Policy Submission: Safeguarding Vulnerable Adults in Services Operated or Funded by the Department of Families and Communities in South Australia
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The purpose of this submission is to provide comment on the draft policy framework Safeguarding Vulnerable Adults in Services Operated or Funded by the Department for Families and Communities in South Australia. This will ensure that understandings gained by Purple Orange from working alongside people living with disability and representative organisations are considered in the development of the policy.
Recommendations
Recommendation 1
Purple Orange recommends that alternatives to the use of the term ‘vulnerable adults’ be used in the policy framework including' adults eligible for community care services' ‘adults experiencing vulnerability’ or ‘safeguarding adults'
Recommendation 2
Purple Orange recommends that use of the term ‘grossly disturbed’ on page 16 be removed from the policy framework so that it reads “Seclusion should only be used when all other strategies to manage challenging or aggressive behaviour has been exhausted”. This will ensure that people living with disability are not judged based on the behavioural and/or emotional issues they experience.
Recommendation 3
Purple Orange recommends that the notion and use of the term ‘least restrictive’ be removed from the policy framework and replaced with the notion of ‘safeguarding’ to support services to move beyond managing the situation to actively enhancing what is possible in people’s lives.
Recommendation 4
Purple Orange recommends that the term “planning and delivery of services to people with disability” on page 35 be replaced with “planning and delivery of services with people living with disability” to emphasise the importance of working with people living with disability to co-design the supports they receive.
Recommendation 5
Purple Orange recommends that reference to the “United Nations Rights for People with Disability” on page 42 be replaced with “United Nations Convention on the Rights of Persons with Disabilities”.
Recommendation 6
To highlight that the policy framework specifically relates to people living with disability, Purple Orange recommends that the title of the policy be changed from “Safeguarding Vulnerable Adults Policy” to an alternative such as “Safeguarding people living with disability who are eligible for community support”.
Recommendation 7
Purple Orange recommends that in the first paragraph of the ‘Introduction’ section on page 7 reference to a person’s rights being ‘promoted’ be included to ensure services actively raise awareness and provide education about the rights of people living with disability.
Recommendation 8
Purple Orange suggests that a more balanced perspective on the reality of human rights initiatives be included in the ‘Introduction’ section on page 7 by including a statement such as “Although a range of human rights treaties and polices exist people living with disability continue to experience violation of their rights. Therefore, services need to be diligent in ensuring their practices uphold, protect and promote the rights of people living with disability”.
Recommendation 9
Purple Orange suggests on page 8 the inclusion of the wording “it is not uncommon for people living with disability who receive personal supports because of their circumstances, to be at greater risk of sexual abuse, sexual assault or rape” to avoid association between living with disability and experiencing increased risk of sexual abuse or assault.
Recommendation 10
Purple Orange recommends the removal of the term ‘where possible’ on page 10 and suggests the wording “The rights of people with disability to actively make informed decisions and choices affecting their lives will be upheld, unless legal reasons or duty of care dictate otherwise”.
Recommendation 11
Purple Orange suggests that the policy framework emphasises the following point:
- “Safeguarding people living with disability through preventative work needs to focus on changing the environment and conditions that surround a person rather than focussing solely on the individual.”
Recommendation 12
Purple Orange believes the section on ‘Prevention’ be the primary focus of the policy framework as this will encourage services to provide supports that minimise the risk of abuse. We recommend positioning the section on ‘Prevention’ prior to the section on ‘Responding to Allegations of Abuse’.
Recommendation 13
Purple Orange recommends that templates and examples of policies and safeguarding plans be included in the policy framework to support services to establish these important documents.
Recommendation 14
Purple Orange suggest that in order for the policy framework to support people living with disability to live valued and ordinary lives, and thereby reduce the risk of abuse, the policy framework should emphasise the following point underlined (Page 8 under ‘Purpose’):
- This policy provides guidance and direction to organisation who deliver services to people who experience increased vulnerability on best practice in establishing and maintaining safeguarding systems that:
- are rights based and person centred
- “promote supporting people to live ordinary, valued lives through actively working with people to make decisions and choices about their lives”…
Recommendation 15
Purple Orange suggests that the policy framework highlight that support workers be provided with training on the issues surrounding the disclosure of rape with particular emphasis on looking after the person who has experienced rape.
Recommendation 16
Purple Orange recommends creating two separate documents in place of the current policy framework to reduce the size of the document and make policies and procedure more accessible.
- The first document would highlight the policy and procedures that services are required to follow. This document could contain links to the second document.
- The second document would include the important supporting information which currently exists in the policy framework.
Recommendation 17
In the final dot point under the ‘Neglect (Extreme)’ section on page 56 we suggest the following:
- “Witnessing a client commit an act of sexual or physical abuse toward another client without intervening and failing to make an immediate report of the abuse to the manager/supervisor”.