Safeguarding Policy

1. Our commitment to safeguarding

AtWell Clinic (operated by MRL Health Ltd) is committed to the safety and welfare of all patients, with a particular duty of care towards children, young people, and vulnerable adults. We recognise that healthcare settings can be places where abuse or neglect first becomes apparent, and we take our responsibility to act on any concern very seriously.

Safeguarding is everyone’s responsibility. Every member of our team — clinical and non-clinical — has a duty to be alert to signs of abuse or neglect, to know how to raise a concern, and to act promptly when a concern arises.

This policy is consistent with the legislative framework and statutory guidance applicable in England, including:

• Children Act 1989 — which establishes the legal framework for the care and protection of children and the principle that a child’s welfare is paramount
• Children Act 2004 — which introduced the duty to cooperate to safeguard and promote the welfare of children, and established multi-agency working
• Care Act 2014 — which sets out the legal framework for safeguarding adults at risk of abuse or neglect
• Working Together to Safeguard Children 2018 (updated 2023) — the statutory guidance setting out how organisations and agencies must work together to safeguard and promote the welfare of children

2. Who this policy applies to

Children and young people

For the purposes of this policy, a child is any person under the age of 18, in accordance with the Children Act 1989. AtWell Clinic provides healthcare services to children from birth through to 17 years. Our safeguarding obligations apply to all children and young people who attend as patients, or who accompany adult patients or visitors.

Vulnerable adults

An adult at risk (sometimes called a vulnerable adult) is a person aged 18 or over who has needs for care and support, and who is experiencing, or is at risk of, abuse or neglect, and as a result of those needs is unable to protect themselves. This definition is drawn from the Care Act 2014.

Vulnerability may arise from a wide range of circumstances, including but not limited to: cognitive impairment or dementia, mental health conditions, learning disabilities, physical disability, substance misuse, or circumstances of coercive control.

3. Our safeguarding principles

Our approach to safeguarding is guided by the following core principles:

• Welfare is paramount. The safety and wellbeing of a child or vulnerable adult will always take precedence over other considerations.
• Act, don’t wait. Where there is a reasonable concern, we will not delay in taking action or seeking advice. Inaction in the face of concern is not acceptable.
• Listen and believe. We take disclosures seriously. We will listen carefully, without leading or pressuring, and treat every disclosure with respect.
• Record carefully. We maintain accurate, contemporaneous records of any safeguarding concern, observation, or action taken, using the patient’s own words where a disclosure is made.
• Involve, don’t investigate. It is not our role to investigate allegations of abuse. Our role is to recognise, record, and refer to the appropriate agencies.
• Share information proportionately. Safeguarding concerns can override normal duties of confidentiality. We will share relevant information with appropriate agencies where there is a risk to life or welfare, in accordance with Information Commissioner’s Office (ICO) guidance on data sharing in public interest.
• Work in partnership. We cooperate with local authority children’s services, the police, NHS services, and other agencies where required to protect individuals at risk.

4. How we handle safeguarding concerns

Recognising a concern

Safeguarding concerns may arise in many ways — through direct disclosure by a patient, through clinical observations during examination, through patterns in presentation, through behaviour, or through information shared by a third party. Our clinical staff are trained to recognise indicators of:

• Physical abuse (unexplained injuries, injuries inconsistent with the account given, injuries at different stages of healing)
• Emotional and psychological abuse
• Sexual abuse
• Neglect (poor nutrition, hygiene, unmet medical needs, persistent absence)
• Domestic violence and coercive control
• Female genital mutilation (FGM) — a mandatory reporting duty applies to registered healthcare professionals
• Modern slavery and trafficking
• Child sexual exploitation and criminal exploitation

Reporting process

1. Do not delay. Any member of staff who has a safeguarding concern must raise it immediately with the Named Safeguarding Lead (see section 5). If the Safeguarding Lead is not available, a senior clinician must be informed without delay.
2. Record contemporaneously. The concern must be recorded clearly and accurately in the patient’s clinical record at the time it arises. Use the patient’s own words where a disclosure has been made. Record facts, not opinions.
3. Take advice if unsure. If in doubt about whether a concern meets the threshold for referral, contact the local authority’s Multi-Agency Safeguarding Hub (MASH) or children’s services duty team for advice. Seeking advice does not automatically trigger a formal referral.
4. Refer where appropriate. Where a concern warrants formal referral, the Safeguarding Lead will contact the local authority children’s or adult safeguarding team, or the police, as appropriate. Referrals will be made within 24 hours of the concern being identified, or immediately in cases of immediate risk.
5. Mandatory reporting — FGM. Under section 5B of the Female Genital Mutilation Act 2003 (as inserted by the Serious Crime Act 2015), regulated healthcare professionals in England and Wales have a legal duty to report to the police where they discover that an act of FGM appears to have been carried out on a girl under 18. This report will be made without delay.

