Safeguarding Protocol

Document Owner John Fogarty

Author John Fogarty

Approval Date xxxx

Review Date xxxx

Contents Glossary ...... 3 1. Background ...... 4 2. What is Safeguarding? ...... 5 3. Where is this Protocol Applicable? ...... 6 4. Children & Young People ...... 6 4.1 Abuse and Risks ...... 6 4.2 Legal Framework ...... 6 5. Adults at Risk ...... 7 5.1 Abuse and Risks ...... 7 5.2 Legal Framework ...... 7 5.3 Values ...... 8 6. General Principles Affecting Both Groups ...... 9 6.1 LCRCA Roles and Responsibilities ...... 9 6.1.1 LCRCA Attendance at External Events ...... 11 6.2 LCRCA’s Commitment to Safeguarding ...... 11 6.3 Information & Advice ...... 12 6.4 Confidentiality & Information Sharing...... 13 6.5 Record Retention ...... 13 6.6 Safe Recruitment (DBS Checks) ...... 14 6.7 Allegations against LCRCA Employees ...... 15 6.8 Reporting Incidents ...... 15 7. General Duties of Employees ...... 15 7.1 Expectations on LCRCA Employees and Agents ...... 15 7.2 Employee Conduct ...... 17 7.3 Website/Online Safety ...... 17 8. Consequences of Non-Compliance ...... 18 9. Appendices ...... 19 APPENDIX A - Types of Abuse and Physical/Behavioural Indicators of Abuse ...... 19 APPENDIX B – Outline of Safeguarding Reporting Pathway ...... 23 APPENDIX C – SAFEGUARDING REPORT FORMS ...... 24 APPENDIX D – Employee Reporting Procedure ...... 30 APPENDIX E - Useful Contacts ...... 32

Glossary

Adult at risk - A person aged 18 or over who is in need of care and support, regardless of whether they are receiving them, and because of those needs are unable to protect themselves against abuse or neglect.

Adult safeguarding - Protecting a person‟s right to live in safety, free from abuse and neglect. Advocacy – Support for people who have difficultly expressing their concerns and the outcomes they want during the safeguarding process. Best interest – The Mental Capacity Act 2005 states that if a person lacks mental capacity to make a particular decision then whoever is making that decision or taking any action on that person‟s behalf must do so in the person‟s best interest. Concern - Describes when there is or might be an incident of abuse or neglect. Enquiry - An enquiry is the action taken or instigated by the Local Authority in response to a concern that abuse or neglect may be taking place. The purpose of the enquiry is to establish whether or not the local authority or another organisation, or person needs to do something to stop or prevent the abuse or neglect. Equality Act 2010 – Protects people from discrimination in the workplace and in wider society. It replaced previous anti-discrimination laws making the law easier to understand and strengthening protection in some situations. General Data Protection Regulations 2018 – These regulations govern how and why personal data is processed and are intended to strengthen and unify data protection. Article 9(h) in particular allows the processing of special categories of personal data necessary to provide health and social care.

Independent Mental Capacity Advocate (IMCA) - Established by the Mental Capacity Act 2005. IMCAs are mainly instructed to represent people who lack mental capacity when there is no-one outside of services, such as a family member or a friend, who can represent them. IMCAs are a legal safeguard who will help people make important decisions about where they live, serious medical treatment options, care reviews, or adult safeguarding concerns. Making Safeguarding Personal – This refers to person-centred and outcome- focused practice. It is about empowering individuals to express what is important to them by whatever means appropriate. Practitioners must demonstrate through their practice that they have carefully listened to the individual and those important to them and how they want matters to progress. Outcomes of interventions should be meaningful to the person at the centre of the enquiry and reflect their original wishes wherever practicable.

Person/organisation alleged to have caused harm - The person/organisation suspected to be the source of risk to an adult at risk, child or young person.

Person in position of trust – When a person holds a position of authority and uses that position to his or her advantage to commit a crime or to intentionally abuse or neglect someone who is vulnerable and unable to protect him or herself. Safeguarding Adults Board (SAB) – Each local authority must have a SAB to assure itself that local safeguarding arrangements and partners act to help and protect adults at risk. SABs will oversee and lead adult safeguarding and will be interested in all matters that contribute to the prevention of abuse and neglect. Safeguarding Adults Review (SAR) – Undertaken when an individual with care and support needs dies or suffers unnecessarily as a result of abuse or neglect and there is a concern that the local authority or a partner organisation could have done more to protect them. 1. Background

With the introduction of the Care Act 2014, adult safeguarding was given a statutory footing. All local authority areas were now obliged to:

 Establish and lead on a multi-agency safeguarding system that seeks to prevent abuse and neglect and stop it quickly when it found to be happening;  Make enquiries, or request others to make them when they consider an adult with care and support needs may be at risk of abuse or neglect and they need to find out what actions may be needed;  Establish a Safeguarding Adults Board with the local authority, NHS and police as core members and develop share and implement a joint safeguarding strategy;  Carry out a Safeguarding Adults Review (SAR) when someone with care and support needs dies as a result of neglect or abuse or suffers harm and there is a concern that the local authority or its partners could have done more to protect them; and  Arrange for an independent advocate to represent and support someone who is subject of a safeguarding of a safeguarding enquiry or review, if required.

The Liverpool City Region Combined Authority (LCRCA) recognises the vision of the Care Act 2014 and the Children Act 1989, that safeguarding vulnerable groups is vital and is the responsibility of all agencies. Whilst the LCRCA is not subject to the same statutory duties under these Acts as its constituent local authorities, it nonetheless acknowledges that it has a responsibility to promote the wellbeing and safety of all people it comes into contact with in the exercise of all of its devolved functions.

In particular the LCRCA is committed to practices that protect children, young people and adults at risk from harm and recognises its duty to ensure that appropriate action is taken where someone is, or is suspected of, either experiencing harm or at risk of harm.

All employees of Merseytravel are to be interpreted as LCRCA employees for the purposes of this protocol.

The purpose of this protocol is to:

 Ensure the safety and wellbeing of children and adults at risk who access services provided by the LCRCA;  Provide assurance that the LCRCA takes reasonable steps to manage risk and keep these vulnerable groups safe;  Ensure all employees and agents of the LCRCA understand their roles and responsibilities in respect of safeguarding and are provided where necessary with the correct information, training and support on safeguarding matters to most effectively safeguard these vulnerable groups;  Ensure appropriate action is taken in the event of any allegations, concerns or suspicions regarding harm or potential harm of individuals and or vulnerable groups accessing services provided by the LCRCA; and  Work in partnership with Local Safeguarding Boards and authorities with a statutory duty in relation to safeguarding.

