Jubilee Christian Centre and Ministerial Association (JCCMA) acknowledge the right to protect children and adult from abuse, irrespective of gender, ethnicity, disability, sexuality or beliefs. We believe that the wellbeing of children is vital to us. We will ensure that legislation, statutory guidance are followed and will recognise good practice in order to protect vulnerable people within our church. We will ensure we establish a caring environment in which there is an up to date awareness about the dangers of abuse. We will put into practice, maintain and regularly review the procedures outlined in this policy, which are designed to prevent and to be alert to abuse.
JCCMA will assign a Safeguarding Coordinator and Deputy Safeguarding Coordinator, who will have specific responsibilities for safeguarding, although we identify that safeguarding is a whole church responsibility. The Safeguarding Coordinator is the person to whom all concerns or allegations should be addressed. In the event that the Safeguarding Coordinator is unavailable, then, the Deputy Safeguarding Coordinator should be contacted. Their contact details can be found in Key Contacts page.
We will arrange activities in such a way as to support a safe environment and minimise the risk of harm to children and adults. We are committed to providing support, supervision, resources and training to those who work with children and adults. We will be meticulous and careful in protecting people from the risks associated with known offenders within the congregation, including implementing contracts with known offenders and those who have been assessed as posing a risk. Also as a church, we believe that domestic abuse is unacceptable and inconsistent with a Christian way of living and recognise that it can affect both adults and children. All concerns and allegations of abuse will be responded to properly, including referring to the statutory authorities if necessary. We will co-operate with the statutory authorities in any investigation, will follow multi-agency decisions and will maintain confidentiality of any investigations to those directly involved. We will refer concerns about staff - volunteers and paid, lay and ordained - that meet the relevant criteria to the Local Authority Designated Officer
Aim and purpose of this policy
The aim of this policy is to recommend procedures for promoting safeguarding, preventing abuse and protecting children, adults at risk and staff. This includes understandable procedures for taking suitable action when safeguarding concerns involving children and adults within our church are raised, or visitors who attend our activities and events. The Children Act 1989 allocates duties to local authorities, courts, parents, and other agencies in the United Kingdom, to ensure children are safeguarded and their welfare is promoted.
Who this policy applies to
This policy is approved and endorsed by the Trustees of JCCMA and applies to:
- All those who attend our church and other activities of the church (Children and Adults)
- Trustees and staff (both paid and voluntary)
- Organisations who hire our building with the agreement to operate under the church safeguarding policy. Children and parents/carers will be informed of this policy and our procedures. The term ‘children’ refers to those under the age of 18 years.
Duty of care and confidentiality
We have a duty of care to all beneficiaries of the church, whether adults or children. We will maintain confidentiality at all times, except in circumstances where to do so would place the individual or another individual at risk of harm.
The General Data Protection Regulation (GDPR) is a legal framework that sets guidelines for the collection and processing of personal information of individuals within the European Union (EU). The GDPR is enforceable in each EU member state and gives individuals greater control over their personal data. It comes into effect on 25th May 2018. The GDPR applies to any organisation that processes personal data of EU individuals, regardless of whether the organisation has a physical presence in the EU.
The General Data Protection Regulation places new obligations on organizations that process EU personal data. JCCMA happens to be one of such organisations. And as such, we are committed to comply by this new regulation.
How we prevent abuse
JCCMA will appoint Safeguarding and Deputy Safeguarding Coordinator(s) for safeguarding children and adults. A job description is attached as Appendix B.
Activities will be organised in accordance with JCCMA good practice guidelines so as to promote a safe environment and healthy relationships, whilst minimising opportunities for harm, misunderstanding or false accusation. For each event, risk assessments will be carried out, appropriate consent forms will be used (for children’s activities), appropriate records will be kept and adequate insurance will be in place.
JCCMA is committed to safer recruitment and selection of all paid staff and volunteers and will ensure that these procedures are followed, which include:
- Applicants completing an application form
- Job descriptions and person specifications provided for workers
- Completion of self-declaration forms
- Applicants providing Disclosure and Barring Service (DBS)
- Applicants providing two references (not from family members)
- Interviewing candidates
Safeguarding training will be provided, and volunteers and paid staff will be given support and supervision in their role. All trustees, paid staff and volunteers will work within a code of conduct (code for workers, attached as Appendix C) and understand that there may be action taken if this code is not followed, possibly involving suspension or termination of working with us. If we become aware of someone within our congregation known to have harmed children or adults in the past, we will inform the Trustee Safeguarding Officer and co-operate with them and the relevant statutory authorities to put in place a plan to minimise the risk of harm to children and adults.
