Safeguarding Policy

Our Commitment to Safeguarding

Hildenborough and Tonbridge Medical Group is committed to safeguarding and promoting the welfare of children, young people, and adults at risk. We recognise that all children, young people and adults at risk have a right to protection from abuse and neglect, and the practice accepts its full responsibility to safeguard the welfare of such persons with whom staff may come into contact.

We will respond quickly and appropriately where information requests are made, abuse is suspected, or allegations are made. We will give children, young people, their parents, and adults at risk the opportunity to raise concerns over their own care or the care of others, and we have a clear system in place for managing, escalating and reviewing those concerns.

Safeguarding is the responsibility of every member of our team

Scope of This Policy

This policy applies to all members of practice staff, including clinical and non-clinical team members, trainees, volunteers and contractors. It covers the following areas:

• Safeguarding children and young people (under 18 years of age)
• Safeguarding adults at risk / vulnerable adults
• Domestic abuse and coercive control
• Female Genital Mutilation (FGM)
• County Lines and criminal exploitation
• Modern slavery and human trafficking
• Honour-based violence and forced marriage
• CONTEST / PREVENT — preventing radicalisation

Our Named Safeguarding Leads

Our practice has designated Safeguarding Leads who are responsible for overseeing safeguarding activity, providing advice and support to staff, and liaising with external agencies. All staff know who the safeguarding leads are and how to reach them — including out of hours.

• Safeguarding Adult Lead: Dr Nicki Perry – GP Partner
• Safeguarding Children Lead: Dr Rahul Joshi – GP Partner
• Safeguarding Administration Lead: Joanne M / Charlie C

Principles of Safeguarding

Our approach to safeguarding is guided by the six statutory principles:

• Empowerment: Supporting people to make their own decisions and give informed consent
• Prevention: Taking action before harm occurs
• Proportionality: The least intrusive response appropriate to the risk presented
• Protection: Support and representation for those in greatest need
• Partnership: Local solutions through services working collaboratively
• Accountability: Transparency and accountability in safeguarding practice

Safeguarding Children and Young People

We follow the statutory guidance set out in Working Together to Safeguard Children (2023) and adhere to our Local Safeguarding Children Partnership (LSCP) — Kent Safeguarding Children Multi-Agency Partnership (KSCMP) — procedures.

Our approach includes:

• Ensuring all staff complete safeguarding children training at the required level for their role
• Identifying children and young people who may be at risk of harm, abuse, neglect or exploitation — including County Lines involvement
• Monitoring Looked After Children (LAC) and children subject to Child Protection Plans
• Maintaining accurate, contemporaneous records using appropriate SNOMED CT codes
• Referring concerns to Children's Social Care or the police without delay where a child may be at risk of significant harm
• Following up 'Was Not Brought' (WNB) appointments — children rely on adults to bring them, and missed appointments are taken seriously
• Participating in Child Protection Conferences, Core Groups and multi-agency meetings as appropriate
• Following the Child Protection Information Sharing (CP-IS) system

Safeguarding Adults at Risk

We follow the Care Act 2014 and the statutory guidance Making Safeguarding Personal, working in line with Kent and Medway Safeguarding Adults Board (KMSAB) procedures.

Our approach includes:

• Making safeguarding personal — always seeking the views and wishes of the adult at risk
• Identifying adults experiencing abuse, neglect, exploitation, modern slavery or financial abuse
• Applying the Mental Capacity Act 2005 and Liberty Protection Standards appropriately
• Referring to Adult Social Care under Section 42 of the Care Act 2014 where safeguarding concerns exist
• Managing concerns about a Person in a Position of Trust (PiPoT) through the appropriate local authority safeguarding framework

Domestic Abuse

We recognise that domestic abuse — including physical, emotional, sexual, financial, technological and coercive control — has a significant impact on the health and wellbeing of patients and their families. The Domestic Abuse Act 2021 shapes our approach.

Our approach includes:

• Training staff to recognise indicators of domestic abuse and to make safe enquiries sensitively
• Using the DASH (Domestic Abuse, Stalking and Honour-based Violence) Risk Identification Checklist where appropriate
• Making appropriate MARAC referrals for high-risk cases
• Providing information about local and national support services
• Signposting to the National Domestic Abuse Helpline: 0808 2000 247 (free, 24 hours)

Female Genital Mutilation (FGM)

FGM has been illegal in the UK since 1985. The Serious Crime Act 2015 strengthened requirements for healthcare professionals. FGM is a form of child abuse and violence against women and girls.

Our approach includes:

• Training clinical staff to identify patients at risk of FGM or affected by FGM
• Complying with the mandatory reporting duty: any regulated health professional who identifies that a girl under 18 has had FGM must report this to the police
• Documenting FGM using correct SNOMED CT codes in patient records
• Referring under-18s at risk using standard safeguarding procedures to Children's Services
• Treating patients with sensitivity and compassion

County Lines, Modern Slavery and Exploitation

We recognise that exploitation can take many forms. County Lines involves gangs using children and vulnerable adults to move drugs and money, often involving intimidation and violence. Modern slavery includes trafficking, servitude and forced labour.

Staff are trained to recognise indicators such as unexplained injuries, missing episodes, unexplained money or phones, association with controlling individuals, and signs of physical or emotional abuse. Concerns are escalated to the Safeguarding Lead in the same way as other safeguarding concerns.

CONTEST / PREVENT

As part of the Government's counter-terrorism strategy CONTEST, the PREVENT duty requires us to have due regard to the need to prevent people from being drawn into terrorism, including violent and non-violent extremism.

