Spicy Minds Ltd safeguarding adults policy
Section 1: Introduction
Scope of policy
This policy needs to be understood in relation to other Spicy Minds policies and processes
Key responsibilities at various levels
Section 2. What do we mean when we talk about safeguarding for adults?
Defining safeguarding
Defining abuse
Section 3. How we will safeguard adults at Spicy Minds
Section 5: Reporting safeguarding adult concerns outside of the apps
Section 6 - Managing allegations against members of the Spicy Minds team and whistleblowing at Spicy Minds
Section 7 - Safer recruitment
Safer recruitment in supply chain and partnership working
Section 9 - Creating a safeguarding culture - training, communications and support
Appendix 1: Defining abuse
Physical abuse
Domestic abuse
Sexual abuse
Psychological abuse
Financial or material abuse
Modern slavery
Discriminatory abuse
Organisational abuse
Neglect and acts of omission
Self-neglect
Appendix 2: What are the six principles of adult safeguarding?
Empowerment
Prevention
Appendix 3: Guidance on what we do if an adult using one of our apps might be at risk and what action we take preventatively
What we do preventatively to protect people from risk in our apps
Appendix 5 - Reporting adults safeguarding concerns for users outside of the app
Steps for reporting concerns for adults in activities outside of apps
Appendix 6 - Confidentiality and information sharing in reporting adult safeguarding concerns
Seven helpful rules for information sharing concerning adults
Appendix 7 - Internal safer recruitment processes
Section 1: Introduction
As a tech organisation focused on improving mental health and wellbeing through innovative products and services, Spicy Minds is committed to building a strong, safe community. We believe every individual has the right to feel safe and are dedicated to contributing positively to their wellbeing.
Spicy Minds might come into contact with vulnerable adults by providing digital products and services. These include (but are not limited to):
Rowan, an app which provides mental health support through AI-powered conversations and activities which use third generation Cognitive Behavioural Therapy models such as Acceptance and Commitment Therapy and psychodynamic techniques.
Hazel is a parenting support app which enables parents and carers to explore their child’s neurodivergent traits alongside offering supportive, coaching conversations and resources.
Sasha, an AI supervisor to support clinical practitioners and therapists to better analyse and support their own professional development.
At present, none of these services are registered as medical devices, and are not aimed at adults with diagnosed mental conditions or designed to replace or be a substitute for therapy or counselling.
These services are currently all aimed for use with adults (people aged 18 and over) rather than children and young people, therefore safeguarding has been considered in relation to adult users.
Outside of its apps, Spicy Minds may also come into contact with adults who have safeguarding needs through work and activities such as research, user testing, marketing and other promotional events. This policy covers such activity.
Currently, Spicy Minds interactions with vulnerable adults are not classified as regulated activity because the organisation does not provide therapy or counselling. Therefore, staff are not legally required to have a DBS check. However, as a good practice measure, all employed staff have undergone a basic DBS check. If Spicy Minds begins offering traditional therapy or counselling, this would likely be considered regulated activity, meaning staff would then require an enhanced DBS check. Additionally, as Spicy Minds works towards registering certain services as medical devices, this is an important consideration.
Spicy Minds aspires to work towards best practice in safeguarding, and this policy will be reviewed every six months as we work towards refining and expanding safeguarding features and capacity within the app. We use the key principles of adult safeguarding (Appendix 2) to guide design and development of app features, shape the design and development of our safeguarding for adults and to remind everyone in the team to stay focused on the needs of people using the app.
Scope of policy
This policy seeks to ensure that Spicy Minds undertakes its responsibilities with regard to protection of vulnerable adults and responds to concerns appropriately. The policy establishes a framework to support the team, whether employed, self-employed contractors or partners in their practices and clarifies the organisation’s expectations around safeguarding. This policy also covers safer recruitment and whistleblowing.
The primary piece of legislation that we use to inform our practices is the Care Act 2014. The other legislative frameworks are listed here:
England
Children Act 1989: Sets out the duties of local authorities, courts, and parents to ensure the welfare of children.
Human Rights Act 1998 (HRA): Applies across the UK.
Public Interest Disclosure Act 1998: Applies mainly to England and Wales.
Education Act 2002 (Section 175): Places a duty on schools to safeguard and promote the welfare of children
Children Act 2004: Amends the 1989 Act and introduces the Every Child Matters framework. It strengthens the duty on local authorities and other agencies to work together to safeguard children.
Mental Capacity Act 2005 (MCA): Applies in England and Wales
Safeguarding Vulnerable Groups Act 2006: Introduces the Vetting and Barring Scheme for people working with children.
Equality Act 2010: Applies across the UK.
Protection of Freedoms Act 2012: Applies across the UK
The Care Act, 2014: Applies in England and sets out duties to safeguard adults with care and support needs.
Counter-Terrorism and Security Act 2015: Applies across the UK.
Children and Social Work Act 2017: Improves the welfare of looked-after children and sets up new safeguarding arrangements for local areas.
Working Together to Safeguard Children (2018): Government guidance that outlines statutory responsibilities for safeguarding, including multi-agency collaboration.
Wales
Children Act 1989: Applies in Wales and includes specific provisions for child protection.
Human Rights Act 1998 (HRA): Applies across the UK.
Public Interest Disclosure Act 1998: Applies mainly to England and Wales.
Education Act 2002 (Section 175): As in England, this places a duty on schools to safeguard children.
Children Act 2004: Introduces duties in Wales, including creating Local Safeguarding Children Boards (now replaced by Regional Safeguarding Boards under the 2014 Act).
