NHS LondonLondon-wide Overview ReportSafeguarding Adults Self Assessment andAssurance Framework (SAAF)March 2012A thematic Review

2

Summary

The Safeguarding Adults Self Assessment and Assurance Framework (SAAF) forHealth Care Services was completed in 2011 by 47 organisations or partnerships.The planned process for this first self assessment did not include external validation,so the findings in this report should be treated as indicative and used as learningpoints for future development. The NHS Operating Framework for 2012/13 gives ahigher priority to safeguarding, so there is a good opportunity for NHS organisationsto prepare now to improve their individual and cluster performance.

The report provides a commentary on the self assessed performance against each ofthe SAAF standards and highlights reported examples of good practice.

Overall it was encouraging that organisations appeared to have systems andprocesses in place to meet their responsibilities. Some demonstrated thatsafeguarding had both senior leadership and organisation-wide commitment. Areasfor development included:

• Ensuring that safeguarding is embedded as ‘everybody’s business’• Developing stronger strategies that link safeguarding, quality and workforce

development• Strengthening the relationship between commissioners and service providers

on safeguarding• Embedding good practice in mental capacity securely with safeguarding• Developing the range and quality of local partnership working.

3

1. Introduction

‘No Secrets’ (DH, 2007) set out the responsibilities of public services, including theNHS, to safeguard service users who may be least able to protect themselves fromharm. Following this the SHAs (in collaboration with the Department of Health,commissioners and clinicians) developed the Safeguarding Adults Self Assessmentand Assurance Framework (SAAF) for Health Care Services, to support healthservices to meet their responsibilities for safeguarding adults and to achieveimproved outcomes. The SAAF is particularly aimed at health services and their rolesin relation to safeguarding adults. It draws on existing standards and inspectionframeworks including: the Care Quality Commission Essential Standards for Qualityand Safety; ADASS Standards for Adult Protection, and the NHS OutcomesFramework.

The SAAF has five standards, which relate to measures that support goodsafeguarding: strategy, systems, workforce, partnerships and commissioningarrangements. Patient and carer involvement is a core feature integrated into all thestandards. The SAAF uses a ‘red, amber, green’ (RAG) rating scale and invites thosecompleting it to add evidence to support their self assessed scores. A copy of thestandards and criteria is attached as Appendix 1.

Whilst completion of the SAAF was not mandatory in 2011, NHS London encouragedLondon health services (commissioners and trusts) to complete and submit theframework. Forty-seven submissions were received; some were integratedsubmissions from more than one organisation. (Over 60 bodies could have submittedresponses). Some submissions were ‘signed off’ by the local Safeguarding AdultsBoards; others were sent in by individual organisations. The planned process for thisfirst self assessment did not include external validation of the self assessed scores orsupporting statements.

The 2011 SAAF should therefore be treated as a learning exercise, enabling NHSorganisations to prepare for implementation of the NHS Operating Framework for2012/13. Safeguarding features more strongly in the new Operating Framework; panLondon guidance has been issued and the SAAF complements this. This reportprovides information that clusters, Clinical Commissioning Groups and providerorganisations can use to improve their performance, both individually andcollaboratively. NHS London will work with clusters to ensure that: commissionersand provider organisations can deliver the requirements of the Operating Framework;Clinical Commissioning Groups are prepared for their safeguarding responsibilities,and national guidance and lessons learned are embedded and implemented.

2. Analysis

The RAG scores for each organisation were entered into a spreadsheet. As notedabove, these scores were not externally validated. Each submission was reviewed indetail to draw out themes and examples of good practice. A number of organisationsonly completed the RAG section of the self assessment and did not provide anyfurther narrative or evidence to support their scores. It was therefore not possible todetermine the appropriateness of their self-score. Those organisations that didprovide more detail showed some variation in their interpretations of the

4

requirements for each level. It is perhaps to be expected that some exercised morecaution than others in awarding themselves the higher ratings. It is anticipated that,as organisations become more familiar with both the process and the specificrequirements, there will be a greater consistency of interpretation.

