6.1 Policies, Values and Principles

Contents

1. Legislative Framework
2. Philosophy and Key Policies
3. Equal Opportunities
4. Recording Values and Principles
5. Confidentiality Values and Principles
6. Consultation Values and Principles

1. Legislative Framework

Clifford House operates across England and Wales, and ensures all its procedures reflect relevant key pieces of legislation, regulations and standards, for example:

In England:

Children's Homes Regulations (England) 2001 (and associated Standards)

Fostering Services Regulations 2002 

Fostering Services (Amendment) Regulations 2009

National Minimum Standards for Fostering Services 2002

Department for Education website

Working Together to Safeguard Children 2010

In Wales:

Children's Homes Regulations (Wales) 2002 (and associated Standards)

Toward a Stable Life and Brighter Future (Regulations and Guidance issued by the Welsh Assembly June 2007)

Working Together Under the Children Act 2004

All Wales Child Protection Procedures

2. Philosophy and Key Policies

Clifford House offers quality residential placements in small group situations and family placements to adolescents who exhibit behavioural difficulties as a result of past emotional/physical trauma. Children and young people are admitted to our resources between the ages of 9 and 18 years. We provide Individual Education Programmes based on a tutorial model with teaching groups of no more than three pupils in our own DCSF registered day school situated in Leominster, Herefordshire.

When children and young people are admitted to Clifford House they are frequently lacking in confidence and self esteem and are often unable to form and sustain positive relationships. Generally they are unable to function to their full capability, whether socially, emotionally or intellectually, and are therefore extremely vulnerable.

Our objective is to provide a safe, secure environment in typical family houses accommodating a maximum of four young people. In these placements - with regard to appropriate group dynamics - we will empower them to recognise and deal with their feelings and behaviours, increase their self-esteem and social skills.  At all times the homes will be adequately staffed. The staff turnover will be kept to a minimum through good recruitment processes and support for staff, thereby promoting stability and continuity of relationships for children.

There are arrangements to review care plans following critical incidents and make decisions that represent the best interest of the child.

We achieve this by adopting a 'good parenting' approach, thereby enabling our young people to move on to independence, return home or move to a substitute family. Clifford House is committed to achieving optimum outcomes for children within the Every Child Matters five outcomes and the seven Children's Rights Conference 2005, these being children should be happy, have enough food and drink, stay in contact with their family, have friends, have fun, experience love and receive respect.  At Clifford House children will be at the centre of the service. This is Clifford House's foremost principle.

This summarises our key policies:

1.	Protecting Children from Harm: Children will be given the opportunity to disclose safeguarding issues and be safeguarded from abuse with the support of fair safe caring policies and planned interventions to reduce risk. Clifford House understands our first priority is to promote children's rights, protect them from harm or injury, safeguard their welfare, ensure children are listened to and their views are taken into account and fairness is given a high priority.  All reasonable steps will be taken to ensure staff and children are informed about how to deal with suspicions or allegations of Significant Harm, and Clifford House will ensure that any such reports are dealt with promptly, in keeping with procedures issued by Local Safeguarding Children Board (LSCB). Clifford House are committed to being Section 11 of the Children Act 2004 compliant. The staff team promotes systems that protect children and minimise risk from, for example, internet sites, mobile phones and unwanted photography.
2.	Admissions, Assessment, planning and Review: Clifford House has a Central Referral Management System that oversees the referral process within and between our resources. This enables sensitive and appropriate matching of young people to our resources. Thereafter, services are provided on the basis of continual assessment, planning, monitoring and review. To this end, each child will have a Placement Plan which underpins their Care Plan and accurately reflects the way in which the young person's needs will be met whilst placed within Clifford House. This will include meeting identified outcomes in accordance with the five areas depicted within 'Every Child Matters'.  There are placement review meetings to evaluate compatibility between children and staff.  A Behavioural and Activity Risk Assessment will be undertaken as part of the process of placement planning and review to ensure the young person lives within a structured, productive and safe environment within which it is hoped they can make steps to meeting their full potential in all areas of their life and development.
3.	Avoiding delay: All decisions in relation to the provision of services to children will be made promptly and within agreed time-scales, having regard to the needs of the child; the achievement of these timescales will be monitored and reviewed by Clifford House.
4.	Equality and Diversity: We recognise our staff and young people we look after come to us from a diverse, multi-cultural, background and we intend to provide services which celebrate and promote each person regardless of age, race, gender, health, disability, sexuality, religion, marital status or social background. We are committed to ensuring all employees and young people demonstrate fairness to each other and to those they come into contact with. There is a strong culture of non tolerance of bullying and discriminatory behaviour; any such incidents are taken seriously.  We are committed to recruiting and retaining staff whose background is diverse and to eliminating racism and other forms of discrimination. We will challenge any form of discrimination in the organisation.
5.	Disability Discrimination; Clifford House believes in providing a welcoming, comfortable and accessible environment that is safe and easy to use for children, parents, relatives, staff,  visitors and other users of the premises. Clifford House endeavours to achieve equality of opportunity for all to ensure equal access to its facilities. Clifford House will where possible avoid physical features that make it difficult for people with a disability and make reasonable adjustments to improve the environment.
6.	Partnership: Clifford House values the contributions made by professionals caring for or working with children in other agencies and we will do all that is reasonably possible to engage and work in partnership with such professionals with a view to promoting and protecting the rights of children placed with us.
7.	Family Contact: Services will be provided in partnership with parents and with other agencies to assist and support parents in meeting their children's needs. To this end Clifford House will do all we can to promote contact between children and their parent(s), wider families and significant others.  Clifford House will promote contact with at least one friend outside of the home.  It will aim to prevent children from being lonely or isolated.
8.	Quality services for children: Clifford House's service for children and young people will be provided by competent members of staff, committed to meeting children's needs; in a manner which promotes their physical, emotional, social and psychological needs and in an environment where they feel safe, positive and encouraged.  It will aim to prevent unplanned ends to placements and keep staff turnover to below fifteen percent.
9.	Keeping children informed: All young people will be involved in planning their care and future. They will be involved in target setting and participating in achieving their full potential:  Young people have access to appropriate information and support which they may find beneficial in their ability to make choices. For example Clifford House provide information and advice on matters relating to children's health care and to services for facilities available to them.
10.	Physical Contact and Relationships: We encourage staff to develop professional relationships with children, based on clear boundaries, which demonstrate affection, acceptance and reassurance. We encourage staff to use appropriate physical contact, positively and safely in keeping with children's past experiences, needs and wishes. This means staff will promote protective and comforting behaviour based on mutual respect and care for all within and outside the home. We understand that staff often have to spend time alone with children, these situations will only occur if a lone working risk assessment has been completed.  We ensure that such practice is underpinned by effective procedures and training which safeguard the interests of both children and staff. No play fighting under any circumstances between staff and young people is allowed.
11.	Promoting independence: Clifford House helps young people to be as independent and to take a full and active part in everyday life as is appropriate and know their rights and responsibilities. This means children will be given support in receiving eligible statutory allowances and managing money and budgets.  We will provide young people with information, advice and support with further education to help prepare them for adult life.  We work in partnership with appropriate agencies in the development and implementation of Pathway Plans and we will develop appropriate social and life skill packages which promote young people's independence and prepare them for the time when they move on from us or leave care.
12.	Health Care: The staff team will have a caring approach and emotional resilience to deal with challenging behaviour and be skilled in being alert to children's emotional well being. The staff team will help children attend regular health checks and engage them in any necessary treatments. Clifford House ensures that there is a continuity of treatment and that physical, emotional and psychological health needs of each child placed at Clifford House will be identified, recorded and appropriate action will be taken to meet these needs in full (e.g. dental , optical and general medical needs).  Clifford House can access, in line with assessed need, specialist services and external psychological provision where necessary.  These services will be undertaken by appropriately qualified and supervised practitioners.  All children will be encouraged to make their own positive choices and decisions about their health, treatment and lifestyle. Children are provided with guidance, advice and support on health and personal care issues (including HIV/AIDs, Sexual Health and relationships, smoking and other drug and solvent misuse) appropriate to the needs and wishes of each child. Staff will look for early signs of ill health and substance abuse, misuse and addiction and take appropriate actions to resolve any issues. The staff team will help children understand the importance of healthy eating and leisure activity.