Confidentiality and information sharing

Concerns about a patient’s safety can override the normal duty of confidentiality. We will share relevant information with appropriate agencies without the patient’s consent where:

• There is a risk to the life of the patient or another person
• There is reasonable cause to suspect that a child is suffering, or is likely to suffer, significant harm
• A mandatory reporting duty applies (e.g. FGM)

We will seek the patient’s agreement to share information where possible, unless doing so would place them or another person at increased risk, or would prejudice the prevention or detection of crime. Information will only be shared on a need-to-know basis and to the minimum extent necessary.

5. Staff training and DBS checks

Safeguarding training

All AtWell Clinic staff receive safeguarding training appropriate to their role and level of responsibility:

• Clinical staff — trained to at least Level 3 safeguarding (children) and Level 2 safeguarding (adults), in line with the Intercollegiate Document Safeguarding Children and Young People: Roles and Competencies for Healthcare Staff (2019) and equivalent adult safeguarding competency frameworks. Training is refreshed every three years as a minimum.
• Non-clinical staff — trained to Level 1 safeguarding awareness as a minimum, refreshed every three years.
• Named Safeguarding Lead — trained to Level 4 and participates in local multi-agency safeguarding training and forums.

Safeguarding training records are maintained and reviewed at annual appraisal.

Disclosure and Barring Service (DBS) checks

All clinical staff and any staff who may have direct contact with children or vulnerable adults hold a current Enhanced DBS certificate with barred list check, obtained prior to commencement of employment and renewed at regular intervals in line with our DBS policy. Records of DBS certification are maintained by the clinic manager and reviewed annually.

6. Named Safeguarding Lead

AtWell Clinic has a Named Safeguarding Lead who holds overall responsibility for the implementation of this policy and acts as the first point of contact for any safeguarding concern raised by staff, patients, or members of the public.

Named Safeguarding Lead: [To be confirmed — name will be published here upon appointment]
Contact: hello@wellclinics.co.uk — please mark correspondence “Safeguarding”
Telephone: 01676 545111

In the absence of the Named Safeguarding Lead, safeguarding concerns should be escalated to the senior clinician on duty, who will take immediate responsibility and contact the Named Lead as soon as practicable.

7. Useful contacts

National organisations

• NSPCC Helpline (children)
  Free, 24/7, confidential advice and support. Concerns about a child can be reported whether or not you are a professional.
  Telephone: 0808 800 5000 • Email: help@nspcc.org.uk • Website: nspcc.org.uk
• Childline (for children and young people)
  Telephone: 0800 1111 (free, 24/7) • Website: childline.org.uk
• Adult safeguarding — local authority
  Adult safeguarding concerns should be reported to the local authority for the adult’s area of residence. For Solihull Metropolitan Borough Council (our local authority):
  Telephone: 0121 788 3737 (adults) or 0121 788 4848 (children)
  Website: solihull.gov.uk/safeguarding
• Police
  In an emergency: 999
  Non-emergency: 101
• NSPCC FGM Helpline
  Telephone: 0800 028 0285
• Modern Slavery Helpline
  Telephone: 0800 0121 700 (free, 24/7)

8. How to raise a concern with us

If you have a safeguarding concern about a patient you have seen at AtWell Clinic, or about a child or vulnerable adult connected to our patients, you can contact us as follows:

• By telephone: 01676 545111 — ask to speak to the Named Safeguarding Lead or, if unavailable, the senior clinician on duty
• By email: hello@wellclinics.co.uk — please mark your message “Safeguarding”
• In person: 164 Station Road, Balsall Common, CV7 7FD

Concerns can also be raised directly with the local authority, the NSPCC, or the police without contacting us first. You do not need to have definitive proof of abuse to make a referral — a reasonable concern is sufficient.

We welcome concerns raised in good faith and will not penalise anyone who raises a genuine concern, even where a subsequent investigation finds that no abuse has occurred.

9. Policy review

This policy will be reviewed annually by the Named Safeguarding Lead and the Clinical Lead, or sooner if required by changes in legislation, statutory guidance, or learning from a safeguarding incident. Staff will be notified of any material changes. The policy is available to all staff and to the public on request.