Our commitment
Safeguarding is embedded in everything we do. Bubble Fresh (Bubblefresh Limited, company number 12691029) is committed to safeguarding the welfare of all vulnerable adults we work with, in accordance with the Care Act 2014 and associated statutory guidance. We recognise our responsibility to support Section 42 enquiries under the Care Act 2014, which requires local authorities to make enquiries where an adult with care and support needs may be at risk of abuse or neglect. Our safeguarding approach is guided by the six principles of adult safeguarding set out in the Care Act 2014 statutory guidance: empowerment, prevention, proportionality, protection, partnership, and accountability. We are committed to Making Safeguarding Personal (MSP), which means we always involve the adult at risk in decisions about their own safety. We ask what outcomes they want, we listen to their views, and we act in a way that respects their choices wherever it is safe to do so.
Scope
This policy applies to all Bubble Fresh employees, contractors, agency workers, volunteers, and anyone working on our behalf. It covers all situations where our team may come into contact with vulnerable adults, whether through direct service delivery, council referrals, or incidental contact during our work. It applies on client premises, in our offices, while travelling to and from jobs, and in any situation where someone is representing Bubble Fresh. Our team is also aware of the principles of the Mental Capacity Act 2005, including the presumption of capacity, the two-stage capacity test, the requirement to support individuals to make their own decisions wherever possible, and the best-interests principle where a person lacks capacity to make a specific decision. Where we have reason to believe that a person may lack capacity to make a specific decision about their safety, we will follow the Mental Capacity Act 2005 framework and involve the relevant local authority or independent mental capacity advocate (IMCA) where appropriate.
Designated safeguarding lead
The Bubble Fresh Designated Safeguarding Lead (DSL) is Lance James, Director. You can contact the DSL on 01933 213045 or at svxraukmfafwesgjgphaufncaenurgvhdrpaizmonkpfgoupqz@bbhdulynbpfgbbrglsvzemnbfrxdrxdpejpcsjiphoqo.zsvczlpobjg.mxjukuykwjv. If you use Relay UK, call 18001 then 01933 213045. The DSL holds Level 3 safeguarding training and is responsible for receiving and acting on safeguarding concerns, making referrals to local authority adult safeguarding teams, maintaining oversight of all safeguarding activity, and ensuring all staff receive appropriate safeguarding training. The DSL attends or contributes to multi-agency meetings as required. The Deputy DSL is the senior team leader on duty, who also holds Level 3 safeguarding training. The Deputy DSL takes responsibility for all DSL functions when the DSL is unavailable for any reason, including leave, illness, or absence exceeding 4 hours.
Our approach
We check all team members through Enhanced Disclosure and Barring Service (DBS) checks before they start work. We subscribe to the DBS Update Service for all client-facing staff, enabling us to carry out annual status checks and receive notification of any changes. If an Update Service check returns new information, we obtain a new Enhanced DBS check immediately and assess the employee's suitability for continued client-facing work. All team members receive safeguarding training to Level 2 as a minimum, delivered by an accredited provider and refreshed annually. Team leaders and the DSL hold Level 3 safeguarding training. Staff also receive awareness of the Prevent duty under the Counter-Terrorism and Security Act 2015, so that concerns about radicalisation can be escalated through the DSL to the relevant local authority Prevent lead or Channel panel. We maintain a safer recruitment process, including verifying identity, checking employment history and references, and ensuring all pre-employment checks are completed before any team member has unsupervised access to clients. We maintain a culture of professional curiosity, where any concerns are reported and acted upon promptly. Safeguarding is everyone's responsibility.
Position of trust
Our work takes us into people's homes during difficult and often distressing periods of their lives. We recognise that this places our team members in a position of trust. Clients may be isolated, unwell, or under significant stress. They may not feel able to refuse a request, assert their own boundaries, or raise a complaint. The responsibility for maintaining appropriate conduct always rests with the team member, not the client. All team members must understand and respect this power dynamic. Any abuse of a position of trust is a serious safeguarding matter and will be investigated under this policy and our Professional Boundaries Policy. The Sexual Offences Act 2003 (sections 16 to 19) creates specific criminal offences for sexual activity by a person in a position of trust. While the statutory definition applies primarily to certain care settings, we apply the principle of position of trust to all of our client-facing work as a safeguarding standard.
