Safeguarding Policy

Introduction and Purpose

Flourish with Neurodiversity is committed to safeguarding and promoting the welfare of children, young people, and adults at risk. We believe that everyone has the right to feel safe, respected, and supported, regardless of age, disability, gender, race, religion, sexual orientation, or background.

This policy outlines our approach to safeguarding in the context of delivering support and coaching sessions virtually. It sets clear standards for keeping service users safe and ensuring that risks are managed appropriately.

Who and What This Policy Applies To

This policy applies to all staff, associates, and professionals working on behalf of Flourish with Neurodiversity. It covers:

⦁ Children and young people (under 18 years of age)

⦁ Adults at risk of harm (for example, those with a disability, health condition, or other vulnerabilities)

⦁ Parents/guardians and carers engaging with us on behalf of children or dependent adults.

Equality and Diversity Statement

Flourish with Neurodiversity is committed to protecting from harm all individuals without exception, regardless of age, gender, marital status, family or caring responsibilities, gender identity, ethnicity, disability, sexual orientation, religion or belief.

Roles and Responsibilities

Business Owner

The business owner holds overall accountability for the service's operation, ensuring compliance with legal standards and the effective implementation of safeguarding policies. Key responsibilities include:

⦁ Cultivating a culture that prioritises children's and vulnerable adults' health, safety and welfare.

⦁ Ensuring the safe recruitment and engagement of qualified staff and partner professionals.

⦁ Providing the appropriate level of safeguarding training to staff.

⦁ Having appropriate safeguarding policies and procedures in place, which are followed by all staff.

⦁ Ensuring that our safeguarding policy and procedures are effectively applied and understood by all staff.

Staff

All staff (including self-employed professionals) are expected to:

⦁ Contribute to a safe and supportive environment for our clients and their families/carers, respecting their rights and promoting their health, safety and well-being.

⦁ Read our safeguarding policy and procedures and abide by them, taking a proactive approach to safeguarding issues.

⦁ Know how to spot safeguarding concerns.

⦁ Understand the system of seeking help as concerns are suspected or identified.

⦁ Abide by any current and future requirements of the role, including but not limited to the requirement to submit to Police or other statutory checks as required.

⦁ Attend any mandatory safeguarding training and updates.

Designated Safeguarding Lead (DSL)

The DSL's responsibilities encompass:

⦁ Leading the response to safeguarding incidents, including reporting to external agencies when necessary.

⦁ Maintaining detailed records of safeguarding concerns and actions taken.

⦁ Follow up on any referrals and ensure the issues have been addressed.

Overarching Policy

Designated Safeguarding Leads

Flourish with Neurodiversity has appointed the following Designated Safeguarding Lead (DSL):

⦁ Natasha Wakeling, business owner.

Our Commitment: Safeguarding Principles

⦁ We firmly believe that the welfare of the child and/or adult at risk is paramount and have a zero-tolerance approach to abuse.

⦁ All staff must be clear on what appropriate behaviour is.

⦁ All staff will be alert to possible signs of abuse and consider whether there may be safeguarding concerns.

⦁ We will create an environment where staff, clients and all stakeholders feel able and supported to raise safeguarding concerns.

⦁ All staff are required to report any suspected abuse and neglect and be aware of the appropriate reporting and support procedure for safeguarding, including the reporting of people at risk of radicalisation and extremism. There are no excuses for not taking all reasonable action to protect those at risk from abuse, neglect and exploitation.

⦁ Flourish with Neurodiversity is committed to responding swiftly and effectively when concerns are raised and is committed to working with appropriate agencies, including our local Safeguarding Children Partnership Board, local Safeguarding Adults Board and the Police, to ensure the reporting of abuse is appropriate and in line with local and national requirements and Information Sharing guidance.

⦁ All those making a complaint or allegation or expressing concern will be taken seriously, and Flourish with Neurodiversity is committed to providing support as necessary.

Staff Training

Flourish with Neurodiversity will provide all staff with induction training on safeguarding matters. This training will include, but is not limited to, reading this policy and our procedures, familiarising themselves with local procedures, and reading at least Chapter 1 of the most updated Working Together to Safeguard Children.

We may also insist that staff undertake additional training as required (and as may be required by our partners, clients, Local Authority, etc.).

The Designated Safeguarding Lead at Flourish with Neurodiversity will undertake advanced safeguarding training, ensuring they are equipped to manage complex safeguarding issues and provide guidance to all staff members.

