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People and safeguarding

Safeguarding Adults at Risk Policy and Procedure

Al-Waris Foundation is committed to safeguarding adults at risk who come into contact with the charity through its activities, services, projects, events, communications, partnerships or other work.

Current version 2.0

1. Policy Statement

Al-Waris Foundation is committed to safeguarding adults at risk who come into contact with the charity through its activities, services, projects, events, communications, partnerships or other work.

Everyone has the right to live free from abuse, neglect, exploitation and avoidable harm.

Al-Waris Foundation recognises that safeguarding is everyone's responsibility.

The Board of Trustees has ultimate responsibility for safeguarding within the charity. Operational safeguarding responsibilities may be delegated to appropriately appointed individuals, but the trustees retain overall responsibility for ensuring that safeguarding risks are identified, managed and reviewed.

Al-Waris Foundation will take reasonable and proportionate steps to prevent harm and will respond promptly and appropriately where a safeguarding concern arises.

Safeguarding action should respect the adult's rights, dignity, wishes and autonomy while recognising that circumstances may sometimes require action without consent to protect the adult or another person from serious harm.

2. Scope

This policy applies to:

  • trustees;
  • staff;
  • volunteers;
  • contractors;
  • consultants;
  • representatives;
  • project workers;
  • fundraisers acting on behalf of Al-Waris Foundation;
  • delivery partners where relevant;
  • any other person acting on behalf of the charity.

It applies to Al-Waris Foundation activities:

  • in the United Kingdom;
  • overseas;
  • online;
  • in person;
  • at charity premises;
  • at events;
  • during fundraising;
  • during project delivery;
  • during visits to beneficiaries;
  • during distributions of aid;
  • when taking photographs or video;
  • when communicating electronically;
  • when working through partner organisations or contractors.

3. Who is an Adult at Risk?

For the purposes of this policy, an adult is a person aged 18 or over.

In England, the Care Act 2014 safeguarding duties concern an adult who:

  • has needs for care and support, whether or not those needs are being met;
  • is experiencing, or is at risk of, abuse or neglect; and
  • as a result of those care and support needs is unable to protect themselves from the abuse or neglect, or the risk of it.

Al-Waris Foundation recognises that vulnerability is not always permanent.

A person may become particularly vulnerable because of circumstances including:

  • disability;
  • illness;
  • mental ill-health;
  • age;
  • frailty;
  • bereavement;
  • displacement;
  • homelessness;
  • poverty;
  • dependency;
  • domestic abuse;
  • emergency or disaster;
  • isolation;
  • communication difficulties;
  • exploitation;
  • immigration or refugee circumstances;
  • reliance upon another person for care, money, accommodation or access to services.

The charity should consider the person's actual circumstances rather than applying labels unnecessarily.

4. Safeguarding Principles

Al-Waris Foundation will apply the following principles:

Empowerment

Adults should be supported to make their own decisions and give informed consent wherever possible.

Prevention

It is better to take reasonable action before harm occurs.

Proportionality

The response should be proportionate to the risk presented.

Protection

People at greatest risk should receive appropriate support and protection.

Partnership

Safeguarding often requires cooperation between individuals, communities, statutory authorities and organisations.

Accountability

Safeguarding decisions and responsibilities should be clear and appropriately recorded.

Al-Waris Foundation will also:

  • respect dignity and human rights;
  • take concerns seriously;
  • provide accessible ways to report concerns;
  • avoid discrimination;
  • maintain appropriate boundaries;
  • recruit safely;
  • share information appropriately;
  • maintain safeguarding records;
  • manage risks associated with partners and overseas work;
  • learn from incidents and near misses.