Recognising abuse and neglect
We train our team to recognise signs of abuse and neglect, including all 10 categories defined in the Care Act 2014 statutory guidance: physical abuse, domestic abuse, sexual abuse, psychological abuse, financial or material abuse, modern slavery, discriminatory abuse, organisational abuse, neglect and acts of omission, and self-neglect. We understand that accumulation of possessions and clutter, severe domestic neglect, and poor living conditions can be indicators of wider vulnerability. We also train our team to recognise signs of county lines and criminal exploitation, where vulnerable adults may be coerced into allowing their homes to be used for drug dealing or other criminal activity (known as cuckooing). Indicators may include unfamiliar people at the property, signs of drug use, damage to the property, or the client appearing frightened or controlled. Our team is also trained to be aware of adults who may go missing, including those with dementia or other cognitive conditions, and to report any concerns about a missing or absent client to the DSL and, where appropriate, to the police.
Domestic abuse
We recognise that domestic abuse is a safeguarding concern. The Domestic Abuse Act 2021 defines domestic abuse broadly to include physical or sexual abuse, violent or threatening behaviour, controlling or coercive behaviour, economic abuse, psychological abuse, and emotional abuse between people who are personally connected. Our team may encounter signs of domestic abuse when working in a client's home, including unexplained injuries, a controlling partner present during the work, signs of fear or distress, restricted access to money, or damage to the property. If a team member suspects domestic abuse, they should follow the reporting procedures in this policy. Where a client discloses domestic abuse, we will listen without judgement, record the disclosure accurately, and refer to the relevant local authority safeguarding team or specialist domestic abuse service with the client's consent wherever possible. In cases of immediate danger, we will contact the police on 999 without delay.
Female genital mutilation
Female genital mutilation (FGM) is a criminal offence under the Female Genital Mutilation Act 2003 (as amended by the Serious Crime Act 2015). Section 5B of the Act places a mandatory reporting duty on regulated health and social care professionals. While our cleaning and clearance staff are not regulated professionals under this provision, we take a voluntary safeguarding approach to FGM. If any team member becomes aware of or suspects FGM, including through disclosure by a client or the discovery of items that suggest FGM has taken place or is being planned, they must report this immediately to the DSL. The DSL will refer the concern to the police and the relevant local authority safeguarding team without delay. FGM is never acceptable, regardless of cultural or religious justification.
Managing disclosures
A disclosure happens when a client or another person tells a team member about abuse, neglect, or harm they have experienced or are at risk of. Our team is trained to respond to disclosures in a way that supports the person and preserves important information. If someone makes a disclosure to you, listen carefully and let them speak at their own pace. Do not ask leading questions or press for details beyond what the person wants to share. Reassure them that they have done the right thing by telling you, and explain that you will need to pass the information on to someone who can help. Do not promise to keep the disclosure confidential, as you have a duty to report safeguarding concerns. Make a written record of the disclosure as soon as possible, using the person's own words wherever you can. Record what was said, when and where the disclosure was made, and any other people who were present. Do not interpret what the person said or add your own opinions. Pass your record to the DSL immediately. The DSL will decide on the appropriate next steps, which may include a referral to the local authority safeguarding team.
Reporting concerns
If any team member has a safeguarding concern, they report it immediately to the Designated Safeguarding Lead (DSL), Lance James, on 01933 213045 or at szniaissfzksejqngmcyutynahhprdlddzotiwdhntwhgzdiqz@bwaluelvbpirblpxlzyrexecfcwfrrhdekxfsreyhcvd.wtdcghsoexp.qnsuirrkiil. If the DSL is unavailable, report to the Deputy DSL (the senior team leader on duty). The DSL will assess the concern and, where a referral is required, make it to the relevant local authority adult safeguarding team within 4 working hours of receiving the report, or immediately where there is a risk of imminent harm. In emergencies, our team contacts the police or emergency services directly on 999 without waiting for DSL assessment. Team members must not investigate concerns themselves. Your role is to report what you have seen, heard, or been told. The DSL will coordinate the response and any referrals. All concerns are taken seriously, including those that may seem minor. Patterns of small concerns can indicate serious and ongoing abuse.
Allegations against staff
We take any allegation or concern about the conduct of a Bubble Fresh team member seriously. If a client, family member, council partner, or colleague raises a concern that a team member may have harmed, or poses a risk of harm to, a vulnerable adult, the DSL will assess the allegation immediately. The team member will be removed from client-facing duties while the allegation is investigated. This is a neutral act to protect all parties and does not imply a finding of fault. Where the allegation meets the threshold, the DSL will refer it to the relevant local authority Designated Officer (formerly known as the Local Authority Designated Officer or LADO) and to the police where a criminal offence may have been committed. We will cooperate fully with any external investigation. The team member will be kept informed of the process and offered support, including access to our Employee Assistance Programme. Where an investigation finds that a team member has caused harm or poses a risk of harm, we will take disciplinary action up to and including dismissal, following a fair process in line with the ACAS Code of Practice on Disciplinary and Grievance Procedures. We will also make a referral to the Disclosure and Barring Service (DBS) in line with our DBS referral duty. We protect anyone who reports a concern in good faith from any penalty. For serious concerns about wrongdoing, staff may also use our Whistleblowing Policy to report confidentially.