Safe Recruitment (All Staff and Self-Employed Professionals)

Confirmation of Identity

Applicants and partners will be required to provide two up-to-date proofs of Identity, including a recent photograph and proof of address.

Employment History

Applicants for employed roles will be required to provide a full employment history, together with a satisfactory explanation of any gaps in employment in writing.

DBS Checks

All roles are risk assessed considering the working environment to determine if they are eligible for a Disclosure and Barring check and, if so, at what level. At this time, and due to the nature of our work, we undertake enhanced checks on all staff.

Where required, we will fund the check for employees. However, non-employees (self-employed professionals working in partnership) will finance their own checks.

Any criminal history disclosed on the DBS Certificate will be reviewed by the DSL, and any formal offer made will depend on the number of offences, the nature of the offence(s), and the time which has passed since the offences occurred.

Flourish with Neurodiversity undertakes to discuss any matter revealed on a DBS Certificate with the applicant before withdrawing a conditional offer. Where any checks indicate that the applicant is unsuitable for a position or partnership, they will be informed in writing of the reason for the withdrawal and their right to appeal.

New staff or partners who present a DBS certificate issued within the last 12 months may be permitted to begin work, subject to a risk assessment and confirmation that the certificate is valid and relevant to the role. However, they must either:

⦁ Apply for a new DBS check; or

⦁ Register with the DBS Update Service, within one week of their start date.

Registration with the DBS Update Service is strongly preferred, as it allows for continuous monitoring and enables quicker and more efficient safeguarding checks throughout their employment.

References

Flourish with Neurodiversity requires all job applicants (including those who will be self-employed) to provide the names and contact details of two referees. Referees will be contacted and must state that:

⦁ The applicant is known to them.

⦁ The applicant is thought to be suitable for employment in the specified role.

⦁ The applicant is of good character.

⦁ They know of no reason the applicant should not work with children or vulnerable adults.

In addition, to ensure that references are verified, Flourish with Neurodiversity will:

⦁ Not accept open references, e.g., to whom it may concern or rely on applicants to obtain their own references.

⦁ Ensure any references are from a senior person with appropriate authority (Directors, clinical managers, HR managers, etc.).

⦁ Always verify any information contained within the reference with the person who provided the reference and ensure electronic references originate from a legitimate source.

⦁ Contact referees to clarify content where information is vague or insufficient information is provided.

⦁ Compare the information on the application form with that in the reference and take up any discrepancies.

⦁ Ensure any concerns with references are satisfactorily resolved before the appointment is confirmed.

At least one referee should be a professional person, and the other referee should be able to provide a character reference. Neither referee must be related to the applicant.

If the applicant's last job involved working with children or vulnerable adults, their last employer or partner organisation must be included as a referee.

Where the applicant has previously worked in a position involving work with children or vulnerable adults, we will verify, so far as reasonably practicable, the reason why the employment or position ended.

Proof of Qualifications

Documentary evidence of any qualifications that the person considers relevant for the position will also be reviewed.

Online Checks

Where appropriate, we will carry out an online search on the shortlisted applicants. This may help identify any incidents or issues that have happened and are publicly available online, which we might want to explore with the applicant at interview.

Continuance of Good Character

All staff are responsible for ensuring that they report to the DSL any criminal proceedings or charges. Following disclosure, we will reassess their suitability as we would for an applicant for a new position.

Individuals failing to provide such information will be disciplined and may be subject to summary dismissal or immediate severance of any working contract/agreement.

Safer Practice in Virtual Sessions

All staff must follow the points below:

⦁ Before engaging with a child, young person or vulnerable adult who cannot legally give informed consent themselves, written permission will be obtained from their parent or legal guardian.

⦁ When working with younger children, parents or guardians will be encouraged to remain present on the call or remain nearby to provide supervision (and reassurance as required).

⦁ All sessions will be conducted via secure, agreed platforms with appropriate privacy settings enabled. No private contact should be made with children outside of the arranged sessions.

⦁ Staff must work from professional accounts, not personal profiles.

⦁ Staff must maintain professional boundaries at all times and must not share personal contact details.

⦁ Where possible, sessions should be recorded (with consent) or logged to provide an audit trail.

⦁ Appropriate dress, language, and conduct must be maintained at all times.

Safeguarding Children Policy and Procedure

Safeguarding Children Definitions

Children: A child is defined as anyone who has not yet reached their 18th birthday.

Young People: A young person is a person between 16 and 18 years of age. Young people have certain rights, but are still considered children.

