A. Introduction and purpose
Safeguarding means protecting people's health, wellbeing and human rights, and enabling them to live free from harm, abuse and neglect. At Scottish Book Trust we understand this to mean protecting people, including children and at-risk adults, from harm that may arise from coming into contact with our staff or our programmes, either face to face or online.
This policy applies to all Scottish Book Trust staff and the Board of Trustees, as well as to contractors, consultants, freelancers, creative practitioners, student placements, interns or anyone else working on behalf of Scottish Book Trust.
This policy is concerned with our commitment and approaches to safeguarding adults at risk of harm. For information on our approach to safeguarding for Children and Young People please see our parallel Scottish Book Trust Child and Young Person Protection Policy.
Adult at risk is defined in the Protection of Vulnerable Groups (Scotland) Act 2007 as anyone over 16 who:
- Are unable to safeguard their own well-being, property, rights or other interests
- Are at risk from harm
- Because they are affected by disability, mental disorder, illness or physical or mental infirmity, are more vulnerable to being harmed than adults who are not so affected
An adult is at risk for the purposes above if:
- Another person's conduct is causing or is likely to cause the adult to be harmed, or
- The adult is engaging in (or is likely to engage in) conduct which causes (or is likely to cause) self-harm
This policy recognises that young people aged between 16 and 18 years can be considered both adults and children. For those under 18 we will apply the child protection policy.
Scottish Book Trust is committed to safeguarding the wellbeing of everyone the charity interacts with and as such our approach can be summarised under three headings:
- Safeguarding people engaging with our programmes – audiences, participants, donors, research and evaluation participants – particularly adults at risk.
- Ensuring the welfare of people employed by us – staff, freelancers, creative practitioners, student placements, interns and volunteers
- Safeguarding in partnership – how we ensure best safeguarding practice with organisations whom we either co-deliver programmes and opportunities with or fund to deliver events and activities as part of Scottish Book Trust programmes.
This policy will be reviewed on an annual basis.
B. Roles and Responsibilities
1. Setting policy
Scottish Book Trust's Board of Trustees and the Chief Executive are responsible for ensuring an appropriate adult safeguarding policy is in place and staff are trained in the use of the policy. The policy is regularly reviewed annually by the Designated Adult Safeguarding Officer to ensure it is up to date and compliant with current legislation and best practice.
2. Accountability and responsibility for this policy
Accountability for this policy rests with the Director of Operations and Finance but all employees, partners and volunteers have a duty to know what action to take if they are concerned that a participant, or colleague, is at risk.
Individual teams will have specific policies and procedures around their own areas of work and the Adult Safeguarding Officer should be involved in the development and review of such policies. These include, but are not exclusive to:
- Evaluation and Research
- Press and Media
Heads of Team have a responsibility to ensure that any new activity developed for participants/audiences is appropriate and acceptable. Each team will appoint a safeguarding representative who will attend regular safeguarding and welfare meetings with the Adult Safeguarding Officer to raise any issues their teams may encounter and feedback any safeguarding or welfare practice or issues to the teams. Safeguarding will be a standing item on management meetings to ensure that new projects are discussed and any arising measures/project parameters are agreed before the activity is carried out.
3. Lead Officers
Scottish Book Trust has a Designated Adult Safeguarding Officer, and a deputy, to whom staff can refer any concerns or issues regarding adult safeguarding or discuss and seek guidance on adult safeguarding more generally. The contact details are as follows:
Designated Adult Safeguarding Officer
Philippa Cochrane, Head of Reading Communities
Telephone: 0131 524 0160
Deputy Designated Adult Safeguarding Officer
Katherine Wilkinson, Head of Research and Evaluation
Telephone: 0131 524 0160
The activities carried out by Scottish Book Trust means that a range of employees, freelancers and supported partners may come into contact with adults who are at risk of harm.