5. Legal and Regulatory Framework

This policy should be read in the context of applicable law and guidance, including where relevant:

  • Care Act 2014;
  • Care and Support Statutory Guidance;
  • Mental Capacity Act 2005;
  • Human Rights Act 1998;
  • Equality Act 2010;
  • Domestic Abuse Act 2021;
  • Modern Slavery Act 2015;
  • Safeguarding Vulnerable Groups Act 2006;
  • Protection of Freedoms Act 2012;
  • Data Protection Act 2018;
  • UK General Data Protection Regulation;
  • relevant Disclosure and Barring Service requirements;
  • Charity Commission safeguarding guidance;
  • Charity Commission serious incident reporting guidance.

Where Al-Waris Foundation operates outside the United Kingdom, applicable local safeguarding law and reporting requirements must also be considered.

Where local law provides a lower level of protection than this policy, Al-Waris Foundation should seek to maintain the standards contained in this policy so far as lawful and reasonably practicable.

6. Forms of Abuse and Neglect

Abuse may be a single act, repeated acts, deliberate conduct or a failure to act.

It may occur in person or online.

It may be committed by:

  • a family member;
  • partner;
  • carer;
  • neighbour;
  • professional;
  • volunteer;
  • trustee;
  • staff member;
  • contractor;
  • another beneficiary;
  • stranger;
  • organisation;
  • group.

Forms of abuse may include:

6.1 Physical Abuse

Including assault, hitting, slapping, pushing, misuse of medication, inappropriate restraint or inappropriate physical sanctions.

6.2 Domestic Abuse

Including physical, sexual, psychological, emotional, economic, coercive or controlling behaviour between personally connected people.

6.3 Sexual Abuse

Including sexual activity without consent, sexual assault, rape, sexual harassment, inappropriate touching, sexual exploitation or being made to view or participate in sexual activity.

6.4 Psychological or Emotional Abuse

Including threats, intimidation, humiliation, coercion, harassment, isolation, controlling behaviour or unreasonable restriction.

6.5 Financial or Material Abuse

Including:

  • theft;
  • fraud;
  • scams;
  • coercion relating to money or property;
  • misuse of benefits;
  • misuse of bank accounts;
  • exploitation of financial dependency;
  • misuse of charitable assistance.

6.6 Modern Slavery

Including:

  • slavery;
  • human trafficking;
  • forced labour;
  • domestic servitude;
  • exploitation.

6.7 Discriminatory Abuse

Including abuse or harassment connected with a protected characteristic or other aspect of a person's identity.

6.8 Organisational Abuse

Including neglect, poor practice or abuse within an organisation, service, institution, project or care environment.

6.9 Neglect and Acts of Omission

Including ignoring medical, emotional or physical needs, failing to provide appropriate care, or withholding necessities.

6.10 Self-Neglect

Including behaviour that seriously threatens a person's health, safety or wellbeing, where safeguarding intervention may be appropriate.

6.11 Online and Digital Abuse

Including:

  • scams;
  • financial exploitation;
  • coercion;
  • harassment;
  • stalking;
  • grooming;
  • impersonation;
  • misuse of images;
  • unauthorised disclosure of private information.

7. Roles and Responsibilities

7.1 Board of Trustees

The Board of Trustees has ultimate responsibility for safeguarding.

The Board will:

  • approve this policy;
  • ensure safeguarding risks are considered within risk management;
  • ensure appropriate safeguarding arrangements are maintained;
  • receive appropriate safeguarding assurance;
  • ensure serious incidents are considered for reporting to the Charity Commission;
  • ensure safeguarding failures are addressed;
  • review safeguarding arrangements at least annually.

7.2 Designated Safeguarding Lead

Al-Waris Foundation will appoint a Designated Safeguarding Lead (DSL).

The DSL is responsible for coordinating operational safeguarding arrangements.

Responsibilities include:

  • receiving concerns;
  • providing safeguarding advice;
  • maintaining appropriate records;
  • assessing escalation requirements;
  • coordinating referrals;
  • following up concerns;
  • supporting safeguarding awareness and training;
  • communicating significant safeguarding matters to the Board appropriately;
  • maintaining knowledge of relevant safeguarding procedures.

The identity and current contact details of the DSL should be maintained in controlled organisational records and made available to those who need them.