3. Overall commentary

Most submissions were received from provider trusts; a very small number werecombined provider/commissioner submissions and there were some commissioning-only responses. (See chart).

In future it would be helpful to clarify which organisations should complete the sectionon commissioning. Many providers assumed this was not relevant to them and left itblank. However, some took the opportunity to demonstrate their understanding of thecommissioning and contract review process by detailing the types of safeguardinginformation they provided to support it. Commissioner submissions varied in thestrength of the working relationships depicted: some commented on activeinvolvement through contract review and improvement plans, but others merely notedthat safeguarding was included in contracts.

Standards in relation to wider partnerships were self-rated consistently higher thanany other group of standards. These positive assessments were not always wellsupported by evidence, however, and some responses mentioned only a limitedrange of local partners (e.g. the local authority or other NHS organisations). This mayreflect the amount of work that has been done to strengthen partnership working,such that it is now more ‘taken as read’. There were a lot of references to the LondonSafeguarding Adults Network; according to NHS London there are in fact severalnetworks and other groups that have some link to safeguarding and this forms quite acomplex picture: see Appendix 2.

There was no evidence as yet of cluster-wide themes or trends, but there was someevidence of cluster-wide activity (e.g. in responses from NHS Wandsworth, NHSEnfield, NHS Southwark). However, references to developing cluster strategies weretypically not included in other responses from within the cluster, which may indicatethat joint activity was not deeply embedded at the time of the submissions.

ProviderCommissionerIntegrated

5

A number of submissions included comments on the difficulties of ensuringconsistent approaches during structural change. Some had taken this as a positiveopportunity to review strategies and systems with partners and a few noted that theyhad ensured robust interim measures to secure the approach during mergers.

Whilst some submissions had scored performance against workforce standards quiteconservatively, others included more positive ratings that were not well supported byevidence. In particular there were very few submissions that demonstratedconvincingly that there was a strategic approach to workforce planning, linkinginformation on population need, safeguarding system evidence and user/carerfeedback to future planning for capacity, role design, skills and training.

One other specific area merits a mention in this overview: there were some goodexamples of systems to ensure widespread understanding of and action onrequirements in relation to mental capacity, deprivation of liberty and restraint.However, the majority of responses suggested that this is an area for focusedimprovement. This was recognised in some submissions, but in others it appearedthat the development needs had not yet been understood or that all the responsibilitywas concentrated in a small number of posts.

4. Overview by standard

The commentary that follows is based solely on the submissions received by NHSLondon. As noted at the start, the self assessments were not externally validated andthe conclusions can only be as strong as the evidence submitted.

4.1 StrategySome cluster-wide strategies were beginning to be developed, but not allrespondents from those clusters mentioned them. It is therefore unclear how wide ordeep the involvement was. Some submissions showed that organisations were usingstructural change as an opportunity to review and develop their strategies, involving arange of local partners and the users of their services.

There were a few examples of evidence that safeguarding strategies were stronglylinked into overall organisational strategies and backed up by workplans (forexample, Hillingdon community health; Barnet and Chase Farm Hospitals, where thePatient Experience Strategy is also linked in). Very few respondents made explicitreference to basing strategies on information such as the Joint Strategic NeedsAssessment (JSNA) or feedback from service users and carers (see commissioningsection). Some said very little about strategy, but evidence from other sectionssuggested a coherent approach.

There was a range of good examples given of user involvement (for example, fromthe Royal National Orthopaedic Hospital, which described a variety of individual andgroup methods of identifying unmet need and developing user and family-ledsolutions). This was not universal, however, and from some submissions it was notclear whether or how user feedback influenced strategy or action.

6

Good practice examples: strategy and involvement

The Hillingdon Hospitals NHS Foundation Trust has an executive lead forsafeguarding and also a non-executive lead for learning disability. Safeguarding isincluded in the Trust’s strategic plan, which has monthly updates on performanceagainst objectives. There is an annual safeguarding report to the Trust Board.Evidence on patient experience and outcomes to inform action was drawn togetherfrom sources such as:

• incidents• PALS feedback• complaints• audits• safeguarding alerts.