Mental Capacity Act 2005 (MCA): Applies in England and Wales
Safeguarding Vulnerable Groups Act 2006
Protection of Freedoms Act 2012: Applies across the UK.
Social Services and Well-being (Wales) Act 2014: Provides the legal framework for improving the well-being of people who need care and support, including children.
Equality Act 2010: Applies across the UK.
Rights of Children and Young Persons (Wales) Measure 2011: Places a duty on Welsh Ministers to consider the rights of children in all decisions.
Counter-Terrorism and Security Act 2015: Applies across the UK.
Keeping Learners Safe (2020): Welsh government guidance on safeguarding in schools and education settings.
Scotland
Social Work (Scotland) Act 1968 and other legislation, such as the Community Care and Health (Scotland) Act 2002, govern social care services.
Children (Scotland) Act 1995: Establishes the responsibilities and rights of parents and guardians, including child protection duties.
Human Rights Act 1998 (HRA): Applies across the UK.
Adults with Incapacity (Scotland) Act 2000.
Protection of Vulnerable Groups (Scotland) Act 2007
Equality Act 2010: Applies across the UK.
Protection of Freedoms Act 2012: Applies across the UK.
Children and Young People (Scotland) Act 2014: Enhances the provisions for children's services, child protection, and the implementation of the Getting It Right for Every Child (GIRFEC) approach.
Counter-Terrorism and Security Act 2015: Applies across the UK.
Northern Ireland
Children (Northern Ireland) Order 1995 – Main framework for safeguarding children's welfare.
Education and Libraries (Northern Ireland) Order 2003 – Establishes safeguarding duties for schools.
Mental Capacity Act (Northern Ireland) 2016 – Covers decision-making for those who lack capacity.
Safeguarding Vulnerable Groups (Northern Ireland) Order 2007 – Establishes vetting and barring for people working with vulnerable groups.
Protection of Freedoms Act 2012: Applies across the UK.
Adult Safeguarding Prevention and Protection in Partnership (2015) – Provides safeguarding guidance for adults.
Co-operating to Safeguard Children and Young People in Northern Ireland (2017) – Sets out multi-agency safeguarding responsibilities.
Counter-Terrorism and Security Act 2015: Applies across the UK.
Human Rights Act 1998 (HRA): Applies across the UK.
Equality Act 2010 applies partially to NI. Sex Discrimination (NI) Order, 1976 & Race Relations (NI) order, 1997 also apply.
This policy needs to be understood in relation to other Spicy Minds policies and processes:
Child Safeguarding Policy
ISO 27001 Security Policy
ISO 62305 Software Development Policy
ISO 13485 Quality Management Policy
ISO 14971 Risk Management Plan
DCB0129 Clinical Risk Management Plan
DCB0129 Clinical Risk Management System
Spicy Minds Whistle Blowing Policy 270225
Employee Handbook inc EDU policy
Appendices to safeguarding policy
Safeguarding risk assessment/s for user activities in apps
Key responsibilities at various levels:
All team members at Spicy Minds (paid or unpaid, employed or contracted) have responsibility to follow the guidance laid out in this policy and related policies, and to pass on any welfare concerns using the required procedures.
We expect all team members to adhere to good practice, contribute to discussions about safeguarding and to positively involve people in developing safe practices.
Beth Shedden is the Designated Safeguarding Lead (DSL). Beth has overall safeguarding responsibility and is supported to develop practice and knowledge in this area by the safeguarding consultancy SCIE (Social Care Institute for Excellence) and the safeguarding committee which is composed of three senior team members - the CEO, DSL and tech lead.
The DSL is responsible for ensuring the safeguarding policy is in place and appropriate as recommended by the safeguarding committee and external safeguarding consultancy. The DSL is also responsible for ensuring that the policy is accessible and cascaded to the team and safer recruitment policies detailed in this policy are followed including for recruitment, induction and training.
The DSL is also responsible for ensuring that time and budget are allocated to ensure safeguarding is prioritised within the organisation and that recommendations from safeguarding consultants are actioned.
The DSL is responsible for embedding safeguarding culture in the whole organisation including organising appropriate training and reviewing and monitoring practices. The DSL will stay up to date with safeguarding briefings and updates such as community care adult safeguarding updates and will share these with the safeguarding committee as a standing agenda item.
The DSL will receive staff concerns and respond swiftly to any allegations or concerns raised; they will also deal with allegations against members of the team.
The DSL is responsible for processing and responding to complaints and conflicts either about individuals in relation to safeguarding or more broadly in terms of operations, processes or strategy.
The safeguarding committee is responsible for supporting the DSL to implement the guidelines recommended in the policy and that processes outlined in this policy are followed. They are also responsible for managing any complaints or allegations made against the DSL and will seek external HR and safeguarding support when necessary.
The safeguarding committee is also responsible for supporting the DSL in managing safeguarding concerns, supporting a person-based culture and reflective learning environment and to support the DSL to consider how to best manage any safeguarding concerns where relevant.
For internal safeguarding concerns, contact details for DSL and safeguarding committee members should be provided to the whole team and any member of the safeguarding committee can be messaged on slack or by phone if staff have concerns. If the complaint/ concern is about the DSL, then the other committee members should be enabled to access a budget and commission independent external HR support to conduct an investigation.
For external safeguarding queries or concerns (from outside the team), please email:
compliance@spicyminds.org
And allow 48 hours for a response from the safeguarding committee. If you are worried about someone at risk of harm, please contact emergency or local services as appropriate.