7.3 Deputy Safeguarding Arrangements

Where practicable, the charity should appoint a deputy or alternative safeguarding contact.

Safeguarding action must not be unnecessarily delayed because the DSL is unavailable.

7.4 Trustee Safeguarding Oversight

The Board may appoint a Trustee Safeguarding Lead.

This does not remove the collective responsibility of all trustees.

7.5 Everyone Acting for Al-Waris Foundation

Everyone covered by this policy must:

  • understand safeguarding responsibilities relevant to their role;
  • follow this policy;
  • maintain professional boundaries;
  • report concerns promptly;
  • cooperate with safeguarding processes;
  • avoid undertaking their own unauthorised investigation.

8. Recognising a Safeguarding Concern

A concern may arise because:

  • an adult makes a disclosure;
  • another person reports a concern;
  • abuse or neglect is witnessed;
  • injuries or behaviour cause concern;
  • financial exploitation is suspected;
  • a beneficiary appears controlled by another person;
  • a person is denied access to assistance intended for them;
  • a charity representative behaves inappropriately;
  • inappropriate communications are discovered;
  • a partner reports an incident;
  • information is received from a statutory authority;
  • a pattern of smaller concerns suggests greater risk.

Proof is not required before reporting a genuine safeguarding concern.

9. Responding to a Disclosure

If an adult tells you they are being harmed or are at risk:

Do:

  • remain calm;
  • listen;
  • take the concern seriously;
  • allow the person to speak in their own words;
  • respect their dignity;
  • establish whether immediate help is required;
  • explain that information may need to be shared where necessary for safeguarding;
  • make an accurate record;
  • report the concern appropriately.

Do not:

  • promise absolute confidentiality;
  • interrogate the person;
  • ask unnecessary leading questions;
  • confront the alleged perpetrator;
  • make assumptions;
  • attempt to investigate the allegation yourself;
  • dismiss the concern because the adult previously declined assistance.

10. Immediate Danger

If an adult is in immediate danger or requires urgent medical assistance:

  1. contact the appropriate emergency service without delay;
  1. take reasonable steps to protect the person without placing yourself or others at unnecessary risk;
  1. inform the DSL as soon as reasonably practicable;
  1. make an accurate record.

In the United Kingdom, emergencies should normally be reported using 999 or 112.

For overseas activities, the relevant local emergency arrangements should be used.

11. Reporting a Concern

Concerns should normally be reported to the DSL as soon as possible.

A safeguarding report should include, where known:

  • the person's name;
  • relevant contact details;
  • date and time;
  • location;
  • people involved;
  • factual description of what occurred;
  • exact words used where significant;
  • immediate risks;
  • action already taken;
  • wishes of the adult where known;
  • name of the person making the report.

If the DSL is unavailable and delay could increase risk, the concern should be raised directly with the appropriate authority.

12. Consent and the Adult's Wishes

Adults should normally be involved in decisions about their safeguarding.

Where an adult has capacity to make the relevant decision, their wishes should be respected so far as possible.

However, there may be circumstances where information needs to be shared or action taken without consent.

Examples may include where:

  • another person is at risk;
  • a child may be at risk;
  • a serious crime may have occurred;
  • the adult may be under coercion or undue influence;
  • there is an overriding public-interest or legal reason;
  • the adult lacks capacity to make the relevant decision;
  • a statutory duty requires action.

The reason for acting with or without consent should be recorded.

13. Mental Capacity

Al-Waris Foundation will not assume that a person lacks capacity merely because they:

  • have a disability;
  • have a mental health condition;
  • are elderly;
  • communicate differently;
  • make a decision others consider unwise.

Where the Mental Capacity Act 2005 applies, the charity will have regard to its principles.

Capacity is decision-specific and time-specific.

Where significant uncertainty exists, appropriate professional advice should be sought.