13.	Smoking: Staff are not permitted to smoke in the presence of children. Children are permitted to smoke if they are habitual smokers prior to their admission to Clifford House. On admission, a smoking contract is implemented which encourages and structures the gradual reduction and eventual termination of the young person smoking. Smoking is only permitted in designated areas, with the authority of social workers and parent(s), if appropriate
14.	Alcohol: Clifford House operate a 'No Alcohol' Policy. Staff are not permitted to consume alcohol on our premises except at formally organised functions, and only if they are not on duty or in the presence of young people.
15.	Education: Clifford House promote and support the educational attainment of Children throughout the time they live at Clifford house.  We aim to ensure children do not miss more than 25 days schooling in any one year. We promote a positive learning environment both at school and within the home, for example, by supporting Children with homework, coursework and possibly home study.  We have a suitably qualified person to exercise oversight of all children's education if required; this person can work directly with children if necessary. The staff team will endeavour to aim to have children taking at least one accredited examination in Maths, English, Science and ICT or other suitable qualifications according to their PEP target; this will be in addition to their accredited record of achievement. We develop close working relationships with external education facilities including colleges for Further Education, and we encourage young people to pursue G.N.V.Q and other vocational courses. Clifford House also work closely with social workers and other professionals e.g. teachers to ensure that each Child has a clear Personal Education Plan (PEP), Individual Education Plan (IEP) and Individual Behaviour Plan (IBP) which accurately reflects their needs and is reviewed at regular intervals. The staff maintain links with education with the aspiration that children will move into these settings. Clifford House will audit any deficiency or special requirements in educational provision and ensure all relevant individuals are informed and any deficiency will be resolved or action planned immediately. The staff teams will attend parent's evenings and other educational events. Those children with a Special Educational Needs Statement will have annual reviews and transition plans where relevant. Those children whose first language is not English will be enabled to receive extra support in the home to retain their first language and develop their English.
16.	Leisure and Recreation: All staff will actively encourage and support children in a range of activities, sport or play. This will include the promotion of involvement in appropriate youth, community, educational and other group based activities. Children are provided with opportunities to participate in a range of leisure, exercise and recreational activities and learning opportunities appropriate to their needs and choice, abilities and interests. Clifford House have a budget to fund suitable leisure activities and consideration is given to how young people will be encouraged and financially supported. Children's birthdays, name days, cultural and religious festivals will be celebrated where appropriate, and children will participate with staff in the planning of these events.  Children are to be encouraged and supported to pursue particular interests and develop confidence in social skills within and outside the home. Children who have been in placement for 38 weeks or more will have a holiday equivalent to 14 days a year. The homes will be equipped with diverse resources and materials to reflect the interests of each child.
17.	Giving and Receiving Gifts: Clifford House discourage the exchanging of all gifts between Clifford House staff and children. However, Clifford House appreciate that a card or small gift may be acceptable in the appropriate circumstances. Staff are required to make a written record of any gift that has been given. We discourage all children from lending items to each other or to staff.
18.	Behaviour Management: Clifford House ensures that plans and risk management strategies are in place for each individual child. These plans will identify the most effective de-escalation strategies to calm down situations that may lead to the need for restrictive physical intervention strategies as well as ways of equipping children with positive ways of managing their anger and anxiety.  Clifford House ensures that staff respond positively to acceptable behaviour, by giving praise, recognising achievement and possibly through incentive schemes where appropriate. The staff team will decide rules and permissions on an individual basis taking into account their age level of risk and trustworthiness.  Where the behaviour of children is regarded as unacceptable, they will be responded to in a way which is applied consistently and fairly in line with their Placement Plans. Also taking into account their age, level of understanding and previous behaviour. Sanctions or Reparation will only be imposed following an evaluation of the incident or circumstances, with the intention of encouraging acceptable behaviour or acting as a disincentive for unacceptable behaviour in the future. The use of Sanctions is based on the principle that the staff members have established a positive relationship with the young people. All sanctions are used to enable the children to recognise and take responsibility for their behaviour.
19.	Restraint and other forms of Physical Intervention: The staff are trained in practices that explicitly address how children are safeguarded from unnecessary restrictive restraint.  Clifford House appreciate that, on occasions, it is necessary to physically intervene when managing the behaviour of young people. The circumstance in which Physical Intervention is used is in accordance with government guidance and with approved methods. All staff are trained in P.R.I.C.E. (Protecting Rights in a Care Environment) and work in accordance with the Clifford House policy on the use of Physical Intervention. The use of Physical Intervention is a last resort and only implemented with the agreement of the Placing Authority.
20.	Incidents: Clifford House takes all reasonable steps to prevent incidents, such as Self harming, Bullying and Violence, from occurring. All young people, on admission, have a Behaviour Risk Assessment, which is regularly reviewed by the staff team working with the young person. This Risk Assessment addresses all areas of the young persons are and is used in collaboration with the young person's Placement Plan on a daily basis. Should incidents occur, Clifford House ensure they are recorded accurately at the earliest opportunity following the incident. Clifford House will also ensure that Management Reviews are undertaken to help reduce or prevent re-occurrence. Advice and intervention will be sought from appropriate resources as required.