Much of Scottish Book Trust's work with adults involves supporting participants to share personal stories. Our programmes seek to ensure that people from all walks of life and with a diverse spectrum of lived experience have the opportunity to share their stories, to ensure that those stories find an audience of readers and are valued by those who read them. People who are engaging with the creative processes of reading and writing can often find emotions are triggered or emotional states created where they will open up and may share information with their peers, our staff or our freelance practitioners. Whilst such sharing or triggering might not be anything to worry about or cause concern, this aspect of our work can bring specific safeguarding challenges around:
- The disclosure of historic and/or current harm and abuse
- Informed consent around where and how stories are shared
- Responsibilities around the readers who might access them
We recognise that we have responsibilities to ensure the welfare of people in three areas:
1. Safeguarding for adults at risk engaging with our programmes
Adults at risk may participate in our programmes by engaging with our content, attending events, taking part in workshops and activities and by sharing their own creative work, including sharing personal stories. In all instances our programmes must:
- Promote safety in person and online
- Ensure that adults at risk have as much choice and control over their participation as possible
- Focus on improving life for the person concerned
- Balance the promotion of safety and informed decision making with respecting the views and wishes of the individual
- Signpost accessible information and support about how to stay safe and how to raise a concern
- Consider that participating adults come from a diverse range of backgrounds and some may be sensitive to certain issues and situations
2. Ensuring the welfare of people employed by us – staff, freelancers, creative practitioners, student placements, interns and volunteers
Because some of our work is focussed on supporting people to share personal stories that matter to them, employees and freelancers can experience increased mental health and wellbeing impacts. Scottish Book Trust has a responsibility to ensure that employees and freelancers are:
- Supported (through Scottish Book Trust guide materials and/or training) to establish professional boundaries for themselves and participants
- Able to access support immediately following any activity to discuss any concerns around disclosure
- Aware of safeguarding policy and their responsibilities and clear about procedures, appropriate channels and available support for raising any safeguarding concern
- Provided with appropriate time to plan and debrief sessions – particularly with staff from Scottish Book Trust and any partner organisations
- Aware of procedures and support for lone working
3. Partnership working
How we support best safeguarding practice with organisations with whom we co-deliver programmes and opportunities. Scottish Book Trust engages in two distinct kinds of partnership working:
- Working with partners in active joint delivery of the programme, where the partner organisation brings the expertise in supporting the audience/participants they work with. This work will take the form of co-planned and delivered programmes of work. Scottish Book Trust will agree with partners how safeguarding policy will be incorporated into the project as part of the project inception process.
- Supporting partners financially and in other ways to participate in Scottish Book Trust programmes. This work takes place at arm's length with funded partners reporting to Scottish Book Trust on their activity. Scottish Book Trust will share tools with partners to support good safeguarding practice – including a safeguarding check sheet, risk assessment template, reporting template.
D. Policy Statement
Scottish Book Trust's adult safeguarding and welfare policy document is based on the following principles:
- The welfare of all people engaging in our programmes is paramount and the best interests of adults at risk must always be the primary consideration.
- All adults at risk should be treated fairly and with dignity and respect
- All people, regardless of age, disability, gender reassignment, race, religion or belief, sex, or sexual orientation have a right to equal protection from all types of harm or abuse
- All adults at risk have a right to express their views on matters that affect them
- Empowerment – people being supported and encouraged to make their own decisions and to exercise informed consent. 'I am asked what I want as the outcomes of the safeguarding process.'
- Prevention – it is better to take action before harm occurs
- Proportionality – making the response appropriate to the risk
- Protection – support and representation for those in greatest need
- Partnership – finding solutions through partnership with organisations supporting an individual and working in their communities
- Accountability and transparency
Scottish Book Trust will:
- Value, respect and listen to people participating in our programmes
- Appoint an Adult Safeguarding Officer and a Deputy Adult Safeguarding Officer, to uphold this policy and to give staff and freelance staff the appropriate support to be able to put it into practice
- Maintain an open and supportive organisational culture where staff can discuss any concerns or issues around adult safeguarding with their colleagues, manager or the Adult Safeguarding Officer and Deputy Adult Safeguarding Officer
- Take seriously any concerns over an adult at risk's safety or welfare and take appropriate action as soon as possible
- Adopt adult safeguarding best practice through our policies, procedures and code of conduct for staff and freelancers
- Develop and implement an effective digital adult safeguarding policy and related procedures
- Provide effective management and support of staff and freelancers through appropriate training, support and quality assurance measures
- Ensure safeguarding is a core part of all project inception meetings and ongoing project meetings
- Ensure that all freelancers and partners working with Scottish Book Trust are issued with this policy in advance of work beginning
- Assess each programme to determine whether basic or enhanced PVG is required for those delivering and obtain the requisite PVG accordingly
- Recruit staff and freelancers safely, ensuring all necessary checks are carried out
- Record and store personal information securely – according to GDPR standards
- Use our adult safeguarding procedures to share concerns and relevant information with any agencies who need to know, and involving adults at risk, and, as they wish and with their consent, those in their support network which could be family, carers or friends.