The Trust refers to strong engagement with a range of local partners, including thevoluntary sector as well as community health and social care. People with learningdisabilities and family carers have been directly involved.

NHS Outer North East London has led robust work since submission of the SAAFto develop a new strategy for the cluster. This is linked firmly into overall quality andsafety for the cluster and sets clear development priorities for 2012/13, including safetransition to new structures, building clinical engagement, and using the SAAF tostrengthen monitoring of care homes.

4.2 SystemsMost respondents reported that they had safeguarding procedures in place or wellunder way and most had arrangements in place for reporting to their Boards.

Personalised care: a number of submissions provided convincing evidence of personcentred care to meet the needs of patients at particular risk. For example,Community Health Services Barking and Dagenham (part of the North East LondonFoundation Trust) described a range of methods (focused particularly on people withlearning disabilities, people with mental health problems, end of life care andcontinuing care), including face to face discussions on admission, regular reviews,patient passports, safeguarding information in accessible formats. Outer North EastLondon Community Services demonstrated examples of taking patient expertise intoconsideration in shared decision-making. South West London & St George’s MentalHealth Trust described work they are doing to base services on the principles ofrecovery and self directed support.

Good practice example: personalisation and identifying and managing risks

Central and North West London NHS Foundation Trust is embeddingpersonalisation and recovery principles in practice across the organisation. It is oneof the national pilots for ImRoc (Implementing Recovery through OrganisationalChange) and is “piloting a new risk assessment tool that will be more transparent andinclusive to the views of users and carers”. A CQUIN target for recovery principles incare planning is in place and performance is monitored. User led audit of serviceexperiences includes safeguarding.

7

The Trust has mature inter-agency information sharing protocols to identifysafeguarding risks and internally ensures staff awareness through the trainingstrategy and audits. This includes a robust escalation process for all staff in relationto concerns around management of risk. Learning from incidents is disseminatedacross the organisation and shared with partners.

Identifying and acting on risk: respondents provided a range of examples of systemsfor identifying people in the service setting who might be at risk (e.g. all vulnerableadults, people with learning disabilities, people with dementia) or for anticipating andmanaging specific types of risk (e.g. falls, pressure sores, domestic violence). Forexample, the Royal Free Hampstead NHS Trust has developed an ‘alert’ card forpeople with learning disabilities and this is being linked into electronic flagging on thehospital patient record system. Examples were also given of systems to shareinformation across providers, e.g. using Rio.

Listening to and acting on patients/users’ and carers’ views: responses that includedstrong evidence against this standard included some highly specialist trusts (such asthe Tavistock and Portman) and general acute services (such as Whipps Cross).Good examples demonstrated a range of ways of engaging with people who useservices and carers, including those often seen as ‘hard to reach’ (e.g. buildingengagement into the responsibilities of a variety of roles). They showed how viewsfed into formal groups and processes (e.g. using patient stories in ward-basedimprovement activity) and were able to cite examples of action based on suchfeedback. Submissions that were weaker on this standard often describedinformation-giving activities (important but not sufficient), or gave examples ofobtaining feedback but without clear routes for this to influence action.

Good practice example: listening to and acting on user views

The Hillingdon Hospitals NHS Foundation Trust has a range of systems in placeto involve patients, carers and public groups in reviewing care. This includesinvolvement in relevant groups and committees that can influence change and“expert by experience” programmes. There is evidence of action based on concerns:for example, patients with learning disabilities are now fast-tracked through A&E as aresult of learning from a previous incident. The service tracks data on ‘protectedcharacteristics’ under the Equality Act in order to identify any trends.

Mental capacity/Deprivation of Liberty Safeguards/restraint: self assessedperformance against this standard was quite patchy: some organisations had verylittle to say or recognised that they were at the start of an improvement journey.Some submissions set out training and systems on these topics, but seemed to berelying on one or two posts to hold responsibility and deliver the activity described. Afew organisations gave clear evidence of more robust policies and widespreadtraining (e.g. Hillingdon Hospital), backed up by approaches such as observation ofpractice (Royal National Orthopaedic Hospital). Speech and language therapists aredeployed in some areas (e.g. Harrow) to support communication in relation tocapacity and ‘best interests’ decision making.