21.	Safe Practices, Health and Safety: Clifford House have a written Health and Safety policy that makes clear its responsibilities under The Health and Safety at Work Act and related legislative guidance. In accordance with this Clifford House implement a very organised and efficient control of the health and safety risks arising from our work activities. The organisation has in post a person responsible for Health and Safety and designated competent Health and Safety representatives within each resource. All members of staff are consulted on matters affecting health and safety in all capacities and provide and maintain safe working and living environments. Each resource and department completes comprehensive Health and Safety Risk Assessments, which are regularly reviewed and monitored. Utmost vigilance is ensured in the safe handling and use of substances and information, instruction and training are given to all employees. Regular training ensures all staff are competent to complete their tasks, and Clifford House take all reasonable steps to prevent accidents and cases of work-related ill health occurring. Additionally as an organisation Clifford House maintain safe and healthy working conditions and review and revise our Health and Safety policies in this respect at regular intervals.
22.	Obtaining Views and Listening: Clifford House promote an 'open door' policy for all parents , significant others and children, which encourages them to express their views, wishes and feelings on all areas that affect the young person's life, future or their living environment. Clifford House strive to ensure the young person's views are taken into account when decisions are made.  This is supported by a conflict resolution strategy.  However, we ensure that the best interests of the young person are paramount at all times. The young person's views are sought during formal forums such as residents meetings, Link Worker sessions and confidential questionnaires and 'Review of Quality of Care Audits'. In addition also during informal times during day to day interaction. Clifford House will ensure that children have access to a Children's Rights Officer and or an independent Advocate when appropriate.
23.	Comments and Compliments: Clifford House welcome comments and compliments about the service we provide, and actively seek information and feedback under our review and quality of care procedures. Routinely, Clifford House seek information through consultative questionnaires from all professional bodies that have knowledge about the service. The purpose of seeking this information is to give us the opportunity to learn, adapt and provide a better service.
24.	Complaints and Grievances: We understand that complaints can arise from a simple misunderstanding or a general dissatisfaction. Complaints often give the opportunity to do something better and it is Clifford House's policy to engender a culture of continuous improvement. This policy is intended to ensure that representations are dealt with properly and that all complaints or comments by young people, their relatives and carers are taken seriously. Overall, Clifford House operates a NO BLAME culture. Clifford House values comments made by its employees, whether positive or negative. Where staff have grievances, we will do all we can to ensure rapid and effective resolution, preferably informally, without recourse to formal procedures. Where it is not possible for a grievance to be resolved informally we will initiate formal procedures aimed at resolving matters to the satisfaction of all.
25.	Respecting Privacy: Those in our care can expect to experience the same standards of privacy that we all expect to enjoy. Clifford House recognises that being 'Looked After' can make it difficult to enjoy privacy. All staff are alert to this and sensitive to its significance. Clifford House believe it is fundamental to treat children with respect and provide them with opportunities for privacy and personal space. During this time they have the opportunity to express their individuality through personal choice, possessions, reflection and maintain their self respect and independence where appropriate. This philosophy hopefully enables the young person to identify who they are and provide them with skills and belongings that they can enjoy during their placement within the organisation and when they move on.
26.	Searching Children: Prior to admission to any of the Clifford House Resources it is agreed with the young person's Placing Authority that in exceptional circumstances a search of the young person or their possessions may be necessary, where children or others welfare maybe at risk. Should this circumstance arise in an effort to protect a young person, Clifford House may feel it is necessary to conduct a search of the young person or their belongings. If such action is taken, Clifford House ensure that the actions taken are those that are deemed the least restrictive, intrusive and disruptive. Prior to any search taking place the young person is informed of the action that is being taken and the reasons behind any search proceeding. A young person's dignity will be maintained at all times. Prior to any room or body search taking place a Risk Assessment will be completed and authority given by a Senior member of the organisation. All searches of any kind are recorded in line with the Clifford House procedures and legislative guidance in place.
27.	Promoting Contact, Friends and Visitors: Clifford House promote meaningful contact between children, their families, friends and other significant persons unless particular circumstances indicate that such contact would not be in their best interests. Clifford House will assist young people in having regular contact with official visitors such as Field Social Workers and those that have some responsibility for the child's welfare. We will encourage those with Parental Responsibility to participate in some way in the child's daily life in so far as this is compatible with the facilities of the home, the child's Placement Plan and associated agreements. Clifford House encourage children to establish and maintain relationships with friends within and outside the home and with people from the wider community. Clifford House take steps to ensure that such relationships protect children's rights and interests.
28.	Monitoring and Improving Quality: Clifford House believes itself to be a learning organisation by identifying what the customer needs. Clifford House has a quality assurance system in place that has as its focus an aim to continually improve the service and providing the highest quality of service possible for children and those who commission a service. The system focuses on various in house performance indicators and external accreditation.  The staff teams are expected to demonstrate their commitment to quality and quality improvement in every aspect of their work.  The Quality Assurance Manager is responsible for establishing, maintaining and ensuring a quality management system is in place in the home. Clifford House have policies and procedures established to continually review and revise the quality of care provided for the young people placed. Clifford House has a number of internal and  quality assurance systems of continuous self assessment and regular monitoring, reviewing and auditing with its aim to be responsive to all forms of feedback these include: Internal reviews, audits, unannounced visits and compliance tracking Outcome based strategic strategies and processes for measuring progress progressing actions and improvements Customer response surveys Young Person response surveys An annual development plan for quality development which is drawn up as part of the business plan via the heads of service agenda Children at the centre of care and assessed needs audits Staff exit interviews Staff response surveys Staff performance reviews and appraisals Regulation 33/34 reviews and monthly manager  reporting Best Value meetings with commissioning teams where plans and goals are fully measurable Regularly reviewing and revising policies procedures and practices Updating practice in light of changing legislation and good practice advice from professional organisations Where appropriate contracting into an external professionally recognised quality assurance system  Staff and Young People meetings Regulation 32/33 visits trends and patterns audits Monthly Registered Manager Meeting's. Annual Reviews of Key Policies and Procedures

