Safeguarding Policy

NEUROVERIFY SAFEGUARDING POLICY

Version 1.0 | Effective Date: 2026 | Review Date: 2027

This policy applies to all NeuroVerify staff, clinicians, contractors, and volunteers.

1. Policy Statement

NeuroVerify is committed to the safety and wellbeing of every person who uses our service. We recognise that neurodivergent people — and in particular children, young people, and adults in vulnerable circumstances — may be at heightened risk of harm, and that neurodiversity screening may sometimes bring sensitive disclosures to the surface.

This policy sets out our approach to safeguarding children and adults at risk across all NeuroVerify screening tiers. It applies to every member of the NeuroVerify team — including employed staff, contracted clinicians, coaches, and any volunteer or associate who has contact with clients.

Safeguarding is everyone's responsibility at NeuroVerify. It is not a compliance exercise. It is a fundamental commitment to the people we serve.

2. Legal Framework

This policy is grounded in the following legislation and guidance:

Children

Children Act 1989 and 2004
Working Together to Safeguard Children 2023 (HM Government)
Keeping Children Safe in Education 2023 (where applicable)
The UN Convention on the Rights of the Child
Children and Social Work Act 2017

Adults

Care Act 2014
Mental Capacity Act 2005 and 2019 amendment
Domestic Abuse Act 2021
Modern Slavery Act 2015

Data and confidentiality

UK General Data Protection Regulation (UK GDPR)
Data Protection Act 2018
Human Rights Act 1998

Equality

Equality Act 2010

NeuroVerify also has regard to the statutory guidance issued by NHS England and NHS Improvement relating to safeguarding in health and care services.

3. Definitions

Child: Any person under the age of 18, in accordance with the Children Act 1989.

Adult at risk: An adult aged 18 or over who has needs for care and support, and who is experiencing, or is at risk of, abuse or neglect, and as a result of those needs is unable to protect themselves against abuse or neglect or the risk of it, as defined by the Care Act 2014.

Safeguarding: The action we take to promote the welfare of children and adults at risk and to protect them from harm.

Abuse: Including but not limited to physical abuse, emotional abuse, sexual abuse, neglect, financial abuse, domestic abuse, modern slavery, self-neglect, and organisational abuse.

Disclosure: When a client reveals information — directly or indirectly — that suggests they or another person may be at risk of harm.

4. Scope

This policy applies to:

All individual screening clients across all three tiers — adult (18+), young adult (16–17), and adolescent (12–15)
All NeuroVerify staff, clinicians, coaches, and contractors
All stages of the NeuroVerify pathway — including the application and registration process, Stage 1 screening, Stage 2 clinical interview, Stage 3 feedback session, Stage 4 report, and Stage 5 coaching
All modes of service delivery — online, video, and in-person

5. Designated Safeguarding Roles

Designated Safeguarding Lead (DSL)

NeuroVerify has a designated safeguarding lead who holds overall responsibility for safeguarding policy and practice. The DSL is available during all scheduled service hours.

Name: [To be completed on appointment] Contact: [DSL direct line and email — for internal use] Qualification: Level 3 Safeguarding qualification (minimum) | Enhanced DBS certificate

Deputy Designated Safeguarding Lead

In the absence of the DSL, the deputy DSL assumes full safeguarding responsibility.

Name: [To be completed on appointment]

Clinical Lead

The NeuroVerify clinical lead is jointly responsible for ensuring that clinical safeguarding protocols are embedded in all clinical processes and that all clinicians are appropriately trained and supported.

All safeguarding concerns involving a clinical session must be reported to both the DSL and the clinical lead.

6. Recognising Abuse and Harm

All NeuroVerify staff and clinicians must be able to recognise the signs of abuse, neglect, and harm. The following are indicators that a safeguarding concern may exist. This list is not exhaustive.

Children and young people

Disclosure of physical, sexual, or emotional abuse
Disclosure of neglect — including poor nutrition, inadequate supervision, or educational neglect
Unexplained changes in behaviour, mood, or presentation
Signs of self-harm — including disclosure, visible injuries, or descriptions of self-harming behaviour
Suicidal ideation — any expression of thoughts of not wanting to be alive or of ending their life
Indication that a child is being exploited — including county lines, sexual exploitation, or trafficking
Disclosure of domestic abuse in the home
Indication that a child is a carer for a family member and that this is placing them at risk

Adults at risk

Disclosure of domestic abuse or coercive control
Disclosure of self-harm or suicidal ideation — at any level of expressed severity
Indication of neglect — including self-neglect where a person is unable to care for their own basic needs
Disclosure of financial, physical, or emotional abuse — by a family member, carer, or other person
Indication of modern slavery or exploitation
Significant mental health crisis indicators — including active psychosis, severe dissociation, or indicators that the person is not safe
Indication that the person lacks capacity to make decisions about their own safety