Organisations wishing to hire our building for activities with children or adults must confirm in writing that they will follow the principles of this safeguarding policy as a condition of the letting agreement. If they have their own safeguarding policy, they will be asked to provide a copy. If they do not have their own safeguarding policy, the church will encourage them to adopt one before agreeing to the hire, or may agree that they can follow the church safeguarding policy and procedures.
How to recognise abuse
It is imperative that everyone is aware of the possible signs and symptoms of abuse. Please see Appendix for those relating to children and Appendix for those relating to adults at risk. Some signs could be indicators of a number of different categories of abuse. It is essential to note that these are only indicators of possible abuse. There may be other, innocent, reasons for these signs and/or behaviour. They will, nevertheless be a guide to help in assessing whether abuse of one type or another is a likely description for a child or adult’s behaviour.
What to do if there is a disclosure or allegation of abuse
If a child, young person or adult makes a disclosure that they are being abused and / or an allegation of abuse against someone, it is important that the person being told:
- stay calm and listen carefully
- reassures them that they have done the right thing by telling
- do not investigate or ask leading questions
- explains that they will need to tell someone else if anyone is at risk of harm, in order to help them
- does not promise to keep secret what they have been told
- informs the church Safeguarding Coordinator as soon as possible (if they are implicated in the allegation, informs the Deputy or the trustee Safeguarding Officer)
- makes a written record of the allegation, disclosure or incident and signs and dates this record. This should be given to the church Safeguarding Coordinator and stored securely in a locked filing cabinet.
Procedure in the event of a concern of abuse
The Police should be contacted without delay if there is an immediate threat of harm.
Where it is judged that there is no immediate threat of harm, the following will occur:
- The concern should be discussed with the church Safeguarding Coordinator and a decision made as to whether the concern warrants a referral to the statutory authorities (see Key Contacts)
- A confidential record will be made of the discussion and the situation surrounding it. This record will be kept in a secured place and a copy passed to statutory authorities if a referral is made.
- The person about whom the allegation is made must not be informed by anyone in the church if it is judged that to do so could place a child or adult at increased risk. The statutory authorities should be consulted beforehand if they are involved.
- The trustee Safeguarding Officer should be kept informed of any serious concerns.
If someone in the church is alleged or known to have harmed children or adults
The Safeguarding Officer will be informed so that they can offer advice and support, and we will contact the relevant statutory authority.
If the allegation concerns a church staff member or volunteer
If there are any concerns relating to children, the Local Authority Designated Officer (LADO) or the equivalent will be contacted. The timing and method of any action to be taken will be discussed and agreed with the LADO. This will cover communication with the worker, suspension, investigation and possible strategy meetings. A decision will be taken by the LADO about when to inform the worker and the church will follow this advice. For LADO contact details, see Key Contacts.
For concerns relating to adults, Adult Social Care will be contacted. See Key Contacts, for details. A referral will be made to the Disclosure and Barring Service (DBS). In accordance with the law if the church withdraws permission for an individual to engage in work with children / adults at risk OR would have done so had that individual not resigned, retired, been made redundant or been transferred to a different position because the employer believes that the individual has engaged in relevant conduct, satisfied the harm test, or committed an offence that would lead to automatic inclusion on a barred list.
In such cases, a report will also be made to the Charity Commission, as they deem such a referral to be a ‘serious incident’ and therefore require notification.
Concerns, Complaints and Compliments
If anyone has any concerns, complaints or compliments, please contact:
Name: Jubilee Christian Centre Administartion office
Telephone No: 020 7277 5999
In order to avoid any possible misunderstanding about what the issue is It would be useful to have complaints in writing. However, complaints will be acted upon whether verbal or in writing. Any written complaint will be responded to within 10 days.
The Trustees will review this policy annually, amend and update it as required, and inform the Church Meeting that this has been done.