The DSL will progress, record and respond to any concerns raised in line with this policy seeking external HR support and advice as required.
As part of safeguarding committee meetings, the DSL will monitor the following items as agenda items in their recurring meetings:
• Safe recruitment practices including DBS checks undertaken and references applied for new team (lease see safer recruitment section 7 and relevant appendix 7)
• Training – register/record of staff training and ensure that staff are trained to an appropriate level for their role (please see section 9 - training and creating a safeguarding culture)
• Ensure that safeguarding concerns are being reported and actioned (please see section 3 - how we safeguard adults at Spicy Minds and appendix 3 and 4)
• Ensuring that this policy is reviewed every six months as Spicy Minds works towards being a best practice safeguarding organisation, or more often if service design alters substantially with version control in place. (please see section 10 - policy review)
• Ensuring safeguarding is a standing agenda item across team meetings types such as UX and retrospectives as documented in this policy (please see section 3 - how we safeguard adults at Spicy Minds).
• Ensuring that safeguarding is embedded in design and development across all apps and services. (please see section 3 - how we safeguard adults at Spicy Minds).
• Ensuring the safeguarding committee includes focus on monitoring, reflection and improvement. (please see Section 9 - creating a safeguarding culture).
• Ensuring that any change in user activity or service requires an update in the risk register for the user activity and that this informs product design. (please see section 3 - how we safeguard adults at Spicy Minds).
Section 2. What do we mean when we talk about safeguarding for adults?
Defining safeguarding
Safeguarding is about embedding practices throughout the organisation to ensure the protection of vulnerable adults wherever possible and responding to circumstances that arise.
The Care Act 2014 defines adult safeguarding as:
‘Protecting an adult’s right to live in safety, free from abuse and neglect. It is about people and organisations working together to prevent and stop both the risks and experience of abuse or neglect, while at the same time making sure that the adult’s wellbeing is promoted including, where appropriate, having regard to their views, wishes, feelings and beliefs in deciding on any action. This must recognise that adults sometimes have complex interpersonal relationships and may be ambivalent, unclear or unrealistic about their personal circumstances.’
Who might need safeguarding as an adult?
Safeguarding for adults sits at the intersection of needs and abuse and neglect. Safeguarding is for adults who, because of a particular need such as dementia, disability including learning disabilities, mental illness or physical illness, homelessness, addiction, might not be able to protect themselves from abuse or neglect or the risk of abuse and neglect.
Some people, because of particular care needs, might be at a higher risk, might not realise they are being abused or might not be able to report it as easily due to barriers in society to hearing their voices.
Defining abuse
Abuse can be caused by those inflicting harm or those who fail to act to prevent harm. The Care and Support Statutory Guidance (2024) identifies 10 types of abuse. Please see this Appendix 1 of this policy for details on the 10 types of abuse.
At Spicy Minds, we will also use the six principles of adult safeguarding (Appendix 2) to inform the ways in which we respond to service users and to inform the ways in which we respond to needs, and to shape service design and development. Please see Appendix 2 to see the principles of adult safeguarding.
Section 3. How we will safeguard adults at Spicy Minds
There is relatively little guidance in best practice on adult safeguarding in the wellness/mental health digital space. It feels therefore particularly important to be considered and reflected in our service and product design in relation to safeguarding and, more broadly, the wellbeing of our community of users.
While our products and services, such as our apps, are not aimed at those with diagnosed mental health needs, we need to recognise the fact that some of our users will have mental health needs, be neurodivergent and have disabilities. Indeed, given that our services are aimed at those who want to explore and regulate their feelings and manage worry and stress, people using our apps might be more likely to have more support needs than some other communities. Additionally, since the apps use large language models and AI, and do not currently deploy human to human interaction, we need to consider how we can support and care for our community with these limitations and opportunities.
Therefore, In order to safeguard adults at Spicy Mind effectively, we commit to the following processes and governance:
Safeguarding at Spicy Minds is overseen by Beth Shedden who acts as the DSL (Designated Safeguarding Lead) for the organisation but is supported in this activity by a safeguarding committee. The committee meets every four weeks to discuss safeguarding updates/reviews and to ensure that safeguarding culture is embedded within the organisation. The safeguarding committee will include the tech lead, CEO and DSL.
Safeguarding risk register and hazard log to be reviewed by the safeguarding committee for each new activity, service or product before that activity/service is released live.
Safeguarding is approached with curiosity, compassion and a focus on continual improvement and in line with the six principles of adult safeguarding (Appendix 2).
There is a sign off from the DSL or member of the safeguarding committee to whom this safeguarding responsibility has been delegated (eg consultant with safeguarding knowledge) before live material is released.
The safeguarding policy is available to the public which could also include a shorter ‘plain text’ version available as a ‘short read’ with a link to full copy.
As a UK-based company, this framework is based on UK policy but as users become global, safeguarding reviews will need to account for any other legislation that might need to be adopted and how different cultures and languages intersect with safeguarding needs.
Appendix 3 contains guidance for what actions are currently taken by Spicy Minds to support users of the apps who might be at risk of harm as we work towards safeguarding best practice and what design features in the apps have been considered to prevent and reduce risk of harm for our community of users.
Appendix 4 contains guidance for how we approach safeguarding adults at Spicy Minds outside of app based activities (for example, in user research or at events). This is separate from the reporting of concerns for adults in activities outside of the app which is detailed in Section 5 below.