- Use our adult safeguarding procedures to appropriately manage any allegations against staff or freelancers
- Create and maintain an anti-bullying environment
- Ensure we have effective complaints and whistleblowing measures in place
- Ensure we provide a safe physical environment for participants, staff and freelancers, by applying health and safety measures and risk assessments in accordance with the law and regulatory guidance
- Provide a Scottish Book Trust contact whenever activities are taking place, including out of office hours, to provide advice and support on safeguarding issues. To be agreed at the start of any project.
- Use risk assessments to ensure that where potential risk to an individual is identified, appropriate measures are put in place to mitigate such a risk
- Agree with partners how to manage safeguarding jointly during the project. This may include:
- Provide a copy of our safeguarding policy and request a copy of the partner's
- Agreeing reporting procedures, including named points of contact in each organisation (as per safeguarding policies)
- Setting regularly safeguarding meetings to review process – including project leads and practitioners
- Delivering a shared safeguarding induction to any practitioners hired for the project
- Signpost to safeguarding legislation and expertise/training
- Develop and share tools with partners who need them to support good safeguarding practice – including a safeguarding check sheet, risk assessment template, reporting template etc
- Require funded partners to have a safeguarding policy in place with PVG certificates received for all relevant personnel
E. Disclosures of harm
Recognising abuse and harm
The following summary outlines the keys areas of abuse and harm that adults at risk may be subject to.
- Physical abuse is deliberately hurting a person causing injuries such as bruises, broken bones, burns or cuts.
- Neglect is the ongoing failure to provide the amount and type of care that a reasonable person may be expected to provide. It can be the intentional or unintentional failure to provide medical, social or educational needs. It is withholding necessities such as food, drink, warmth and a lack of protection from hazards.
- Sexual abuse is when a person is forced or persuaded to take part in sexual activities. This doesn't have to be physical contact and it can happen online.
- Psychological or emotional harm is the ongoing emotional maltreatment of a person. It can involve deliberately trying to scare or humiliate a person or isolating, controlling, harassing, intimidating, coercing or ignoring them. It can happen online and includes cyber bullying.
- Financial harm is when someone prevents a person from having control over their own finances in order to exert control over that person. Financial harm can involve the theft of money or material belongings, the fraudulent use of money or belongings, coercion and undue influence to relinquish money or property; it can also involve the improper use of a legal authority, such as a Power of Attorney.
- Self harm is when a person is neglecting to care for their personal hygiene, health or surroundings. It might include hoarding.
Who can be abusers?
Where can abuse happen?
Anywhere, including online.
You can find more detail on the types and indicators of abuse.
F. Noting and sharing a concern
Given the nature of our work, it is unlikely that staff or freelance practitioners will encounter an abuse situation or disclosure. However, should this happen, it is important to take it seriously and act as soon as possible.
It can be very hard for an adult at risk to speak out about abuse. Often they fear there may be negative consequences if they tell anyone what's happening or has happened to them. It is vital therefore that whoever they tell takes them seriously and acts on what they've been told.
Even if an adult at risk doesn't tell someone verbally about what's happened to them, there may be other indicators that something is wrong. These could include subdued or changed behaviour, uncharacteristic failure to engage in social interaction, unkempt appearance, frequent injuries, bruising, signs of malnutrition.
In the course of our work, it is important to maintain an open and supportive culture around safeguarding adults at risk with Scottish Book Trust staff, our partners and the communities we work with. Therefore, we should communicate any concerns about a adult at risk as soon as we become aware of it.
The majority of Scottish Book Trust's work with adults at risk happens in partner and community settings such as libraries, partner run activity spaces and community centres, where participants are in groups and accompanied by partner staff and carers, as well as our staff. Staff members are therefore not alone with adults at risk or in sole charge; partners staff are usually supporting the groups and the adults at risk.
