Meridian Health Associates Ltd
Safeguarding Policy
London, Greater London · 11–50 employees
| Organisation | Meridian Health Associates Ltd |
| Document Type | Safeguarding Policy |
| Location | London, Greater London |
| Organisation Size | 11–50 employees |
| Issue Date | 18 April 2026 |
| Review Date | 18 April 2027 |
| Version | 1.0 |
| Status | Active — Current |
Document Approval
| Approved By | Date |
|---|
| Name: | |
| Position: | |
| Signature: | |
Generated by ProPolicyForge · propolicyforge.com · Confidential
Contents
1. Executive Summary
2. Purpose and Objectives
3. Scope and Applicability
4. Key Definitions
5. Abbreviations and Key Terms
6. Roles and Responsibilities
7. Legislative and Regulatory Framework
8. Policy Statement / Detailed Procedures
9. Risk Assessment and Management
10. Training and Competency Requirements
11. Monitoring, Audit and Compliance
12. Reporting and Record Keeping
13. Review and Version Control
14. Related Documents and References
15. Document Change Log
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Meridian Health Associates LtdSafeguarding Policy
1. Executive Summary
This Safeguarding Policy ("the Policy") sets out the commitment of Meridian Health Associates Ltd ("the Organisation") to safeguard all individuals who access its clinical services — including children under the age of 18, vulnerable adults, and patients with mental health conditions — and to protect members of staff from harm associated with their professional duties.
The fifth edition NHS England Safeguarding Accountability and Assurance Framework (SAAF 2026) builds upon its 2024/25 predecessor, reinforcing the commitment to ensuring the safety, protection, and welfare of babies, children, young people, and adults. This Policy aligns with that framework and with all applicable primary legislation, regulatory standards, and professional body guidance.
The Care Quality Commission (CQC) is introducing major framework changes in 2026, replacing the Single Assessment Framework with sector-specific frameworks tailored to different areas of care. This Policy is designed to evidence compliance under both the current Single Assessment Framework Quality Statements and the emerging sector-specific assessment approach. The five key questions — Safe, Effective, Caring, Responsive and Well-led — will remain the same, but the way services are assessed will change, with new sector-specific frameworks expected from mid-2026.
The Organisation holds an existing CQC registration with a current rating of Good and is registered with the Health and Care Professions Council (HCPC). Updated versions of the HCPC Standards of Conduct, Performance and Ethics came into effect on 1 September 2024. This Policy reflects those revised standards throughout.
The Employment Rights Act 2025 introduced important changes that came into force from 6 April 2026, including the abolition of the three waiting days for Statutory Sick Pay, meaning SSP is now payable from the first day of absence. The Terrorism (Protection of Premises) Act 2025 (Martyn's Law) received Royal Assent on 3 April 2025. Although not yet in force, this Policy incorporates preparatory measures commensurate with the Organisation's premises and patient-facing environment.
This Policy has been approved by the Board of Directors and applies to all individuals employed by, contracted to, or practising within Meridian Health Associates Ltd.
2. Purpose and Objectives
2.1 Purpose
The purpose of this Policy is to:
• Establish a clear, lawful, and proportionate framework for safeguarding children and adults at risk within the Organisation's clinical and non-clinical operations.
• Define the responsibilities of all individuals — regardless of role or seniority — with respect to identifying, reporting, and responding to safeguarding concerns.
• Ensure that the Organisation meets its statutory, regulatory, and professional obligations in respect of patient safety, dignity, and welfare.
• Demonstrate to the CQC, HCPC, Greater London ICB, and other relevant bodies that the Organisation operates a robust, evidence-based safeguarding culture.
• Protect staff from harm, exploitation, and undue risk arising from lone working, patient-facing clinical practice, and psychosocial workplace pressures.
2.2 Objectives
The Organisation's specific safeguarding objectives are to:
1. Prevent abuse, neglect, exploitation, and harm to all patients — in particular children, vulnerable adults, and individuals with mental health conditions — who receive care at Meridian Health Associates Ltd.
2. Ensure that all clinical and non-clinical staff are appropriately trained, competent, and supported to recognise and respond to safeguarding concerns.