Section 5: Reporting safeguarding adult concerns outside of the apps
There might be situations where a member of the team has safeguarding concerns about an adult involved in research, focus groups, events, marketing or other activities outside of the apps/digital services.
As SCIE summarises, organisations need to share safeguarding information with the right people at the right time to:
prevent death or serious harm
coordinate effective and efficient responses
enable early interventions to prevent the escalation of risk
prevent abuse and harm that may increase the need for care and support
maintain and improve good practice in safeguarding adults
reveal patterns of abuse that were previously undetected and that could identify others at risk of abuse
identify low-level concerns that may reveal people at risk of abuse
help people to access the right kind of support to reduce risk and promote wellbeing
help identify people who may pose a risk to others and, where possible, work to reduce offending behaviour
reduce organisational risk and protect reputation.
If not an immediate emergency that requires 999, the process outlined in Appendix 5 details the stages involved in raising and reporting safeguarding concerns at Spicy Minds for users outside of the app. Any member of the team including volunteers, contractors and advisors as well as the employed team should always follow this process if they have concerns that might reflect a safeguarding concern (see definition above) that is putting that person, or someone else, at risk of harm.
Appendix 6 details confidentiality and information sharing in reporting adult safeguarding concerns and contains seven helpful rules for sharing information concerning adults. Appendices 5 and 6 create guidelines and further sources of information in how to approach and manage consent in information sharing including where consent is not given and duty of care through alternatives to referral to social care.
Section 6 - Managing allegations against members of the Spicy Minds team and whistleblowing at Spicy Minds
Spicy Minds whistleblowing policy
Section 7 - Safer recruitment
One ongoing safeguarding risk in any organisation is hiring people in any capacity who might pose a risk to others. Spicy Minds ensures safer recruitment through a number of internal safer recruitment processes which are detailed in Appendix 7 of this policy.
Safer recruitment in supply chain and partnership working
Contracts and memorandums of agreement for partnership delivery work will include clear minimum requirements, arrangements for safeguarding and non-compliance procedures.
Service delivery contracting and subcontracting with individuals or partners should normally follow the steps detailed above. Where partnership or subcontracting is undertaken with suppliers then the organisation subcontracting/supplying must have the same commitment to safeguarding and safer recruitment as Spicy Minds and be able to demonstrate this/or be willing to work under this policy here. There will be systematic checking of safeguarding arrangements of partner organisations and safeguarding will be a fixed agenda item on any partnership set and in partnership reporting meetings and, given the nature of our work, should include particular attention to privacy and data security in relation to safeguarding.
Where in doubt of process, Spicy Minds should follow its own safer recruitment processes and seek further advice from the safeguarding consultant, SCIE.
Section 8 - Data protection and information sharing in relation to adult safeguarding
Due to the nature of the organisation’s activities which predominantly involve user activity digitally through apps, data protection and information sharing is absolutely key to effective safeguarding.
We believe that one of the biggest safeguarding risks to our community and beneficiaries is data breach, data theft and other misuse of personal data including from external, internal actors or errors. Therefore a lot of detailed work has been undertaken.
Please see our privacy policy for details of key actions which are being taken by Spicy Minds to keep users’ data safe and to prevent data breaches which also need to be understood in the context of wider Spicy Minds’ data protection and security policies.
The privacy policy also details when we would share information with law enforcement authorities to prevent or stop the abuse of children and adults.
Section 9 - Creating a safeguarding culture - training, communications and support
Spicy Minds understands that effective safeguarding only happens in organisations where safeguarding is cultural, embedded and systemic rather than ad hoc and reactive.
Therefore the organisation commits resources for induction, training of the team (paid and unpaid including contractors), effective communications and support mechanisms in relation to safeguarding.
Induction and communications for all members of the team in any role will include:
Time to read the safeguarding policy and provide written confirmation they have understood it to their line manager.
Allocated time in the monthly safeguarding committee meetings for new app feature discussions to check any safeguarding implications.
Clear repeated instruction to come to the DSL or other member of the safeguarding committee with any safeguarding questions or concerns.
Regular prompting and introduction of safeguarding as a topic so that it becomes culturally ‘normalised’ in team meetings as above, with time given to people to reflect on any concerns, thoughts and room for improvement.
Time to read other related policies such as equalities and diversity policy and privacy and data security policies.
Induction and communications for team in roles including UX, direct work with users/overseeing direct work with users, training the AI and designing therapeutic services will include:
All of the above for the whole team and in addition:
SCIE recommended adult safeguarding training repeated formally every three years with briefing on trends annually
Opportunities to explore other training which should be encouraged and normally funded by the organisation eg mental health first aid training and digital safeguarding . so that everyone is trained to an appropriate level for their role
Ongoing culture of training and learning for the team around safeguarding, inclusion, diversity and equalities through safeguarding topics at retro and all hands meetings as well as external opportunities.
Ability to contact an external safeguarding/HR consultant with any concerns or queries with contact provided if the DSL is unable to help, or there is a concern about the DSL.
The safeguarding committee has a culture of monitoring, reflection and improvement and this is reflected in the terms of reference and minutes from each committee meeting.
Support for team in dealing with safeguarding concerns:
Spicy Minds recognises that involvement in situations where there is risk or actual harm can be stressful for staff concerned. This might be because of concerns about an adult or because of an allegation received or made. In any of these situations, the DSL will provide support and reassurance around the next steps that will be taken. The DSL may signpost to counselling or self-help resources. If the DSL cannot help, or there is a concern about the DSL, independent safeguarding advice will be sought by the safeguarding committee.