14. Making Safeguarding Personal

Where appropriate, the adult should be asked:

  • what they want to happen;
  • what outcome they would like;
  • what support they need;
  • whether there are communication or accessibility requirements;
  • whether there is anyone they would like involved.

The person's wishes should inform the safeguarding response, subject to the need to protect them or others and comply with legal obligations.

15. External Referrals

The DSL will consider whether a concern should be referred to:

  • local authority adult social care;
  • police;
  • health services;
  • Disclosure and Barring Service;
  • Charity Commission;
  • another regulator;
  • overseas safeguarding or law-enforcement authorities;
  • another appropriate specialist organisation.

Al-Waris Foundation does not replace statutory safeguarding authorities.

Appropriate safeguarding advice should be obtained where the correct referral route is unclear.

16. Concerns About the DSL or Senior Person

If an allegation concerns the DSL, it should be reported to the Chair or Trustee Safeguarding Lead.

If it concerns the Chair, it should be reported to another unconflicted trustee.

Where multiple trustees are implicated or internal reporting may create further risk, the concern should be raised directly with an appropriate statutory authority and, where appropriate, the Charity Commission.

17. Allegations Against People Acting for the Charity

An allegation that a trustee, staff member, volunteer, contractor, representative or other person acting for Al-Waris Foundation has harmed or exploited an adult at risk must be treated seriously.

Interim protective measures may include:

  • removing the person from direct beneficiary contact;
  • changing duties;
  • suspending access to systems or premises;
  • temporary suspension from activities.

Such measures are precautionary and do not themselves determine guilt.

External safeguarding or criminal investigations must not be compromised by an internal investigation.

18. Disclosure and Barring Service

Roles must be assessed individually for DBS eligibility.

Al-Waris Foundation will request the appropriate level of DBS check where:

  • the role is legally eligible; and
  • the check is proportionate to the safeguarding responsibilities involved.

A DBS certificate alone does not establish suitability.

Recruitment decisions must consider the wider safeguarding risk of the role.

Where the legal criteria for a DBS referral are met, Al-Waris Foundation will make the required referral.

See the Safer Recruitment Policy.

19. Financial Abuse and Charitable Assistance

Because Al-Waris Foundation may provide money, food, essential items or other assistance to people experiencing hardship, particular attention must be paid to financial exploitation.

Warning signs may include:

  • another person demanding control of assistance;
  • coercion over how aid is used;
  • theft of distributed goods;
  • manipulation of beneficiary details;
  • unauthorised collection of assistance on another person's behalf;
  • demands for payment in return for access to charitable aid;
  • bribery or kickbacks;
  • exploitation by charity representatives, contractors or local intermediaries.

No person acting for Al-Waris Foundation may demand personal payment, gifts, favours or other benefits from a beneficiary in exchange for charitable assistance.

Suspected fraud involving charity resources must also be considered under the Anti-Fraud, Bribery and Corruption Policy.

20. Aid Distribution

Aid distributions should be planned to minimise safeguarding risks.

Consideration should be given to:

  • crowd management;
  • privacy;
  • dignity;
  • accessibility;
  • safe queuing;
  • vulnerable individuals;
  • safeguarding supervision;
  • photography;
  • protection from exploitation;
  • transport;
  • security;
  • safe handling of beneficiary information.

Receiving aid must not be made conditional upon participation in photography, publicity, religious activity, political activity or the provision of unnecessary personal information.

21. Humanitarian Emergencies

Emergencies and disasters can increase safeguarding risks.

Risks may include:

  • displacement;
  • trafficking;
  • exploitation;
  • violence;
  • family separation;
  • homelessness;
  • dependency;
  • fraud;
  • coercion;
  • unsafe accommodation;
  • lack of access to authorities.

Safeguarding must therefore be incorporated into emergency-response planning and not treated as an administrative issue to be considered only after aid is distributed.

22. Overseas Activities

Safeguarding obligations apply to overseas activities.