3. Maintain lawful, secure, and transparent management of personal and special category health data in compliance with the UK GDPR, the Data Protection Act 2018, and the Data (Use and Access) Act 2025.
4. Promote a culture in which staff feel empowered and safe to raise safeguarding concerns without fear of detriment, consistent with the provisions of the Public Interest Disclosure Act 1998 and the expanded whistleblowing protections introduced by the Employment Rights Act 2025.
5. Maintain effective liaison with the Greater London ICB, Local Authority Designated Officers (LADOs), the Metropolitan Police Service, and other relevant statutory agencies.
6. Sustain and improve upon the Organisation's Good CQC rating by continuously evidencing the quality of safeguarding practice against the five CQC Key Questions.
3. Scope and Applicability
3.1 Persons to Whom This Policy Applies
This Policy applies to all:
• Employed clinical staff, including allied health professionals registered with the HCPC, nursing staff, and clinical support workers.
• Non-clinical staff, including reception staff, administrative personnel, and office managers.
• Self-employed practitioners and independent contractors practising from or through Meridian Health Associates Ltd premises.
• Locum or bank staff engaged on a temporary or sessional basis.
3.2 Patient Groups
This Policy applies to all patients receiving services from the Organisation, with particular emphasis on:
• Children under 18 years of age: The Organisation occasionally treats children; accordingly, child safeguarding obligations are engaged.
• Vulnerable adults: The Organisation regularly treats adults who meet the threshold of an "adult at risk" under Section 42 of the Care Act 2014.
• Individuals with mental health conditions: Clinical staff must apply the Mental Capacity Act 2005 and be alert to the intersection of mental health and safeguarding risk.
3.3 Setting and Context
The Organisation operates from fixed clinic premises in London, Greater London. All patient records are maintained electronically. Staff work alone with patients on occasion. The Organisation is an independent limited company registered with the CQC.
4. Key Definitions
Abuse: A violation of an individual's human and civil rights by another person or persons. Types of abuse include: physical, emotional or psychological, sexual, financial or material, modern slavery, neglect, self-neglect, domestic abuse, discriminatory abuse, and organisational abuse.
Adult at Risk: As defined by Section 42(1) of the Care Act 2014, an adult who has needs for care and support, is experiencing or at risk of experiencing abuse or neglect, and as a result of those needs is unable to protect themselves.
Child: Any person who has not yet reached their 18th birthday, as defined by Section 105 of the Children Act 1989 and affirmed by Working Together to Safeguard Children (2023).
Domestic Abuse: As defined by the Domestic Abuse Act 2021, behaviour of a person ("A") towards another person ("B") where A and B are personally connected, and the behaviour is abusive — encompassing physical, sexual, violent, threatening, controlling, coercive, or economic behaviour.
Female Genital Mutilation (FGM): A form of gender-based abuse involving procedures that intentionally alter or cause injury to the female genital organs for non-medical reasons. A mandatory duty to report FGM to the Police applies under the FGM Act 2003 (as amended by the Serious Crime Act 2015).
Mental Capacity: The ability of an individual to make a specific decision at a specific time, as assessed in accordance with the MCA 2005 and its Code of Practice.
Prevent: The strand of the UK Government's counter-terrorism strategy (CONTEST) concerned with preventing people from becoming radicalised. All healthcare staff have duties under the Counter-Terrorism and Security Act 2015 to have "due regard to the need to prevent people from being drawn into terrorism."
Safeguarding: Protecting people's health, wellbeing, and human rights and enabling them to live free from harm, abuse, and neglect.
6. Roles and Responsibilities
6.1 The Board of Directors
The Board of Directors has ultimate corporate responsibility for safeguarding within Meridian Health Associates Ltd. The Board must ensure that:
• A named Safeguarding Lead Director (SLD) at board level holds strategic accountability for safeguarding policy, performance, and culture.
• Safeguarding is a standing agenda item at all Board meetings (minimum: quarterly).
• Adequate resources — financial, human, and training — are allocated to meet all safeguarding obligations.
