ADULT SAFEGUARDING & GDPR COMPLIANCE POLICY

1. Purpose, Scope & Professional Identity

1.1 Core Purpose: Crusade Health & Wellbeing is committed to a zero-tolerance approach toward the abuse, neglect or exploitation of vulnerable and elderly individuals. This policy outlines the operational mandates required to preserve the safety, autonomy and physical integrity of clients during the delivery of specialized in-home exercise programming, cognitive stimulation and remote support.

1.2 Sole Trader Status & Accountability: As a sole trader enterprise directed by the Principal Coach, the legal and operational responsibility for administering this safeguarding framework rests entirely with the Director. The Director acts as the Designated Safeguarding Lead (DSL) and is the sole internal point of contact for executing disclosures, managing risk escalations and conducting multi-agency referrals.

1.3 CIMSPA Professional Alignment: This document integrates and strictly enforces the Chartered Institute for the Management of Sport and Physical Activity (CIMSPA) Code of Conduct and Adult Safeguarding Best Practices. Professional practice remains continuously anchored to the foundational standards of transparency, respect, professional boundaries and person-centered duty of care defined by CIMSPA.

1.4 Staff Vetting & Future-Proofing: The Director maintains a current, verified Enhanced Disclosure and Barring Service (DBS) check including the Adult Barred List check. Comprehensive public liability and professional indemnity insurance are continuously maintained. In the event that Crusade Health & Wellbeing recruits secondary coaches, contractors or administrative staff, no individual will be permitted to conduct client contact until they have successfully passed an identical Enhanced DBS check, up to date first aid certification and active qualification verification.

2. Systemic Principles (Care Act 2014 Alignment)

In complete alignment with the UK Care Act 2014 statutory guidance, all safeguarding activities are governed by the following six core principles:

• Empowerment: Preserving a person-led, consent-driven approach. Clients are supported to make independent choices and provide informed, voluntary verbal consent prior to any physical assistance or technical exercise correction.
• Prevention: Proactively mitigating risk before harm manifests. Executed continuously through routine environmental evaluations via Home Fall Prevention Audits and localized functional conditioning.
• Proportionality: Engaging in the least intrusive response appropriate to the presentation of risk, respecting the individual's domestic privacy and cognitive rights.
• Protection: Providing clear, actionable support and reporting structures for individuals demonstrating clear exposure to or experience of abuse or neglect.
• Partnership: Forming robust local configurations. Facilitating seamless cooperation with healthcare professionals, designated family stakeholders and the local multi-agency framework.
• Accountability: Ensuring total transparency and complete defensibility in all safeguarding interventions and record-keeping as detailed in Monthly Reassurance Reports.

3. Recognising Abuse in Elderly Populations

As an in-home practitioner, special vigilance must be maintained regarding specific environmental and behavioral indicators. Recognised forms of abuse and indicators include:

• Physical Abuse: Unexplained bruising in protected areas, finger marks, regular falls lacking mechanical explanation or defensive injuries during technical transfers (e.g., Independent 'Get Up' Training).
• Psychological or Emotional Abuse: Uncharacteristic withdrawal, sudden vocal anxiety, looking at family members or caregivers for permission to speak, or expressed fear regarding a specific individual.
• Financial or Material Abuse: Discrepancies in home environment maintenance, sudden inability to process standard service payments, missing personal possessions or high levels of third-party anxiety concerning the client's spending on health and mobility services.
• Neglect and Acts of Omission: Inadequate heating, severe unhygienic living conditions identified during Home Fall Prevention Audits, withholding of mandatory mobility aids, severe nutritional depletion or unmanaged medication regimens.
• Self-Neglect: A manifest refusal to manage personal hygiene, nutrition, or immediate environment, leading to a profound deterioration in health, functional capacity, and cognitive clarity.

4. Service-Specific Safeguards & Boundaries

4.1 Physical Handling Boundaries: Due to the tactile nature of restoring joint mobility, building core stability and practicing floor transfers (Independent 'Get Up' Training), physical contact is occasionally necessary to ensure physical safety. The coach must always secure explicit verbal consent BEFORE initiating any physical contact. The contact must be strictly limited to the functional requirement (e.g., stabilizing a hip, supporting a shoulder). Staff must never use physical force or coercive handling techniques.