3. Equal Opportunities

3.1 Introduction

• We recognise that discrimination is unacceptable and although equality of opportunity has been a long-standing feature of our employment practices and procedure, we have made the decision to adopt a formal equal opportunities policy. Breaches of the policy will lead to disciplinary proceedings and if appropriate, disciplinary action.
• The aim of the policy is to ensure no job applicant or employee is discriminated against either directly or indirectly on the grounds of race, colour, creed, nationality, ethnic or national origin, religious belief, political opinion or affiliation, sex, marital status, sexual orientation or disability.
• We will ensure that the policy is circulated to any agencies responsible for our recruitment and a copy of the policy will be made available for all employees and made known to all applicants for employment.
• The policy will be communicated to all private contractors reminding them of their responsibilities towards the equality of opportunity.
• The policy will be implemented in accordance with the appropriate statutory requirements and full account will be taken of all available guidance and in particular any relevant Codes of Practice.
• We will maintain a neutral working environment in which no worker feels under threat or intimidated.

3.2 Recruitment and Selection

• The recruitment and selection process is crucially important to any equal opportunities policy. We will endeavour through appropriate training to ensure that employees making selection and recruitment decisions will not discriminate, whether consciously or subconsciously, in making these decisions.
• Promotion and advancement will be made on merit and all decisions relating to this will be made within the overall framework and principles of this policy.
• Job descriptions, where used, will be revised to ensure that they are in line with our equal opportunities policy. Job requirements will be reflected accurately in any person specifications.
• We will adopt a consistent, non-discriminatory approach to the advertising of the vacancies.
• We will not confine our recruitment to areas or media sources, which provide only, or mainly, applicants of a particular group.
• All applicants who apply for jobs with us will receive fair treatment and will be considered solely on their ability to do the job.
• All employees involved in the recruitment process will periodically review their selection criteria to ensure that they are related to the job requirements and do not unlawfully discriminate.
• More than one person will carry out short listing and interviewing where possible.
• Interview questions will be related to the requirements of the job and will not be of any discriminatory nature.
• We will not disqualify any applicant because he/she is unable to complete an application unassisted unless personal completion of the form is a valid test of the standard of English required for the safe and effective performance of the job.
• Selection decisions will not be influenced by any perceived prejudices of other Staff.

3.3 Disability Discrimination

Clifford House believes in providing a welcoming, comfortable and accessible environment that is safe and easy to use for children, parents, relatives, staff, visitors and other users of the premises. Clifford House endeavours to achieve equality of opportunity for all to ensure equal access to its facilities. Clifford House will where possible avoid physical features that make it difficult for people with a disability and make reasonable adjustments to improve the environment.