8

Good practice example: Mental Capacity Act

Outer North East London Community Services have training and procedures inplace to ensure staff understand Mental Capacity Act issues; more ‘best interests’assessors are being trained. Observation of multi-disciplinary team dischargemeetings demonstrates that staff are aware. Any individual training needs of clinicalstaff are followed up through personal development planning. Staff are aware of theDeprivation of Liberty Safeguards and an example was given of a multi-disciplinaryapproach to planning care for one person, but the organisation recognises that itneeds a formal system to identify, record and review any use of restriction and theneed to apply for and manage a Deprivation of Liberty authorisation.

Integrated review of alerts and other relevant data: some good examples were givenof strong leadership of regular reviews and audits. For instance, at the NorthMiddlesex Hospital matrons lead a quarterly review and audit; weekly reviews are ledby the executive lead at King’s College Hospital. A number of responses describedhow information is brought together from different systems for integrated review,drawing out the learning and acting on the feedback. Some trusts specificallymentioned using a system called Datix for this purpose. For example, this is used atGuy’s for a quarterly review led by the Chief Nurse and involving partner agencies.

Good practice example: integrated review and reporting

The Community Health Services Barking and Dagenham (part of North EastLondon Foundation Trust) use a Safeguarding Dashboard that collates data (suchas referrals and training). Data are collected via the safeguarding lead and thegovernance team and themes are reported regularly to safeguarding groups, alongwith specific reports on any serious incidents.

4.3 WorkforceLeadership: a few respondents scored this standard as ‘not applicable’ and in someorganisations all the responsibility seemed to rest with one or two posts. Commonlysubmissions cited an executive lead together with leadership responsibilities built intosome middle management posts (e.g. matrons, site managers). Some also had anon-executive lead and described cascaded leadership responsibility throughout theorganisation, with champions at a variety of levels and safeguarding built into a widerange of job descriptions (for example, at South London and the Maudsley, andLewisham Healthcare), backed up by clear governance arrangements.

Good practice example: leadership

King’s College Hospital has both an executive and non-executive lead; theexecutive lead reviews all safeguarding complaints. Leadership responsibility iscascaded through the organisation, via ward managers and matrons, so that“safeguarding is everyone’s responsibility”. Safeguarding issues are reviewedquarterly through governance meetings and annually at the Board.

Capacity and capability: the overwhelming majority of responses showed noevidence of a strategic approach to workforce planning that would link intelligence

9

from the Joint Strategic Needs Assessment and training needs analyses to skills,recruitment and training. However, there were a few examples given of matchingsupport and skills to care plans and matching training to role profiles (Guy’s), andusing skill mix review to inform annual plans (Hillingdon Hospital). The Royal NationalOrthopaedic Hospital uses assessment of future risks to inform workforce planning.

Good practice example: capacity, capability and recruitment

Outer North East London Community Services have a workforce developmentstrategy group that reviews organisational requirements for safeguarding training,building on recruitment practices that ensure competent staff are appointed. Pre-employment checks are carried out, CRB checks are updated every three years andsafeguarding is reflected in clinical supervision and personal development plans.Managers receive fortnightly updates on numbers of staff who are up-to-date withtraining. Review of integrated information on complaints and incidents is used toinform workforce and service design; internal KPIs provide benchmarking data.

Training: despite the lack of workforce strategies, some submissions did showevidence of a good grip on matching training to skills required and to feedback fromservice users. This included both highly specialist services (e.g. the Tavistock andPortman, Royal Marsden) and general acute (e.g. King’s College Hospital).Hillingdon Community Health follow up routine training with case studies and alsooffer training to independent contractors (GPs, dentists, optometrists, pharmacists).This was the only submission to mention these groups. Central and North WestLondon NHS Foundation Trust described a comprehensive approach to co-production and co-facilitation of training that is open to staff, service users andcarers.

