Safeguarding is the policy CQC inspectors go to first. Not because it is the most complex - though it is one of the longest - but because it tells them immediately whether your agency understands its legal duties to the people it cares for.
A generic safeguarding policy that lists the types of abuse and says staff should report concerns is not enough. It has not been enough for years. CQC expects to see a policy that demonstrates genuine understanding of the legal framework, your specific local authority arrangements, and a culture of proactive safeguarding rather than reactive reporting.
Here is what your policy must include and why each element matters.
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Section 42 of the Care Act 2014
Your policy must reference Section 42 explicitly. Not just "the Care Act 2014" - specifically Section 42, which creates the statutory duty to make or cause enquiries when an adult meets the three-stage test:
- They have needs for care and support
- They are experiencing or are at risk of abuse or neglect
- As a result of those care and support needs they are unable to protect themselves
All three must be met for the formal Section 42 duty to apply. But your policy should also be clear that the referral threshold is reasonable suspicion - not certainty. If a care worker suspects abuse, they refer. The local authority decides whether to proceed with a formal enquiry. Your staff do not investigate.
This distinction matters because the most common staff error in safeguarding is waiting for certainty before reporting. Your policy must be unambiguous: if in doubt, report.
The Six Principles of Safeguarding
The Care Act 2014 statutory guidance establishes six principles that must underpin all safeguarding work. Your policy must include all six - and they must be explained in the context of your service, not just listed.
Empowerment: Adults have the right to make decisions about their own safety. Safeguarding is person-led and outcome-focused. Your policy must show how you support service users to be involved in decisions about their own safeguarding.
Prevention: It is better to act before harm occurs. Your policy must cover preventative measures - safer recruitment, staff training, supervision, risk assessment - not just how you respond after abuse has happened.
Proportionality: The response should be proportionate to the risk. Not every concern requires a formal Section 42 referral. Your policy must help staff understand the spectrum of responses available.
Protection: Adults who need it must be supported and represented. This includes access to independent advocacy for those who cannot easily participate in safeguarding processes.
Partnership: Safeguarding requires agencies to work together. Your policy must commit to multi-agency working and information sharing with the local authority, police, and health services.
Accountability: Clear lines of responsibility, transparent governance, and learning from incidents. Your registered manager must be named as accountable for safeguarding, with clear escalation routes.
Making Safeguarding Personal
Making Safeguarding Personal is the approach introduced by the Local Government Association and embedded in the Care Act statutory guidance. It shifts the focus from process-led safeguarding to outcome-focused safeguarding - asking not just "what happened" but "what does this person want to happen".
Your policy must demonstrate this approach. That means:
- The service user's desired outcomes are recorded at the start of any safeguarding process
- The response is built around what the person wants, not just what the agency or local authority thinks is best
- The person is involved throughout - given information, given choices, given support to participate
- Outcomes are reviewed - did the person achieve what they wanted from the safeguarding process?
CQC inspects Making Safeguarding Personal under the Caring domain. It is one of the distinguishing factors between a Good rating and an Outstanding one.
Named Contacts and Local Authority Arrangements
This is where many policies fall short. Your safeguarding policy must name:
- Your registered manager as designated safeguarding lead - with their actual contact number and email
- A named deputy safeguarding lead - with their contact details
- Your local authority safeguarding adults team - with the correct contact number for your area
- Your local authority out-of-hours emergency duty team number
- The local police non-emergency number - 101 - and when to call 999
A policy that says "contact your local authority safeguarding team" without providing the actual number is not good enough. In a real safeguarding situation, a care worker needs to be able to make that call immediately. The contact details must be in the policy.
All Ten Categories of Abuse
The Care Act 2014 statutory guidance identifies ten categories of abuse your policy must cover:
- Physical abuse
- Domestic violence and abuse
- Sexual abuse
- Psychological or emotional abuse
- Financial or material abuse
- Modern slavery
- Discriminatory abuse
- Organisational or institutional abuse
- Neglect and acts of omission
- Self-neglect
For each category, your policy should include the definition, signs and indicators, and what staff should do if they observe them. Signs and indicators are particularly important - care workers need to know what to look for, not just what the category is called.
The Referral Procedure
Your policy must include a step-by-step referral procedure. Not vague guidance - actual steps. What does a care worker do in the next ten minutes after they identify a safeguarding concern?
A clear procedure typically looks like:
- Ensure the immediate safety of the service user
- Do not investigate or ask leading questions
- Document exactly what was observed, heard, or disclosed - in the person's own words where possible
- Contact the registered manager immediately
- If immediate danger, call 999 before contacting the manager
- The registered manager makes a referral to the local authority safeguarding team within 24 hours
- CQC is notified under Regulation 18 if the threshold is met
- The service user is kept informed throughout
Timescales are critical - your local authority will have its own response targets, but as a general rule the registered manager should make the referral within 24 hours of the concern being raised, and sooner if there is immediate risk. Where a verbal referral is made by telephone, it must always be followed up with a written referral using the local authority's multi-agency referral form, and your internal records should note the date, time, and name of the person you spoke with so there is a clear audit trail.
Documentation and Record Keeping
Your safeguarding policy must specify how safeguarding concerns are documented. CQC will ask to see your safeguarding log during inspection. Each entry should include the date and time the concern was identified, who raised it, the nature of the concern, what category of abuse it falls under, immediate actions taken, whether a referral was made to the local authority, the outcome, and any learning or practice changes that resulted.
Good record keeping is not just about compliance. It demonstrates the learning culture that CQC looks for when assessing Well-Led. An agency that documents concerns, tracks outcomes, and changes practice as a result is one that is actively improving. An agency with no safeguarding log, or one with entries that lack detail, tells a different story.
Under Section 42 of the Care Act 2014, local authorities have a duty to make enquiries. Your records should show that you cooperated fully with any enquiry, provided information promptly, and implemented any recommendations that came from it.
Staff Training Requirements
A policy is only as effective as the staff who follow it. CQC expects all care workers to receive safeguarding training at induction and regular refresher training - Skills for Care recommends annual refreshers as a minimum. Your policy should specify the training schedule, who delivers it, and how competency is assessed.
Inspectors will test whether training has been effective by asking care workers direct questions about safeguarding during inspection. If your care workers cannot describe the referral procedure, name the designated safeguarding lead, or explain the three-stage test from Section 42, the training has not worked - regardless of what your training matrix says.
Why Generic Policies Fail This Test
A generic safeguarding policy can include all the right headings and still fail an inspection because the detail is wrong. The wrong local authority. A contact number that goes nowhere. No named safeguarding lead. Signs and indicators that are too vague to be useful.
CQC inspectors read these policies regularly. They know within the first two pages whether a policy was written for this agency or downloaded from the internet.
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