Date of the most recent review: 27 MAY 2018
Date of the next review: 27 MAY 2019
Signed: Patricia Williams (on behalf of the church Trustees)
Key Contacts: Sources of advice and support
- The church Safeguarding Coordinator is the person to whom all concerns or allegations should be addressed:
Name: PASTOR CHIBUIKE OJI
Telephone No: 07985 215592
- In the absence of the Safeguarding Coordinator, the Deputy Safeguarding Coordinator can be contacted:
Name: MR FRANCIS WILLIAMS
Telephone No: 07817 267082
- Trustee Safeguarding Officer
Name: MR NELSON OGBANUFE
Telephone No: 07886 086989
Churches Child Protection Advisory Service (CCPAS) (This should only be used for urgent advice if you are unable to contact your Elders Safeguarding Officer)
24 hour helpline: 0845 120 4550
- Local Authority Designated Officer (LADO)
Name: EVA SIMCOCK
Telephone No: 02075250689
Statutory contact in the case of a child
Designated Officer (referral) Eva Simcock (02075250689)
- Statutory contact in the case of an adult at risk
Older people and adults with physical disability, including people with mental illness or impairment, aged over 65
Impariment , aged 18-65
Email: MentalHealthDivisionAS@ southwark.gov.uk
Adults with Learning disability or living with autism
Email: LearningDisabilitiesDuty@ southwark.gov.uk
The Role of a Church Safeguarding Coordinator
We believe that children and adults at risk deserve the best possible care that the church can provide and that the church should be a safe place for everyone involved. We recognise and give thanks for the time and devotion given by anyone carrying out this role.
Purpose of the role:
- To coordinate safeguarding policy and procedure in the church.
- To be the first point of contact for safeguarding issues.
- To be an advocate for good safeguarding practice in the church.
To coordinate safeguarding policy and procedure in the church
- To familiarise themselves with church policies and procedures and JCCMA good practice guidelines in safeguarding and to keep abreast of any changes and developments.
- To make sure that church policies and procedures are reviewed annually, kept up to date, and are fit for purpose.
- To make others in the church aware of the church safeguarding policies and procedures, as well as JCCMA guidelines.
- To ensure safer recruitment practices are operated in the recruitment of all workers (both volunteers and paid) including, but not exclusively, ensuring that the relevant workers have up to date Disclosure and Barring Service (DBS).
To be the first point of contact for safeguarding issues
- To be a named person that children / adults at risk, church members and outside agencies can talk to regarding any issue to do with safeguarding.
- To be aware of the names and telephone numbers of appropriate contacts within Social Care and the Police in the event of a referral needing to be made.
- Ensure awareness of when to seek advice, and when it is necessary to inform Social Care, the Police or the Local Authority Designated Officer (LADO) or the equivalent in Scotland and Wales of a concern or incident.
- To ensure appropriate action in relation to any safeguarding concerns which arise within the church.
- To cooperate with Social Care or the Police in safeguarding investigations relating to people within the church.
- To ensure that appropriate records are kept by the church and that information in relation to safeguarding issues is handled confidentially and stored securely.
- To inform the Trustee Safeguarding Officer at the time of any referrals made to the statutory authorities, or of any information received from the statutory authorities.
- To ensure report summary on safeguarding information is given to the Trustee Safeguarding Officer annually to enable them to monitor safeguarding within the church.
To be an advocate for good safeguarding practice in the church
- Promoting sensitivity within the church towards all those affected by the impact of abuse.
- Promoting positive safeguarding procedures and practice and ensure procedures are adhered to.
- To arrange and/or promote opportunities for training in safeguarding to any relevant members of the leadership team and congregation, including both paid staff and volunteers.
- Updating their safeguarding training every three years.
- Seeking appropriate support and advice in carrying out this role.
- Making arrangements for a suitable person to carry out this role when they are on leave, and to publicise who this is and the dates of the alternative arrangements.
Code of Conduct for working with children or young people
We should all be aware that behaviour in a worker's personal life (including online) may impact upon their work with children or young people. Therefore, all workers should agree not to behave in a manner which would lead any reasonable person to question their suitability to work with children or act as a role model within the JCCMA.