2. What is Safeguarding?

Safeguarding is the action taken to promote the welfare of children, young people and adults at risk and protect them from harm. Safeguarding is everyone‟s business.

For the purpose of this protocol, children are individuals under the age of 16 and young people are any individuals between the ages of 16 and 18.

An adult at risk is any individual over the age of 18 who:

 Has care and support needs; and  Is experiencing, or is at risk of, harm, abuse or neglect; and  As a result of those care and support needs is unable to protect themselves from either the risk of, or the experience of harm, abuse or neglect.

This may include, but is not limited to, any adult who may:

 Have an illness affecting their mental or physical health;  Have a physical disability, learning disability or sensory impairment;  Misuse substances or alcohol to the extent that it affects their ability to manage day to day living; or  Have a degree of frailty.

Safeguarding adults at risk means protecting their right to live in safety and free from harm, abuse and neglect.

The Care Act 2014 and accompanying guidance state that safeguarding should:

 Be person led;  Engage the person all the way through the process and address their needs;  Be outcome-focused;  Be based upon a community approach from all partners and providers.

Making Safeguarding Personal is the notion of empowering individuals to express what is important to them by whatever means appropriate. It is about seeing people as experts in their own lives and working alongside them with the aim of enabling them to resolve their circumstances and support their recovery. Outcomes of safeguarding enquiries should be meaningful to the person at the centre of the enquiry and reflect their own wishes wherever practicable. There should be “no decision about me without me” 3. Where is this Protocol Applicable?

This protocol applies to anyone working for, or on behalf of, the LCRCA including its agents undertaking work on the authority‟s behalf in any capacity and any setting.

It is not the responsibility of any employee or agent of the LCRCA to conclusively determine whether abuse is actually taking place, has previously taken place or that there is a risk of imminent abuse through undertaking enquiries. However, it is their responsibility to take the actions set out in line with the agreed protocols as appended to this protocol if there are concerns that harm, abuse or neglect is or could be taking place.

Equally it is the responsibility of LCRCA employees and agents to ensure that they do not cause harm to any child, young person or adult at risk whilst discharging the duties of their post or fulfilling their contractual obligations. 4. Children & Young People

4.1 Abuse and Risks

Everyone has a right to be safeguarded from harm, abuse and neglect. We believe that children and young people should never experience abuse of any kind and we as the LCRCA have a responsibility to promote the welfare of these groups, to keep them safe and to excise our duties and activities in ways that protect them. Employees should remain aware that children and young people may be hesitant to disclose instances of abuse and therefore employees should remain alert to any potential indicators of abuse and ensure that any suspicions are escalated through the appropriate channels according to this protocol without delay.

4.2 Legal Framework

This protocol has been drafted on the basis of relevant legislation and guidance that seek to protect children and young people in England. This includes but is not limited to:  The Children Act 1989 (as amended by section 53 of the Children Act 2004).  The Safeguarding Vulnerable Groups Act 2006.  Working Together to Safeguard Children (2018).  Safeguarding Disabled Children Practice Guidance (2009).  What to do if you‟re worried a child is being abused (Dept of Education, 2015).

The LCRCA does not have a statutory duty to comply with the key arrangements listed in Working Together to Safeguard Children (2018), however as a public body with devolved functions, we recognise that we should have in place arrangements that reflect the importance of safeguarding whilst promoting the welfare of these groups. 5. Adults at Risk

5.1 Abuse and Risks

There are 10 categories of abuse listed within the Care Act 2014 that are applicable to adults at risk. Employees should be aware of these different forms of abuse and be vigilant in identifying the different behavioural or physical indicators that may indicate that abuse is taking or has taken place, contained in Appendix A. Employees should be aware that adults at risk may have a number of highly complex social and psychological needs which may affect their willingness to disclose information relating to abuse and that will impact upon the way any safeguarding concerns are dealt with.

Employees should be aware that whilst this protocol relates to adults with care and support needs it is not always possible to identify what the care and support needs of an individual are by casual observation. When there are concerns relating to an adult they should always be reported using the procedures contained within this Protocol.

5.2 Legal Framework

This protocol has been drafted having given due consideration to the relevant legislation and guidance that seeks to protect adults at risk in England. This includes but is not limited to:

 The Care Act 2014 Statutory Guidance (Department of Health 2016);  The Safeguarding Vulnerable Groups Act 2006;  The Mental Capacity Act 2005 Code of Practice;  NHS Accountability and Assurance Framework (Department of Health 2015);  The Human Rights Act 1998;

 The Equality Act 2010;  Modern Slavery Act 2015.

The legislation within this sphere does not impose any specific statutory duties upon the LCRCA. However, the six local authorities making up the LCRCA in the Liverpool City Region are subject to statutory obligations to promote the safeguarding of adults at risk within their districts. The LCRCA is committed to fostering positive working relationships with each local authority and to assist these local authorities in fulfilling their statutory obligations in safeguarding adults.

5.3 Values

All dealings with adults at risk should be based on The Six Principles of Safeguarding that underpin all adult safeguarding work. These are:

1. Empowerment – adults are encouraged to make their own decisions and are provided with support and information; 2. Prevention – strategies are developed to prevent abuse and neglect and that promote resilience and self-determination; 3. Proportionate – a proportionate and least intrusive response is made balanced with the level of risk; 4. Protection – adults are offered ways to protect themselves, and there is a co- ordinated response to adult safeguarding; 5. Partnerships – finding local solutions through services working together within their communities; 6. Accountable – accountability and transparency in delivering a safeguarding response.

The following values should also be considered during the safeguarding of vulnerable adults at risk:

 People should be able to access support and protection to live independently and have control over their lives;  Appropriate safeguarding options should be discussed with the adult taking into account additional factors associated with the person‟s disability, age, gender, sexual orientation, race, religion, culture or lifestyle;  Where possible, the adult at risk should maintain choice and control in their care;  All action should begin with the assumption that the adult at risk is best placed to judge their own situation;  The adult at risk‟s views, wishes, feelings and beliefs should be paramount and are critical to a personalised way of working with them;  All adults at risk should be assisted through the provision of advice, information and support to enable them to be as involved in decision-making that affects them as possible.

6. General Principles Affecting Both Groups

6.1 LCRCA Roles and Responsibilities

Whilst the LCRCA does not have any specific statutory obligations to safeguard children, young persons and adults at risk, we believe firmly that we nevertheless have a duty and responsibility to assist our local authority partners in safeguarding vulnerable groups within the Liverpool City Region.

The LCRCA will meet its responsibilities to safeguard children, young people and adults at risk by nominating one of the Directors to champion safeguarding throughout the organisation, to have overall responsibility for ensuring adherence to the relevant protocols.

