Overview
The Royal College of Obstetricians and Gynaecologists (the College) is committed to ensuring that it maintains the highest possible standards to meet its social, moral and legal responsibilities to protect and safeguard the welfare of children, young people and adults in a vulnerable situation (Vulnerable Adult), defined below, with whom the College’s work brings it into contact.
While it is impossible to ensure that a child, young person or Vulnerable Adult (collectively referred to as Vulnerable Groups) would never come to any harm, the adoption of this policy and associated guidance aims to facilitate the management of the risk associated with the duty to protect such individuals.
The aim of this policy is to highlight the College’s approach to safeguarding the well-being of Vulnerable Groups and to direct individuals to appropriate guidance to enable the correct reporting pathways in the case of witnessing abusive behaviour.
The policy sets out the reporting obligations for all trustees, and members, employees, contract workers, consultants and volunteers, and the procedure that should be followed to report abuse if this occurs during work related activity.
All those groups are expected to contribute to creating and maintaining an environment that prevents safeguarding violations.
The College’s Safeguarding Officer is the Director of HR.
Scope
The College aims to adopt the highest possible standards and take all reasonable steps in relation to the safety and welfare of Vulnerable Groups. The College is mindful of its duty of care and legal obligations, such as those it owes under the Safeguarding Vulnerable Groups Act 2006 (England and Wales), the Protection of Vulnerable Groups (Scotland) Act 2007 (Scotland), and other relevant legislation.
This policy applies to all individuals involved with the College including trustees, members, trainees and volunteers, whether representing the College in the UK or overseas in relation to work undertaken with, or on behalf of, the College (so excludes clinical work of members as employees of a trust and hospital). However, it is specifically aimed at all staff, contract workers partners, consultants, visitors, volunteers and any other individuals who may encounter the following groups through research, professional services, Women’s Network activities, examinations, advocacy, international development activities and any other College related activity:
- children (i.e. those aged under 16),
- young persons (i.e. those aged 16 to 18), and
- Vulnerable Adults. A Vulnerable Adult is defined as a person aged 18 or over: who is or may be in need of community care services by reason of mental or other disability, age or illness; and who is or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation. (Department of Health, 2000).
This policy does not seek to discourage working with these groups. Instead, this policy seeks to support these activities where they occur and to do so in compliance with its commitment to ensure that, through its implementation, the College will protect Vulnerable Groups and keep them safe from harm when in contact with College representatives (whether acting in a paid or unpaid capacity).
This policy does not cover sexual harassment in the workplace, which is dealt with under the College’s Bullying and Harassment Policy.
Principles of the College’s approach
Risk Assessment
A designated individual should complete a risk assessment before any new or changed programme, event, visit or any other activity involving Vulnerable Groups.
All staff who intend to, or may be put in the position of, working with Vulnerable Groups should ensure that they understand and abide by this policy before commencing any programme, event, visit or other activity. The College in such circumstances will request that appropriate checks be carried out via the Disclosure and Barring Service (“DBS”).
All those involved in the risk assessment process should understand that the risk assessment is not only a way to mitigate or remove any potential risks but may also be a prompt to consider alternative working practices.
Recruitment, selection and employment procedures
The College will take all appropriate steps during the recruitment and selection process to ensure that Vulnerable Groups are not exposed to undue risk.
Where a risk assessment has identified that staff are likely to have ‘regular’ contact with or encounter Vulnerable Groups, appropriate checks into their suitability for such contact will be required.
In addition to the DBS checks referred to above, the College will ensure that any trustees, members, member of staff, volunteer or contractor who will have substantial one-to-one contact with Vulnerable Groups, and their role falls within the suitability criteria, will be checked for relevant criminal convictions.
In certain cases, it may be necessary to ask an employee to advise if they have any relevant existing or spent convictions. Advice must always be sought from HR before doing so.
Dealing with suspicions or allegations of abuse
Guidelines on dealing with suspicions or allegations of abuse are provided in the policy and should be referred to immediately if a member of staff becomes aware any instance of abuse, possible abuse or allegation of abuse.
Concerns for the safety and wellbeing of Vulnerable Groups could arise in a variety of ways and in a range of different settings. For example, someone may hint that a colleague is at risk or is an abuser; an individual may witness or hear about abuse of someone in a Vulnerable Group in the College or in another organisation with which the College is working. It is essential to act quickly and professionally in all cases of suspected abuse.
Any allegation by someone in a Vulnerable Group against a member of staff, trustee, fellow, member, trainee or volunteer should be reported immediately to the relevant designated individual who has responsibility under this policy. In dealing with any such allegation the College has a duty of care both to the individual concerned and to the member of staff, trustee, fellow, member, trainee, volunteer etc., against whom the allegation is made.
Responsibilities
- All staff must make sure they are familiar with the safeguarding policy and able to follow procedures if appropriate.
- Staff are responsible for their own professional conduct.
- Staff should always take action according to this policy if they have safeguarding concerns.
- In certain circumstances, if requested, staff are obliged to notify the College of any post-employment criminal convictions that may impact upon their future employment. If the individual is found in breach of this obligation, then disciplinary action may be taken with a potential sanction up to and including dismissal.
- The People Team will be responsible for ownership and review of this policy.
Procedure for Handling Complaints or Concerns
How to raise a complaint or concern
In no circumstance should concerns of abuse and inappropriate behaviour be ignored. Alleged cases of abuse should be reported to the appropriate Executive Director and Safeguarding Officer. If someone reporting an incident of alleged abuse feels uncomfortable reporting the incident to the appropriate Executive Director or the Safeguarding Officer, they should feel free to report it to another senior individual. Information must be recorded in writing.
In no circumstances should a member of staff attempt to investigate any safeguarding concern themselves as this may cause further harm.
Once a complaint has been received, the Executive Director and Safeguarding Officer will take action in line with the appropriate organisational policy. If an investigation is required, the principles as set out under the Disciplinary Policy and Procedure will apply. An individual alleged to be a perpetrator of abuse may be suspended from their duties in line with the Disciplinary Policy and Procedure.
An individual associated with the College who raises a genuine concern about suspected abuse will not face action if the concern proves unfounded. An individual who makes false and malicious accusations, however, will face disciplinary action.
If a member of staff has a suspicion or is aware that an individual in a Vulnerable Group is being abused they must act quickly but appropriately and professionally.
There is an absolute need for confidentiality in reporting possible violations to protect the individual who is allegedly the subject of the abuse and the alleged perpetrator of abuse.
It is essential that confidentiality is maintained at all stages of the process when dealing with safeguarding concerns. Information relating to the concern and subsequent case management should be shared on a need to know basis only, and should be kept secure at all times.
Duty of disclosure
The College is legally required to send information to the DBS or Disclosure Scotland if a decision is taken to dismiss an employee or remove them or any other individual, including trustees, members, volunteers etc., from working in regulated activity/work.
The College may also be required to inform the DBS or Disclosure Scotland if the College suspends an employee, or an employee or other individuals resigns in suspicious circumstances, as the referral duty criteria may already be met at that stage.
Additional support and guidance
Employees who wish for further information on safeguarding are encouraged to contact their line manager or relevant HR representative. The College will endeavour to provide up to date support and guidance to all staff when it comes to safeguarding and their duty to protect service users from harm. Relevant supporting material is also readily available online and the College will look to furnish employees with this where requested.
For further advice concerning any aspect of this policy, please contact the People team at people@rcog.org.uk.
Date of approval: 26 March 2021