• This Policy and all supporting SOPs are formally ratified and reviewed annually.
6.2 The Designated Safeguarding Lead (DSL)
The Organisation shall appoint a Designated Safeguarding Lead (DSL) who holds specific responsibility for safeguarding governance and practice. The DSL shall be a senior clinical member of staff with qualifications at minimum Level 3 of the NHS Intercollegiate Safeguarding Competency Framework for both children and adults.
The DSL is responsible for:
• Acting as the primary point of contact for all safeguarding concerns raised by staff, patients, carers, or third parties.
• Making referrals to the Local Authority Adult Social Care team, the Metropolitan Police Service, or Local Authority Children's Services as appropriate.
• Liaising with the Greater London ICB Designated Safeguarding Professionals.
• Maintaining the Organisation's Safeguarding Concern Log.
• Ensuring that staff training records are current and that all staff have received role-appropriate safeguarding training.
• Conducting annual internal safeguarding audits and presenting findings to the Board.
6.5 All Clinical Staff
All clinical staff registered with the HCPC shall:
• Comply with the HCPC Standards of Conduct, Performance and Ethics (1 September 2024 revision).
• Complete and maintain safeguarding training at the level required for their role.
• Recognise, record, and report safeguarding concerns in accordance with the procedures in Section 8.
• Obtain valid, informed consent before providing care or treatment, and apply the MCA 2005 where a patient lacks capacity to consent.
• Maintain professional boundaries at all times.
• Never leave a child under 18 or a vulnerable adult without appropriate supervision or safety arrangements in place.
7. Legislative and Regulatory Framework
7.1 Primary Legislation
This Policy is drafted in accordance with the following current UK legislation:
• Children Act 1989: Establishes the paramountcy principle and the duty to investigate where a child is at risk of significant harm (Section 47).
• Children Act 2004: Requires relevant agencies to make arrangements to safeguard and promote the welfare of children.
• Care Act 2014: Places a duty on local authorities to safeguard adults at risk and to establish Safeguarding Adults Boards.
• Mental Capacity Act 2005: Provides a legal framework for decision-making where an individual may lack capacity.
• Human Rights Act 1998: Incorporates ECHR rights into domestic law. Articles 2, 3, and 8 are of particular relevance to safeguarding.
• Female Genital Mutilation Act 2003 (as amended): Creates a mandatory reporting duty upon regulated health and social care professionals.
• Modern Slavery Act 2015: Creates offences of slavery, servitude, forced labour, and human trafficking.
• Domestic Abuse Act 2021: Defines domestic abuse and places a duty on local authorities to provide support to victims.
• Counter-Terrorism and Security Act 2015: Establishes the Prevent duty upon specified public authorities including healthcare providers.
7.2 Data Protection Legislation
• UK General Data Protection Regulation (UK GDPR): Patient health information constitutes "special category data" under Article 9.
• Data Protection Act 2018 (DPA 2018): Supplements and contextualises the UK GDPR in domestic law.
• Data (Use and Access) Act 2025 (DUAA 2025): Introduces a new lawful ground for processing personal data for safeguarding purposes. On 23 March 2026, the ICO released new guidance clarifying the use of the recognised legitimate interest lawful basis for safeguarding disclosures. By June 2026, organisations must implement a process to handle data protection complaints under the DUAA 2025.
7.6 Regulatory Framework
Care Quality Commission (CQC): The Organisation is registered with the CQC and currently rated Good. The CQC has published its 2025/26 business plan alongside a consultation on its inspection and assessment process, moving towards sector-specific assessment frameworks. This Policy is designed to evidence performance against all five Key Questions — Safe, Effective, Caring, Responsive and Well-led.
Health and Care Professions Council (HCPC): The revised HCPC Standards of Conduct, Performance and Ethics came into effect on 1 September 2024. All registered clinical staff must demonstrate continuing compliance with these Standards.
NHS England Safeguarding Accountability and Assurance Framework 2026 (SAAF 2026): This fifth edition of the SAAF has been shaped by findings from recent Public Inquiries, statutory safeguarding reviews, and the 10 Year Health Plan for England. This Policy aligns with SAAF 2026 in full.