Multiple Designated Safeguarding Leads (DSLs) have been appointed across the organisation, detailed in Form 2 of Appendix C, whose responsibilities will include:

 Possessing a higher level of safeguarding knowledge as befits their position;  Ensuring they have completed a suitably comprehensive package of training, including refresher courses as required;  Being the first point of contact for all LCRCA employees and agents to approach for advice;  Providing safeguarding procedures and guidance for all operational employees who come into regular contact with children, young people and adults at risk, or who may observe safeguarding concerns during the discharge of their duties;  Participating in regular „Safeguarding Forums‟ with other DSLs and Heads of Service (HoS) at least four times per calendar year to review the implementation of this protocol and to identify, reflect upon and address trends within its application by LCRCA employees;  Ensuring that concerns are logged and stored securely;  Promoting a safe environment for children, young people and adults at risk;  Liaising with key individuals in the relevant statutory agencies e.g. Children‟s Social Work Services, Police, Local Safeguarding Children Boards and, in the event of allegations being made against LCRCA employees, the Local Authority Designated Officers (LADO) for concerns relating to children. For adults at risk, Safeguarding Adults Boards;  Providing support and advice to managers and all employees and agents;  Ensuring all relevant employees have training on child protection and safeguarding as part of their induction and ongoing continuous professional development;  Maintaining an overview of safeguarding issues and monitoring the implementation of this protocol, in conjunction with the HR lead; and  Liaising with HoS and other DSLs regularly to reflect on lessons learnt.

The HR department will undertake the following actions and review and update the existing recruitment procedures as required:

 Appropriate vetting checks for all employees who work primarily or directly with children, young persons and vulnerable people will be implemented;  Appropriate vetting checks for all employees whose role provides an opportunity for contact or places them in a position of trust with children, young persons and adults at risk will be implemented;  Determine an appropriate training programme for all employees within the LCRCA;  Ensure compliance with safe recruitment procedures for new employees and their induction;  Assist with the necessary DBS checks identified for key employees; and  Develop and maintain an internal procedure in relation to work placements.

Each HoS within the organisation will ensure that employees they manage:

 Have access to appropriate training and information to ensure an understanding of their individual role in the safeguarding of the people that they serve;

 Enable all employees to have a sound understanding of the LCRCA Safeguarding Protocol and associated procedures and consistently work within the parameters;

 Receive role-specific training in safeguarding at a level appropriate to their role to ensure that they can discharge their duties effectively and safely;

 Are aware, and are comfortable and able to raise concerns about poor practice through the LCRCA whistle blowing policy; and

 Have access to safe systems of work. HoS will also:

 Lead on all concerns raised with HR and the DSL in relation to their work area, ensuring that safeguarding concerns raised amongst their teams are reported to the relevant LA area without delay;  Update the Corporate Risk Register process to it considers safeguarding as a subsidiary risk in their area of the business;  Identify key team members requiring Disclosure and Barring Service Checks (DBS checks) and ensure these checks are kept up to date;  Ensure sufficient opportunities for participation in training is available for all;  Monitor training needs for employees in relation to safeguarding and ensure these are reviewed as part of the internal IPP process;  Work with HR on ensuring agents working on behalf of the LCRCA in their area of responsibility adhere to and are compliant with this protocol; and  Follow HR department guidance is followed during any work placement period in their service area.

HoS responsible for commissioned services throughout the LCRCA will ensure that the safeguarding of children, young people and adults is embedded in all services they are contractually obligated to deliver as part of their service area function.

6.1.1 LCRCA Attendance at External Events

There are a number of activities undertaken by the LCRCA in which our employees and agents work with children, young people and adults at risk at events. In such circumstances the lead officer / HoS for such activities should approach the organisers at the point of booking to receive, digest and share their protocols and policies relating to safeguarding with all employees and agents taking part in the activities. If the event organisers have no policy/procedure, the lead officer for this event from the LCRCA should undertake a risk assessment of it based on this protocol and guidance from the LCRCA DSL which should then be disseminated amongst all employees taking part.

Reviewing event participation in relation to safeguarding is best practice and senior officers can use this as a tool to identify risks associated with key employees who may require DBS checks as part of their role.

If employees are attending events at schools, colleges or other centres for learning they should access the relevant protocols and risk assessments for these organisations. For clarity, employees do not necessarily require a DBS check for such events, but a responsible adult or lead for the relevant school/college/other centres should provide supervision for the event whilst our employees discharge their duties. 6.2 LCRCA’s Commitment to Safeguarding

We will demonstrate our commitment by:

 Appointing and supporting nominated DSLs;  Developing policies and procedures which reflect best practice;  Using our policies and procedures to share concerns and relevant information with agencies who have statutory duties in regard to safeguarding within the Liverpool City Region within an acceptable timeframe;  Recruiting employees and appointing agents of the LCRCA ensuring all necessary checks are made whilst providing effective management for employees and agents through performance management, supervision, support, training and quality assurance measures;  Implementing a code of conduct for all employees;  Using policies and procedures to manage any concerns raised involving employees or agents of the LCRCA appropriately;  Ensuring we have effective comments and whistleblowing measures in place;

 Ensuring we have a safe physical environment for our employees and agents by applying health and safety measures in accordance with law and regulatory guidance;  Recording and storing all information professionally and securely with regard to the GDPR; and  Ensuring all LCRCA employees have a basic awareness of safeguarding issues including being alert to the potential for abuse and neglect, having enough knowledge to recognise abusive or potentially abusive events or set of circumstances, knowing who internally to raise concerns with and being competent to take the appropriate action required within an acceptable timeframe.

If any employee of the LCRCA has a concern in relation to safeguarding they must alert the DSL immediately. If grounds for concern are then are agreed, appropriate action must be taken immediately. This will include contacting the relevant local authority, social care service and / or Merseyside Police. Should an employee be certain that there is a safeguarding concern and they are aware of the relevant local authority‟s reporting procedures, the employee should report their concern to this authority immediately. The employee should then inform the relevant LCRCA DSL without delay for this incident to be processed internally in accordance with this protocol.

If a child, young person or adult at risk is in immediate danger the employee who first becomes aware of the danger should dial 999 for the police.

Please refer to Appendices A to E for further guidance in addition to the notes below regarding identifying, reporting and collating information relating to a potential safeguarding issue.

6.3 Information & Advice

Information and advice is critical in preventing or delaying the need for services and, in relation to safeguarding, can be the first step to responding to a concern. This includes information and advice about safeguarding and should include:  How to raise concerns about the safety or well-being of an adult who has care and support needs;  Awareness of different types of abuse and neglect;  How people can keep safe, and how to support people to keep safe.