Any member of staff who suspects that an individual may be at risk of radicalisation should speak to the Safeguarding Lead or, in their absence, the Practice Manager. Referral to the regional PREVENT Coordinator (RPC) or the CHANNEL programme may be made where appropriate

Safeguarding Escalation Process

We have a clear, step-by-step escalation process in place. Every member of staff — clinical and non-clinical — is responsible for recognising and reporting concerns. No concern should ever be dismissed or left unrecorded.

1. IDENTIFY — Any staff member who notices signs of abuse, neglect, exploitation, a patient disclosure, concerning behaviour, or missed appointments raising concern must take it seriously, remain calm and non-judgemental, and reassure the person. Never promise confidentiality.
2. IMMEDIATE RISK CHECK — Ask: is anyone in immediate danger? If YES, call 999 immediately and inform the Safeguarding Lead or Duty GP as soon as safe. If NO, proceed to Step 3.
3. RECORD — Document the concern factually and contemporaneously in the patient record. Use the patient's own words where possible. Avoid opinion. Record date, time, what was seen or heard, who was present, and any actions taken. Apply appropriate SNOMED safeguarding codes.
4. ESCALATE INTERNALLY — Escalate the same working day to the Safeguarding Lead GP or Nurse, or the Deputy Lead, or the Duty GP / Practice Manager if leads are unavailable. The Lead reviews clinical history, previous flags, family context and threshold of concern.
5. DECIDE LEVEL OF RESPONSE — The Safeguarding Lead decides and documents the appropriate response (see response levels below).
6. EXTERNAL ESCALATION — Where required, refer to Children's or Adult Social Care, police, MARAC, or other agencies. Phone referral should be followed by written confirmation within 24 hours.
7. FOLLOW-UP AND REVIEW — Track outcomes of referrals, set reminders in the clinical system, arrange follow-up appointments, discuss at MDT meetings, update the safeguarding register.

Response Levels

Was Not Brought (WNB) — Missed Appointments

Children and young people depend on adults to bring them to appointments. At this practice, a missed appointment for a child or young person is referred to as 'Was Not Brought' (WNB) — a term that reflects this dependency clearly.

Whilst many missed appointments are genuine oversights, repeated cancellations or WNBs give cause for concern. Every WNB is reviewed by a clinician who assesses the risk to the individual's welfare, considering the reason for the appointment, any previous safeguarding concerns, and any known factors in the family. Appropriate SNOMED codes are applied and the parent or guardian is contacted in accordance with the flowcharts contained in the Safeguarding Handbook.

Confidentiality and Information Sharing

We understand that confidentiality concerns can be a barrier to reporting. However, the protection of individuals at risk takes precedence. We follow the UK GDPR, the Data Protection Act 2018, and NHS guidance on information sharing.

Information will only be shared on a need-to-know basis. Where possible, consent to share will be obtained. However, where a person is at risk of significant harm, information may be shared without consent. All decisions — to share or not to share — are recorded with the rationale documented.

Our guiding principle: information sharing saves lives.

Training and Development

All staff complete safeguarding training appropriate to their role, in line with the Intercollegiate Documents for Children and Adults and RCGP supplementary guidance. Training is refreshed regularly.

Minimum Level Required

• GPs and Clinical Staff: Level 3 Children; Level 3 Adults
• Practice Nurses, ANPs, Paramedics: Level 3 Children; Level 3 Adults
• Care Navigation Team / Reception: Level 1 Children and Adults
• Care Navigation Team Lead: Level 2 Children and Adults
• Practice Manager: Level 2 Children and Adults
• Named Safeguarding Leads: Level 3 Children and Adults

Governance and Quality Assurance

Safeguarding governance at this practice includes:

• A written safeguarding policy reviewed annually by the safeguarding leadership team
• Named Safeguarding Leads for adults, children and administration
• A safeguarding register maintained by the Administration Manager, reviewed quarterly
• Regular MDT safeguarding meetings with updates shared across the team
• Annual safeguarding audit against the CQC audit tool
• A clear whistleblowing process enabling all staff to raise concerns safely
• Safer recruitment procedures including enhanced DBS checks for all appropriate roles
• Safeguarding responsibilities defined in all staff job descriptions
• CQC statutory notifications submitted as required

Relevant Legislation and Guidance

This policy has been developed in line with the following legislation and statutory guidance:

• Children Act 1989 and 2004
• Childcare Act 2006
• Working Together to Safeguard Children (2023)
• Care Act 2014
• Mental Capacity Act 2005 and Mental Capacity (Amendment) Act 2019
• Domestic Abuse Act 2021
• Female Genital Mutilation Act 2003 (as amended by Serious Crime Act 2015)
• Human Rights Act 1998
• UK GDPR and Data Protection Act 2018
• CONTEST / PREVENT Duty Guidance
• NHS England: Safeguarding in Primary Care
• CQC GP Mythbusters 25 (Adults), 33 (Children) and 80 (FGM)
• RCGP Supplementary Guide to Safeguarding Training Requirements

Key Contacts

• Named GP for Safeguarding (ICB): Dr Katie Collier
• Designated Nurse — Safeguarding Children: India Sholeh
• Designated Nurse — Safeguarding Adults: Tracey Creaton
• PREVENT Lead / Designated Nurse: Pauline Grieve

Reporting

• Kent Children's Social Care (Front Door): frontdoor@kent.gov.uk | 03000 41 11 11
• Kent Out of Hours Children's Services: 03000 41 91 91
• Kent Adult Social Care: 03000 41 61 61
• Kent & Medway SAB: Report Adult Abuse
• KSCMP (Children's Partnership): Report Child Abuse
• Police (non-emergency): 101
• Police / Emergency Services: 999
• National Domestic Abuse Helpline: 0808 2000 247 (free, 24 hours)
• NSPCC Helpline: 0808 800 5000
• Forced Marriage Unit: fmu@fcdo.gov.uk | 020 7008 0151