In these circumstances, protocols around safeguarding will have been agreed as part of the project inception. If a staff member has a concern that vulnerable person is at risk of harm of experiencing abuse, they should follow that agreement, which should at least require that they should speak to the named safeguarding contact within the partner organisation. This safeguarding contact may well be aware of the situation and be able to reassure the staff member that the issue is being dealt with or agree that they will make a note of the concern and refer it through the usual channels of reporting. The issue should still be treated confidentially and noted by the staff member for reporting on their return to the office, to their line manager and the Designated Adult Safeguarding Officer. All concerns should be reported and Scottish Book Trust will record who was informed at a partner organisation and what steps were agreed, including if the decision was made that no further action was needed. If staff need adult safeguarding advice whilst they are away from the office, they should contact their line manager, the Designated Adult Safeguarding Officer or Deputy Designated Adult Safeguarding Officer by phone.
You can request a form for recording a concern by emailing us at firstname.lastname@example.org.
Whenever designing a new project, or delivering a new series of workshops or new events, whether to be delivered in person or online, Scottish Book Trust staff must complete a Safeguarding Risk Assessment form and have it signed off by one of the safeguarding team (Head of Operations and Finance, Adult Safeguarding Officer, Deputy Adult Safeguarding Officer).
Where working to deliver a sustained project with freelancers and/or partner organisations, the risk assessment form should be completed together as part of the project inception meetings. Where freelancers are being asked to deliver one off workshops, Scottish Book Trust staff should complete the risk assessment form for the project as a whole.
If you are a partner or affiliate please contact your Scottish Book Trust representative if you need these forms.
Due to the nature of our programmes for adults, and the preferences of participants there are situations where a Scottish Book Trust staff member or freelance practitioner may be working one-to-one with a member of the public or an adult at risk. This should be identified through the risk assessment process at the start of any project.
NB – no Scottish Book Trust staff member or freelance practitioner should be alone with an adult at risk unless with the prior consent of the adult you are working with, provided they are considered to have the capacity to make that decision for themselves. Where an adult is considered not to have that capacity, similar permission needs to be sought from an appropriate adult and/or the person who makes decisions on their behalf and the need for one-to-one working should be assessed with the Designated Adult Safeguarding Officer and/or a line manager and deemed to be essential to their participation in the programme prior to the permission being sought.
Dealing with disclosure
It is more likely that staff or freelance practitioners may have stories shared with them that contain information about historic instances of harm or abuse. These may be shared directly in a workshop setting or they may be submitted remotely via the Scottish Book Trust website. In these circumstances it is important to ensure that the individual sharing that story is informed about their options for sharing that story, how it may be used and who will be able to find and read it and it is imperative to make sure that they know their piece will not be shared anywhere without their express permission.
If an adult at risk makes a disclosure of abuse or harm to you:
- Listen carefully to what the person tells you, stay calm, get as clear a picture as you can, but avoid too many questions at this stage
- Assure them that the matter will be taken seriously
- Do not give promises of confidentiality, but do reassure them that the matter will only be discussed with those who need to know about it
- Ask the person what they would like to happen
- Explain that you have a duty to tell your manager or other designated person in any partner organisation and that information may need to be shared with others who could have a part to play in protecting them
- If they have specific communication needs, provide support and information in an appropriate way
- Don't judge or jump to conclusions
- Report concerns to the lead partner contact and your manager in line with agreed safeguarding procedures
- Make a record of the concern and the action taken
Any adult safeguarding concern should be recorded by the staff member as soon as possible following the awareness or disclosure. In the first instance, this can be in the form of a confidential written note which can then be used to write up a fuller formal report where necessary.
The following key information should be noted:
- The date and time of the incident or concern arising
- The setting and/or circumstances
- Who else was present
- The nature of the concern or disclosure
- A note of the actual words spoken by the vulnerable adult about the incident or issue
- Who the information was shared with
- What action was taken
Please email us at email@example.com request appropriate forms to record a disclosure.
The Designated Adult Safeguarding Officer/Deputy Designated Adult Safeguarding Officer or line manager will review this, confirm any further action required and make a note of it. If the situation merits, this information can also be passed on to the lead safeguarding contact for any partner organisation or any other agency which becomes involved.
However, if the situation is urgent and the adult's safety is in immediate danger, the staff member should call the local authority Social Services duty officer, the police or the emergency services, whichever is appropriate to the nature of the risk.
Read more on adult support and protection on the Act Against Harm website.