Information sharing
Effective safeguarding depends on the timely and appropriate sharing of information between agencies. We follow the seven golden rules for information sharing set out in the HM Government guidance Information Sharing: Advice for Practitioners (2018), and the Caldicott principles as updated by the National Data Guardian. These principles require us to share information only when there is a clear purpose, to share only the information that is needed, to share it only with people who need it, to keep it accurate and up to date, to keep a record of what was shared and why, and to share it securely. We will share personal information without consent where necessary to prevent or detect a crime, to protect the vital interests of the person or others, or where required by law. The legal basis for sharing safeguarding information under data protection law is set out in our Safeguarding Records section. Staff who are unsure whether to share information should speak to the DSL. When in doubt, the safety of the adult at risk takes priority.
Safeguarding records
We record all safeguarding concerns using a standardised safeguarding concern form. Each record includes the date and time the concern was raised, the name and role of the person raising the concern, the name and details of the individual at risk, a factual description of the concern (using the person's own words where a disclosure was made), any immediate actions taken, and the outcome and any referral made. We store safeguarding records securely with access restricted to the DSL, Deputy DSL, and the Data Protection Officer. The legal basis for processing safeguarding data, which may include special category data under Article 9 of UK GDPR, is Article 9(2)(b) (obligations under employment and social protection law), Article 9(2)(c) (vital interests where the data subject cannot consent), and the Data Protection Act 2018 Schedule 1 Part 2 paragraph 18 (safeguarding of individuals at risk). We retain safeguarding records for a minimum of 6 years from the date of last contact with the individual, or in line with the relevant local Safeguarding Adults Board retention schedule where this requires a longer period. For further details on how we handle personal data, see our Privacy Policy.
Out-of-hours safeguarding
Bubble Fresh operates 24/7. Outside office hours, report safeguarding concerns immediately to the DSL on 01933 213045. If the DSL is unavailable, contact the Deputy DSL (the senior team leader on duty). If neither is available or the concern is urgent, contact the relevant local authority emergency duty team directly. In situations of immediate danger, call 999 without delay. Do not wait until the next working day to report a concern. Safeguarding does not follow office hours.
How to raise a concern
If you have a safeguarding concern about someone we work with, you can contact us in any of the following ways. By phone on 01933 213045 (Relay UK: 18001 then 01933 213045). By email at swxbaecsfhjbetxtgljvuuejafrhrdjkdbndiadinmtggbtxqz@bpcguqisbbmlbjlqlgpgeslmfllirwonecydsecehhtg.orscvnvotpy.iqzuwmjklhg. By post to Bubblefresh Limited, 6 Carnegie Street, Rushden, Northamptonshire, NN10 9SN. If you use Relay UK, call 18001 then 01933 213045. You do not need to be a Bubble Fresh employee to raise a concern. Clients, family members, neighbours, council staff, and members of the public can all raise safeguarding concerns with us. We will listen to you and we will act. You will not lose your service because you raise a concern. You can also contact the relevant local authority safeguarding team directly if you prefer.
Working with councils
We work as approved partners with Northamptonshire Council, Milton Keynes Council, Norfolk County Council, and Norwich City Council. We follow each council's safeguarding procedures and reporting requirements, including the multi-agency procedures published by the Northamptonshire Safeguarding Adults Board, Milton Keynes Safeguarding Adults Board, and Norfolk Safeguarding Adults Board. Staff working in each council area are trained on the relevant local procedures and threshold documents. We participate in multi-agency working where required and share information appropriately in the interests of the vulnerable adult. We work within the frameworks established by local Safeguarding Adults Boards (SABs) as required under Section 43 of the Care Act 2014. Where a Safeguarding Adults Review (SAR) is commissioned under Section 44 of the Care Act 2014, we will cooperate fully with the review process and provide information as requested.
DBS referral duty
We will refer to the Disclosure and Barring Service (DBS) any employee who is dismissed or removed from client-facing duties because they have harmed, or pose a risk of harm to, a vulnerable adult. Where our work meets the definition of regulated activity under the Safeguarding Vulnerable Groups Act 2006, this referral is a legal duty. In all other cases, we make the referral voluntarily as a safeguarding commitment. We will also consider whether a referral to the DBS is appropriate where an employee resigns or leaves during an investigation into safeguarding concerns, as the duty to refer is not removed by the person's departure.