All workers should agree to the following code of conduct when working with children and young people:
- All people must be treated with dignity and respect
- Don't abuse the power and responsibility of your role. Don’t belittle, scapegoat, put down, or ridicule a child or young person (even in 'fun') and don't use language or behaviour with sexual connotations (e.g. flirting or innuendo)
- Do act inclusively, seeking to make everyone feel welcome and valued
- Don't exclude other children or workers from conversations and activities unless there is a good reason
- Do treat people with equal care and concern
- Don't show favouritism (e.g. in selection for activities, in giving rewards, etc) or encourage excessive attention from a particular child (e.g. gifts)
- Everyone should be encouraged to follow any behaviour agreement or ground rules and apply sanctions consistently
- Threats or sanctions that have not been agreed, should not be used.
- If a child does not respond to your instructions despite encouragement and warning of possible consequences please refer to a more senior worker
- You do not have to deal with every problem on your own
- Do seek to disseminate aggressive or threatening behaviour without the use of physical contact
- Physical restraint should not be used except as a last resort to prevent injury. This should use minimum force
- Do relate to children in public. If a child wants to talk one-to-one about an issue, tell another worker and find somewhere quieter, but still public, to talk
- Do not spend time alone with children out of sight of other people
- Ensure that any electronic communication is done with parental consent and is transparent, accountable, recorded and adheres to safeguarding policies
- Communication with children should not be kept secret, while still respecting appropriate confidences
- A designated photographer should take, store and share photos of your group’s activities, in line with JCCMA good practice guidelines
- Photos or videos should not be taken without consent, store them in a safe place designated by the church and only use them in the ways agreed, in line with JCCMA good practice guidelines Appendix C Sample Safeguarding Policy
Physical contact should be used wisely; it should be:
- in public
- appropriate to the situation and to the age, gender and culture of the child
- in response to the needs of the child, not the adult
- respectful of the child's privacy, feelings and dignity
- Do not use physical contact which could be misconstrued as aggressive (e.g. rough games) or sexual
- Respect children's privacy
- Don't assume that children should tell you anything you ask just because you are a worker
- Respect the right of children to wash, change and use the toilet in private
- Don’t walk in unnecessarily or unannounced
- Listen to children and tell the church Safeguarding Officer if you have any concerns about a child's welfare
- Do not promise to keep something secret if it is about a child being harmed or at risk of harm, but only tell those who need to know
- Respect and promote the rights of children to make their own decisions and choices
- Ensure you do not work in ways that put your needs and interests before those of the children you work with
- Encourage respect for difference, diversity, beliefs and culture
- Do not discriminate or leave discrimination or bullying unchallenged
I agree to abide by the above code of conduct while working with children and young people
on behalf of Jubilee Christian Centre
Name of worker: - - - - - - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - -
Signed: - - - - - - - - - - - - - - - - - - - -- - - - - - - - - -
Date: - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - -
What is abuse and neglect of children?
The below definitions are taken from Working Together to Safeguard Children 2015 and apply to England.
Abuse and neglect are forms of maltreatment of a child. Somebody may abuse or neglect a child by causing harm, or by failing to act to stop harm. Children may be abused in a family or in an institutional or community setting, by those known to them or, more rarely, by a stranger, for example, via the internet. They may be abused by an adult or adults, or another child or children.
Physical abuse can involve hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating, or otherwise causing physical harm to a child. Physical harm can also be caused when a parent or carer fabricates the symptoms of, or deliberately induces, illness in a child.
Emotional abuse is the constant emotional maltreatment of a child such as to cause severe and persistent adverse effects on the child’s emotional development.
It may involve conveying to a child that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may include not giving the child opportunities to express their views, deliberately silencing them or ‘making fun’ of what they say or how they communicate. It may feature age or developmentally improper expectations being imposed on children. These may include communications that are beyond the child’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child from participating in normal social interaction. It may involve seeing or hearing the ill-treatment of another. It may involve serious bullying (including cyber bullying), causing children frequently to feel scared or in danger, or the exploitation or corruption of children.
Some level of emotional abuse is involved in all types of maltreatment of a child, though it may occur alone.
Sexual abuse involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether or not the child is aware of what is happening.