3.4 Training and Promotion

• Senior staff will receive training in the application of this policy to ensure that they are aware of its contents and provisions.
• All promotion will be in line with this policy.

3.5 Monitoring

• We will maintain and review the employment records of all employees in order to monitor the progress of this policy.
• Monitoring may involve: -
  • The collection and classification of information regarding the race in terms of ethnic/national origin, the sex and disability of all current employees
  • The examination by ethnic/national origin, sex and disability of the distribution of employees and the success rate of the applicants
  • Recording recruitment, training and promotional records of all employees, the decisions reached and the reason for those decisions.
• The results of any monitoring procedure will be reviewed at regular intervals to assess the effectiveness of the implementation of this policy. Consideration will be given, if necessary, to adjusting this policy to afford greater equality of opportunities to all applicants and Staff. 

4. Recording Values and Principles

Also see Access to Records Procedure

Each of the following values is summarised on the page specified.

4.1	Records must be kept on all Children
4.2	The design of records and forms must be approved
4.3	Children and their families must be informed about their records
4.4	The practitioner primarily involved should complete the record
4.5	All relevant information about children and their families must be recorded
4.6	Children and their families should be involved in the recording process
4.7	Information about children and their families should be shared with them
4.8	Managers must monitor information held in confidential section of records
4.9	Records must be legible, signed and dated
4.10	Records must be kept up to date
4.11	Records must be written in plain English and prejudice must be avoided
4.12	Records must be accurate and adequate
4.13	Managers must oversee, monitor and review records
4.14	Records should be kept securely
4.15	Removal of records must be an exceptional occurrence
4.16	Records moved to a new location must be monitored
4.17	Records must usually be retained after closure

4.1 Records must be kept on all Children

Records must be kept on all children: in the form of either paper files or computer records, audio or video recordings may also be kept. These records must conform to the Data Protection Act.

Information held in electronic records must accurately reflect the corresponding information recorded within paper files.

Records held on paper may extend to more than one volume.  Where more than one volume exists, the dates covered by each volume must be clearly recorded on the front cover.

4.2 The design of records and forms must be approved

Records and forms must be designed to fit their purpose and used consistently across the organisation.

The design of all records and forms must be approved by the senior management team before coming into use.

4.3 Children and their families must be informed about their records

Children and their families have a right to be informed about the records kept on them, the reasons why and their rights to confidentiality and of access to their records.

See Section 5, Confidentiality Values and Principles

Information must be provided in a form that children and their families will understand - in their preferred language or method of communication.  An interpreter will be provided if needed.

4.4 The practitioner primarily involved should complete the record

The member of staff primarily involved, that is by the person who directly observes or witnesses the event which is being recorded or who has participated in the meeting/conversation, must complete records.

Where this is not possible and records are completed or updated by other people, it must be clear from the record who has provided the information being recorded.  The originator should read and sign the record.

Records of decisions must indicate who has made the decision and the basis on which it has been made.

4.5 All relevant information about children and their families must be recorded

All contacts by e-mail or telephone, visits, meetings or appointments made in relation to children must be recorded, stating who made the contact, who was present or seen, the relevant discussions which occurred, actions or decisions taken and by whom; the reasons for taking any decisions should also be recorded.

All other relevant contacts with children, their families, colleagues, professionals or other significant people must be recorded.  When recording such contacts, it will be necessary to state who was present or seen, the relevant discussions which occurred, actions or decisions taken and by whom; the reasons for taking any decisions should also be recorded.

4.6 Children and their families should be involved in the recording process

Children must be routinely involved in the process of gathering and recording information about them.  They should feel they are part of the recording process and where possible sign records they have read to confirm their accuracy and confirmation that they have read them.

They should be asked to provide information, express their own views and wishes, and contribute to assessments, reports and to the formulation of plans.

Generally, they must be asked to give their agreement to the sharing of information about them with others - but there are exceptions.

4.7 Information about Children and their families should normally be shared with them

Information obtained about children and their families should be shared with them unless to do so would place them or others at risk.

For example, where the sharing of the information may place the child or another person at risk, or where the Police request that information should be withheld in order to enable them to investigate or prosecute a serious offence.

Where information is recorded which should not be shared with the child concerned, it should be placed in the Confidential Section of the child's file and a note of the lodging of the document should be recorded.