Child protection guidance points out that even if a child has reached 16 years of age and is living independently, in further education, a member of the armed forces, in hospital or in custody in the secure estate, they are still legally children and should be given the same protection and entitlements as any other child (Department for Education, 2023).

Working Together to Safeguard Children, HM Government 2023 defines safeguarding and promoting the welfare of children as:

⦁ Providing help and support to meet the needs of children as soon as problems emerge.

⦁ Protecting children from maltreatment, whether that is within or outside the home, including online.

⦁ Preventing impairment of children's health or development.

⦁ Ensuring that children grow up in circumstances consistent with the provision of safe and effective care.

⦁ Taking action to enable all children to have the best outcomes.

Types of Abuse, Neglect and Exploitation – Children

What is Abuse?

Generally, abuse can be defined as:

"a form of maltreatment of a child. Somebody may abuse or neglect a child by inflicting harm or by failing to act to prevent harm. Harm can include ill-treatment that is not physical, as well as the impact of witnessing ill-treatment of others. This can be particularly relevant, for example, in relation to the impact on children of all forms of domestic abuse, including where they see, hear or experience its effects. Children may be abused in a family or in an institutional or community setting by those known to them or, more rarely, by others. Abuse can take place wholly online, or technology may be used to facilitate offline abuse. Children may be abused by an adult or adults, or by another child or children." (KCSiE 2024)

Types of Abuse, Neglect and Exploitation

Physical abuse: a form of abuse which may involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating or otherwise causing physical harm to a child. Physical harm may also be caused when a parent or carer fabricates the symptoms of or deliberately induces illness in a child.

Sexual abuse: a form of abuse which involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving violence, whether or not the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (for example, rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing, and touching outside of clothing. They may also include non-contact activities, such as involving children in looking at or in the production of sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse. Sexual abuse can take place online, and technology can be used to facilitate offline abuse.

Emotional abuse: the persistent emotional maltreatment of a child, such as to cause severe and adverse effects on the child's emotional development. It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or 'making fun' of what they say or how they communicate. It may feature age or developmentally inappropriate expectations being imposed on children.

These may include interactions that are beyond a child's developmental capability, as well as overprotection and limitation of exploration and learning or preventing the child from participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyberbullying), causing children to frequently feel frightened or in danger, or the exploitation or corruption of children. Some level of emotional abuse is involved in all types of maltreatment of a child, although it may occur alone.

Neglect: the persistent failure to meet a child's basic physical and/or psychological needs, likely to result in the serious impairment of the child's health or development. Neglect may occur during pregnancy, for example, as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to provide adequate food, clothing and shelter (including exclusion 12 from home or abandonment); protect a child from physical and emotional harm or danger; ensure adequate supervision (including the use of inadequate caregivers); or ensure access to appropriate medical care or treatment. It may also include neglect of, or unresponsiveness to, a child's basic emotional needs.

Child-on-child abuse: which is most likely to include, but may not be limited to:

⦁ bullying (including cyberbullying, prejudice-based and discriminatory bullying)

⦁ abuse in intimate personal relationships between children (sometimes known as 'teenage relationship abuse')

⦁ physical abuse such as hitting, kicking, shaking, biting, hair pulling, or otherwise causing physical harm (this may include an online element which facilitates, threatens and/or encourages physical abuse)

⦁ sexual violence such as rape, assault by penetration and sexual assault; (this may include an online element which facilitates, threatens and/or encourages sexual violence)

⦁ sexual harassment, such as sexual comments, remarks, jokes and online sexual harassment, which may be standalone or part of a broader pattern of abuse

⦁ causing someone to engage in sexual activity without consent, such as forcing someone to strip, touch themselves sexually, or engage in sexual activity with a third party

⦁ consensual and non-consensual sharing of nude and semi-nude images and/or videos (also known as sexting or youth-produced sexual imagery)

⦁ upskirting, which typically involves taking a picture under a person's clothing without their permission, with the intention of viewing their genitals or buttocks to obtain sexual gratification or cause the victim humiliation, distress, or alarm, and

⦁ initiation/hazing type violence and rituals (this could include activities involving harassment, abuse or humiliation used as a way of initiating a person into a group and may also include an online element).

Radicalisation: Radicalisation (the process of a person legitimising support for, or use of, terrorist violence) is a gradual process where a child or young person may be groomed online or in person, manipulated, exploited, or exposed to extremist views and harmful material, sometimes without realising what they are being drawn into.