Whereas information may be generic to a lesser or greater extent, advice needs to be tailored to the person seeking it, recognising people may communicate in different ways. Advice and information should, where possible, be provided in the manner preferred by the person and in a format they can understand.

The LCRCA may have a number of direct opportunities to provide, or signpost people to information and advice, in particular of safeguarding.

6.4 Confidentiality & Information Sharing

In any work with children, young persons and adults at risk it is important to be clear about confidentiality. Whilst personal information held by professionals and agencies is subject to a legal duty of confidence, it is essential that employees respond quickly where they have concerns or suspicions of harm, abuse or neglect. Concerns over confidentiality should not override the protection of vulnerable individuals. Information sharing must be done in a way that is compliant with the General Data Protection Regulation (GDPR) and Data Protection Act 2018, The Human Rights Act 1998 and the common law of duty of confidentiality. However a concern for confidentiality must never be used as a justification for withholding information when it would be in the child‟s, young person‟s or adults at risk‟s best interests to share information. The GDPR and the Data Protection Act 2018 allow for the sharing of personal data for the purposes of „safeguarding children and individuals at risk‟. This includes allowing practitioners to share information without consent if:

 It is not possible to gain consent;

 It cannot reasonably be expected that a practitioner gains consent; or

 If to gain consent would place an individual at risk. Decisions about sharing information must be clearly recorded with reasons for sharing clearly stated and these decisions must be open and explicitly discussed at every stage. 6.5 Record Retention

It is essential to keep a clear and comprehensive record of any concern or allegation made regarding safeguarding. Any information relating to an individual, including specific detail of the concern(s) or the allegation(s) made, how the matter was followed up and resolved, details of any decision(s) reached as well as any action taken should be written up as a record in order to:

 Enable accurate information to be given in relation to this safeguarding concern or allegation in the future;

 Ensure that the LCRCA has fulfilled its obligation to have robust procedures in place to safeguard children, young people and adults at risk within its remit;

 Enable the LCRCA to cooperate fully and effectively with any other authorities or public bodies who may assume responsibility for undertaking further enquiries around a safeguarding concern;

 Provide clarification in cases where future DBS disclosure reveals information from the police that an allegation was made against a member of employees but did not result in a prosecution or a conviction;

 Prevent unnecessary re-investigation should an allegation against an employee resurface after time;

 Provide evidence and information if a decision is made to refer an employee for consideration to be barred from working with children, young people and / or adults at risk;

 Enable the LCRCA to review and improve policies, procedures and practice based on learning and feedback. The DSL, in conjunction with the relevant HoS, HR Lead and Legal Representative, is responsible for creating and maintaining this record during the course of managing an identified safeguarding concern or allegation against an employee of the LCRCA. All the information relating to a safeguarding concern, and any subsequent action taken must be recorded using the appropriate safeguarding protocols and report forms, together with an additional log of actions and any accompanying emails. This information should be processed in line with the LCRCA‟s duties under the GDPR and the Data Protection Act 2018. Any report forms relating to a safeguarding concern should be stored in line with the LCRCA‟s duty under the Limitation Act 1980 and stored for a minimum of six years. In the case of a child or young person, this six-year period does not begin until their 18th birthday. Where a safeguarding allegation has been made against an employee, any information or documentation relating to this allegation and the reasons for pursuing / not pursuing a specific course of action is to be retained on the employee‟s HR file. Upon an employee‟s departure from employment with the LCRCA, information relating to a safeguarding allegation against that employee will be retained on their HR file for a minimum of six years from their date of departure. Once this minimum retention period has been reached, all records should be destroyed using shredding and confidential waste disposal or be electronically purged.

6.6 Safe Recruitment (DBS Checks)

The Safeguarding and Vulnerable Groups Act 2006 (as amended by The Protection of Freedoms Act 2012) sets out that it is an offence for an employer to knowingly employ someone in a regulated position if they are barred from doing so. Some roles within the LCRCA whilst not “regulated positions”, may involve working directly with children, young people and / or adults at risk. Instances where this may occur could include (but are not limited to) convening meetings, holding focus groups or engagement events and conducting interviews. Where direct work with vulnerable groups is to take place in instances similar to those listed, the relevant employee may be subject to DBS checks before commencing these activities. Where a criminal conviction is disclosed by an applicant to a post at the LCRCA or discovered through a DBS check, the employees‟ line manager and the HR Manager will consider this objectively and, where the check indicates that the level of risk is too high to allow the individual to start or continue working in a particular role or activity, the consequences of this for the individual will depend on:

 The check concerned;

 The reason for the check;

 Relevant legislation;

 The post concerned; and

 Whether the employee is suitable for other employment opportunities available within the LCRCA. Possible outcomes could include amended duties, redeployment, withdrawal of an employment offer or dismissal. 6.7 Allegations against LCRCA Employees

Any suspicion, allegation or actual abuse of a child, young person or adult at risk by an employee, volunteer, agent or contractor of the LCRCA must be reported to the DSL and HR manager immediately. If there are concerns abuse has taken place against a child or young person, the DSL will pass on the information to the LADO for investigation. The DSL will work with the employee‟s line manager and with HR to conduct an internal investigation of the safeguarding allegation made against the employee. Where necessary it may be required to refer to the Disciplinary procedures and decide whether the employee should be suspended pending full investigation. 6.8 Reporting Incidents

If any employees are involved in an actual or suspected safeguarding incident, or if a serious safeguarding incident takes place within any LCRCA workplace or working context, in addition to following this protocol, it should be reported formally. In addition, immediate action should be taken by the DSL, Head of Service and HR Manager to:

 Prevent and minimise any further harm to the child, young person or adult at risk;

 If appropriate, report it to the police;

 In consultation with the internal communications team and the relevant Director(s), plan what to say to employees, the public and media; and

 Review what happened and consider any steps that could be taken to prevent it from happening again. Safe recruitment practice of checking an applicant‟s work history, identity and, in relation to roles where a DBS check is required, obtaining explanations for any gaps in employment, must be followed for all employees working within the LCRCA. 7. General Duties of Employees

7.1 Expectations on LCRCA Employees and Agents

It is important that our employees, agents and contractors work to a high standard of professional conduct and act with integrity at all times. It is important to create a work

15 environment where the risk of abuse is minimised and all concerns are reported expediently to the appropriate authorities.