8. Policy Statement / Detailed Procedures
8.1 Policy Statement
Meridian Health Associates Ltd is unequivocally committed to the safeguarding of all patients who access its services. The Organisation affirms the following principles:
• Prevention: The Organisation will take proactive steps to prevent harm before it occurs through training, environment design, clinical supervision, and culture.
• Protection: The Organisation will act swiftly and proportionately to protect those who are, or may be, at risk of harm.
• Partnership: The Organisation will work collaboratively with the Greater London ICB, local authority safeguarding teams, the Metropolitan Police Service, and other relevant agencies.
• Proportionality: All interventions will be proportionate to the level of risk and the needs of the individual.
• Empowerment: Patients will be supported to make informed decisions about their care, and their views, wishes, and feelings will be sought and respected at all times.
• Accountability: The Organisation will maintain clear records, regular audit, and transparent governance of all safeguarding activity.
8.2 Recognising Abuse and Neglect
All staff must be able to recognise the signs and indicators of abuse, neglect, and exploitation.
In children:
• Unexplained injuries, bruising, or burns.
• Significant changes in behaviour, mood, or engagement.
• Inappropriate sexual knowledge or behaviour.
• Disclosure — direct or indirect — of harm.
• Signs of malnutrition, poor hygiene, or inappropriate clothing.
• Fearfulness around a parent, carer, or other adult.
In adults at risk and patients with mental health conditions:
• Unexplained injuries or signs of physical harm.
• Fearfulness, withdrawal, or anxiety in the presence of a specific individual.
• Financial concerns, including unexplained asset depletion.
• Indicators of self-neglect, including poor hygiene or weight loss.
• Disclosures — direct or indirect — of harm, coercion, or exploitation.
• Evidence of controlling or coercive behaviour by a third party.
• Indicators of trafficking, labour exploitation, or domestic abuse.
• Signs of radicalisation or vulnerability to extremist influence (Prevent duty indicators).
8.3 Procedure for Reporting a Safeguarding Concern — Children
Step-by-step procedure:
1. Any member of staff who identifies or suspects a safeguarding concern involving a child under 18 shall immediately cease any activity that may interfere with evidence and shall not attempt to conduct their own investigation.
2. The staff member shall record their observations factually and contemporaneously in the EHR system, noting the date, time, nature of the concern, and the exact words used by the child where applicable.
3. The staff member shall report the concern to the DSL — or, in the DSL's absence, the Deputy DSL — within two hours if the concern involves a risk of immediate harm.
4. The DSL shall assess the level of risk and determine whether a referral to the Local Authority Children's Services is required under Section 47 of the CA 1989.
5. If the DSL considers the child to be in immediate danger, the DSL shall contact the Metropolitan Police Service at 999 and notify the Local Authority Emergency Duty Team simultaneously.
6. Where a concern relates to FGM in a girl under 18, the DSL shall make a mandatory report to the Police without delay in compliance with the FGM Act 2003. This duty cannot be delegated or deferred.
7. If the alleged perpetrator is a member of staff, the DSL shall notify the LADO (Local Authority Designated Officer) within one working day.
8.4 Procedure for Reporting a Safeguarding Concern — Adults at Risk
Step-by-step procedure:
1. Any member of staff who identifies or suspects that an adult at risk is being, or is at risk of being, abused or neglected shall record their concern factually and contemporaneously in the EHR system without delay.
2. The staff member shall report the concern to the DSL within the same working day.
3. The DSL shall conduct an initial safeguarding enquiry, including assessment of the adult's mental capacity in accordance with the MCA 2005.
4. Where possible and safe to do so, the DSL shall seek the adult's views, wishes, and feelings consistent with the "Making Safeguarding Personal" principle.
5. Where the DSL determines that a Section 42 enquiry is required, the DSL shall make a referral to the relevant Local Authority Adult Social Care team within 24 hours.
6. Where domestic abuse is identified, the DSL shall consider whether a referral to MARAC (Multi-Agency Risk Assessment Conference) is appropriate.