While anyone can be radicalised, some factors can increase vulnerability, such as low self-esteem, isolation, grief, a strong need for belonging, or feelings of discrimination and injustice. These factors do not always lead to radicalisation, but where it occurs, a young person's behaviour may become increasingly centred around an extremist ideology, group, or cause.

Signs can include spending more time engaging with people who hold extreme views (online or offline), changes in appearance, losing interest in other friendships and activities, possessing extremist symbols or materials, or attempting to recruit others (Home Office, 2020).

Child criminal and/or sexual exploitation: forms of abuse that occur where an individual or group takes advantage of an imbalance in power to coerce, manipulate or deceive a child into taking part in criminal or sexual activity. It may involve an exchange for something the victim needs or wants, and/or for the financial advantage or increased status of the perpetrator or facilitator and/or through violence or the threat of violence. CCE and CSE can affect children, both male and female and can include children who have been moved (commonly referred to as trafficking) for the purpose of exploitation.

Domestic abuse: Domestic abuse can encompass a wide range of behaviours and may be a single incident or a pattern of incidents. That abuse can be, but is not limited to, psychological, physical, sexual, financial or emotional. Children can be victims of domestic abuse as they may see, hear, or experience the effects of abuse at home and/or suffer domestic abuse in their own intimate relationships (if they are over 16 and are themselves a victim of domestic abuse).

Female genital mutilation: The non-medical practice of partially or fully removing or injuring the external female genitalia. It is a procedure often carried out on girls and young women, typically under the age of 15, as a cultural or social practice with no health benefits. In the UK, FGM is considered a form of child abuse, recognised as a severe violation of human rights and a criminal offence under the Female Genital Mutilation Act 2003.

Forced marriage: involves a child or young person being coerced, threatened, or manipulated into marriage without their free and informed consent. It is illegal in the UK, and the Forced Marriage (Civil Protection) Act 2007 provides protective orders for those at risk. Unlike arranged marriage, where both parties consent, forced marriage deprives a child of their right to choose and may involve emotional, physical, or financial abuse.

Gender and Honour-based violence: A type of violence that is perpetrated in the name of protecting or restoring the perceived "honour" of an individual, family, or community. It can include various forms of abuse—such as physical assault, emotional abuse, threats, or even homicide—often targeted at individuals who are seen as bringing shame to their family or not conforming to traditional gender roles.

Note: This list is not exhaustive.

Procedure

What to do if you have concerns about a child or young person

All staff must:

⦁ In an emergency (if any child is in immediate danger), call the Police on 999 and continue with the process as appropriate.

⦁ If medical assistance is required, phone for an ambulance on 999.

⦁ Report their concerns to the DSL, who will make a safeguarding referral to the local authority if one is required, and may also contact the Police on 101.

Do I need consent to report abuse or a concern?

Safeguarding concerns about children must always be taken seriously and acted upon promptly. In most cases, you do not need the child's consent to report a safeguarding concern.

It is always better to (where appropriate and safe), explain to the child what you are going to do and why, using language they can understand. If they are a young person, you may even ask for their consent to share your concern – but never promise confidentiality, as the welfare of the child is the paramount concern (Children Act 1989). Therefore, if a child is at risk of significant harm or a serious crime may be prevented, you have a legal and moral duty to report the concern, regardless of whether the child or young person agrees.

Remember, data protection legislation does not stop you from making a report where necessary!

Should I tell the parents/guardians?

Best practice shows that parents/guardians should be notified of the intended referral if the organisation has contact with them, and it is appropriate to do so, although only if doing so would not put the child or young person at further risk of harm.

The following are circumstances where disclosure to the parent, guardian or guardian is not appropriate:

⦁ Where sexual abuse or sexual exploitation is suspected.

⦁ Where organised or multiple cases of abuse are suspected.

⦁ Where Fabricated or Induced Illness (previously known as Munchausen Syndrome by Proxy) is suspected.

⦁ Where Female Genital Mutilation is the concern.

⦁ In cases of suspected Forced Marriage.

⦁ Where it would place a child or young person, yourself, or others at immediate risk.

Where to Report Concerns - Children

The safeguarding report should be made to the local authority where the victim lives or, if this is unknown, where the abuse took place or disclosure was made. To find this information, type "report concerns about a child in #TOWN or #CITY name".

However, the Police should be contacted on 999 immediately (and without consent):

⦁ If a serious crime is being committed.

⦁ If life is at risk.