Where records contain information about third parties (for example, other family members or other children), this information cannot usually be shared, unless permission is gained from the person concerned.  In such cases efforts must be made to separate the information relating to third parties from that concerning the child/parents.

4.8 Managers must monitor information held in the confidential section of records

Managers must monitor information held in the confidential section of files, ensuring that the reason for holding it there is valid; if not, it should be shared with the child and/or moved to another section of the file.

However, before sharing any information previously deemed to be confidential, the manager must take all reasonable steps to consult the originator and take account of their views and wishes.

4.9 Records must be legible, signed and dated

If possible, manual records should be typed or handwritten in black ink and all records must be signed and dated.  Those completing computerised records must show their name and the date when the recording was completed.

Any handwritten records must be produced so that readers not familiar with the handwriting of the writer can read the records quickly and easily.  It must be possible to distinguish the name and post title or status of the person completing the record.  If there is any doubt of the identity of the writer from a signature, the name should be printed.

4.10 Records must be kept up to date

Records should be updated as information becomes available or as decisions or actions are taken as soon as practicable or, at the latest, within 24 hours.

Where records are made or updated late or after the event, the fact must be stated as a 'Late Entry' in the record, and the date and time of the entry must be included.

4.11 Records must be written in plain English and prejudice must be avoided

Records must be written concisely, in plain English, and must not contain any expressions that might give offence to any individual or group of people on the basis of race, culture, religion, age, disability, or sexual orientation.

Use of technical or professional terms and abbreviations must be kept to a minimum; and if there is likely to be any doubt of their meaning, they must be defined or explained.

4.12 Records must be accurate and adequate

Care must be taken to ensure that information contained in records is relevant and accurate and is sufficient to meet legislative responsibilities and the requirements of these procedures.

Every effort must be made to ensure records are factually correct.

Records must distinguish clearly between facts, opinions, assessments, judgements and decisions.  Records must also distinguish between first hand information and information obtained from third parties.

See Section 5, Confidentiality Values and Principles

4.13 Managers must oversee, monitor, and review and evaluate records

The overall responsibility for ensuring all records are maintained appropriately rests with managers with day to day responsibility, delegated to other staff as appropriate.

The Manager should routinely check samples of records to ensure they are up to date and maintained as required and, if not, that deficiencies are rectified as soon as practicable.

4.14 Records should be kept securely

All records held on children must be kept securely.

Children's files should normally be stored in a locked cabinet, or a similar manner, usually in an office which only authorised carers have access to.

Other day to day records, such as Contact or Daily Records, should also be kept securely in a manner authorised by the manager.

These records should not be left unattended when not in their normal location.

4.15 Removal of records must be an exceptional occurrence

Records should not normally be taken from the location where they are normally kept.

If it is necessary to remove a record from the home, a manager, who should stipulate or agree how long it is necessary to remove the record, should approve this.  The manager must also be satisfied that adequate measures are in place to ensure the security of the record(s) whilst they are removed.

For example, records must never be left in unattended vehicles.

The authorisation for a record to be removed must be recorded and those who may have need to see the records should be informed of their removal.

The manager must then ensure the record is returned as required/agreed.

4.16 Records moved to a new location must be monitored

Where records are moved to a new location, the date of transfer should be clearly recorded by a Manager.

The same person should check that the records have arrived at their intended destination.

4.17 Records must usually be retained after closure

Objectives:

• Establish Archive Store facilities
• Raise the profile of records management
• Ensure effective cross-referencing of documents held
• Generate a unique reference number per storage box/unit/cabinet
• Establish suitable Confidential Waste arrangements for destruction of records

In essence, the purpose of the homes archive and destruction policy and procedure is to ensure each home meets its duty and responsibility under regulation by:

Detailing the requirements for the collection, preservation, cataloguing and destruction of records as listed in the National Minimum Standards for Children's homes, Regulation 18, Schedule 3, Regulation 29 Schedule 4. 

5. Confidentiality Values and Principles

5.1	Legal duty of confidence
5.2	Disclosure of confidential information in exceptional circumstances
5.3	Informing children about disclosure
5.4	Disclosures and sharing information with colleagues and agencies

5.1 Legal duty of confidence

Personal information held about children is subject to a legal duty of confidence as adults, and should not normally be disclosed without the consent of the subject.

The legal framework for confidentiality is contained in common law, the Human Rights Act 1998 and the Data Protection Act 1998.