Section 10 - Policy review
Spicy Minds will make sure users can access the safeguarding policy easily, preferably working towards an ‘easy read’ version as well as link to a full copy on each of the service apps and on the website.
The policy will be reviewed by the DSL and the safeguarding committee every six months or more often if service design alters substantially with version control in place. The review will be mindful of emergent best practices in safeguarding, and activity development in the apps, as well as user feedback, and user needs, in line with the principles of adult safeguarding.
Last updated March 2025
Six month review: September 2025
Appendices
Appendix 1: Defining abuse
Abuse can be caused by those inflicting harm, to themselves or others, or those who fail to act to prevent harm. The Care and Support Statutory Guidance (2024) identifies 10 types of abuse which are detailed here. Please see this link to the SCIE for details on indicators and signs of abuse under each type of abuse.
https://www.scie.org.uk/safeguarding/adults/introduction/types-and-indicators-of-abuse/
This is not an exhaustive list of what abuse is, nor do these examples prove that abuse is occurring. However, they do indicate that a closer look and possible investigation may be needed.
Physical abuse
Assault, hitting, slapping, punching, kicking, hair-pulling, biting, pushing
Rough handling
Scalding and burning
Physical punishments
Inappropriate or unlawful use of restraint
Making someone purposefully uncomfortable (eg opening a window and removing blankets)
Involuntary isolation or confinement
Misuse of medication (eg over-sedation)
Forcible feeding or withholding food
Unauthorised restraint, restricting movement (eg tying someone to a chair)
Female genital mutilation (FGM)
Domestic abuse
The cross-government definition of domestic violence and abuse is: any incident or pattern of incidents of controlling, coercive, 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. The abuse can encompass, but is not limited to:
psychological
physical
sexual
financial
emotional abuse
so called ‘honour’ based violence
coercive control
Sexual abuse
rape
indecent exposure
sexual harassment
inappropriate looking or touching
sexual teasing or innuendo
sexual photography
subjection to pornography or witnessing sexual acts
indecent exposure
sexual assault
sexual acts to which the adult has not consented or was pressured into consenting / sexual exploitation
Psychological abuse
Enforced social isolation – preventing someone accessing services, educational and social opportunities and seeing friends
Removing mobility or communication aids or intentionally leaving someone unattended when they need assistance
Preventing someone from meeting their religious and cultural needs
Preventing the expression of choice and opinion
Failure to respect privacy
Preventing stimulation, meaningful occupation or activities
Intimidation, coercion, harassment, use of threats, humiliation, bullying, swearing or verbal abuse
Addressing a person in a patronising or infantilising way
Threats of harm or abandonment
Cyber bullying
Radicalisation
Financial or material abuse
Theft of money or possessions
Fraud, scamming
Preventing a person from accessing their own money, benefits or assets
Employees taking a loan from a person using the service
Undue pressure, duress, threat or undue influence put on the person in connection with loans, wills, property, inheritance or financial transactions
Arranging less care than is needed to save money to maximise inheritance
Denying assistance to manage/monitor financial affairs
Denying assistance to access benefits
Misuse of personal allowance in a care home
Misuse of benefits or direct payments in a family home
Someone moving into a person’s home and living rent free without agreement or under duress
False representation, using another person’s bank account, cards or documents
Exploitation of a person’s money or assets, eg unauthorised use of a car
Misuse of a power of attorney, deputy, appointeeship or other legal authority
Rogue trading – eg unnecessary or overpriced property repairs and failure to carry out agreed repairs or poor workmanship
Financial abuse is the main form of abuse investigated by the Office of the Public Guardian both among adults and children at risk. Financial recorded abuse can occur in isolation, but as research has shown, where there are other forms of abuse, there is likely to be financial abuse occurring. Although this is not always the case, everyone should also be aware of this possibility and be aware of the indicators which can be found on the SCIE website along with other indicators of abuse.
https://www.scie.org.uk/safeguarding/adults/introduction/types-and-indicators-of-abuse/#domestic
Modern slavery
Human trafficking
Forced labour
Domestic servitude
Sexual exploitation, such as escort work, prostitution and pornography
Debt bondage – being forced to work to pay off debts that realistically they never will be able to
Criminal exploitation
GOV.UK has more information on identifying and reporting modern slavery
Discriminatory abuse
Unequal treatment based on age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion and belief, sex or sexual orientation (known as ‘protected characteristics’ under the Equality Act 2010)
Verbal abuse, derogatory remarks or inappropriate use of language related to a protected characteristic
Denying access to communication aids, not allowing access to an interpreter, signer or lip-reader
Harassment or deliberate exclusion on the grounds of a protected characteristic
Denying basic rights to healthcare, education, employment and criminal justice relating to a protected characteristic
Substandard service provision relating to a protected characteristic
Organisational abuse
Discouraging visits or the involvement of relatives or friends
Run-down or overcrowded establishment
Authoritarian management or rigid regimes
Lack of leadership and supervision
Insufficient staff or high turnover resulting in poor quality care
Abusive and disrespectful attitudes towards people using the service
Inappropriate use of restraints
Lack of respect for dignity and privacy
Failure to manage residents with abusive behaviour
Not providing adequate food and drink, or assistance with eating
Not offering choice or promoting independence
Misuse of medication
Failure to provide care with dentures, spectacles or hearing aids
Not taking account of individuals’ cultural, religious or ethnic needs
Failure to respond to abuse appropriately
Interference with personal correspondence or communication
Failure to respond to complaints
Neglect and acts of omission
Failure to provide or allow access to food, shelter, clothing, heating, stimulation and activity, personal or medical care
Providing care in a way that the person dislikes
Failure to administer medication as prescribed
Refusal of access to visitors
Not taking account of individuals’ cultural, religious or ethnic needs
Not taking account of educational, social and recreational needs
Ignoring or isolating the person
Preventing the person from making their own decisions
Preventing access to glasses, hearing aids, dentures, etc.