Confidentiality and consent
We treat all personal information with strict confidentiality. We share information only on a need-to-know basis and in accordance with data protection law and the information sharing principles set out in this policy. We will always try to get the consent of the adult at risk before sharing their information, in line with the Making Safeguarding Personal approach. However, we may share information without consent where there is a risk of serious harm to the individual or others, where a crime has been or may be committed, where a court order requires disclosure, or where it is in the vital interests of the person and they are unable to consent. This is not a matter of discretion but of legal obligation under the Care Act 2014. Lack of consent is never a reason to fail to act on a safeguarding concern where someone is at risk of serious harm.
Safeguarding supervision
All client-facing staff receive regular safeguarding supervision. Safeguarding supervision gives team members a structured opportunity to discuss any concerns, reflect on their work with vulnerable adults, and receive guidance from a more experienced colleague. Supervision sessions are held at least quarterly for all client-facing staff, and monthly for team leaders and the Deputy DSL. The DSL receives external safeguarding supervision from a suitably qualified professional at least twice a year. Safeguarding supervision records are kept confidentially. We recognise that supervision is not just a management tool but a safeguarding measure in its own right, helping to prevent drift, maintain professional curiosity, and ensure that concerns are not overlooked.
Support for staff after safeguarding incidents
We recognise that dealing with safeguarding concerns can be emotionally demanding. Our team works with people in difficult and sometimes distressing circumstances. If you are involved in a safeguarding incident, whether you raised the concern, witnessed the situation, or were the subject of an allegation, we will support you. This includes a debrief with your manager or the DSL after the incident, access to our Employee Assistance Programme for confidential counselling and emotional support at no cost to you, and the opportunity to discuss the impact of the incident in your safeguarding supervision sessions. We will not judge you for finding the work difficult. Seeking support is a sign of professionalism, not weakness. If you feel that a safeguarding incident has affected your ability to work safely, tell your manager so that we can make appropriate adjustments.
Annual safeguarding audit
The DSL carries out an annual safeguarding audit to review the effectiveness of our safeguarding arrangements. The audit covers the number and type of safeguarding concerns raised during the year, the outcomes of referrals made to local authorities, compliance with DBS checking and update service requirements, completion rates for safeguarding training at all levels, the timeliness of safeguarding referrals, the quality of safeguarding records, any lessons learned from safeguarding incidents or Safeguarding Adults Reviews, and feedback from council partners. The findings of the annual audit are reported to the Director and shared with council partners on request. We use the audit to identify areas for improvement and to update our training, procedures, and this policy as needed.
Training
All employees receive safeguarding training as part of their induction before they begin client-facing work. This includes recognising abuse and neglect, responding to disclosures, reporting procedures, the Mental Capacity Act 2005, the Prevent duty, domestic abuse awareness, county lines and criminal exploitation, professional boundaries, and the specific safeguarding procedures for the council areas where they will work. All team members receive refresher training at least annually. Team leaders and the DSL hold Level 3 safeguarding training, which is also refreshed annually. Safeguarding training forms part of the minimum 20 hours of annual training each employee receives (see our Training & Development Policy for details). We keep records of all safeguarding training, including the date, provider, content, and attendees. Training records are reviewed as part of our annual safeguarding audit.
Related policies
This policy should be read alongside our Professional Boundaries Policy, which covers expected conduct and power dynamics when working with vulnerable adults; our Code of Conduct, which sets out standards of behaviour for all staff; our Whistleblowing Policy, which explains how to raise serious concerns confidentially; our Privacy Policy, which explains how we handle personal data; our Lone Working Policy, which covers safety when working alone at client properties; our Modern Slavery Statement, which sets out our approach to preventing modern slavery and human trafficking; our Equality & Diversity Policy, which confirms our commitment to fair treatment; our Incident Reporting Policy, which covers how we record and respond to incidents; our Body-Worn Camera Policy, which covers the use of recording equipment on client premises; and our Training & Development Policy, which covers our approach to staff training.
Changes to this policy
We may update this policy from time to time to reflect changes in legislation, statutory guidance, or best practice. Where we make material changes, we will notify our council partners, brief all employees on the changes before they take effect, and update the date shown at the top of this page. The current version of this policy is always available from management and on our website.
Contact
If you have questions about this policy or need to raise a safeguarding concern, contact us by phone on 01933 213045, by email at sxpfakwofpreegzzgctnubpbakpgrpxgdnhzitlmnclugeseqz@bawpuadcbajnbdutlqkqeiibfmsprbvpepmtsdfdhyeh.fofcdlfopqs.xhiugdtkpxr, or by post at Bubblefresh Limited, 6 Carnegie Street, Rushden, Northamptonshire, NN10 9SN. If you use Relay UK, call 18001 then 01933 213045. If your concern is about the Director, you may contact the relevant local authority safeguarding team directly or use our Whistleblowing Policy.
Review
The Director, Lance James, reviews this policy annually. Last reviewed: February 2026. Next review due: February 2027.