Safeguarding Policy
Care Monitoring & Governance Platform
| Policy Owner | Creed Expressions Ltd |
|---|---|
| Approved by | Patricia Nkonge |
| Date Approved | 29 May 2026 |
| Next Review | 28 May 2027 |
| Applies to | All staff, contractors, and users of the Platform |
1. Policy Statement
Creed Expressions Ltd is committed to safeguarding and promoting the welfare of all children, young people, and adults at risk who may be supported by care providers using this platform. We recognise that safeguarding is everyone's responsibility.
This policy applies to all employees, contractors, consultants, volunteers, and any third parties who access or use the Platform.
2. Legislative Framework
This policy is underpinned by the following legislation and statutory guidance:
Children:
- Children Act 1989 and 2004
- Working Together to Safeguard Children 2023 (statutory guidance)
- Keeping Children Safe in Education 2023 (where applicable)
- United Nations Convention on the Rights of the Child
Adults at Risk:
- Care Act 2014 — Section 42 safeguarding duty
- Mental Capacity Act 2005 and Deprivation of Liberty Safeguards (DoLS)
- Mental Health Act 1983 (as amended 2007)
- Safeguarding Vulnerable Groups Act 2006
Cross-Cutting:
- Human Rights Act 1998
- Equality Act 2010
- Data Protection Act 2018 / UK GDPR (Article 9 — special category data)
- Serious Crime Act 2015 (Female Genital Mutilation mandatory reporting)
- Counter-Terrorism and Security Act 2015 (Prevent duty)
3. Definitions
3.1 Safeguarding
Safeguarding means protecting people's health, wellbeing, and human rights and enabling them to live free from harm, abuse, and neglect.
3.2 Categories of Abuse
The Platform's incident and safeguarding reporting module captures all recognised categories of abuse:
| Category | Description |
|---|---|
| Physical abuse | Hitting, slapping, pushing, restraint, misuse of medication |
| Emotional / psychological abuse | Threats, humiliation, controlling behaviour, isolation |
| Sexual abuse | Rape, sexual assault, sexual acts without consent |
| Financial / material abuse | Theft, fraud, exploitation, misuse of property or finances |
| Neglect and acts of omission | Failure to provide care, food, medical treatment, or warmth |
| Discriminatory abuse | Harassment based on protected characteristics |
| Institutional / organisational abuse | Poor care practices, rigid regimes, ill-treatment |
| Domestic abuse | Any abuse within intimate or family relationships |
| Modern slavery | Forced labour, human trafficking, exploitation |
| Self-neglect | Failure to maintain personal hygiene, health, or safety |
4. Roles & Responsibilities
4.1 Platform Responsibilities
- Provide a secure, auditable safeguarding reporting workflow within the Platform
- Ensure all safeguarding records are stored with restricted access and a full audit trail
- Maintain this policy and ensure it is accessible to all users
- Appoint a Designated Safeguarding Lead (DSL) for the company
- Ensure staff with access to the safeguarding module receive appropriate training
- Respond promptly to safeguarding concerns raised about the Platform's use or data
4.2 Designated Safeguarding Lead (DSL)
| DSL Name | Patricia Nkonge |
|---|---|
| Deputy DSL | Micheal Semujju |
| Contact | patricia@creedexpressions.com |
4.3 Provider Responsibilities
Care providers using this Platform retain full responsibility as Data Controllers and Regulated Providers for:
- Reporting safeguarding concerns to the appropriate Local Authority Safeguarding Adults Board (LSAB) or Children's Services
- Making referrals to the Disclosure and Barring Service (DBS) where required
- Notifying CQC of serious incidents as required by Regulation 18 (Notification of other incidents)
- Maintaining their own organisational safeguarding policies
5. Confidentiality & Information Sharing
Safeguarding information must be handled with the utmost care. The following principles apply:
- Information will be shared on a need-to-know basis only
- Consent to share information should normally be sought — but where there is risk of serious harm, information can be shared without consent
- The decision to share or not share must be recorded with rationale
- The seven Caldicott Principles apply to all health and social care data sharing
- GDPR does not prevent sharing where there is a lawful basis — do not allow data protection to become a barrier to safeguarding
6. Mandatory Reporting Obligations
Certain safeguarding concerns carry a legal duty to report. Staff and providers must be aware of:
| Obligation | Trigger | Who Reports |
|---|---|---|
| Female Genital Mutilation (FGM) | Identified or disclosed FGM in under-18s | Regulated professionals — mandatory, not discretionary |
| Prevent (Channel) | Concerns about radicalisation | Any staff member — refer to Channel |
| Modern Slavery NRM referral | Potential victim of trafficking or forced labour | First Responders (includes care workers) |
| CQC Regulation 18 Notification | Deaths, serious injuries, abuse allegations in regulated settings | Registered Manager of CQC provider |
| Local Authority S42 Enquiry | Abuse or neglect of adult at risk | Any professional — duty to refer |
| DBS Referral | Staff dismissed / removed due to harm or risk of harm to vulnerable persons | Employer — mandatory referral |
7. Training Requirements
All staff with access to the safeguarding module of the Platform must have completed appropriate safeguarding training:
| Role | Minimum Training Level | Renewal Frequency |
|---|---|---|
| All platform users | Safeguarding Awareness (Level 1) | Every 2 years |
| Managers with DSL access | Safeguarding Practitioner (Level 2) | Every 2 years |
| Designated Safeguarding Lead | Advanced / Level 3 + DSL training | Every 2 years |
| Platform staff with data access | Safeguarding Awareness + Data Protection | Every 2 years |
Training completion is tracked within the Platform's Staff Compliance module. Automated alerts notify managers of expiring certificates.
8. Policy Breach & Disciplinary Action
Failure to comply with this policy, including failure to report a safeguarding concern, may result in:
- Disciplinary action up to and including dismissal
- Referral to the Disclosure and Barring Service
- Referral to professional regulatory bodies (NMC, HCPC, SWE etc.)
- Police referral where a criminal offence may have been committed
9. Related Policies & Documents
- Data Protection Policy and DPIA
- Whistleblowing Policy
- Safer Recruitment Policy
- Code of Conduct
- Incident Reporting Procedure
- Information Sharing Protocol
This policy should be reviewed annually or following any safeguarding incident, legislative change, or significant change to the Platform's processing activities.