Failure to ensure privacy and dignity
Self-neglect
Lack of self-care to an extent that it threatens personal health and safety
Neglecting to care for one’s personal hygiene, health or surroundings
Inability to avoid self-harm
Failure to seek help or access services to meet health and social care needs
Inability or unwillingness to manage one’s personal affairs
Appendix 2: What are the six principles of adult safeguarding?
The following six principles apply to all sectors and settings including care and support services, further education colleges, commissioning, regulation and provision of health and care services, social work, healthcare, welfare benefits, housing, wider local authority functions and the criminal justice system. The principles should inform the ways in which professionals and other staff work with adults.
Empowerment
People being supported and encouraged to make their own decisions with informed consent.
I am asked what I want as the outcomes from the safeguarding process and these directly inform what happens.
Prevention
It is better to take action before harm occurs.
I receive clear and simple information about what abuse is, how to recognise the signs and what I can do to seek help.
Proportionality
The least intrusive response appropriate to the risk presented.
I am sure that the professionals will work in my interest, as I see them and they will only get involved as much as needed.
Protection
Support and representation for those in greatest need.
I get help and support to report abuse and neglect. I get help so that I am able to take part in the safeguarding process to the extent to which I want.
Partnership
Local solutions through services working with their communities. Communities have a part to play in preventing, detecting and reporting neglect and abuse.
I know that staff treat any personal and sensitive information in confidence, only sharing what is helpful and necessary. I am confident that professionals will work together and with me to get the best result for me.
Accountability
Accountability and transparency in delivering safeguarding.
I understand the role of everyone involved in my life and so do they.
At Spicy Minds, we will use the six principles to shape the design and development of our safeguarding for adults and use them to remind everyone in the team to stay focused on the needs of the service beneficiaries.
Appendix 3: Guidance on what we do if an adult using one of our apps might be at risk and what action we take preventatively
Responding to people who might be at risk of harm within the apps:
Rowan and Hazel are trained to be aware of a high number of possible safeguarding flags and to ask clarifying questions if it is in doubt.
Safeguarding flags around a range of issues generate signposting for further support with reputable known agencies.
Reputable known agencies will be statutory (eg NHS, police) and/or national charity experts with accessible helplines to help ensure quality and accessibility.
Spicy Minds uses detailed signposting as much as possible eg if someone is talking with the Hazel or Rowan app about domestic violence, or housing, then they are given at least two options for a specific national helpline that supports the specific issue, as well as generalist contacts such as Samaritans and Shout. This means community members have more choice and are more empowered to access tailored support and advice.
If suicide or intent to harm is expressed, signposting is immediate and will include a prompt to call an ambulance for support with emergency mental health needs as well as specialist helpline options.
For other issues, the signposting might appear later in the interaction with the app so that someone who is upset does not feel interrupted in the middle of something they wanted to say or express, or finalise (for example, if something arises during a screening or a session).
Helpline numbers are clearly displayed in a banner during the conversation. This will ensure users can access support quickly, without having to search for helpline numbers. Signposting appears more than once and people are able to reference the helpline contacts again easily in their app experience.
Conversations which contain safeguarding flags will be reviewed by Barbara, an AI that evaluates Hazel and Rowan's safeguarding conversations independently. Any conversations Barbara flags that Rowan and Hazel have not dealt with well will be reviewed by the DSL. The conversations are automatically anonymised and redacted, which means we cannot read conversations in full or link anything back to you. This allows us to monitor frequency of issues arising for community members and helps ensure our apps are responding appropriately and sensitively and signposting to further support in the correct way. Please refer to our privacy policy for more information as there are rare safety occasions when we may review conversations unredacted.
The copy in our apps normalises seeking support and aims to be nurturing and empathetic. It reminds people that if they have a trusted person in their life it might be helpful to talk to them as well as seeking professional support. This is worded thoughtfully to ensure it does not provoke negative feelings for people who don’t have someone they feel they trust.
What we do preventatively to protect people from risk in our apps
Train our apps in BACP framework and ethics standards as well as in other reputable ethics frameworks to ensure that it does not give inadequate, poor, inaccurate or dangerous responses.
Train the apps to be empathic, curious and supportive in its responses to enable people to feel heard and seen while using the app.
Work towards training apps in a number of dialects and modes of speech with consideration to best practice in inclusive AI. The AI is trained to ask questions and seek clarification where there is ambiguity over meaning.
Train the AI to recognise the six principles of adult safeguarding and the 10 signs of abuse documented in this policy and to recognise indicators documented in The Care and Support Statutory Guidance (2024). It can reflect sensitively if someone raises behaviour which might be abusive and the AI can offer clear boundaries around abusive behaviour eg it is never ok to hurt someone, it is not ok that they hit you when they are angry.
Ensure that seeking support and talking to people both in their networks (friends, family members) and professionals (helplines, NHS) is normalised within dialogue and content within the services and products so that people have an ongoing sense of encouragement to engage - rather than just at crisis points.