Employees and agents of the LCRCA should make sure they have read the relevant safeguarding procedures in full. They should highlight and discuss any issues requiring clarification and any further training needs with their line manager. Employees should ensure they understand the different forms of abuse, as set out in Appendix A as well as possible indicators of it. Regardless of position or grade, safeguarding is a duty on all employees of the LCRCA. It is everyone‟s responsibility to take the actions set out in line with the agreed protocols, as appended to this protocol, if they are concerned harm, abuse or neglect is taking place. Equally, all employees are required to ensure that they do not cause harm to any child, young person or adult at risk whilst discharging the duties of their post.

It is the responsibility of all employees to:

 Read and understand this protocol, seek further guidance appropriately as required and undertake any compulsory training on its application, context and impact on their role;  Raise awareness of the need to protect children, young people and adults at risk and reduce risks to them as part of their role;  Maintain an organisation that is safe for all and an environment where poor practice is legitimately and robustly challenged;  Ensure that when harm, abuse or neglect is suspected, witnessed or disclosed they are clear on what action must be taken and who to contact immediately;  Ensure they feel competent and fully informed on safeguarding matters in relation to children, young people and adults at risk so they have the requisite knowledge, skill, expertise and qualifications to carry out their roles safely and effectively; and  Ensure safe working practice in relation to safeguarding when working in partnership with other organisations off site, understanding what safeguarding policies and procedures these partners have in place so they can be followed.

Concerns for the safety and wellbeing of children, young people and adults at risk could arise in a variety of ways and in a variety of situations. There are multiple forms of abuse, which are outlined in Appendix A. It is not easy to recognise a situation where abuse may occur or has taken place and LCRCA employees and their agents are not experts in such recognition. However, each person has a responsibility to act if they have concerns about someone‟s behaviour toward a child, young person or adult at risk. It is important that the recipient of any complaint or accusation that a child, young person or adult at risk has been or is being abused listens carefully without making or implying any judgement as to the truth of the complaint or accusation. You should not probe, letting the person talk without

16 interrupting, and try to provide assurance that you will seek help to resolve the situation. You should not pass judgement. To ensure all the details of any disclosure or concern are captured for any future investigation, a detailed record should always be made at the time of the matter being raised. See Appendix C. All customer facing employees should be aware of the potential indicators of abuse and neglect as set out in the Appendices and if they are in any doubt, they should inform their team leader or HoS immediately, who can seek advice from the DSL, if necessary.

7.2 Employee Conduct

Where an LCRCA employee is suspected of behaving inappropriately or abusively towards children, young people or adults at risk, employees who become aware of this should inform their Team Leader/line manager in line with the organisation‟s whistleblowing policy. The LCRCA also expects employees not to act in an inappropriate or abusive manner to these vulnerable groups in their private lives. Where an employee is suspected or found to have behaved in such a manner, this will be investigated internally and a decision will be made on whether taking disciplinary action is appropriate. In performing their contractual duties, all employees should ensure that they are not placing themselves, children, young people or adults at risk in situations where harm could, or is likely to, occur. All employees who work with vulnerable groups as defined within this protocol have a duty to safeguard these groups through their conduct and should ensure that they comply with any policies relevant to the exercise of their contractual functions. For example, any LCRCA employees who might reasonably and entirely appropriately be expected to work on a 1:1 basis with members of vulnerable groups should have regard to the guidance on Lone Working 7.3 Website/Online Safety

Employees should take care when communicating with others online, particularly when identifying themselves as LCRCA employees and when in contact with children, young people and adults at risk.

Any project or work that provides service users with direct access to the internet must have protocols in place to ensure safe use. LCRCA would consider employees distributing indecent materials or making personal contact inappropriate activity and gross misconduct; this could ultimately lead to dismissal and referral for police investigation. If an employee inadvertently accesses inappropriate material whilst online and performing their duties, they should remove themselves from the website and report the matter to their line manager, the DSL and HR. Breach of this could be treated as gross misconduct.

8. Consequences of Non-Compliance

Employees, volunteers, agents or contractors who work on behalf of the LCRCA are required to comply with this protocol and its associated protocols.

Failure to comply with the content of this protocol may result in disciplinary proceedings being commenced against the employee in question in accordance with the Disciplinary Procedures. Whilst proceedings are ongoing, the employee may be suspended pending an investigation which may ultimately result in their dismissal. Depending on the severity of the breach of this protocol, the employee‟s conduct may be referred for a police investigation.

Where an individual fails to comply with the content of this protocol, and that individual is not an „employee‟ of the LCRCA under employment law, the legal department should be contacted to advise on the most appropriate remedy or course of action.

9. Appendices

APPENDIX A - Types of Abuse and Physical/Behavioural Indicators of Abuse

Abuse is an act of ill treatment that can harm or is likely to harm a person‟s safety, wellbeing and development. Abuse is never acceptable. Abuse can consist of a single act or repeated acts. It may be an act of neglect or an omission to act, or it may occur where a adult at risk is persuaded to enter into a financial or sexual transaction to which they do not, or cannot, consent. Abuse can also be harm that an individual causes to themselves through act or omission. Intent is not an issue at the point of deciding whether an act or a failure to act is abuse; it is the impact of the act on the person and the harm or risk of harm to that person. The Care Act 2014 categorises 10 types of abuse, which are set out below. Some of these categories are more likely to be encountered than others by employees of the LCRCA, however it is important to remain aware of all of them. Physical Abuse

Deliberate physical harm to a child, young person or adult at risk or any other form of harm which causes illness in child, young person or adult at risk. This may also include domestic violence.

Sexual Abuse

Forcing or manipulating a child, young person or adult at risk to take part in, or observe, sexual activities.

Sexual Exploitation is a type of sexual abuse aside that those who are vulnerable may be susceptible to. Children, young people and adults at risk in exploitative situations and relationships often receive something such as gifts, money or affection as a result of performing sexual activities or others performing sexual acts on them. This form of grooming for the purposes of sexual exploitation happens both online and in person. Groomers will hide their true intentions and may spend long periods of time gaining the trust of their victim. They often pretend to be someone or something they are not, offering advice, guidance, support or buying gifts.

In particular, transport hubs and public places are frequently locations that can be chosen by paedophiles or those seeking to groom children, young people or adults at risk for the purposes of sexual exploitation. These environments with public facilities offer an opportunity to observe and seek out potential victims. Employees should remain aware of this when discharging their contractual duties at transport hubs or public places owned by the LCRCA and refer to this protocol where safeguarding concerns are identified at these locations.