Before relevant overseas work, the charity should consider:

  • local safeguarding risks;
  • local law;
  • emergency contacts;
  • referral mechanisms;
  • partner arrangements;
  • contractor suitability;
  • beneficiary vulnerability;
  • financial exploitation;
  • trafficking;
  • safe distributions;
  • transport;
  • photography;
  • cultural and language barriers;
  • risks to women, elderly people and disabled people;
  • risks arising from instability or disaster.

Where local reporting mechanisms are weak or unsafe, the charity should determine an appropriate alternative safeguarding response.

23. Partners and Contractors

Safeguarding must form part of proportionate partner and contractor due diligence.

Depending on the arrangement, Al-Waris Foundation may:

  • review safeguarding policies;
  • identify safeguarding contacts;
  • examine recruitment practices;
  • assess past safeguarding concerns;
  • include safeguarding obligations in agreements;
  • establish reporting requirements;
  • monitor compliance;
  • require notification of serious incidents.

A partner's failure to manage serious safeguarding risks may result in suspension or termination of the relationship.

See the Overseas Operations and Partner Due Diligence Policy.

24. Professional Boundaries

People acting for Al-Waris Foundation must not exploit beneficiaries.

They must not:

  • seek sexual or romantic relationships through their charitable position;
  • request personal payments;
  • borrow money from beneficiaries;
  • pressure beneficiaries into giving gifts;
  • obtain inappropriate personal benefit;
  • engage in coercive behaviour;
  • misuse confidential information;
  • deliberately create inappropriate dependency;
  • exploit a person's vulnerability.

Where gifts are offered, the Gifts and Hospitality Policy should be followed.

25. Online Safeguarding

Safeguarding responsibilities apply to digital communications.

Official channels should be used where reasonably practicable.

Communications must remain professional.

People acting for the charity must not:

  • use beneficiary information for personal purposes;
  • engage in harassment;
  • send inappropriate sexual content;
  • exploit beneficiaries through private communications;
  • disclose confidential information;
  • misuse beneficiary images.

Safeguarding concerns arising online must be reported.

26. Photography and Video

Al-Waris Foundation may document charitable work through photographs and video.

The dignity, privacy and safety of beneficiaries must take priority over content creation.

Appropriate consent or another lawful basis must be established according to the circumstances.

People must not be pressured to participate as a condition of receiving assistance.

The charity should avoid:

  • humiliating imagery;
  • unnecessarily revealing medical or personal information;
  • unnecessary identification of vulnerable people;
  • sexualised or degrading imagery;
  • publishing information that creates a safety risk.

Where illustrative or AI-generated content is used, it must not be falsely represented as evidence of a real beneficiary, completed project or distribution.

See the Photography, Video and Beneficiary Consent Policy.

27. Information Sharing

Safeguarding information should be shared when necessary, lawful and proportionate.

Information should be:

  • relevant;
  • accurate;
  • limited to what is necessary;
  • shared securely;
  • provided only to people who need it;
  • appropriately recorded.

Consent should be sought where appropriate, but it is not always required for safeguarding information sharing.

Data protection law should not be incorrectly used as a reason to avoid necessary safeguarding action.

28. Safeguarding Records

Safeguarding records must:

  • be factual;
  • distinguish fact from opinion;
  • record dates and times;
  • record actions;
  • record significant decisions and reasons;
  • record the adult's wishes where relevant;
  • be securely stored;
  • have restricted access;
  • be retained appropriately.

Sensitive safeguarding information should not be stored unnecessarily on personal devices or personal messaging accounts.

29. Confidentiality

Safeguarding information is confidential but not absolutely confidential.

Information may need to be shared where necessary to:

  • protect the adult;
  • protect another adult;
  • protect a child;
  • prevent or investigate serious crime;
  • comply with legal requirements;
  • cooperate with statutory safeguarding authorities.

Only information reasonably necessary for the purpose should be shared.

30. Data Protection

Safeguarding information must be processed in accordance with the Data Protection Act 2018 and UK GDPR.

Safeguarding records may contain:

  • health information;
  • special category personal data;
  • criminal offence data;
  • highly sensitive personal information.