The activities may involve physical contact, including assault by penetration (for example, rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing and touching outside of clothing. They may also include non-contact activities, such as involving children in looking at, or in the production of, sexual images, watching sexual activities, encouraging children to behave in sexually inappropriate ways, or grooming a child in preparation for abuse (including via the internet). For churches Sexual abuse is not solely perpetrated by adult males as Women can also commit acts of sexual abuse, as can other children.
Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect may occur during pregnancy as a result of maternal substance abuse. Once a child is born, neglect may involve a parent or carer failing to:
- provide adequate food, clothing and shelter (including exclusion from home or abandonment);
- protect a child from physical and emotional harm or danger;
- ensure adequate supervision (including the use of inadequate care-givers)
- ensure access to appropriate medical care or treatment.
It may also include neglect of, or unresponsiveness to, a child’s basic emotional needs
What is abuse of adults at risk?
Abuse is a violation of an individual’s human and civil rights by any other person or persons. Abuse may consist of a single act or repeated acts. It may be physical, verbal or psychological, it may be an act of neglect or an omission to act, or it may occur when a vulnerable person is persuaded to enter into a financial or sexual transaction to which he or she has not consented, or cannot consent. Abuse can occur in any relationship and may result in significant harm to, or exploitation of, the person subjected to it. Section 42 of the Care Act 2014 identifies various types of abuse as listed below
This is the infliction of pain or physical injury, which is either caused deliberately, or through lack of care.
Psychological or emotional abuse.
These are acts or behaviour, which cause mental distress or anguish or negates the wishes of the adult at risk. It is also behaviour that has a harmful effect on the adult at risk’s emotional health and development or any other form of mental cruelty.
This is the involvement in sexual activities to which the person has not consented or does not truly comprehend and so cannot give informed consent, or where the other party is in a position of trust, power or authority and uses this to override or overcome lack of consent.
Neglect, or Act of Omission
This is the repeated deprivation of assistance that the adult at risk needs for important activities of daily living, including the failure to intervene in behaviour which is dangerous to the adult at risk or to others. A vulnerable person may be suffering from neglect when their general well being or development is impaired.
Financial or material abuse
This is the inappropriate use, misappropriation, embezzlement or theft of money, property or possessions.
This is the inappropriate treatment of an adult at risk because of their age, gender, race, religion, cultural background, sexuality, disability, etc. Discriminatory abuse exists when values, beliefs or culture result in a misuse of power that denies opportunity to some groups or individuals. Discriminatory abuse links to all other forms of abuse.
The Home Office definition of domestic abuse (2013):
- Incident or pattern of incidents of controlling, coercive or threatening behaviour, violence, or abuse by someone who is or has been an intimate partner or family member regardless of gender or sexuality
- Includes psychological, physical, sexual, financial, emotional abuse; so called ‘honour’ based violence; Female Genital Mutilation; forced marriage
- Includes anyone aged 16 or over
Modern slavery includes slavery, human trafficking, forced labour and domestic servitude.
Traffickers are those who arrange for the people to move from place to place to do various tasks that they are asked to do. This can be moving within the UK and doesn’t have to be from abroad. You may often hear the words ‘harvesters’ or gardeners’ used in relation to the victims of modern slavery being made to grow and look after cannabis farms. Very often the traffickers trick victims into believing that they are arranging for them to have a better life and genuine employment.
If you think that someone is the victim of Modern Slavery please ring the Modern Slavery National Helpline on 08000 121 700.
This is the mistreatment or abuse of an adult at risk by a regime or individuals within an institution (e.g. hospital or care home) or in the community. It can be through repeated acts of poor or inadequate care and neglect or poor professional practice.
Signs of possible abuse in children
Physical signs include:
- Unexplained injuries
- Injuries that are inconsistent with the explanation
- Injuries that reflect an article being used e.g. an iron
- Bruising, especially the trunk, upper arm, shoulders, neck or finger tip bruising
- Burns/scalds, especially from a cigarette
- Human bite marks
- Fractures, especially spiral
- Swelling and lack of normal use of limbs
- Serious injury with lack of / inconsistent explanation
- Untreated injuries
Psychological/emotional signs include:
- Unusually fearful with adults
- Unnaturally compliant to parents
- Refusal to discuss injuries/fear of medical help
- Withdrawal from physical contact
- Aggression towards others
- Wears cover up clothing
Fictitious illness by proxy
This is a psychiatric illness, whereby a parent or carer deliberately inflicts harm onto a child, normally the child’s mother. The child has commonly had genuine serious illness in the first year of life and a dependency on medical attention has developed in the mother. It is very difficult to diagnose/evidence.