Neurodiversity-specific safeguarding considerations

NeuroVerify recognises that neurodivergent people face specific and elevated safeguarding risks, including:

Higher rates of abuse — autistic people and people with ADHD experience significantly higher rates of all forms of abuse than the neurotypical population
Masking — neurodivergent people may mask distress, making safeguarding indicators less visible
Communication differences — disclosures may be indirect, literal, or expressed in non-standard ways that require careful interpretation
Mental health — rates of anxiety, depression, suicidal ideation, and self-harm are significantly elevated in neurodivergent populations
Exploitation — neurodivergent people may be at heightened risk of financial and emotional exploitation

All NeuroVerify staff and clinicians are trained to recognise safeguarding risks as they present specifically in neurodivergent people and to ensure that communication differences do not prevent safeguarding concerns from being identified and acted upon.

7. Safeguarding Triggers in the NeuroVerify Screening Process

The following situations require an immediate safeguarding response at any stage of the pathway:

Stage 1 — Screening

Any score above zero on PHQ-9 Question 9 (thoughts of self-harm or not wanting to be alive)
Any score in the clinical or borderline range on RCADS suicidal ideation item (adolescent tier)
Any disclosure made in the free text fields of the application form indicating current risk

Stage 2 — Clinical Interview

Any verbal disclosure of current self-harm or suicidal ideation
Any disclosure of abuse — current or recent
Any indication that a child or adult at risk is in danger
Any disclosure of domestic abuse
Any observation by the clinician that the client appears to be in acute mental health crisis

All stages

Any communication received from the client — by email, message, or phone — indicating that they or another person may be at risk
Any third party contact raising concerns about a NeuroVerify client

8. Responding to a Safeguarding Concern — Step by Step

8.1 During a Clinical Session

Step 1 — Receive and acknowledge Receive the disclosure calmly and without visible shock. Acknowledge what has been shared. Do not probe for detail beyond what is necessary to establish the nature and immediacy of risk. Use open questions such as: "Can you tell me a little more about that?" Do not ask leading questions.

Step 2 — Assess immediacy Is the risk current and active — is the person in danger right now? Or is the concern historical, past, or non-immediate? Current active risk requires a different response to historical disclosure.

Step 3 — Do not promise confidentiality If not already covered in the session opening, remind the client of the limits of confidentiality: "I want to make sure you know that if I become concerned about your safety or the safety of someone else, I may need to share some information with others to help keep you safe. I will always try to talk to you about this first."

Step 4 — Contact the DSL Contact the NeuroVerify DSL via the emergency safeguarding channel during the session. Do not end the session abruptly. Keep the client engaged while seeking guidance.

Step 5 — Provide crisis resources Provide the client with appropriate crisis resources directly and clearly: "I want to make sure you have support available right now. Samaritans are available 24 hours a day on 116 123 — free and confidential. If you are in immediate danger please call 999." For young people: "Childline is available 24 hours on 0800 1111 — free and confidential."

Step 6 — Follow DSL guidance Follow the DSL's instructions regarding onward referral, statutory notification, or other action.

Step 7 — Document Complete Template D (Safeguarding Record) immediately after the session. Record the exact words used by the client where possible. Time-stamp all actions.

8.2 Outside a Clinical Session

If a safeguarding concern is identified through the application form, a client communication, or any other route outside a clinical session:

Bring the concern immediately to the DSL
Do not respond to the client before consulting the DSL unless the situation requires an immediate safety response
If the client is in immediate danger — call 999 if in contact with them, or advise them to call 999
Document all information received and actions taken

8.3 If a Client Discloses Abuse of a Child

If a client discloses that a child is being abused or is at risk of abuse — including if the client is a child disclosing their own abuse:

Receive the disclosure calmly
Reassure the client that they have done the right thing in telling you
Do not promise to keep the information secret
Contact the DSL immediately
The DSL will determine whether a referral to children's services or police is required
Do not conduct an investigation or ask detailed questions about the alleged abuse
Document the disclosure verbatim where possible

9. Specific Safeguarding Provisions by Tier

9.1 Adult Tier (18+)

All adults are presumed to have capacity to make decisions about their own safety and wellbeing unless there is clear evidence to the contrary
Safeguarding concerns involving adults are primarily addressed through information sharing and referral to appropriate services — with the adult's knowledge and consent where possible
Where a client lacks capacity or is in acute crisis, the DSL will determine the appropriate response which may include referral to statutory services without consent
Any PHQ-9 Q9 score above zero must be addressed in the Stage 2 interview regardless of the total score