⦁ If a child or young person is in immediate danger.

What if the DSL is Unavailable?

It is always better to make a referral to the Local Authority than to let a concern go unreported. Therefore, staff should use this document to guide their decision as to whether they should refer the matter to the authorities and always air on the side of caution and make the referral if they have any nagging doubt.

Safeguarding Vulnerable Adults Policy and Procedure

Safeguarding Vulnerable Adults Definitions

An at-risk or vulnerable adult is defined as someone aged 18 years or over who, according to paragraph 42.1 of the Care Act 2014:

⦁ has care and support needs

⦁ is experiencing, or is at risk of, abuse or neglect

⦁ as a result of those needs is unable to protect himself or herself against the abuse or neglect or the risk of it.

If someone has care and support needs but is not currently receiving care or support from a health or care service, they may still be an adult at risk.

Types of Abuse - Adults

Adult safeguarding concerns may relate to the following:

Physical Abuse: Deliberately hurting an adult, causing injuries such as bruises, broken bones, burns or cuts, or otherwise causing harm. It could also be when a carer makes up the symptoms of or deliberately brings on an illness or misuses medication.

Sexual Abuse: Any sexual activity, including rape and sexual assault or sexual acts to which the adult has not consented or was pressured into consenting.

Psychological or Emotional Abuse: Includes emotional abuse, threats of harm or abandonment, deprivation of contact, humiliation, blaming, controlling, intimidation, coercion, harassment, verbal abuse, cyberbullying, isolation or unreasonable and unjustified withdrawal of services or supportive networks.

Neglect and Acts of Omission: The ongoing failure to meet basic needs; includes ignoring medical or physical care needs, failing to provide access to appropriate health, care and support or educational services, and withholding the necessities of life, such as medication, adequate nutrition, and heating.

Financial and Material Abuse: The theft or misuse of money (including benefits), property or personal belongings, taken without consent or under pressure, including in connection with wills, property, inheritance or financial transactions.

Organisational Abuse: Includes neglect or poor care practice within an organisation or specific care setting and may range from one-off incidents to ongoing ill-treatment.

Discriminatory Abuse: Includes forms of harassment and discriminatory treatment based on age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion and belief, sex or sexual orientation.

Self-neglect: The lack of self-care, lack of care for one's environment, and/or the refusal of services to the extent that it threatens personal health and safety. This includes behaviours such as hoarding. (Note that only adults with capacity can self-neglect. Children and adults who lack capacity cannot!)

Domestic Abuse: Includes any incident or pattern of incidents of controlling, coercive or threatening behaviour, violence or abuse between those aged 16 or over who are or have been intimate partners or family members, regardless of gender or sexuality. It also includes so-called 'honour-based' violence, female genital mutilation and forced marriage.

Modern Slavery: Where an individual is exploited, forced to work, or sold. It involves the recruitment and movement of individuals using threats, deception and coercion for the purpose of exploitation.

Criminal Exploitation: Criminal exploitation in adult safeguarding involves the manipulation or coercion of vulnerable adults to participate in criminal activities for the benefit of others. This can include financial exploitation, forced drug trafficking, or "cuckooing," where criminals take over the home of a vulnerable adult to carry out illegal activities.

Radicalisation: Radicalisation in adult safeguarding refers to the process by which a vulnerable adult is encouraged to adopt extremist views or support terrorism, which may lead to harmful or violent behaviours. Vulnerable adults, particularly those who are isolated or experiencing mental health challenges, may be at greater risk of radicalisation.

Procedure

What to do if you have concerns about a vulnerable or at-risk adult

All staff must:

⦁ In an emergency (if someone is in immediate danger or a serious crime is being committed), call the Police on 999 and continue with the process as appropriate.

⦁ If medical assistance is required, phone for an ambulance on 999.

⦁ Report their concerns to the DSL, who will make a safeguarding referral to the local authority if one is required, and may also contact the Police on 101.

Do I need consent to report abuse or a concern?

Unlike children, adults have a general right to independence, including control over information about themselves. Therefore, every staff member MUST try to gain consent from an adult before sharing information outside of Flourish with Neurodiversity. However:

⦁ The law DOES NOT prevent the sharing of sensitive, personal information within organisations where there is a legitimate need to know (e.g., sharing information with the DSL).

⦁ The law DOES NOT prevent the sharing of sensitive, personal information between organisations if the adult is believed to lack capacity.