Female Genital Mutilation
A cultural (not religious) procedure whereby parts of female genitalia are removed - also referred to as female circumcision. This is normally undertaken on pre pubescent girls, who are either taken abroad for procedure or “practitioners” come to the UK. There can be no anaesthetic and no sterile equipment used. Complications include serious infection, septicaemia, numerous gynaecological problems and in some cases, death.
The classic description of emotional abuse is a “Low Warmth, High Criticism” style of parenting.
- Physical, mental and emotional lags
- Acceptance of punishments, which appear excessive
- Over reaction to mistakes
- Continual self-depreciation
- Unexpected speech disorders
- Fear of new situations
- Neurotic behaviour (such as rocking, hair twisting, thumb sucking)
- Self harm
- Extremes of passivity or aggression
- Running away
- Overly compliant behaviour
- Overeating or loss of appetite
- Sleep disorders
Physical signs include:
- Poor personal hygiene
- Poor state of clothing
- Emaciation, potbelly, short stature
- Poor skin tone and hair tone
- Untreated medical problems
- Failure to thrive with no medical reason
Psychological/emotional signs include:
- Constant hunger
- Constant tiredness
- Frequent lateness/non attendance at school
- Destructive tendencies
- Low self esteem
- Neurotic behaviour
- No social relationships
- Running away
- Compulsive stealing/scavenging
- Multiple accidents/accidental injuries
• Sexual abuse
Physical signs include:
- Damage to genitalia, anus or mouth
- Sexually transmitted disease
- Unexpected pregnancy, especially in very young girls
- Soreness to genitalia area, anus or mouth
- Repeated stomach aches
- Loss of weight
- Gaining weight
- Unexplained recurrent urinary tract infections, discharges or abdominal pain
- Unexplained gifts/money
Psychological/emotional signs include:
- Sexual knowledge unsuitable for the child’s age
- Sexualised behaviour in young children
- Sexually provocative behaviour/promiscuity
- Hinting at sexual activity
- Unexpected changes in personality
- Lack of concentration, restlessness
- Socially withdrawn
- Overly compliant behaviour
- Poor trust in significant adults
- Regressive behaviour, onset of wetting – day or night
- Suicide attempts, self mutilation, self disgust
- Eating disorders
Signs of possible abuse in adults
- A history of unexplained falls, fractures, bruises, burns, minor injuries
- Signs of under or over use of medication and/or medical problems unattended
- Alteration in psychological state e.g. withdrawn, agitated, anxious, tearful
- Intimidated or subdued in the presence of the carer
- Fearful, flinching or frightened of making choices or expressing wishes
- Unexplained paranoia
- Pregnancy in a woman who is unable to consent to sexual intercourse
- Unexplained change in behaviour or sexually implicit/explicit behaviour
- Torn, stained or bloody underwear and/or unusual difficulty in walking or sitting
- Infections or sexually transmitted diseases
- Full or partial disclosure or hints of sexual abuse
Neglect or Omission
- Malnutrition, weight loss and /or persistent hunger
- Poor physical condition, poor hygiene, varicose ulcers, pressure sores
- Being left in wet clothing or bedding and/or clothing in a poor condition
- Failure to access appropriate health, educational services or social care
- No callers or visitors
Financial or Material
- Disparity between assets and living conditions
- Unexplained withdrawals from accounts or disappearance of financial documents
- Sudden inability to pay bills
- Carers or professionals fail to account for expenses incurred on a person’s behalf
- Recent changes of deeds or title to property
- Inappropriate remarks, comments or lack of respect
- Poor quality or avoidance of care
- Lack of flexibility or choice over meals, bed times, visitors, phone calls, etc
- Inadequate medical care and misuse of medication
- Inappropriate use of restraint
- Sensory deprivation e.g. denial of use of spectacles or hearing aids
- Missing documents and/or absence of individual care plans
- Public discussion of private matter
- Lack of opportunity for social, educational or recreational activity
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