People in Positions of Trust (PiPoT)

Safeguarding is everybody’s responsibility.

People in Positions of Trust (PIPOT) refers to a person, whether an employee, volunteer or student, paid or unpaid who works with or cares for adults with care and support needs.

Positions of trust may include, but are not limited to, any staff working on behalf of:

Social care
Health services
Police and criminal justice
Housing
Education
Advocacy
GPs
Private and Voluntary Sector
Agency and Bank Workers
Religious/Faith Leaders
Commissioning Services

A PIPOT allegation may also be triggered by concerns in an individual’s personal life. For example, they may have committed a criminal offence against an adult with care and support needs or there may be other concerns such as domestic abuse or child protection.

Care and Support Statutory Guidance (section 14.120 – 14.132) established the requirement that all relevant Safeguarding Adults Board (SAB) partners (employers, student bodies and voluntary organisations) must have policies and procedures in line with those of Safeguarding Adults Boards for responding to concerns against any person who works with adults, in either a paid or unpaid capacity, in positions of trust. This applies to all organisations commissioned to provide services by them, so they respond appropriately to allegations made.

All agencies should have a PIPOT lead.

A referral should be made in line with individual agency protocol and be submitted to each agency’s PIPOT lead. A referral should only be sent to the Adult MASH Team if there is a safeguarding concern. There will need to be a discussion between the Position of Trust Lead/Safeguarding Lead, LBH Adult Safeguarding Team and Police to determine the actions to be taken.

Where a concern is raised, it will be necessary for the employer, student body or voluntary organisation to assess any potential risk to adults who use their services and consider how to respond to allegations and concerns. A referral should be made to the Local Authority Designated Officer (LADO) if the individual works with children. The LADO for Havering is lisa.kennedy@havering.gov.uk

The Commissioner of your service or agency should also be alerted.

Disclosure and Barring Service

It may be necessary to alert the Disclosure and Barring Service.

Regulated activity providers and the following personnel suppliers have a legal duty to refer to the DBS:

An employment agency that makes arrangements to either find a work-seeker employment with a hirer, or to supply him to a hirer to employ
An employment business that engages a work-seeker and supplies him to a hirer to work under a hirer’s control
An educational institution, if it makes arrangements to supply a student – following a course at the institution – to a regulated activity provider such as a school.

A person who is under a duty to refer and fails to do so without reasonable justification is committing an offence, and if convicted, they may be subject to a fine up to £5,000.

The following two conditions must be met

If you are a regulated activity provider or fall within the category of personnel supplier, you must make a barring referral to DBS when both of the following conditions have been met:

Condition one

You withdraw permission for a person to engage in regulated activity with children and/or vulnerable adults, or you move the person to another area of work that isn’t regulated activity

This includes situations when you would have taken the above action, but the person was re-deployed, resigned, retired, or left. For example, a teacher resigns when an allegation of harm to a student is first made.

Condition two

You think the person has carried out one of the following:

engaged in relevant conduct in relation to children and/or adults; an action or inaction has harmed a child or vulnerable adult or put them at risk or harm
satisfied the harm test in relation to children and/or vulnerable adults e.g. there has been no relevant conduct but a risk of harm to a child or vulnerable still exists
been cautioned or convicted of a relevant (automatic barring either with or without the right to make representations) offence

You can raise your concern at any time about an incident that happened in the past that may be happening now, or you believe will happen in the near future. More on DBS can be found here: Disclosure and Barring Service (DBS) – Havering Safeguarding Adults Board (safeguardinghavering.org.uk)

Whistleblowing

Whistleblowing should also be considered. The wrongdoing you disclose must be in the public interest. This means it must affect others, for example the general public.

Look here for more information on whistleblowing: Whistleblowing for employees: What is a whistleblower – GOV.UK (www.gov.uk)

The whole PIPOT process should be fully and clearly documented.

If you believe that it is appropriate for a SAR referral to be made, please use the request form here: SARs Request Form – Havering Safeguarding Adults Board (safeguardinghavering.org.uk)

The SAB PIPOT Multi Agency Guidance for dealing with Allegations against People in Positions of Trust PIPOT guidance can be found here SAB-PiPoT-GUIDANCE.pdf (safeguardinghavering.org.uk)

A 7 minute briefing can be found here Final-PiPoT-7-Minute-Briefing.pdf (safeguardinghavering.org.uk)

Organisational abuse

Organisational or institutional abuse is the mistreatment of people typically in their workplace brought about by poor or inadequate care or support, or systematic poor practice that affects the whole care setting. It occurs when the individual’s wishes and needs are sacrificed for the smooth running of a group, service or organisation.

Why does it happen?

In formal settings organisational or institutional abuse is more likely to occur where staff are:

inadequately trained
poorly supervised
not supported by management
have poor communication skills
part of a ‘closed’ culture, for example a care setting where new ideas, visitors, care management or other professional involvement is discouraged

Examples of organisational or institutional abuse

failure to respect or support a person or group’s right to independence, dignity or choice
lack of person centred care planning or a ritualised care routine
no flexibility in bed times or getting up or deliberately waking someone up
inappropriate confinement, restraint or restriction
lack of personal clothing or possessions
stark living areas, deprived environment or lack of stimulation
lack of choice in decoration or other aspects of the environment
lack of choice in food or menus or menu planning
unnecessary involvement in personal finances by staff or management
inappropriate use of nursing or medical procedures, e.g. using un-prescribed medication enemas or catheterization
inappropriate use of power or control

Indicators of organisational or institutional abuse

treating adults like children
arbitrary decision making by staff group, service or organisation
strict, regimented or inflexible routines or schedules for daily activities such as meal times, bed / awakening times, bathing / washing, going to the toilet
lack of choice or options with food and drink, dress, possessions, daily and social activities
lack of privacy, dignity, choice or respect for people as individuals
unsafe or unhygienic environment
lack of provision for dress, diet or religious observance in accordance with an individual’s belief or cultural background
withdrawing people from individually valued community or family contact.

More on organisational abuse here: Organisational abuse – Havering Safeguarding Adults Board (safeguardinghavering.org.uk)

A PIPOT related SAR for Mr V can be found here: https://nationalnetwork.org.uk/search.html#stq=PIPOT&stp=1

A PIPOT related SAR for Mr E can be found here

sar-case-e-2020-final-report.pdf (lrsb.org.uk)