7. Where modern slavery or human trafficking is suspected, the DSL shall consider referral to the National Referral Mechanism (NRM) and shall notify the Metropolitan Police.
8. Where Prevent indicators are identified, the DSL shall consider making a referral to Channel — the voluntary, multi-agency programme for individuals vulnerable to radicalisation.
10. Training and Competency Requirements
10.1 Safeguarding Training Standards
All staff must complete safeguarding training appropriate to their role:
• Non-clinical staff: Level 1 — Safeguarding awareness (induction and every 3 years).
• Clinical staff (non-registered): Level 2 — Safeguarding children and adults (induction and every 3 years).
• HCPC-registered clinical staff: Level 3 — Safeguarding children and adults (induction and every 3 years).
• Designated Safeguarding Lead and Deputy DSL: Level 3 minimum, refreshed every 2 years, with additional specialist training as required.
10.5 HCPC Registrant CPD
Each HCPC-registered clinician is personally responsible for ensuring that their safeguarding competence is maintained and evidenced as part of their continuing professional development (CPD) portfolio, in compliance with HCPC Standard 6 (CPD). The Organisation's safeguarding training programme is designed to support — but not replace — the registrant's individual professional obligation.
11. Monitoring, Audit and Compliance
The effectiveness of this Policy will be monitored through:
• Monthly review of the Safeguarding Concern Log by the DSL.
• Quarterly audit of safeguarding referrals, outcomes, and training compliance.
• Annual internal safeguarding audit conducted by the DSL, with findings reported to the Board.
• CQC compliance review — this Policy will be reviewed against current CQC Quality Statements at each annual review cycle.
CQC Key Questions Evidence Mapping:
• Safe: This Policy evidences systems to protect people from abuse and avoidable harm, fulfilling the "Safe" Quality Statement.
• Effective: Training requirements fulfil the HCPC Standards of Conduct, Performance and Ethics (2024).
• Caring: The "Making Safeguarding Personal" approach evidences person-centred care under the "Caring" Key Question.
• Responsive: Referral pathways and MARAC referral criteria evidence responsiveness to individual needs.
• Well-led: The Board-level SLD role, annual audit, and Safeguarding Concern Log evidence robust governance under "Well-led."
13. Review and Version Control
This Policy is subject to review no less than annually, or following:
• Any significant safeguarding incident, Safeguarding Adults Review (SAR), or Child Safeguarding Practice Review (CSPR) involving the Organisation.
• Any material change in relevant UK legislation, statutory guidance, CQC framework, or HCPC Standards.
• Any change in the Organisation's Designated Safeguarding Lead, Deputy DSL, or CEO/SLD.
• Any CQC inspection finding or regulatory recommendation relating to safeguarding.
This document is owned by the CEO / Managing Director of Meridian Health Associates Ltd. Version control is maintained in the Document Change Log.
14. Related Documents and References
This Policy should be read in conjunction with the following documents:
• Lone Working SOP
• Infection Control Policy
• Data Protection and UK GDPR Policy
• Mental Capacity Assessment SOP
• Incident Reporting and Investigation SOP
• Recruitment and DBS Checking Policy
• Whistleblowing Policy
• Staff Supervision and Appraisal Policy
External references:
• Working Together to Safeguard Children 2023 (HM Government)
• Care and Support Statutory Guidance (DHSC)
• NHS England Safeguarding Accountability and Assurance Framework 2026 (SAAF 2026)
• Prevent Duty Guidance 2023
• CQC Single Assessment Framework (cqc.org.uk)
• HCPC Standards of Conduct, Performance and Ethics 2024 (hcpc-uk.org)
• ICO Guidance on recognised legitimate interests under DUAA 2025 (March 2026)
15. Document Change Log
Complete this table each time this document is reviewed or updated to maintain an audit trail for inspection purposes.
| Version | Date of Review | Reviewed By | Changes Made / Reason |
|---|
| 1.0 | 18 April 2026 | | Initial version — generated by ProPolicyForge against current UK legislation |
| | | |
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Version 1.0 · 18 April 2026Page 1 of 1propolicyforge.com