9.2 Young Adult Tier (16–17)

Clients aged 16 and 17 have greater autonomy than younger children but are still legally children
Parental consent is required for participation but does not override the young person's right to confidentiality in most circumstances
Where a safeguarding concern is identified for a 16 or 17 year old, the response should be discussed with the DSL before deciding whether to involve the parent or guardian
If involving the parent would place the young person at greater risk — for example where the parent is the alleged abuser — parental notification must not occur without DSL guidance
Enhanced DBS certificates are required for all clinicians working with 16 and 17 year old clients

9.3 Adolescent Tier (12–15)

All clients in this tier are children and the full child safeguarding framework applies
Mandatory parental consent is required before any screening begins
All NeuroVerify staff and clinicians working with this tier must hold a current enhanced DBS certificate
Any safeguarding concern identified in the adolescent tier must be referred to the DSL immediately
Parents and guardians must be notified of any safeguarding concern unless doing so would place the young person at greater risk
Referral to children's services or police will be made by the DSL where indicated — this does not require parental consent where the concern is sufficiently serious
NeuroVerify will not conduct adolescent sessions in isolation — a second adult must be on the premises during all in-person adolescent sessions
Video sessions with adolescents must be conducted from a professional setting, not a private home

10. Information Sharing

Confidentiality is fundamental to NeuroVerify's service. However, confidentiality is not absolute. Information may be shared without consent where:

There is a risk to the life of the client or another person
A child is at risk of abuse or neglect
There is a legal obligation to share — for example a court order
The client lacks capacity and sharing is in their best interests

The following principles apply to all information sharing decisions:

Information should be shared on a need-to-know basis — only what is necessary to address the safeguarding concern
The DSL must authorise all information sharing decisions except in emergency situations where immediate action is required to prevent serious harm
Wherever safe to do so, the client should be informed that information is being shared and why
All information sharing decisions must be documented in Template D with the rationale recorded

Statutory referral

Where a referral to children's services, adult social care, or police is required, the DSL will make the referral. Referrals to children's services should be made within 24 hours of a concern being identified where indicated. In urgent cases — where a child is at immediate risk — a referral should be made to police or children's services without delay.

11. Recording and Documentation

All safeguarding concerns and the actions taken in response must be documented. Documentation must:

Be completed as soon as possible after the concern is identified — ideally within one hour for urgent concerns
Record the facts as known — not opinions or interpretations
Record the client's own words where possible — using direct quotes
Record the date, time, and method of all actions taken
Be stored securely in accordance with NeuroVerify's data protection policy
Be retained for a minimum of seven years for adult clients and until the young person's 25th birthday for clients who were under 18 at the time — or longer if required by law

Safeguarding records are stored separately from the main client clinical record. They are accessible only to the DSL, clinical lead, and where legally required, statutory authorities.

12. Training and Supervision

All NeuroVerify staff and clinicians must:

Complete NeuroVerify safeguarding induction training before working with clients
Complete a safeguarding refresher every 12 months
Attend safeguarding supervision following any safeguarding case
Know the name and contact details of the DSL
Know how to access the safeguarding escalation protocol at any time

Clinicians working with under-18 clients must additionally:

Hold a current enhanced DBS certificate at all times
Complete child safeguarding training at Level 2 or above as a minimum
Be familiar with the Working Together to Safeguard Children 2023 framework

The DSL maintains a training record for all staff and contractors and ensures that training currency is maintained.

13. Whistleblowing

NeuroVerify expects all staff and contractors to report any concern about the conduct of a colleague or the safety of a client — including concerns about whether safeguarding protocols are being followed correctly.

Concerns can be raised:

With the DSL
With the Clinical Lead
With the NeuroVerify director
Externally — to the Care Quality Commission, the relevant professional regulatory body, or the NSPCC Whistleblowing helpline on 0800 028 0285

No member of staff will be penalised for raising a genuine safeguarding concern in good faith.

14. Policy Review

This policy is reviewed annually by the DSL and Clinical Lead, or following any significant safeguarding incident. Staff and clinicians will be notified of any updates and are responsible for ensuring they are working to the current version.

Next review date: 2027

15. Key Contacts

Contact

Details

NeuroVerify DSL

[Name] — [direct number] — [email]

NeuroVerify Clinical Lead

[Name] — [direct number] — [email]

Samaritans - 116 123 — free, 24 hours

Childline - 0800 1111 — free, 24 hours, for young people

NSPCC - 0808 800 5000 — 24 hours

Emergency services - 999

NHS non-emergency - 111