Access must therefore be appropriately restricted.

The charity must identify an appropriate lawful basis and any additional processing condition required.

See the Data Protection and UK GDPR Policy.

31. Serious Incident Reporting

A safeguarding incident may constitute a serious incident for charity regulatory purposes.

The Board of Trustees is responsible for ensuring consideration is given to whether the Charity Commission should be notified.

Regulatory reporting must not delay urgent safeguarding action.

See the Serious Incident Reporting Policy.

32. Whistleblowing

People acting for Al-Waris Foundation should be able to raise genuine safeguarding concerns without fear of retaliation.

Concerns about:

  • concealed abuse;
  • failure to act;
  • unsafe organisational practices;
  • improper interference with safeguarding;
  • deliberate suppression of information;

may also be raised under the Whistleblowing Policy.

A person will not be penalised for raising a genuine concern in good faith merely because it is not ultimately substantiated.

33. Complaints

Complaints about safeguarding practices may be raised under the Complaints Policy.

However, an immediate safeguarding concern must not be delayed while an ordinary complaint is processed.

Safeguarding procedures take priority where protection from harm is required.

34. Training

Training should be proportionate to the person's role.

Training may cover:

  • recognising abuse;
  • responding to disclosures;
  • mental capacity;
  • consent;
  • professional boundaries;
  • financial exploitation;
  • information sharing;
  • online safeguarding;
  • humanitarian safeguarding;
  • overseas risks;
  • partner safeguarding.

Those with designated safeguarding responsibilities should receive more detailed training.

Training should be refreshed periodically and when significant changes occur.

35. Induction

Relevant trustees, staff and volunteers should receive safeguarding information during induction.

This should include:

  • this policy;
  • reporting procedures;
  • safeguarding contacts;
  • professional boundaries;
  • confidentiality;
  • emergency procedures;
  • role-specific responsibilities.

36. Monitoring and Assurance

The Board should receive proportionate safeguarding assurance.

This may include anonymised information concerning:

  • safeguarding concerns;
  • incidents;
  • referrals;
  • training;
  • recruitment;
  • partner safeguarding;
  • complaints;
  • overdue actions;
  • emerging risks.

Reports must avoid unnecessary disclosure of personal information.

37. Policy Breaches

Failure to comply with this policy may result in:

  • additional training;
  • removal from an activity;
  • restriction of duties;
  • disciplinary action where applicable;
  • termination of volunteering or contractual arrangements;
  • removal from office where lawful and applicable;
  • referral to safeguarding authorities;
  • referral to regulators;
  • referral to police.

Action will be proportionate to the circumstances.

38. Related Al-Waris Foundation Policies

This policy should be read alongside, where applicable:

  • Safeguarding Children Policy;
  • Safer Recruitment Policy;
  • Volunteer Policy;
  • Trustee Code of Conduct;
  • Complaints Policy;
  • Whistleblowing Policy;
  • Serious Incident Reporting Policy;
  • Data Protection and UK GDPR Policy;
  • Confidentiality Policy;
  • Information Security and Cybersecurity Policy;
  • Photography, Video and Beneficiary Consent Policy;
  • Social Media and Digital Communications Policy;
  • Overseas Operations and Partner Due Diligence Policy;
  • Anti-Fraud, Bribery and Corruption Policy;
  • Health and Safety Policy;
  • Risk Management Policy;
  • Conflict of Interest Policy.

39. Review

This policy will be reviewed:

  • at least annually;
  • following a serious safeguarding incident;
  • following an identified safeguarding failure;
  • following a significant change in activities;
  • where the charity begins operating in a materially different environment;
  • following significant changes to relevant law, regulation or guidance.

Changes must be approved in accordance with Al-Waris Foundation's governance arrangements.

40. Approval

Version: 2.0 Status: Approved Approved by: Board of Trustees Approval date: 25/08/2026 Next scheduled review: 24/08/2027

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