with what they have said;
e. Discuss with the vulnerable adult any steps which could be taken immediately to protect them from harm, and what the vulnerable adult will do after the discussion;
f. Invite the vulnerable adult to participate in any discussion with a safeguarding officer
g. Make a report to a Safeguarding Officer ;
h. One of the Lead Safeguarding Officers should decide upon next steps: seeking further advice, informing Tri-Borough Adults Services, informing the Disclosure & Barring Service (DBS) and/or the Police;
i. Advise the vulnerable adult what is going to happen and seek their consent wherever possible; and
j. Advise the vulnerable adult of the outcome of any conversations with outside agencies and what will happen next.
How to deal with suspicions abuse of a vulnerable adult
If there are genuine suspicions that a staff member is abusing a vulnerable adult, staff should:
a. Maintain confidentiality but alert one of the Lead Safeguarding Officers in the first instance.
b. The Lead Safeguarding Officer should take such steps as they consider necessary to ensure the safety of the vulnerable adult in question and any other individuals who might be at risk. The Lead Safeguarding Officer should speak to the vulnerable adult about any actions taken and offer support and advice about what will happen next.
c. The Lead Safeguarding Officer shall keep the person who reported the original concern informed of how the matter is progressing to the extent that this is appropriate.
A member of staff who has any concerns regarding the welfare of a vulnerable adult who is involved in Imperial College activities must report their concerns to their local safeguarding officer as set out in the Safeguarding referrals flowchart [pdf]. The Local Safeguarding Officer will escalate to a Lead Safeguarding Officer who may then refer the case as appropriate to the DBS, to Tri-Borough Adults Services where they have concluded that someone may have caused harm or abuse or poses a risk of harm or abuse to a vulnerable adult, or where there are concerns that that a member of staff may be abusing a vulnerable adult, and/or to the Police where there is a concern that a crime may have been committed.
The Lead Safeguarding Officer will also consult the Disability Advisory Service or Imperial College’s Occupational Health / HR department on whether the student or staff member is known to have has declared a disability and if so whether this is likely to affect their vulnerability.
Staff who are worried about sharing concerns about abuse are encouraged to speak with an appropriate agency such as the Public Concern at Work helpline for further advice.
Where the individual of concern is a member of staff, the Director of Safeguarding will take any relevant action, such as suspension or commencing disciplinary proceedings, if necessary (and if such action has been approved by the Police and/or Tri-Borough Adults Services, where such external agencies are involved).
Imperial College will make a referral to the DBS when a member of staff is dismissed or leaves following safeguarding allegations and where the DBS harm criteria is met.
In the event there is a risk of immediate serious harm to a vulnerable adult the emergency services should be contacted via 4444 if on campus or 999 if off campus or the police via the 101 service. Anybody can make a referral in these circumstances. The Lead Safeguarding Officer should then be notified of the case.
Recording information
The member of staff who raises the initial concern must record what the vulnerable adult disclosed or what they have observed, and speak with a Safeguarding Officer about the case as soon as reasonably possible.
The record should detail what the person said or the incident they witnessed or details of any significant marks or behaviour which were observed, noting any names and contact details (yours and those of the vulnerable adult and any witnesses), dates and times. Staff must bear in mind that this record could become disclosable evidence in the event of a prosecution or other proceedings.
The Safeguarding Officer should record any subsequent actions, decisions or conversations.
A Lead Safeguarding Officer is responsible for forwarding referrals to the DBS.
Safeguarding Officers are responsible for storing information in a secure area and ensuring that only authorised staff have access to this.
Confidentiality
It is impossible to promise complete confidentiality when a concern is raised or an accusation made. Imperial College owes a legal duty of care to its staff, students or visitors that cannot be fulfilled unless it takes action on the basis of information that may have been provided in confidence. The duty of confidentiality must be weighed against the duty of care, in case of potential or actual harm of an individual. Where issues arise via Counselling, Occupational Health, etc alternative specific professional guidelines may need to be followed. At all stages, only those people who need to be made aware of an incident or concern, whether internal or external to Imperial College, should be informed on a ‘need to know’ basis.
Any enquiries made by the media about possible allegations of abuse should be referred to the Communications and Public Affairs immediately.