5.2 Disclosure of confidential information in exceptional circumstances

Whilst the general principle is that information obtained about children must be shared with them and not with others, there are exceptions.  The public interest in child protection overrides the public interest in maintaining confidentiality and the law permits the disclosure of confidential information necessary to safeguard a child or children.

Disclosure should be justifiable in each case, for example to provide information to professionals from other agencies working with the child, and where possible and appropriate, the agreement of the person concerned should be obtained.

Those working with children must make it clear that confidentiality may not be maintained if the disclosure of information is necessary in the interests of the child.

Even in these circumstances, disclosure will be appropriate for the purpose and only to the extent necessary to achieve that purpose. There may also be situations where third parties have a statutory right of access to the information or where a Court Order requires that access be given.

The circumstances in which information held in records on children and families can and should be disclosed and shared with others with or without consent are set out in the following sections.

In all other cases, where third parties such as advocates, solicitors or external researchers request access to information, this should only be given if written consent is given by the person concerned.

5.3 Informing children about disclosure

Children should be informed of the circumstances in which information about them will be shared with other professionals.  This may be provided in the form of a User/Children's Guide or in other ways, and it will be made clear that in each case the information passed on will only be what is relevant and on a 'need to know' basis.

Clifford House are signatories to the West Mercia Information Sharing Agreement.

5.4 Disclosures and sharing information with colleagues and agencies

Sharing information promptly with others working with the same child, or who may need to know, is invariably the key to safeguarding the child's interests.

Therefore, relevant information about children must be shared with colleagues, other professionals or agencies who may have a role to play in their care.

However, the general principle is that information may only be shared on a 'need to know' basis.

For example:

• Where professionals are undertaking a Child Protection Enquiry or Complaints investigation in relation to a child.
• Where the Police are investigating a criminal offence or require information to help them find an absent, missing or absconded child.
• Where information is requested in the furtherance of an inquiry or tribunal, or for the purposes of a Part 8 Review.

In such circumstances the person to whom the information relates should be informed that records have been requested unless to do so would prejudice the purpose of the request.

Any objections they have should be considered before responding to the person making the request.

Where information or records are passed to others it should be noted and confirmed in writing.

Information may also be disclosed to persons who have a statutory right of access to the information; for example

• Where the Court directs that records be produced or a Children's Guardian is appointed.
• Where information is requested by Inspectors of the Regulatory Authority e.g. Ofsted or CSSIW (who have specific statutory powers that permit access to records)

Where information is requested by telephone or electronically, great care must be taken to ensure that the recipient is entitled to receive the information requested.  Where there is any doubt the information may not be provided without the approval of a Manager.

6. Consultation Values and Principles

6.1	General Principle of Consultation
6.2	Management Consultation

6.1 General Principles of Consultation

Everyone involved in the receipt and delivery of services should be consulted about decisions which may affect them.  This includes children, their parents, other significant family members and those charged with providing the service; including managers, staff, carers and professionals or colleagues from other agencies.

This means that people's views should be sought and taken into account in relation to all decisions which are likely to affect their daily life and their future.

Consultation should take place on a regular and frequent basis and assumptions should not be made about the inability or lack of interest of those who should be consulted.

Where people have communication difficulties, of any sort, suitable means must be provided to enable them to be consulted; including access to advocates or representatives who may speak on their behalf.

Consultation should be undertaken in a creative and attractive manner.

If consultation is not possible or is restricted, for whatever reason, steps should be taken to ensure they are informed of the decisions as soon as practicable thereafter;  an explanation should be given and the person involved given the opportunity to make a comment and express their views.

If it is then felt that a different decision may have been appropriate, steps should be taken to reconsider it.

If decisions are made against people's wishes, they should be informed of the decision and the reasons for the decision should be explained.  In these circumstances, the person should be informed of any rights they have to formally challenge the decision, for example by way of a Complaints or Grievance Procedure.

6.2 Management Consultation

Unless otherwise stated in specific procedures in this manual, it is assumed that people working in this organisation will take reasonable steps to keep their managers informed of their actions; and will consult and seek their approval where they do not have decision making responsibility delegated to them.

In order to facilitate this, managers must ensure that effective lines of communication are established and maintained.

If procedures in this manual require that managers are informed within specified timescales or their approval is sought before actions are taken, this must be complied with unless there are exceptional circumstances which prevent it; for example, where it is necessary to act immediately to protect a child from injury.

In which case, the most senior person should take what action seems appropriate in the circumstances and the manager must then be informed as soon as practicable thereafter, but within 24 hours.

End