Ensure very high levels of data and privacy protection and transparency around this with our community to protect people from feeling anxious about data breach or misuse of data.
Ensure that all copy and content within the app feels non-judgemental, empathetic, curious and supportive.
Ensure that the AI remembers what has last happened for this person and proactively checks in on how they are feeling about that issue, including whether they spoke about or sought support for more difficult issues if relevant.
Ensure that during the onboarding process, people with mental health needs are invited to access professional support in a nurturing and welcoming way, and ensure it is clear that these services are not intended to replace medical or other professional help.
Ensure that the app is aimed at over 18s - currently by asking for age during onboarding and being available only to over 18s on the app store
Ensure that there is an accessible and easy to find list of resources for different needs that someone might have so they have choice about how they access these within the apps.
Ensure that any screening or questionnaires are robust, fully explained and framed in non judgmental and supportive terminology.
Ensure that any screening or questionnaires are clear that they are not diagnostics and give clear signposting for further resources and help.
Ensure that all Spicy Minds apps feel safe, nurturing, accessible, inclusive and warm therefore providing a digital space where people feel safe to explore and expand on more difficult feelings and emotions as well as learning how to better regulate and manage and reflect on what is calming, joyful or peaceful in their lives.
Appendix 5 - Reporting adults safeguarding concerns for users outside of the app
Steps for reporting concerns for adults in activities outside of apps
If you are worried about immediate risk of significant harm to someone or in any doubt this is a risk, ring emergency services (999) and follow their advice. Wherever possible seek permission from the adult you are calling about.
See if any medical attention or treatment is required and call an ambulance if needed.
Discuss with the person you are worried about that you are concerned about them and hear their views and thoughts as soon as possible. Find out whether they are receiving support and whether there are other people who are already aware. Explain to them that you might need to take your concerns to the safeguarding lead (DSL) in the organisation to discuss your concerns further and reassure them you will keep them updated with what is happening. Ensure the best means of communicating with them and a home address is taken, as well as other key details. Be interested and compassionate, and aware of boundaries and physical and verbal cues that they are giving.
Communicate your concerns with the DSL by phone or if possible in person or on the relevant slack channel the same day. The DSL will then take the concerns to the Spicy Minds safeguarding committee within 24 hours so they can discuss further. If you are messaging the DSL and safeguarding committee and you are remote, please use the phrase ‘safeguarding concerns’ in your message so they can see you are worried about someone.
If the DSL is unavailable for any reason (eg due to illness), concerns can be taken to another member of the safeguarding committee by using the appropriate slack channel.
Duty of care should include discussion and thoughtful consideration about what follow up is needed and would be most appropriate and supportive eg a referral to further support through a specialist agency or charity. This might be what is advised instead of a referral at the point of discussion with adult social care or in discussion with the adult or as advice from the DSL. Ensure that this is compassionate, person centred, timely and proportionate and delivered in full and thoughtful consultation with the person you are concerned about.
Details of the concern and any follow up action should be recorded in safeguarding committee meeting minutes.
If it is felt that a referral to adult social care might be needed then obtain permission from the person you are worried about to make a referral if safe and appropriate.
If they do not want you to make a referral, listen to their reasons so that consent or withholding consent is fully contexualised and seek further safeguarding advice about whether consent should be overridden before making a decision. Please see https://www.scie.org.uk/safeguarding/adults/practice/sharing-information/ where there is a detailed section on ‘What to do if a person does not want you to share their information’. Please also see Appendix 6 for confidentiality and information sharing in reporting adult safeguarding concerns and seven helpful rules for sharing concerns about adults.
If there are any areas of uncertainty (eg about best next steps for support or if they do not want to give permission for a referral) the DSL will seek advice from Adult Social Service/Access and Response, local to where the adult lives. Advice can also be sought internally from the DSL. If permission has not been given to share information, this can be done anonymously to protect identity. Again, if you are discussing what to do if someone does not want you to share information, this can also be done anonymously.
To make a referral, contact the the DSL who will complete the Local Authority Safeguarding Incident Report Form if required which will be on the website of the relevant local authority to where the adult is living and submit to the local authority within 48 hours of receiving concerns.
All concerns should be reported to the DSL and recorded in the safeguarding committee meeting minutes. If the concern relates to the DSL, contact the CEO. Please see Section 6 - Managing allegations in the safeguarding policy for more information.
Appendix 6 - Confidentiality and information sharing in reporting adult safeguarding concerns
Ensure that the adult you are concerned about is informed and involved in the information sharing and if you have concerns or worries about this, seek advice from the adult social care referral and assessment team or the correct team in the relevant local authority. No information should be shared with people who do not need to know this information for safeguarding reasons.
For example, if you need to discuss with a peer because this will help you reach a more informed safeguarding decision, then this is absolutely best practice. Do not share information if sharing with a peer will not aid safeguarding, and their involvement is not part of the safeguarding process.
Similarly, it is sensible to ask the adult if there is someone else in their network or a loved one that you can talk to if you have worries but if they don’t want you to do this, this needs to be respected and decision making passed to adult social care as part of the referral. Below contains seven helpful rules for sharing concerns about adults which should also be consulted before information sharing. As detailed in Appendix 5, please also see https://www.scie.org.uk/safeguarding/adults/practice/sharing-information/ where there is a detailed section on ‘What to do if a person does not want you to share their information’.