Find your local contact for reporting urgent incidents.
The information should be stored securely, in accordance with our Data Protection Policy, and signed off by the staff member as an accurate record.
If merited, the incident will also be reported to the Board under the Significant Incident Reporting system.
Notwithstanding the need to report concerns as soon as possible to the relevant named/responsible adult and/or the staff member's line manager/Designated Adult Safeguarding Officer, it is important that in the course of reporting such concerns, confidentiality is managed internally and we should not involve other staff unnecessarily. Any decision to share information related to these concerns beyond the responsible adult/named person should be taken in consultation with the line manager or Designated Adult Safeguarding Officer, unless the situation is urgent, is an emergency or a person is at risk of serious harm, in which case other agencies should be alerted as appropriate.
Concerns about staff or freelancers
If staff have concerns about the behaviour of/need to pass on allegations about another member of staff or a freelancer working on our behalf, they should speak to the Designated Adult Safeguarding Officer/Deputy Designated Adult Safeguarding Officer.
If staff have concerns about the behaviour of the Designated Adult Safeguarding Officer or Deputy Designated Adult Safeguarding Officer, they should speak to a member of the Senior Management Team.
E. Further support
F. Risk assessment and general good practice
When planning and carrying out our work involving adults, and particularly adults at risk, the following general rules should help to provide a supportive and safe environment for staff and participating adults:
- Before beginning work on the project complete a risk assessment and have it signed off by either the Director of Operations and Finance, the Adult Safeguarding Officer or the Deputy Adult Safeguarding Officer
- Ensure that circumstances where working one to one with an adult are the best option to enable that person to take part in the programme. If you are working one-to-one with an adult at risk, ensure that they have given prior consent to work in this way. Where an adult is considered not to have that capacity, similar permission needs to be sought from an appropriate adult and/or the person who makes decisions on their behalf and the need for one-to-one working should be assessed with the Designated Adult Safeguarding Officer and/or a line manager and deemed to be essential to their participation in the programme prior to the permission being sought
- Where possible/appropriate, plan to work with support from at least one member of staff from the partner organisation
- When working in partnership, hold at least one inception meeting, including Scottish Book Trust staff, partner organisation staff and any freelancers working on the project, focussed on safeguarding. In that meeting you should:
- Share safeguarding policies and identify any situations where those policies may differ – agree the importance of monitoring safeguarding to our standards
- Establish which organisation is the safeguarding lead (if you are working with an organisation that works with the participant's regularly and therefore has built a higher level of trust and expertise it is most appropriate that they should be the safeguarding lead)
- Establish whether at any point any staff member or freelancer will need to have one-to-one contact with an adult at risk. This should only be the case if no model of team delivery will ensure that the adult at risk will have an accessible, positive and meaningful experience of taking part in the programme. In circumstances where one-to-one working is required, agree who will need PVG scheme membership
- Conduct a shared risk assessment of the activity
- Agree who has what safeguarding responsibilities
- Agree any required protocols around safeguarding for shared working – including regular safeguarding meetings, how to progress any report of disclosure, delivery parameters in terms of number of staff/freelancers in place for each engagement, how to set a safe space for each engagement, how to debrief, if necessary, following each engagement.
- While planning any project, risk assess your activities and the environment from a participant's perspective, as well as your own. Every risk assessment must be signed of by either the Director of Operations and Finance or the Designated Adult Safety Officer or Deputy Adult Safety Officer
- Model good behaviour, maintain appropriate boundaries. This includes not making contact with an adult at risk outside organised workshops, unless for the specific purpose of making practical arrangements for their participation.
- Respect the agency and expressions of all participants whilst also establishing, together with participants, the boundaries and expected behaviours necessary to ensure that all participants feel safe and respected .
Event and activity planning
Staff should use one of the available templates, as appropriate to the programme/event being planned.
Please email us at firstname.lastname@example.org request appropriate forms.
G. Recruitment and Disclosure Scotland
An important element of Scottish Book Trust's Adult Safeguarding and Welfare Policy is to recruit appropriately trained and experienced staff into post. All staff who, through their work with Scottish Book Trust, have access to adults at risk in any form (e.g. face to face, telephone, online, through our programme submissions) must have basic clearance from Disclosure Scotland.