Good practice example: training

North Middlesex University NHS Trust has a very thorough approach to training,which includes volunteers and the Board. There are good multi-agency links thatmean Trust staff have access to a range of external training opportunities; theLearning and Development department oversees training and reports on it to thePatient Safety Board and the Patient Safety and Quality Board. Training reflectslearning from incidents and investigations and is tailored to different roles. Forexample, feedback from family carers of people with learning disabilities led tochanges in patient management practices on surgical wards. Training is evaluatedand updated regularly.

Supervision and performance management: some, but not all, responses providedevidence of using supervision, appraisal and personal development plans well, bothto support staff and to manage performance. For example, the West MiddlesexUniversity Hospitals described clear systems to offer clinical supervision, professionalsupervision and informal discussion of issues, with counselling available if required.Hillingdon Hospital mentioned meeting monthly with other local leads to shareexpertise and offer support.

10

Good practice example: supervision and support

The Royal National Orthopaedic Hospital has a policy on supervision and supportand can evidence its use. Training and support is offered to managers involved indisciplinary hearings. The Human Resources team audits awareness of and attitudesto whistleblowing and support is offered to whistleblowers. Outcomes fromwhistleblowing show what changes have been made as a result.

Safe recruitment: whilst some submissions described internal approaches to saferecruitment (such as Outer North East London Community Services’ ‘SaferRecruitment’ plan), there was scant evidence of local collaboration with partners tobuild safeguarding into recruitment. South London and the Maudsley trainsinterviewers to cover safeguarding. South West London and St George’s MentalHealth Trust involves service users in recruitment.

Advice and support: NHS Bromley mentioned offering advice and support to localpartners such as care homes and also self-funders; the Royal National OrthopaedicHospital offers peer review and training to other local organisations. This may beimplied in what some other submissions said about links with local partners, but wasnot always explicit.

4.4 Partnerships‘Protecting adults at risk: London multi-agency policy and procedures to safeguardadults from abuse’ represents the commitment of organisations in Greater London towork together to safeguard adults at risk by:

• working together to prevent and protect adults at risk from abuse• empowering and supporting people to make their own choices• investigating actual or suspected abuse and neglect• supporting adults and providing a service to adults at risk who are

experiencing abuse, neglect and exploitation.

Most SAAF submissions mentioned the London Safeguarding Adults Network andmost mentioned working with a few local partners, typically the local authority andother NHS organisations. Some mentioned the local Safeguarding Adults Board andalso referred to a wider range of local partners, such as voluntary organisations anduser-led organisations. Activity with partners commonly included sharing informationand training, and acting on feedback. Chelsea and Westminster describedcollaborative review of safeguarding cases to improve practice. Only the WestMiddlesex University Hospitals referred to links with the Health and Wellbeing Board,which will be increasingly important for the future.

Many responses did not include strong evidence on public information. Someappeared to focus on information giving, whereas a few described a moreparticipative approach. Both Hillingdon Hospital and the West Middlesex UniversityHospitals described playing active roles in a variety of local public events, such as alocal ‘Safeguarding Awareness’ week.

11

Good practice example: openness and transparency

North Middlesex University NHS Trust operates a variety of ways of informingpatients and the public and listening to feedback. Reports on individual cases and onlearning from incidents are managed as part of the local safeguarding partnershiparrangements and the information about how vulnerable adults are protected is alsoprovided through these partnerships. The PPI Officer visits local patient groups tomaintain a two way conversation and regular "open day" visits to the hospital areoffered; feedback is also received from the Patient Representative Forum.

4.5 CommissioningMost providers assumed this section was not relevant to them and scored it as ‘notapplicable’. However, some took the opportunity to comment on collaboration withcommissioners (including contract management and arrangements for informationsharing). Some mental health trusts are involved in commissioning services: forexample, Central and North West London NHS Foundation Trust describedcontractual processes focused on outcomes, and also mentioned using S.75agreements with local councils to review issues.