4.2 Digital Communication & WhatsApp Group Messaging: The Direct Messaging Access channel delivered via group WhatsApp represents a formal service environment. All communications must remain strictly professional, transparent and focused entirely on bookings, goal accountability and general motivation. To protect vulnerable adults, where cognitive vulnerabilities exist or where requested by the client, a designated family member or trusted advocate must be added to the WhatsApp group to preserve complete transparency and eliminate hidden one-to-one digital spaces.

5. Escalation Pathway & Reporting Procedures

If a safeguarding concern is identified during an in-person session, check-in or via digital channels, the following step-by-step reporting framework must be executed immediately without delay:

Step 1: Immediate Safety Valuation: If the client faces immediate physical danger, medical emergency or severe injury, contact emergency services directly via 999. Take immediate, reasonable actions to secure the environment safely.

Step 2: Objective Recording: Within a strict maximum of 4 hours from the encounter, the Director must formally document all observations verbatim using the official Safeguarding Incident Logging Form. The report must contain purely objective facts.

Step 3: External MASH Referral: If the threshold of abuse, neglect or exploitation is met, an official external referral must be submitted directly to the local authority safeguarding team. For operations within the Dudley borough, the referral must be delivered to:
Dudley Metropolitan Borough Council Adult Safeguarding Hub (MASH)
• Contact Number (Working Hours): 0300 555 0055
• Contact Number (Out of Hours): 0300 555 8574
• Online Referral Portal: www.dudley.gov.uk/residents/care-and-health/adult-social-care/safeguarding

Step 4: Insurer & Professional Notification: Following a formal MASH submission, the Director must log the action confidentially with their public liability insurance provider to preserve legal compliance.

6. GDPR & Information Security Framework

6.1 Legal Basis for Processing: Under the UK GDPR and Data Protection Act 2018, Crusade Health & Wellbeing processes special category health data (such as joint mobility metrics, cognitive condition notes, and medical records) under Article 6(1)(b) 'Performance of a Contract' and Article 9(2)(h) 'Health or Social Care'. Safeguarding records are processed under Article 9(2)(g) 'Reasons of Substantial Public Interest'.

6.2 Data Preservation & Storage Protocols: All physical documents and digital records must be kept strictly secure. Digital assets must be stored exclusively on a secure cloud infrastructure protected by multi-factor authentication (MFA) and device-level encryption. Safeguarding records must be kept completely separate from general client files.

6.3 WhatsApp Data Minimization: To ensure strict compliance with UK GDPR, the WhatsApp messaging service must never be used to transmit or archive sensitive clinical documents, official safeguarding incident forms or detailed medical files. If a client transmits sensitive health details via text, the information must be extracted, logged securely into the encrypted cloud storage platform and the source WhatsApp text message permanently deleted from the mobile interface within 48 hours.

6.4 Overriding Confidentiality for Public Interest: While client confidentiality is a core professional pillar under the CIMSPA code, the duty to protect vulnerable adults from abuse or neglect legally overrides the requirement for explicit client consent. If a client refuses permission to share a safeguarding concern, but the Director assesses that they are at significant risk of harm or lack the mental capacity to make the decision, a formal referral to Dudley MASH will still be completed.

6.5 Mandatory Data Retention Limits: In complete alignment with standard UK insurance mandates, all general client files, medical intake forms, and reassurance logs must be securely retained for a minimum period of 7 years following the termination of the service contract. Official safeguarding incident logs and multi-agency referral copies must be retained for 10 years.

Policy Ratification & Review Log

Company Name: Crusade Health & Wellbeing
Designated Safeguarding Lead: Jonathon Burnett Director (Sole Trader / Principal Coach)
Current Credentials: Enhanced DBS Checked | Registered CIMSPA Member | Insured
Date of Enactment / Review: September 20, 2026