Safeguarding children, young people and vulnerable adults is paramount.
Kooth has more than 20 years of experience developing and refining our safeguarding approach and expertise in the digital mental health space, becoming a trusted and safe provider of NHS services.
We have robust and effective safeguarding governance, processes, training and quality frameworks in place to ensure we are proactive and committed.
Our safeguarding policies, while already robust and meeting all existing standards, are being fully aligned with the Online Safety Act, following draft guidance from Ofcom which will apply from later this year onwards.
Compliance
Kooth complies with statutory safeguarding frameworks and best practice. We conduct annual organisational audits to ensure our safeguarding arrangements are fully in line with the requirements of safeguarding legislation within each nation we operate.
For safeguarding children, this predominantly includes Children Act 1989 (2004), Social Services and Well-being (Wales) Act 2014, Children (Scotland) Act 1995, The Children (Northern Ireland) Order 1995.
In addition, the statutory guidance within each nation also underpins our arrangements, notably Working Together to Safeguard Children 2018, Wales Working Together to Safeguard People 2022, National Guidance for Child Protection in Scotland 2021 and Co-operating to Safeguard Children and Young People in Northern Ireland 2017.
In addition to the above, for safeguarding adults, we comply with the Care Act 2014 and associated Care and Support Statutory Guidance and The Adult Support and Protection (Scotland) Act 2007 and associated statutory guidance.
Additional assurance of our safeguarding arrangements is routinely conducted internally and externally against NHS England’s Safeguarding Assurance and Accountability Framework and the NHS Scotland’s Public Protection Accountability and Assurance Framework.
Governance of the safeguarding framework is led by our board lead for safeguarding (non-exec director), Professor Dame Sue Bailey OBE DBE FRCPsych, our chief clinical officer, Dr Lynne Green and our head of safeguarding. It is continuously monitored and reviewed by our clinical safeguarding committee.
The clinical safeguarding committee reports directly to the board on audits, safeguarding concerns, incidents and any areas assessed as requiring improvement, and signs off safeguarding improvement action plans.
Our specialist safeguarding team is made up of experienced, multidisciplinary safeguarding professionals from healthcare, social work and education backgrounds. The team consists of a head and deputy head of safeguarding, a safeguarding lead (social worker) and safeguarding officers.
Safeguarding assessment and thresholds
Our staff are extensively trained and supported to identify and assess safeguarding concerns in relation to risk to self, risk from others and risk to others. Specifically, in relation to risk to self, it is standard practice in our service to make routine enquiries into suicide and self-harm risk in every user session.
Our safeguarding threshold for escalating concerns is met when there are indicators of or potential indicators of imminent risk to self, significant harm (as defined for children in Working Together to Safeguard Children Statutory Guidance 2018 and for adults in relation to ‘adults at risk’ within Care and Support Statutory Guidance 2022) and accumulation of low level concerns.
Additionally, staff are required to record and escalate any concerns that relate to a serious crime or allegations against professionals or volunteers to a team manager, with oversight from our safeguarding team, to ensure the appropriate authorities are reported to.
Escalation process
In line with our safeguarding procedures and safeguarding training, where safeguarding risk is identified, staff will immediately escalate to a manager (Level 4 trained) to discuss and agree the concern, the threshold of risk/harm and the required safeguarding actions. Managers are trained and supported by Kooth’s specialist safeguarding team to act as duty safeguarding leads on shift.
They have the authority within policy and procedure to make decisions and take all necessary safeguarding actions (or oversee that they are carried out), including referrals to external agencies.
All staff have access to a duty safeguarding officer from Kooth’s specialist safeguarding team to provide advice and guidance on thresholds and required actions.
Informed consent and waiving consent
Users are informed about our safeguarding process and the limits of confidentiality during the account signup process and during every chat.
During this process, the user is required to recall understanding of this to enable a basic capacity check and ensure the criteria for informed consent is met. Where there are doubts or concerns about capacity to give informed consent, support staff are required to escalate and seek advice from a team manager.
As the Kooth service is anonymous at point of entry, wherever the safeguarding threshold is met, practitioners are required to attempt to seek identifiable information from the user.
Consent is desirable to best support the user, but not required to share information where the threshold is met. We always endeavour to minimise distress by fully explaining the need to share information and, wherever possible, offer choice and involve the user within the process.
Where a service user chooses to remain anonymous, Kooth has a range of effective strategies to safeguard them, including safety/harm reduction planning, signposting, resources, and safe person identification.
Ensuring consistency
To ensure consistency of our safeguarding approach, all staff complete mandatory safeguarding training and are provided with a set of clear, robust safeguarding procedures, including flow charts and threshold descriptors.
The policy and procedures ensure consistent decisions and actions are taken in relation to risk. Our induction, mandatory refresher training and supervision all continuously reinforce our safeguarding approach.
Additionally, Kooth’s safeguarding case system has technical guardrails and guidance prompts that ensures steps within the procedure are being applied consistently.
A cycle of monthly safeguarding audits and staff surveys are conducted to identify learning, monitor compliance and organisation-wide consistency with policy and procedure, and maintain our continuous improvement safeguarding approach.
Safeguarding Training
All staff across the organisation complete safeguarding training. Roles and safeguarding training requirements are aligned to the NHS Intercollegiate competency documents for Adults Safeguarding and Safeguarding Children and Young People.
Those specifically in service delivery and clinical roles complete Level 2 for adult safeguarding and Level 3 for child safeguarding; these are one day learning modules. This training ensures that all staff and contractors are adequately trained to recognise a safeguarding issue, understand their responsibilities and to take appropriate steps. A further module is completed in Prevent (radicalisation and extremism).
Additionally, all support teams and clinical teams complete an online digital safeguarding module that focuses on identifying and managing safeguarding issues within Kooth’s digital context in line with our safeguarding procedure. Our further training incorporates suicide prevention, domestic abuse, Mental Capacity Act and Deprivation of Liberty standards, Modern Slavery, FGM and whistleblowing.
Managers and the safeguarding team are trained to Level 4 (one day) and our safeguarding leadership and board lead are trained to Level 5 (half day).
All of the safeguarding training is mandatory, refreshed annually and monitored and audited via our online learning management portal. Update briefings are provided when there are changes to legislation, statutory guidance, or guidance issued from Safeguarding Partnerships/Boards.
Quality Audit
All safeguarding concerns indicating risk of harm or the likelihood of risk of harm, are recorded by support staff on Kooth’s comprehensive safeguarding case management system.
Each safeguarding record captures the detail of the safeguarding concern, the rationale for decision making, the initial safeguarding actions taken, the escalation to team manager duty safeguarding lead, advice provided, and details of referrals and any initial outcomes of actions and referrals.
Once a safeguarding record is completed and submitted on the safeguarding system, it is quality assured within one working day by a Level 4 trained team manager within the service delivery team.
Kooth’s safeguarding team conducts monthly audits on a sample of safeguarding cases. This audit assures the quality of record keeping, but more importantly the consistency of threshold decision making, rationale and actions. Monthly audits are also conducted specifically on the reviews of cases carried out within one working day by Level 4 trained managers.
This audit assures the quality of managerial oversight within our safeguarding escalation process, and the quality of follow-up and outcome tracking. Additional audits are conducted on the safeguarding team’s requests for advice and guidance.
The outcomes of audits feed into individual learning and development plans and Kooth’s wider quality improvement process. Recent improvements from this process have included enhancements to our safeguarding case management system and our guidance for multi-agency working.
Audit data, lessons learned and improvement recommendations are reported monthly to the clinical and safeguarding leadership team and to the executive board and clinical and safeguarding committee quarterly.