Emotional Abuse

This involves the emotional maltreatment of a child, young person or adult at risk such as to cause severe and persistent adverse effects on the child, young person or adults at risk‟s emotional wellbeing and/or development. This can be very difficult to identify as it can go unrecognised for a long time. A person does not have to be shouting and screaming at another, it may be that they are ignoring or dismissing individuals as if they have no worth. It may appear as a form of verbal abuse, where an individual is threatened with a risk of harm, isolation or seclusion, but can include anything that alters the individual‟s behaviour. Financial Abuse This is a form of abuse where an individual controls and/or uses the finances of another for their own material gain and/or to control the individual. Organisational Abuse This is defined as a service, agency or care home putting its own needs before those of the service users. It may include elements of other forms of abuse, for example neglect, financial, sexual, physical or discriminatory abuse. It includes any acts or omissions by those with a degree of responsibility for the individual which is detrimental to that individual. Domestic Violence Domestic abuse may often include elements of other categories, for example physical, sexual, emotional or financial abuse. It involves any incident or pattern of incidents of controlling, coercive or threatening behaviour, violence or abuse, between family members or those who are intimate partners. Female Genital Mutilation (FGM) is also covered within the Domestic Abuse category. This is a practice that is often imposed upon children and is now widely regarded as a form of child abuse which is punishable under criminal employees will encounter a child who they may believe to have been subject to FGM Additionally, honour-based abuse would also constitute domestic abuse. This refers to crimes or incidents of threatening, coercive or violent behaviour often committed with the view of protecting or defending the honour of a family and/or community. This is frequently committed by families or communities in response to a perceived contravention of religious or cultural beliefs or values. Individuals subject to honour-based abuse may have physical signs of abuse and be very strictly controlled by family members or acquaintances. Modern Slavery This practice most commonly affects adults and includes working for little or no wages where they are subject to the control of another. This form of abuse may commonly be found where an adult is vulnerable by virtue of their citizenship or economic status.

Modern Slavery may therefore also be linked with human trafficking in certain circumstances. Human trafficking is the action or practice of illegally transporting people from one country or area to another, typically for the purposes of forced labour or sexual exploitation.

Discriminatory Abuse

Similarly, discriminatory abuse is where those in a position of responsibility refuse to acknowledge that the individual has specific care needs, distinct from another. For example, it may include purposefully ignoring that individual‟s religion, personal beliefs, dietary views or other personal preference. Neglect

This involves the persistent failure to meet a child, young person or adults at risk‟s basic physical and/or psychological needs, likely to result in serious impairment of the child, young person or adults at risk‟s health or development.

Self-Neglect

The Care Act also recognises self-neglect as a form of abuse. This is where an individual fails to attend to their personal care and hygiene to their detriment. There could be multiple reasons for this including low self-worth, depression or mental health issues.

Other Forms of Abuse Radicalisation Radicalisation is not detailed within the Care Act, but is defined by the Government‟s „PREVENT‟ duty guidance as „the process by which a person comes to support terrorism and extremist ideologies associated with terrorist groups‟. Similar to sexual exploitation, radicalisation is frequently initiated online; individuals may target vulnerable groups and provide them with affection or friendship, drugs or alcohol in order to manipulate them for their own gain. As part of radicalisation, children, young persons or adults at risk may seek to isolate themselves, they may espouse radical or extreme views that were not previously held and they may become particularly secretive around their internet use. Physical/Behavioural Indicators of Abuse Some of the more obvious signs of abuse may include the following:

 Unexplained or suspicious injuries such as bruising, cuts or burns, particularly if situated on a part of the body not normally prone to such injuries;  An injury for which the explanation seems inconsistent;  The individual describes what appears to be an abusive act having occurred;  Someone else expresses concern about the welfare of the individual;  Unexplained changes in behaviour (e.g. becoming very quiet, withdrawn or displaying sudden outbursts of temper);  Engagement in uncharacteristically sexually explicit behaviour;

 The individual having difficulty in making friends or appears to be prevented from socialising with others;  Displays variations in eating patterns including overeating or loss of appetite;  Loses weight for no apparent reason;  Becomes increasingly dirty or unkempt;  Changes in dress/style of clothing;  Shows signs of fear or emotional distress;  Demonstrates self-harming behaviour;  Unexplained sudden inability to pay bills or manage finances; or  Espousing explicit extremist views or visiting extremist websites.

It should be recognised that the above is not an exhaustive list. Similarly, the presence of one or more of the indicators listed above is not definitive proof that abuse is taking place. It is not the responsibility of employees to decide whether or not abuse is taking place, however it is their responsibility to act on any concerns they may have by reporting it using the prescribed procedures contained in this protocol. Patterns of Abuse Those working with adults at risk, children and young people need to look beyond single incidents or people to identify patterns of harm. In order to see these patterns it is important that information is recorded and appropriately shared. Patterns of abuse vary and include:

 Serial abusing in which the abuser actively and routinely targets vulnerable groups. Sexual abuse sometimes falls into this pattern as do some forms of financial abuse;

 Long-term abuse in the context of a continuing family such as domestic violence between spouses or generations, or persistent psychological abuse;

 Opportunistic abuse such as theft occurring because money may have been left lying around.

APPENDIX B – Outline of Safeguarding Reporting Pathway

Employee made aware of/identifies safeguarding concern/incident/allegation(s)

If certain that child, young person or adult at risk is at risk of suffering immediate harm, or The employee completes Form 1 of

is currently suffering harm, dial 999 without Appendix C and passes this on to their delay. Contact the relevant Local Authority‟s identified DSL without delay or, if that DSL is Safeguarding Team (Appendix E) and inform unavailable, to a DSL in another directorate. them of this concern and then alert their identified DSL. If this DSL is unavailable, a

DSL in another directorate should be alerted.

HoS and DSL liaise with each other and arrange for Form 2 is completed by all relevant

employees. HoS/DSL will continue to liaise with emlpoyees who have reported safeguarding concern/incident/allegation. A decision will be made on whether a referral to the relevant local authority, LADO or Police is appropriate at this

Referral time. Referral not made made

If the allegation revolves around a LCRCA member of staff, HoS and DSL to consider also utilising other internal procedures, e.g. disciplinary processes.

File Case kept under Closed review. Liaise with local authority

partners/Police as required.

HoS and DSL review lessons learnt. All paperwork connected with this case must be stored centrally

and retained for the minimum period required by law.

APPENDIX C – SAFEGUARDING REPORT FORMS Case No:

STRICTLY PRIVATE AND CONFIDENTIAL

Form 1 - ‘Front Sheet’

This form should be completed by an employee in immediate response to identifying a safeguarding concern. Please complete as much of this form as possible.

This form must be kept up to date as the case progresses.