PVG scheme membership is required for staff or freelancers delivering our programmes who will have or could have one-to-one unsupervised contact with adults at risk.This clearance is obtained as part of the recruitment and appointment process and is renewed every three years for continuing staff. In addition, the appraisal process checks annually whether there is any change to the nature of a staff member's role which requires a new disclosure or a higher level of disclosure i.e. membership of the PVG scheme.
The HR and Operations Team is responsible for ensuring the appropriate disclosure checks/memberships are made prior to appointment and reviewed at the three year anniversary.
Line managers are responsible for checking annually during the appraisal process that the Disclosure level is appropriate and in place before signing off the appraisal.
H. Allegations of abuse made against Scottish Book Trust employees and freelancers
Where a Scottish Book Trust employee or freelancer is alleged to have abused someone, the following procedures must be followed.
The employee or freelancer's supervisor must discuss the allegation with the Safeguarding officers and the Director of Operations and Finance and, where relevant, the appropriate partner organisation and on the safeguarding team's recommendation agree:
- Whether the allegation needs to be reported to the police
- Whether the employee or freelancer is able to continue in their normal duties or whether adjustments should be made to their work to protect them and/or others
Adjustments may include:
- Changing their role to temporarily remove them from having direct contact with members of the public
- If they work alone in the community, arranging for them to work with someone else rather than alone
- Temporarily suspending them from work, either on full pay, or with payment of any agreed fee for sessions missed
Making an adjustment to a role does not in any way imply guilt. It is purely an action designed to allow an investigation to be carried out as quickly as possible while minimising risk.
All employees and freelancers who are alleged to have abused someone will be offered appropriate support until any investigation, internal and/or external is concluded.
All allegations will be looked into and as a minimum will involve an initial process to establish the facts and whether a formal investigation is warranted. The statutory authorities have thresholds which must be met before an alleged offence will be investigated by them and therefore not all allegations will be forwarded to the relevant authority for investigation. In all cases however, the safeguarding team will be involved from the outset.
Following on from any external involvement, a formal internal process will be carried out under the disciplinary policy for employees and the code of conduct for freelancers.
The Director of Operations and Finance will advise on this process and on an appropriate person to carry it out
Line managers and Heads of Team must ensure that all staff who work with or come into contact with Adults at risk of harm as part of their role at Scottish Book Trust have attended the Social Care Institute for Excellence (SCIE) online safeguarding training.
Scottish Book Trust nominates a Designated Adult Safeguarding Officer who is required to complete the SCIE online safeguarding training or refresher course prior to appointment to this role. Refresher training should be undertaken where changes to legislation occur but at least every three years. The Deputy must also complete the SCIE online safeguarding training.
The Designated Adult Safeguarding Officer/Deputy Designated Adult Safeguarding Officer will hold workshops or one-to-one sessions as required to ensure new staff, or staff new to a post, where working with adults at risk is a significant part of their role are confident they understand the Safeguarding and Welfare for Adults Policy and know how to implement it.
The Designated Adult Safeguarding Officer and Deputy Designated Adult Safeguarding Officer will monitor through newsletters and other networking channels any changes to legislation and best practice and ensure the Safeguarding and Welfare for Adults Policy is kept up-to-date. Changes to the Safeguarding and Welfare for Adults Policy will be flagged to staff and relevant training given if the changes are significant.
Legal framework and link to other Scottish Book Trust policies
This policy has been drawn up on the basis of legislation, policy and guidance that seeks to protect adults as risk of harm in Scotland:
- Adult Support and Protection (Scotland) Act 2007
- Adults with Incapacity (Scotland) Act 2000
- Community Care and Health (Scotland) Act 2002
- Mental Health (Care and Treatment) (Scotland)Act 2003
- Equality Act 2010
- Human Rights Act 1998
- European Convention on Human Rights (ECHR)
- Data Protection Act 2019
Other Scottish Book Trust policies and procedures connected to adult safeguarding are:
- Child Protection Policy
- Adult Safeguarding Risk Assessment
- Media Authorisation Forms and process
- Recruitment Policy (including Disclosure Scotland processes)
- Health and Safety Policy
- Data Protection Policy (including Data Sharing)
- Equal Opportunities Policy
- Bullying & Harassment Policy
- Email, Internet and Social Networking Policy
- Complaints Policy
- Whistleblowing Policy
- Significant Incident Reporting