Seven helpful rules for information sharing concerning adults:
Remember that the General Data Protection Regulation (GDPR) is not a barrier to sharing information but provides a framework to ensure that personal information about living persons is shared appropriately.
Be open and honest with the person (and/or their family where appropriate) from the outset about why, what, how and with whom information will, or could be, shared, and seek their agreement, unless it is unsafe or inappropriate to do so.
Seek advice if you are in any doubt, without disclosing the identity of the person where possible.
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 judgement, that lack of consent can be overridden in the public interest. You will need to base your judgement on the facts of the case.
Consider safety and wellbeing: base your information-sharing decisions on considerations of the safety and wellbeing of the person and others who may be affected by their actions.
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.
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.
Appendix 7 - Internal safer recruitment processes
Providing the following safeguarding statement in any recruitment adverts or application details even where this is informal eg on Upwork or LinkedIn: The organisation is committed to keeping people safe and so all recruitment is undertaken in line with safer recruitment practices.
Role descriptions for all roles involving contact with adults who might be more likely to need safeguarding will contain reference to safeguarding responsibilities and will highlight need for DBS enhanced check for adult workforce and invite positive disclosure and offer that positive disclosure will be considered in line with best practice and on a case-by-case basis.
Any roles description including those that have no contact with service users will reference a commitment to safeguarding culture and best practice.
Any gaps on CV or application form are asked about with curiosity and sensitivity. Particular attention is given to any long periods of time abroad or which someone finds it hard to account for. Additional references to cover such periods should be sought.
Each interview for any role should contain one safeguarding question which is curious about people's attitudes to ethics, empathy and empowerment of human rights. One such question might be ‘can you tell us about a time where you noticed something that was worrying you about a situation you didn’t think was ethical or about a person you felt worried about and what you did and why?’
Any interview for a role that has direct contact with service users/or oversees direct contact with service users/or where someone will be training the AI in response to services users/or where someone is designing therapeutic activities should have at least two safeguarding questions which should ask about ‘STAR’ models (Situation, Task, Action, Response) for interactions with people including people who might be vulnerable and actions and follow up taken.
Any interviews for roles relating to direct contact or overseeing direct contact/training AI or designing therapeutic activity/services will be subject to safer recruitment processes.
Recruitment also needs to be understood in line with equalities and diversity policy with the understanding that more diverse teams are also likely to be better able to represent the diverse voices of stakeholders and community of service users and therefore be safer teams.
Every job description, including for volunteers and contractors, should include a statement on commitment to safeguarding, a reference to this policy and a copy of the expectations to members of the team. ‘Every single person in the organisation, regardless of role, is expected to be committed to speaking up for any person using our services who might be at risk of harm, and undertakes to commit to safeguarding policy.’
Where no job description exists, because of, for example, the nature of contracting, then the team member can sign off on such a statement with the statement ‘I understand that I am …. ( see above)’ with a copy stored in writing/email.
Interviewers should seek to get to know the person as an individual for example by asking about their hobbies, how they like to manage their emotions, conflict, what they would do if they felt unsure or worried about something. This is to create a more grounded sense of the person.
For those working in direct contact with users or overseeing direct contact with users/training or overseeing AI or designing therapeutic activities, two references should be sought in writing which also specifically ask about any safeguarding concerns and worries including one from most recent employer where this is possible. Personal references not from friends or family can also be sought where due to self employed status for example, professional references might prove harder.
For those working in ongoing direct contact with users or overseeing direct contact with users/training or overseeing AI or designing therapeutic activities, an enhanced DBS (Adult Workforce or Child and Adult Workforce) should be sought.
For employees working more broadly in the organisation for example with data, privacy, security, a basic DBS check which shows unspent conviction is sought.
Overseas police checks can also be sought when team members are joining from abroad for any role as part of the safer recruitment process and it is advised that additional references including from most recent employers are also sought here. Again personal references not from friends and family can also be sought here. Please see this list for details of how to obtain overseas police checks: https://www.gov.uk/government/publications/criminal-records-checks-for-overseas-applicants/countries-q-z
It is to be noted that sometimes there are excellent reasons why people cannot source overseas checks (for example because of disruption, administration or conflict in country of origin) and it is important that this is understood in relationship to equal opportunities and diversity and sensitivity applied by the recruiting team.
Existing staff who transfer into a role requiring a DBS enhanced level check will be required to undertake one.
All people requiring a DBS enhanced check will be requested to join the DBS update service and then checks will be undertaken annually by the CEO (or delegated to a suitable person) to check for changes/updates against the original certificate with permission sought each time from the team member. A register will be kept in the safeguarding committee folder which will be kept confidential and will document the annual checks performed and any follow up discussion required. Any changes might involve discussion with line managers and HR professionals. Staff should be encouraged to declare any changes as they happen rather than waiting for annual reviews.
For roles that require DBS enhanced level check, the organisation will not seek to undertake new ones if the team member is on the update service, consents to update service check and can produce a copy of the original certificate with the same number as the update service registration with suitable proof of ID and proof of current home address. Update service checks without original certificates cannot be accepted. The DBS must be to a suitable level or higher and must cover the correct workforce (eg Adult or Adult and Child)
Existing DBS enhanced checks which meet the above requirements but are not on the update service can be accepted as a short term measure as long as they are three months old or less and references cover this period of activity.
Generally, the organisation will organise and fund any DBS and update service requirements for its team.
Any safer recruitment queries, concerns or worries should be immediately brought to the attention of the DSL, and taken to the safeguarding committee which should then seek further advice if needed from external safeguarding consultant.