SECTION A: INITIAL DETAILS

Your Name:

Your Position:

Your Line Manager:

Date and Time of am/pm Incident:

Date and Time of am/pm

Report:

SECTION B: PERSONAL DETAILS OF CHILD, YOUNG PERSON OR ADULT AT RISK (IF KNOWN)

Full Name:

Person Type: Child Young Person Adult at risk

(please circle)

Gender: M F Prefer Not to Say

(Please circle)

Other (please specify):

Date of Birth:

Location of Incident:

Is the Perpetrator: A member of the Public An LCRCA employee From another organisation (please circle)

Perpetrator Information (if known):

Home Address/Contact Information:

Contact info for Parent/Guardian/Next of Kin

Contact details of any Lead Agency/Worker:

Case No:

Child‟s School (if applicable)

STRICTLY PRIVATE AND CONFIDENTIAL

Form 2 - ‘Statement Sheet’

This form should be completed by any employee in relation to an identified safeguarding concern. Where an individual is experiencing, or is at risk of experiencing imminent harm, this should be passed to your DSL, or any other available DSL, immediately.

Separate statement sheets are required to be completed by every person who has safeguarding concerns about a child, young person or adult at risk, who has witnessed an incident in relation to them or who has received information about an allegation regarding them.

SECTION A - DETAILS OF CONCERN

Please record, in as much detail as possible, the safeguarding concern that you have become aware of. Please include details of anyone else who witnessed this event if applicable. (Attach extra blank paper if necessary and attach to the rear of this form).

Details of concern:

It may be helpful to answer the following questions in your account; Where exactly did this concern/incident/allegation occur and at what time? What happened? Is the identity of the suspected/alleged perpetrator known to you? Was anything specific said? Who else witnessed this event) (please include contact details where possible)

Action taken, if any, by the person reporting the incident:

Incident reported to Emergency Services? (please tick) Yes ☐ No ☐ If yes, enter log number:

Incident reported to relevant agency? (please tick)

Yes ☐ No ☐

If yes, enter log number:

Serious Incident Form (SIF) competed with the relevant Local Authority? (please tick)

Yes ☐ No ☐

Please pass this form on to the Designated Safeguarding Lead (DSL) or your Team Leader as soon as possible. If they are not available, pass this to a DSL in another area. As aforementioned, where the individual is experiencing, or is at risk of experiencing, imminent harm, this concern must be raised immediately.

The Designated Safeguarding Leads within the LCRCA are:

Michael Cloherty – Customer Operations Manager Debbie Biglowe – HRD Strategy & Systems Manager Lynne Gogerty – HRD Operations Manager Alastair Ramsay – Head of People & Organisational Development Monica Thornton – Learning & Organisational Development Manager Sam Graham – Investment Analyst Tony McDonough – Bus Network Performance Manager Liam Phelan – Mersey Tunnels’ Police Inspector David Poole – Customer Operations Manager Nicola Swanson – Travelsafe Officer John White – Households into Work - Programme Manager Katie Owen – Interim Homelessness Strategic Lead Jill Coule – Chief Legal Officer, Monitoring Officer

Signed: Date:

Please do not discuss this safeguarding referral with anyone other than those directly involved in this referral process and only then in a professional capacity. SECTION B – TO BE COMPLETE BY DESIGNATED SAFEGUARDING LEAD OR HEAD OF SERVICE ONLY

Please sign and date below to confirm receipt of this form. This form should be stored securely in line with our obligations under the GDPR and the Data Protection Act 1998. This form should be retained in accordance with the statutory provisions of the Limitation Act 1980.

If you believe that a child, young person or adult at risk is in immediate danger, you should dial 999 as soon as you receive this form.

Signed: Date Received:

Is a referral required to other services?

YES NO

If yes, specify:

Rationale for the above decision:

SECTION C – TO BE COMPLETED BY DESIGNATED SAFEGUARDING LEAD OR HEAD OF SERVICE ONLY

Details of any action taken:

If the matter was referred, was a response received?

YES NO

(if no, follow up within 48hrs)

(if applicable)

Date response received:

Nature of Response:

Contact who responded (including contact information):

APPENDIX D – Employee Reporting Procedure

This Appendix is designed to provide all employees with a reporting procedure to adhere to in the event that they become aware of an individual requiring safeguarding during their daily activities. The end of this Appendix outlines further actions that those working in identified „High Risk‟ areas of the organisation may have to take, in addition to steps 1-4 outlined below, in fulfilment of their contractual duties.

This procedure must be followed regardless of whether a decision is made to report or not.

This procedure should also be completed alongside any local authority reporting requirements (of which, any paperwork generated should be copied and stored with the corresponding local documents) and in conjunction with the Liverpool City Region Combined Authority‟s Safeguarding Protocol and Procedures.

1. Complete the „Front Sheet‟ (Form 1). This should provide an overview of the case, the particulars of those involved and must be updated as the case progresses. Please consult with the Head of Service to receive a unique identifying number for the each case.

If a decision is made to report this case to the appropriate safeguarding authority, it is the responsibility of the reporter to contact them for an update of action taken and log this on the Front Sheet with the date and details of who

was spoken to. For those in „Low Risk‟ areas, this reporter should usually be the Head of Service or Designated Safeguarding Lead.

2. Complete the „Statement Sheet‟ (Form 2). This should be completed as soon after becoming aware of the safeguarding case as possible, to promote accuracy. It should be completed by the person who has identified the relevant concern, witnessed the incident or who received disclosure comprising an allegation, wherever possible. If you are not that person, you should provide the details of that person, if possible, and an explanation as to why you are completing the Statement Sheet on their behalf. Separate Statement Sheets need to be completed by each person who has identified the concern, witnessed the incident or received disclosure comprising an allegation. All Statement Sheets should be signed by their author.

3. Once all the paperwork is completed, the Front Sheet and any Statement Sheets must be placed together in a clear pocket and passed to your Head of Service.

4. A case will only be closed after it is reviewed by Head of Service. It must then be securely archived as per the timescales set out in the Safeguarding Protocol. It is essential that this paperwork is typed wherever possible, updated and completed fully and all details recorded as it will be required as evidence should this matter develop into criminal proceedings or require a serious case review.

„Low Risk‟ Areas

Employees working in areas of the organisation that are largely office-based are considered to have a low risk of likelihood of encountering safeguarding issues during the fulfilment of their contractual duties.

Nevertheless, the Safeguarding Protocol makes it clear that all employees are subject to a duty to promote safeguarding wherever and whenever the situation arises. In such situations, the aforementioned recording procedure should be followed.