Sixteen commissioner responses were received, including one from a council(Islington) and three from a strong sub-cluster (see box below). One submissionreferred to development of a cohesive cluster strategy, but no other response fromthat cluster mentioned it. This suggests that cluster working was at a very early stageat the time the self assessments were completed. However, rapid development willbe required to keep pace with the establishment of cluster working.

Those that mentioned cluster strategy did mention using information from JointStrategic Needs Assessments, serious case reviews and other information systemsto shape their strategies. Some other submissions also noted that they were usingrestructuring as opportunity to review progress and systems collaboratively.

Whilst it was common for commissioning responses to note that safeguarding wasincluded in contracts, this was not always supported with robust evidence. IslingtonCouncil and NHS Southwark did describe strong working relationships, withsafeguarding set in the context of a robust strategy for quality. Outer North EastLondon Community Services referred to the use of CQUIN targets and some (e.g.NHS Bromley, NHS Hounslow) referred to involvement in improvement plans.

As with the submissions from provider organisations, workforce strategy was an areafor development for commissioners, with little or no evidence of workforce planninglinked to Joint Strategic Needs Assessments or feedback from service users.

Again, the quality of responses on mental capacity and Deprivation of LibertySafeguards was mixed, with few commissioners providing robust evidence to supporttheir scores. However, NHS Southwark described a training needs analysis leadingto action on this topic and both Islington Council and NHS Hounslow demonstratedstrong partnerships.

12

A few commissioners were able to show that they were using feedback from serviceusers and carers and were involving them effectively in shaping commissioningstrategies and plans for safeguarding (e.g. NHS Hounslow and NHS Hillingdon).

Good practice example: commissioning

NHS Hammersmith & Fulham, NHS Kensington & Chelsea and NHSWestminster make up the Inner North West London sub-cluster. Their individualresponses had much in common and referred to the development of sharedresources and approaches. A wide range of evidence was provided to support thesubmissions, which described:• clear and strong strategic planning, based on a range of evidence (such as Joint

Strategic Needs Assessments, user and carer involvement) and linked firmly tooverall strategies for quality. A JSNA for INWL is being developed andsafeguarding information is feeding into this

• full coverage of safeguarding issues (including capacity and deprivation of liberty)in contracts, with a focus on outcomes; a robust range of measures to assureperformance, and involvement in improvement activity. Information and trends areanalysed and reported fully via local safeguarding forums

• clear arrangements to ensure capacity and capability in commissioning,contracting and performance management teams, across INWL and with counciland NHS Trust partners

• close work with a range of partners: this included a range of joint posts, pooledresources, shared systems and ways of involving voluntary sector organisations,service users and carers

• clear procedures and workforce development related to the Mental Capacity Actand Deprivation of Liberty Safeguards, including separation of functions in relationto DoLS

5. Commentary on clusters

As noted in the sections above, there were no clear themes or trends that could bedetected by cluster. This is not surprising given the timing of the self assessments.

There were some references to developing cluster strategies; draft Operating Plansfor 2012/13 show that this work is continuing, but rates of development are variable.

One strong sub-cluster was noted and this is described in more detail in section 4above.

6. Learning

It is clear from the self assessments that most organisations have worked hard to putsystems and processes in place, and most can demonstrate working relationshipswith some key local partners. Clear efforts are being made to sustain a focus onsafeguarding through restructurings. There are many reported examples of goodpractice that can be shared.

13

It may be a reflection of the timing and the shifting pattern of organisations acrossLondon, but on the whole systems and procedures appeared more robust than thestrategic planning that should set the context – in terms of both overall strategies forsafeguarding and strategies for workforce planning and development. There were notmany examples of strategies being based firmly on population data and service userfeedback.

Again, intra-organisational development often looked stronger than activepartnerships with the whole range of key local partners (including betweencommissioners and service providers). At the same time there is clearly time andeffort going into the variety of safeguarding groups shown in Appendix 2. It may bethat some energy could be released if this complex picture could be streamlined.Whilst partnership working can take a great deal of time and energy, there can alsobe pay-offs in terms of shared effort (e.g. on safer recruitment) and learning fromsharing the range of good practice examples.