⦁ The law DOES NOT prevent the sharing of sensitive, personal information between organisations (with the local safeguarding team, the Police, etc.), even without consent, where the public interest served outweighs the public interest served by protecting confidentiality. For example, where a serious crime may be prevented, people are in immediate danger, or children are at a serious risk of harm.

Involving the Adults' Family

Where the adult has the capacity to make decisions about safeguarding concerns, the involvement of family, friends or carers should be agreed with the adult.

In any case where the adult does not have mental capacity, family, friends, or carers (or the individual who has lasting power of attorney) must be consulted in accordance with the Mental Capacity Act 2005.

Think Family

Everyone has a responsibility to take a 'Think Family' approach and consider the needs of the whole family and the individual members of it.

Think: If an adult is at risk, are others in the household or family (including children) also at risk, and would a referral to children's services (Early Help or the Children's Safeguarding Team) be appropriate?

Where to Report Concerns - Adults

However, the Police should be contacted on 999 immediately (and without consent):

⦁ If a serious crime is being committed.

⦁ If life is at risk.

⦁ If a child or young person is in immediate danger.

What if the DSL is Unavailable?

However, the Police should be contacted on 999 immediately (and without consent):

⦁ If a serious crime is being committed.

⦁ If life is at risk.

⦁ If a child or young person is in immediate danger.

Managing Allegations Against Our Staff

All allegations of abuse by staff (including self-employed professionals), both present and historical, must and will be taken seriously.

Any and all reports received must immediately be reported to the business owner.

Contacting the LADO

The Local Authority Designated Lead (LADO) must be contacted within one working day in respect of all cases in which it is alleged that a person who works with children has:

⦁ 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.

Contacting the Police

The business owner will immediately contact the Police if an allegation of abuse is made against a staff member.

If people are in immediate danger, 999 will be called. Otherwise, a report will be made via 101.

Investigation

Following the report, the business owner will carry out a thorough and impartial investigation into the allegation (where appropriate, following LADO/Police advice so as not to jeopardise any formal investigation).

Suspension

In the short term, consideration may be given to suspending or amending the duties of the accused. The staff member's rights, including fair treatment and confidentiality, will be upheld throughout the process.

Actions Following Investigation

If the allegation is sustained, appropriate action will be taken.

If the allegation is unfounded, the staff member's rights, reputation, and well-being will be appropriately considered.

Record Keeping

Safeguarding records must be legible, factual, timely and accurate records of what was done and why to demonstrate transparent, defensible decision-making.

If consent was requested, the records must reflect whether it was or was not obtained and, if relevant, why a referral was made if consent was withheld.

Safeguarding records will be stored in a confidential and secure cloud-based digital file, only accessible by the DSL and those staff members with a legitimate need to know.

Confidentiality and Data Protection

Flourish with Neurodiversity will ensure that staff will read our Data Protection and GDPR Policy and understand that UK law is not a barrier to sharing information.

Flourish with Neurodiversity will also ensure that staff follow the 7 Golden Rules for information sharing as outlined in the appendices of this document.

Monitoring and Reviewing

Flourish with Neurodiversity is committed to ensuring our policies are effective and up-to-date. To do this, we have a process for regularly monitoring and reviewing them.

The business owner and founder is responsible for this process and will review this policy at least once a year or more frequently if needed due to changes in laws or our practices.

Appendix A: Seven Golden Rules on Information Sharing

1. Remember that the Data Protection Act is not a barrier to sharing information but provides a framework to ensure that personal information about living persons is shared appropriately.

2. Be open and honest with the person (and/or their family where appropriate) from the outset about why, what, how and with whom the information will or could be shared, and seek their agreement unless it is unsafe or inappropriate to do so.

3. Seek advice if you are in any doubt, without disclosing the identity of the person, where possible.

4. Share with consent where appropriate and, where possible, respect the wishes of those who do not consent to share confidential information. You may still share information without consent if, in your judgment, that lack of consent can be overridden in the public interest. You will need to base your judgment on the facts of the case.

5. Consider safety and well-being: Base your information-sharing decisions on considerations of the safety and well-being of the person and others who may be affected by their actions.

6. Necessary, proportionate, relevant, accurate, timely and secure: Ensure that the information you share is necessary for the purpose for which you are sharing it, is shared only with those people who need to have it, is accurate and up to date, is shared in a timely fashion, and is shared securely.

7. Keep a record of your decision and the reasons for it – whether it is to share information or not. If you decide to share, then record what you have shared, with whom and for what purpose.