„High Risk‟ Areas

High Risk areas of the organisation are considered to be those with frequent contact with the general public or vulnerable individuals. This may include workers who spend time frequently in transport hubs, on public transport, or those working with the homeless. Such areas necessarily have their own reporting mechanisms and procedures; where these are present throughout the organisation they are set out below:

Housing First

Before completing steps 1-4 as aforementioned in this Appendix, complete the fields in the „Recording Log‟ in Mainstay and issue a sequential identifying number to the case. This number must be quoted on all further paperwork. This log is separate from individual case files.

Households into Work

Before completing steps 1-4 as aforementioned in this Appendix, inform your Team Leader that you are reporting a safeguarding matter. If you are unable to contact your Team Leader or it is not appropriate to do so, you must inform a member of the Programme Support Team.

APPENDIX E - Useful Contacts

Where a safeguarding concern or incident has been identified in relation to a child, young person or adult at risk within the locale of a certain local authority:

Adults at risk Children

Central Advice and Duty Team Wirral Integrated Front Door

0151 514 2222 (Mon-Fri 08:50-17:00) 0151 606 2008 (Mon-Fri 9.00-17:00)

Wirral Outside these hours – 0151 677 6557 Outside these hours - 0151 677 6557

https://www.wirral.gov.uk/health-and-social- E-mail: [email protected] care/adult-social-care/safeguarding- adults/reporting-abuse-or-neglect-adult https://www.wirralsafeguarding.co.uk/

0345 140 0845 (Mon-Fri 08:00-18:00) 0345 140 0845 (Mon-Fri 08:00-18:00)

https://www.sefton.gov.uk/social- 0151 934 3555 (emergency duty team care/adults/worried-about-someone/if-you-think- from 5.30pm Mon to Thurs, and 4pm Sefton someone-is-being-harmed-or-neglected.aspx Friday and weekends

0151 934 3555 (emergency duty team from https://seftonlscb.org.uk/lscb 5.30pm Monday to Thursday, and until 4pm

Friday and weekends)

Careline Careline

0151 233 3800 0151 233 3800

Liverpool https://liverpool.gov.uk/social-care/adult-social- https://liverpool.gov.uk/social-care/adult- care/keeping-adults-safe/adults-at-risk/ social-care/keeping-adults-safe/adults- at-risk/

0151 443 2600 0151 433 2600

Knowsley https://forms.knowsley.gov.uk/AdultSafeguarding https://www.knowsleyscb.org.uk/

01744 676767 01744 676600

0345 050 0148 (Emergency Duty Team) 0345 050 0148 (Emergency Duty Team)

St Helens https://www.sthelens.gov.uk/social-care- https://sthelenssafeguarding.org.uk/scp health/adults/safeguarding-adults/

0151 907 8306 0151 907 8305 (Mon-Fri 9:00-17:00)

Halton 0345 050 0148 (Emergency Duty Service - out 0345 050 0148 (Emergency Duty of office hours) Service - out of office hours)

http://adult.haltonsafeguarding.co.uk/ https://children.haltonsafeguarding.co.uk/

Where an allegation has been made against an adult working with children or young people:

The Local Authority Designated Officer (LADO) helps co-ordinate information- sharing with the right people and will also monitor and track any investigation, with the aim to resolve it as quickly as possible.

The LADO must be told of allegations against adults working with children and young people within 24 hours. This includes all cases where a person is alleged to have:

 Behaved in a way that has harmed, or may have harmed a child;  Possibly committed a criminal offence against, or related to, a child; or  Behaved towards a child or children in a way that indicates they may pose a risk of harm to children.

District LADO Contact Details

Suzanne Cottrell - 0151 666 4582

Wirral Email: [email protected]

https://www.wirralsafeguarding.co.uk/professionals/lado-allegations/

0151 934 3783

Sefton Email: [email protected].

https://seftonlscb.org.uk/lscb/professionals/managing-allegations-local-authoritys- designated-officer

0151 233 3700 via Careline

Liverpool https://liverpool.gov.uk/social-care/childrens-social-care/keeping-children- safe/children-at-risk/

0151 443 3928

Knowsley https://www.knowsleyscb.org.uk/local-authority-designated-officer-lado-guidance- practitioners-parentscarers-children/

Timba Kanngoni - 01744 661 809

St Helens https://sthelenssafeguarding.org.uk/scp/scp/workforce/allegations-against- professionals-lado

0151 511 7229

Halton https://children.haltonsafeguarding.co.uk/contact-us/

Other Useful Contacts

 NSPCC Child Protection Helpline (24 hours) To report or discuss concerns about a child‟s welfare, call 0808 800 5000 or email [email protected]

 Child Exploitation and online Protection Command (CEOP) To report a concern that a child is being abused or groomed online at www.ceop.police.uk

Related policies and procedures

This protocol should be read in conjunction with the following Local Authority and LCRCA policies and procedures:

 Responding to concerns about a child or adults at risk wellbeing  Dealing with allegations of abuse  Role of the Designated Safeguarding Lead  Safer recruitment procedures  Code of conduct for employees and agents of the LCRCA  Anti-bullying guidance and procedures

 General Data Protection Regulations (GDPR)  Whistleblowing policy  Antisocial behaviour on the Merseytravel estate  Protocols for supported bus, train services and Mersey Ferries.  HR policies including but not limited to: Disciplinary and grievance, harassment and bullying, induction, ICT acceptable use, recruitment and selection, employee training and development

The following legislation is also relevant to this protocol:

 Care Act 2014  Children Act 1989, 2004  Counter-terrorism and Security Act 2015  Data Protection Act 2018  Equality Act 2010  Female Genital Mutilation Act 2003  Health and Safety at Work Act 1974  Human Rights Act 1998  Management of Health and Safety at Work Regulations 1999  Mental Capacity Act 2005  Modern Slavery Act 2015  Limitation Act 1980  Police Act 1997  Protection of Children Act 1999  Protection of Freedoms Act 2012  Rehabilitation of Offenders Act 1974 & (exceptions) order 1975  Safeguarding Vulnerable Groups Act 2006  Sex Offenders Act 2003

Protocol Owner

Safeguarding Protocol is owned by the Liverpool City Region Combined Authority (LCRCA). It will be annually reviewed and updated in order to ensure compliance with legislative changes and internal business development. The Lead officer with support from internal stakeholders will ensure that each published version of the protocol is published and cascaded appropriately.

Contact details

Nominated Lead: John Fogarty

Title: Director of Resources

Contact number: 0151 330 1137

Email: [email protected]

In the absence of the nominated lead, please contact:

Name Nicola Swanson

Title Liverpool City Region Travelsafe Officer

Mobile no: 07843 642357

Email [email protected]

Merseyside Police

Emergency number 999

Reporting of a non-urgent issue 101

Document Control

Version Date of issue Date of next review

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