Leadership was clearly strong in many organisations, with appropriate seniorcommitment as well as the development of leaders throughout the structure. In some,however, there was a worrying lack of such evidence and apparent over-reliance onone or two key people to carry the agenda. Similarly it was not clear that frontlinestaff are consistently supervised and supported sufficiently in order to ensure bothgood practice and support to deal with difficult situations. This will need to beimproved if progress is to be made on one of the weaker areas – dealing with mentalcapacity and deprivation of liberty.

7. Recommendations

Recommendations are set out below for different parts of the NHS, with the aim ofbuilding on progress to date and:

• ensuring that safeguarding is embedded as ‘everybody’s business’ as well ashaving senior leadership

• developing stronger strategies that link safeguarding, quality and workforcedevelopment

• strengthening the relationship between commissioners and service providerson safeguarding

• embedding good practice in mental capacity securely with safeguarding• developing the range and quality of local partnership working.

To NHS provider organisations:

• Strategy:o Develop safeguarding strategies further in collaboration with

commissioners and other local partners, based on information from theJSNA (and in future the Health and Wellbeing Strategy) and feedback frompeople who use services and carers, and linked to the Pan London Policy

o Ensure that strategies encompass all the groups and services for which theorganisation has responsibility, including prison health

o Link the safeguarding strategy firmly into overall organisational strategiesfor equalities, quality and workforce

14

• Systems:o Continue to develop person centred approaches to care and to risk

assessment and managemento Continue to develop the range of ways of listening to people who use

services and carers, and demonstrate how action is linked to theirfeedback and involvement

o Ensure that Mental Capacity Act (including deprivation of liberty)awareness and understanding is built into safeguarding training andpractice at all levels

o Continue to develop systems for integrating and reviewing information(relevant to safeguarding) from a variety of sources

• Workforce:o Ensure that every organisation has senior leadership identified, and

continue to build on initiatives to embed safeguarding as ‘everyone’sresponsibility’

o Link safeguarding securely into overall workforce develop strategies, oruse safeguarding to initiate strategy development where this is not yet wellestablished

o Continue to build on partnership approaches to training, sharing expertise(for example, from people who use services and carers)

o Continue to build on partnership approaches to safe recruitment,supervision and support

• Partnerships:o Continue to build up the range of local partnerships, including with the

Health and Wellbeing Boards and voluntary organisations• Commissioning:

o Use the establishment of new cluster and clinical commissioningrelationships to forge collaborative contractual and monitoringarrangements that focus on outcomes.

To NHS commissioners (including the NHS Commissioning Board):

• Continue to develop cluster strategies (keeping pace with establishment of clusterworking), in collaboration with the full range of local partners. Increasingly this willinclude Health and Wellbeing Boards and will link to Health and WellbeingStrategies that are based on Joint Strategic Needs Assessments

• Ensure that safeguarding strategies cover the full range of population groups,including for example prisoners and homeless people

• Continue to develop contractual and monitoring arrangements with all providersthat encourage person centred approaches to risk assessment and managementand focus on outcomes. Clusters will need to assure themselves that appropriatelocal safeguarding arrangements are in place, in accordance with the 2012/13NHS Operating Framework; this will be monitored by NHS London

• Ensure that Mental Capacity Act (including deprivation of liberty) awareness andunderstanding is built into safeguarding training and practice at all levels, and thatthere is appropriate separation of functions in relation to Deprivation of LibertySafeguards.

15

To NHS London:

• Share learning and good practice from the 2011 self assessment• Discuss with partners whether the current complex picture of partnership groups

could be streamlined• Consider with partners whether people who use services and carers have the

right kinds of information to enable them to participate effectively in localsafeguarding activity: it may be that some information could appropriately beprovided pan-London

• Review and revise the self assessment framework, based on learning from 2011,to ensure that it supports the requirements of the 2012/13 Operating Framework.One option would be to focus on the areas for development identified in thisreport

• Consider with partners how self assessments could be validated. For example,options could include:

o peer reviewo review by ‘experts by experience’o review by one of the pan-London safeguarding groups shown in Appendix

2o a combination of the above.

We suggest that there would be value in an approach that combined localexperience with a pan-London view that could add challenge and an overview ofgood practice.

Report produced on behalf of NHS London by:Alison Giraud-SaundersSarah Darby

16

Appendix 1

Safeguarding self assessment standards

1. Strategy and planning

1.1 There is a strategic plan for safeguarding adults and it is an integral part ofquality

1.2 The service’s safeguarding strategy, planning and delivery involves and takesaccount of patients’, users’ and carers’ experiences

2. Systems for prevention; responses; reporting and learning (providers)

2.1 The service has internal safeguarding adults procedures that are consistentwith the local multi-agency safeguarding adults procedures

2.2 The service has systems in place for person centred care to meet the needs ofpatients/users at particular risk of neglect, harm or abuse

2.3 The service has systems in place to identify and act on risks that have thepotential to become a safeguarding adults concern

2.4 The service has clear and accessible systems for patients/users’ and carers’views and concerns to be heard and to influence change

2.5 The service can evidence that the MCA is integral to care and themanagement of safeguarding concerns

2.6 The service has guidance and processes to govern the use of restriction andrestraint and where DoLS should be considered

2.7 Services can demonstrate patient/user-led decisions about their safeguardingand that interventions are person centred

2.8 The service has processes to review and benchmark safeguarding alerts andreferrals. This is integrated with clinical incident reporting, compliments andcomplaints

2.9 The service has set requirements for Board/senior management reporting onsafeguarding adults

3. Workforce, culture and capability (providers)

3.1 Leadership for safeguarding adults is provided by a named executive and non-executive/elected member or equivalent

3.2 The service’s workforce has the capacity and capability to (i) meet the needsof patients who may be at particular risk of harm, and (ii) respond tosafeguarding concerns

3.3 The service provides training to enable the workforce to safeguard adults3.4 The service provides supervision and support for staff involved in

safeguarding adults procedures3.5 The service has robust recruitment processes in place, including procedures

under the Safeguarding Vulnerable Groups Act3.6 The service safeguards adults by addressing staff performance concerns

17

4. Partnerships and collaborative working (providers)

4.1 The service works in partnerships to safeguard adults4.2 The service is open and transparent in relation to safeguarding adults

5. Commissioning

5.1 There is a commissioning strategy for safeguarding adults5.2 Systems are in place to set safeguarding adults into all contracting and

procurement processes5.3 Commissioners have robust assurance for safeguarding adult’s standards and

processes to escalate concerns and risks5.4 Commissioners report on safeguarding adults as part of assurance and

accountability5.5 Workforce – commissioning workforce for safeguarding adults5.6 Effective working relationships and partnership working are in place5.7 Commissioners can demonstrate how they discharge their roles and

responsibilities as a supervisory body as required by MCA and DoLS

6. Additional information

6.1 Evidence of best practice or how systems or structures have improvedoutcomes

6.2 Information about any organisational challenges and how these have beenovercome, or action plans to address them

18

Appendix 2Map of Safeguarding Networks

Dignity, Capacity and SafeguardingSteering Group (Multi-agencygroup)

London Safeguarding AdultsBoards Chairs Meeting

London Safeguarding Adults Network(LSAN)

MCA/DoLS Leads Network

London Approved Mental HealthProfessionals (AMHP) Network

London ADASS Branch

(NHS) London Region SafeguardingLeads Network

Cluster/Local SafeguardingNetwork

AD Network

GLA Multi-AgencySafeguarding Hub

LD Partnership Forum

Pan London Interagency Mental HealthLegislation Oversight & Scrutiny Committee(not yet formed)

NHSLQuality and Clinical GovernanceCommittee

KEY:Direct reporting link :Indirect reporting line available: