In Di Go Dedicated Care and Support
POLICY AND PROCEDURE
SAFEGUARDING AND CHILD PROTECTION
(Reviewed and revised annually)
Last review: November 2017
Next scheduled review: November 2018
Dealing with Safeguarding/Child protection issues must take priority over all other work. If you see, hear, or are told of any issue that raises a concern about possible abuse:
Stay calm and listen to what is said, reassure the child/young person. Do not challenge, criticise, or promise confidentiality. You should not investigate but listen
and gather as much info as they want to tell you. You can ask for clarification-i.e.
“What do you mean? Can you explain?”
You should verbally pass this concern on to the Safeguarding Officer, Diane Marie Price, if you feel this is not appropriate you should contact the Safeguarding Lead Person, Gladys Rhodes
Complete the attached Safeguarding/Child Protection/ Concern form.
Date, sign and record who, what and when.
Record facts and use the language the young person uses. Type the form if possible, if hand written, it needs to be legible and concise.
This report should be given to Diane Price within 24 hours
The Designated Safeguarding Officer will identify who should be contacted and report the concern within 24 hours. If appropriate, the person reporting the concern will be informed and kept up to date with any relevant information.
Name: Gladys Rhodes White, OBE
Mobile: 07769 113408
Safeguarding Children/Young People is everyone’s responsibility
If you are concerned about a child and you feel they are being abused, neglected or at risk of abuse/neglect, then you should consider making a safeguarding child referral.
Contact Blackburn with Darwen Multi-Agency Safeguarding Hub (MASH) for confidential advice and consultation. Monday to Friday 08.45-17.00 please call: 01254 666400
If you are calling outside these hours please contact our Emergency Duty Team on 01254 587547.
Our Safeguarding policy
This policy applies to all staff, including senior managers, the board of directors, paid staff, volunteers, sessional staff, students, admin staff and anyone working on behalf of InDiGo
The purpose of this policy:
- To protect children and young people who receives InDiGo’s services, including the children of adults who also use our services
- To provide staff and volunteers with the overreaching principles that guide our approach to safeguarding and child protection
InDiGo believes that a child or young person should never experience abuse of any kind. We have a responsibility to promote the welfare of all children and young people and to keep them safe. We are committed to practice in a way that protects them
Child abuse is any action by another person – adult or child – that causes significant harm to a child. It can be physical, sexual, and emotional or neglect.
Physical abuse – is deliberately hurting a child causing injuries such as bruises, broken bones, burns or cuts.
Sexual abuse – when a child is forced or coerced into sexual activities, sexual abuse can also occur online
Emotional abuse – also known as psychological abuse, it is described as ongoing emotional maltreatment of a child, it includes deliberately trying to scare, threaten or humiliate a child, isolating or ignoring them.
Neglect – ongoing failure to meet a child’s basic needs, this could include a child being continually left hungry, dirty, living in an unsafe environment and/or not having suitable medical care
This policy has been drawn up on the basis of law and guidance that seeks to protect children, namely:
- Children Act 1989
- United Convention of the rights of the child 1991
- Data protection act 1998
- Human rights act 1998
- Sexual offences act 2003
- Children Act 2004
- Safeguarding vulnerable groups act 2006
- Protection of freedoms act 2012
- Children and families act 2014
- Special educational needs and disability (SEND) code of practice: 0-25 years – Statutory guidance for organisations which work with and support children and young people who have special educational needs or disabilities; HM Government 2014
- Information sharing: Advice for practitioners providing safeguarding services to children, young people, parents and carers; HM Government 2015
- Working together to safeguard children: a guide to inter-agency working to safeguard and promote the welfare of children; HM Government 2015
This policy should be read alongside our policies and procedures on:
- Recruitment; induction and training
- Role of the designated safeguarding officer
- Dealing with disclosures and concerns about a child or young person
- Managing allegations against staff and volunteers
- Recording and information sharing
- Code of conduct for staff and volunteers
- Safer recruitment
- E safety
- Health and safety
- Training, supervision and support
- Lone working policy
- Quality assurance
We recognise that:
- The welfare of the child is paramount, as enshrined in the Children Act 1989
- All children, regardless of age, disability, gender, racial heritage, sexual orientation, sexual identity or religious belief, have a right to equal protection from all types of harm or abuse
- Some children are additionally vulnerable because of the impact of their previous experiences, their level of dependency, communication needs or other issues
- Working in partnership with children, young people, their parents, carers and other agencies is essential in promoting young people’s welfare
We will seek to keep children and young people safe by:
- Valuing them, listening to and respecting them
- Appointing a Designated Safeguarding Officer (DSO) for children and young people; a deputy and lead board member for safeguarding
- Adopting child protection and safeguarding practices through procedures and a code of conduct for staff and volunteers
- Developing and implementing an effective e-safety policy and related procedures
- Providing effective management for staff and volunteers through supervision, support, training and quality assurance measures
- Recruiting staff and volunteers safely, ensuring all necessary checks are made
- Recording and storing information professionally and securely and sharing information about safeguarding and good practice with children, their families, staff and volunteers
- Using our safe guarding procedures to share concerns and relevant information with agencies who need to know and involving children, young people and their families where appropriate
- Using our procedures to manage any allegations against staff and volunteers
- Creating and maintaining an anti-bullying environment and ensuring that we have a policy and procedure to deal effectively with any bullying that may arise
- Ensuring that we have effective complaints and whistleblowing measures in place
- Ensuring we provide a safe physical environment for our children and young people, staff and volunteers, by applying health and safety measures in accordance with the law and regulatory guidance
Designated Safeguarding Officer
Name – Diane Marie Price MBE
Phone/Email – 07505 353508 – firstname.lastname@example.org
Senior Lead for Safeguarding
Name – Gladys Rhodes OBE
Phone/Email – 07769 113408
We are committed to reviewing our policy and good practice annually.
This policy was last reviewed on 01/11/2017
Designated Safeguarding Officer
Print Name : Gladys Rhodes, OBE
Date : 23.11.2017
Signed: D.M. Price
Senior Lead for Safeguarding
Print Name : Diane Marie Price, MBE
INFORMATION TO BE PASSED ON VERBALLY IMMEDIATELY TO
DESIGNATED SAFEGUARDING OFFICER
REPORT TO BE WRITTEN AND PASSED ON WITHIN 24 HOURS.
Date Ref/ Unique No:
SAFEGUARDING – CHILD PROTECTION /CONCERN LOG
Name of staff reporting concern
Child/Young Person Name
Child/Young Person Date of Birth
Details of concern, please describe the issue fully including dates, names, reported allegations, observations of behaviour, injuries etc
Discussed with manager: YES/NO
The following report may include information which could be an INDICATION of abuse. This report should not be shared without permission from InDiGo
Mobile phone/ Social Media Use Policy
Staff and volunteers should not use their mobile phones for personal use whilst on a break or during a group activity. Mobile phones should only be used in an emergency.
Staff should ensure they have the child’s contact details in the event parents/carers need contacting whilst on a break
Photographs and videos should not be taken using a staff mobile, In Di Go has a camera that staff can request before activities
Staff and volunteers are not permitted to use social media websites whilst on a break or during an activity
Staff and volunteers are to refrain from communicating with children and young people via social media, if a child or young person requests communication the staff member or volunteer should discuss this with Diane Price
Photographs, videos or any written evidence of the children/young people InDiGo works with should not be published on any social media platform without consent from Diane Price
Recruitment; induction and training
InDiGo is committed to promoting the welfare of children and young people and keeping them safe
We are also committed to equality, valuing diversity, and working inclusively across all of our activities. We aim to have a workforce that represents a variety of backgrounds and cultures and can provide the relevant knowledge, abilities and skills for our organisation
The purpose of the policy:
- to recruit the best people available to join InDiGo
- to take all reasonable steps to prevent unsuitable people from joining our organisation
- to recruit and manage our staff in a way that complies with legislation designed to combat inequality and discrimination
- to do all we can to achieve and maintain a diverse workforce
- to ensure that our recruitment and selection processes are consistent and transparent
- to ensure candidates are judged to be competent before we make them an offer of a job
- to ensure that new members of staff are given a proper induction
We recognise that:
- our workforce is our most important resource
- unsuitable individuals sometimes seek out opportunities via employment or volunteering to have contact with children in order to harm them
- some groups face unfair discrimination in the workplace
- children, young people and families benefit from our efforts to recruit a skilled and committed workforce from a diverse range of backgrounds
- new staff and volunteers cannot perform their role effectively unless they are inducted properly and receive ongoing support and supervision
InDiGo recruits and provides induction training for our workforce by:
- Advertising all posts through appropriate media and in a way that ensures that we attract high quality applicants from diverse backgrounds
- providing an application pack with relevant information for anybody who expresses an interest in an advertised job
- ensuring that all applications for both paid and volunteer positions are made using our standard application form
- involving more than one person to shortlist applicants for interview
- involving at least two people conducting a face-to-face interview with anyone we may want to appoint
- incorporating the views and perspectives of children, young people, and families into the recruitment and selection process whenever appropriate
- obtaining two references, two pieces of identification and original copies of any necessary qualifications from candidates
- carrying out CRB checks and any other necessary vetting procedures for each member of staff or volunteer working with children or young people, in line with CRB and other official guidelines
- providing a three-month induction for all new staff and volunteers
- ensuring that all staff are made aware, during their induction period, of how to keep children and young people safe in our organisation
- appointing all staff and volunteers on a trial period initially, with a review before they are confirmed in post
- using the list of processes below to follow a consistent procedure for recruitment and induction
We are committed to reviewing our policy and good practice annually.
Recruitment and induction process
- Plan your recruitment process.
- Advertise the vacancy.
- Review all applications for the role.
- Create a shortlist of suitable applicants.
- Agree the interview questions and tests
6. Invite your chosen candidates to be interviewed.
7. Conduct interviews and verify every candidate’s identity and qualifications.
8. Choose your preferred candidate
9. Make a provisional offer of a job, depending on references and vetting processes being completed satisfactorily.
10. Consider any confidential information that the candidate has submitted along with his/her application, and discuss this with the candidate.
11. Complete the take up of references and checks.
12. Are all issues arising from the references, checks and self-disclosed information resolved? Yes – confirm the offer on a trial period of six months. No – withdraw the job offer.
13. Agree a start date.
14. Plan the induction.
15. New staff member starts. Follow through the induction programme.
16. Review the progress of the trial period after a maximum of three months.
17. After six months, are you satisfied with their progress?
Yes – confirm new staff member in post.
Not completely – extend the trial period for a maximum of three further months and agree a further support package.
No, progress has been highly unsatisfactory – end the contract at this point.
18. After nine months, are you still unsatisfied with the new recruit’s progress?
Yes – end contract at this point.
No – confirm new staff member in post.
ANTI BULLYING POLICY
InDiGo’s Statement of Intent
InDiGo’s aim is to create an environment where children and young people can be supported in addressing their emotional, spiritual and social needs. All forms of bullying interfere with achieving this aim. Therefore, such behaviour will not be tolerated. The staff team will be proactive in their use of the strategies and systems in place to address bullying at all levels while providing opportunities for change for those who are bullying and those who are bullied.
Definition of Bullying
Bullying happens when one person exerts some form of power, in a negative and/or oppressive way, over another person for their own popularity, status or material gain. It is for personal gain and is at another person’s expense and sense of well being. Bullying is an abuse of power, which can manifest in any or all of the following.
- Direct or indirect use of threats or actual physical violence.
- Direct or indirect insults and/or offensive remarks about a person or their family.
- Direct or indirect insults and/or offensive remarks based on difference, for example, race, gender, disability or sexuality.
- Direct or indirect ridicule, sarcasm and put-downs.
- The systematic ignoring or exclusion of someone from everyday events, activities and discussion.
- The deliberate destruction of another person’s property.
- Group manipulation eg: inciting others to victimise a young person.
- Cyber bullying (see separate policy for a break down of this).
This list is for guidance and staff need to use their professional judgement to decide if observed or reported behaviour constitutes bullying and act accordingly.
It is important to note that not all forms of bullying can be managed within InDiGo. For example, cyber bullying is a big issue and we therefore need to work in close partnership with parents/carers. InDiGo will not tolerate cyber bullying. The nature of some bullying behaviours may constitute a child protection referral and/or police involvement. Staff should refer to InDiGo’s reporting procedure documented in the Safeguarding policy.
It is also important to recognise that bullying behaviours are not exclusive to young people. It is therefore imperative that as a staff team we remain vigilant and address any indication of bullying by colleagues through the Harassment Policy or the Whistle Blowing Policy.
Staff should strive to deal with incidents of bullying at the lowest level appropriate to the severity of the incident. It will often be the case that incidents can be managed without evoking the levels system.
On observing or having reported to them a bullying incident the member/s of staff should assess the severity of the incident, with colleagues where possible, and decide on the best response. For example, a minor incident may be best managed by facilitating a meeting between the parties involved, working through the incident, agreeing an action plan and how this plan is to be monitored. At the other extreme it may be necessary to involve the senior management team who, depending on the nature of the incident, may evoke a child protection inquiry or have cause to exclude. If in doubt consult Diane Price
IT IS ABSOLUTELY ESSENTIAL THAT THE YOUNG PERSON RECEIVES FEEDBACK SO THAT THEY CAN SEE THAT SOMETHING IS BEING OR HAS BEEN DONE ABOUT THEIR COMPLAINT.
This is an extremely important element in effectively managing bullying behaviour. All staff hold a responsibility to ensure that recording systems are maintained. This means that monitoring systems can effectively work to protect victims of bullying and persistent bullying behaviour can be highlighted and managed.
Any reported incidents of bullying must be recorded on the incident form which can be obtained from Diane Price
- Cyberbullying in context
- What steps are taken at Meadows to prevent cyberbullying
- Useful Contacts for mobile phone networks and social websites
- Education in School
Cyberbullying means deliberately using Information and Communications Technology to cause distress to another person.
2. Cyberbullying in context?
Use of offensive texts that can upset others
Picture/video-clip bullying via mobile phone cameras
Sending unacceptable images to intimidate, such as filming incidents without the person’s consent
Phone call bullying via mobile phone
Use of abusive language, or silent calls
Sending bullying or threatening messages
Chat room bullying
Sending unpleasant messages to individuals
Bullying through instant messaging (IM)
Using unacceptable language or sending unacceptable messages on real time chat sites such as Facebook, or Bebo
Bullying via websites
Putting information or images on Blogs or websites which refer to a person, without their permission
InDiGo seeks to prevent bullying incidents by having a no mobile phone policy during short breaks and whilst on activities, no ICT equipment is accessed by staff or young people whilst on breaks or during activities. Staff are restricted from sharing personal information such as mobile phone numbers and social media profiles with young people and families.
Although bullying is not a specific criminal offence in UK law, there are criminal laws that can apply in terms of harassment or threatening behaviour pertinent for cyberbullying.
In fact, some cyberbullying activities could be criminal offences under a range of different laws, including the Protection from Harassment Act 1997 and the Malicious Communications Act 1988
1. It is necessary to have a minimum number of rules in the interests of the whole Company.
2. The rules set standards of performance and behaviour whilst the procedures are designed to help promote fairness and order in the treatment of individuals. It is our aim that the rules and procedures should emphasise and encourage improvement in the conduct of individuals, where they are failing to meet the required standards, and not be seen as a means of punishment.
3. Every effort will be made to ensure that any action taken under this procedure is fair, with you being given the opportunity to state your case and appeal against any decision that you consider to be unjust.
4. The following rules and procedures should ensure that:-
a) The correct procedure is used when inviting you to a disciplinary hearing.
b) You are fully aware of the standards of performance, action and behaviour required of you.
c) Disciplinary action, where necessary, is taken speedily and in a fair, uniform and consistent manner.
d) You will only be disciplined after careful investigation of the facts and the opportunity to present your side of the case. On some occasions temporary suspension may be necessary in order that an uninterrupted investigation can take place. This must not be regarded as disciplinary action or a penalty of any kind.
e) Other than for an “off the record” informal reprimand, you have the right to be accompanied by a fellow employee who may act as a witness or speak on your behalf, at all stages of the formal disciplinary process.
f) You will not normally be dismissed for a first breach of discipline, except in the case of gross misconduct.
g) If you are disciplined, you will receive an explanation of the penalty imposed and you will have the right to appeal against the finding and the penalty.
It is not practicable to specify all disciplinary rules or offences which may result in disciplinary action, as they may vary depending on the nature of the work. In addition to the specific examples of unsatisfactory conduct, misconduct and gross misconduct shown in this handbook, a breach of other conditions, procedures, rules etc. within this handbook will also result in the disciplinary procedure being used to deal with such matters.
We always aim to conduct ourselves ethically, and with honesty and integrity. We expect the same high standards from all of our staff and volunteers. We do, however, recognise that there may be occasions when we – or our people – do not get this right. In these instances, you may feel that you need to raise your genuine and serious concerns through this whistleblowing policy.
The aims of this policy are to:
• provide an effective way for you to raise serious concerns
• ensure that you receive feedback on any action undertaken by us as a result of you raising serious concerns
• ensure that you will be protected from reprisals or victimisation for having raised your concern in good faith
• signpost you to further options available to you if you are dissatisfied with our response, or if internal investigation is not appropriate
• allow InDiGo to take action against any employee who makes allegations in bad faith and/or publicly discloses information when it is unreasonable for them to do so.
Who this policy applies to
This policy applies to everyone who works for and volunteers with InDiGo
‘Whistleblowing’ is a term used to refer to the internal or external disclosure of malpractice as well as illegal acts, or omissions, at work. It covers, for example, how we raise funds, how we commission work or make payments.
Protecting individuals using this policy
The Public Interest Disclosure Act 1998 amended the Employment Rights Act 1996 and it provides protection for individuals who raise legitimate concerns about specified matters, outlined below. These are called qualifying disclosures. A qualifying disclosure is one made in good faith by an individual who has a reasonable belief that:
• a criminal offence (including fraudulent and corrupt behaviour, e.g. theft, fraud or malpractice)
• a miscarriage of justice
• an act creating risk to health and safety
• an act causing damage to the environment
• a breach of any other legal obligation, or
• concealment of any of the above.
It is not necessary for you to have proof that such an act is being, has been, or is likely to be, committed. You do, however, need to hold a reasonable belief of such an action having been, being or likely to be carried out. If you make such a protected disclosure, you have the right not to be dismissed, subjected to any other detriment, or victimised. This is the case even were it to materialise that you were genuinely mistaken. We will not tolerate any individual being subjected to a detriment as a result of their making a disclosure in good faith. Under the law, interns, contractors or volunteers, are not afforded the same legal protection that is afforded to employees. InDiGo, however, wants to promote and encourage an open and honest environment in which concerns can be freely raised. We will therefore, in so far as is possible, aim to treat all individuals making a disclosure in the spirit of the Public Interest Disclosure Act 1998
If it is found that you have maliciously raised a matter which you know to be untrue or you are involved in any way in the malpractice, wrongdoing or illegal acts or omissions, your behaviour may be addressed through the appropriate policy.
This policy is only to be used in the exceptional circumstances as outlined in section 5, above. There are a number of InDiGo policies that will be relevant in other circumstances. This list includes but is not limited to:
• safeguarding and child protection
• bullying and harassment
Raising a concern
You should raise your whistleblowing concern as soon as possible. This will make it easier to act and to enable any problems to be resolved or reported quickly. You can make your disclosure orally but written disclosures are preferable as these will make the process more efficient and effective. In your disclosure, you should:
• provide any relevant context and background, including relevant dates, venues, names etc • state clearly the reason why the situation causes for concern.
You must say that you are raising your concern using the whistleblowing policy and whether you wish your identity to be kept confidential. While we will make every effort to deal with your case confidentially, depending on the circumstances of the case this may not always be possible. Where this is the case, you will be informed of this and the reasons why it was not possible. We will consider anonymous disclosures, but we do not encourage them as anonymity often makes it difficult to properly investigate concerns, protect employees or give feedback on outcomes.
Who should I raise it with?
You should always look to raise the matter with your line manager in the first instance. Where this is not appropriate because they may be involved in the alleged malpractice, wrongdoing or illegal acts or omissions in some way, raise your concern with Gladys Rhodes, InDiGo’s lead safeguarding officer
What happens after I raise a concern?
Your disclosure will always be acknowledged within three working days. It will be investigated by the person that you raise your concern to. They will arrange to meet you as soon as possible, away from the workplace if necessary, to enable you to explain your concern. We may not always be able to keep your details confidential but we will always let you know if it is not possible to do so. You will be told either at the meeting or as soon as possible afterwards, what action will be taken to address the concern you have raised. Where action is not taken, you will be informed and given an explanation. The action taken in response to a disclosure will depend on the nature of the concern.
Typically, the matters raised may result in one or more of the following:
• no action required
• action being taken under other InDiGo policy or procedure
• an internal investigation under this policy
• a referral to the police or relevant statutory body
• an independent enquiry.
Raising a concern externally
We strongly encourage you to exhaust the internal processes set out above in the first instances. In exceptional or urgent circumstances, however, or where, having made a disclosure, you are unhappy with the outcome, you have a legal right to make a disclosure to prescribed bodies.
These include but are not limited to:
• the Charity Commission;
• HM Revenue & Customs;
• the Health and Safety Executive;
• the Financial Services Authority;
• the Office of Fair Trading;
• the Environment Agency
• office of the Scottish Charity Regulator
• the Charity Commission for Northern Ireland
• fundraising regulator.
Similar to the rights and obligations of an employee, InDiGo reserves the right to make a referral to any of the above agencies without your consent.
LONE WORKER POLICY
- Where an individual’s role requires them to work alone, both the individual staff member and their manager have a duty to assess and reduce the risks which lone working presents.
- This policy should be read in conjunction with the Safeguarding Children policy.
- This policy is designed to raise awareness of the risks presented by lone working, to identify the responsibilities each person has in this situation, and to give guidance on how to manage such risks.
- This policy applies to all staff who work alone at any time whilst undertaking duties for In Di Go including both paid and voluntary
- Staff should have a telephone with them whenever they are lone working.
- Staff working alone must ensure they are familiar with the building’s exits and alarms.
- Staff should never work alone if they are concerned about risks to themselves or others in the situation. Concerns must be reported to Diane Price as soon as it appropriate
- Should an incident occur, the reporting and de-briefing involving an identified person should follow as soon as possible after the incident and no later than 24 hours after such incident, Staff should follow the safeguarding policy for reporting incidents
- Whilst in group activities staff should refrain from being alone with a child or young person when possible
- Volunteers should not be left alone with a child or young person
- Staff are not permitted to take children or young people to the toilet or provide toileting/personal care
Any complaint made against a staff member regarding a child or young person must be completed in accordance with InDiGo’s safeguarding policy
A complaint should be made verbally to Diane Price, a meeting will be arranged to discuss the complaint and how it will be resolved. Diane Price will attempt to resolve the complaint and refer back within 10 days to discuss the outcome
If the complainant is dissatisfied with stage one, then they can request for the complaint to be taken to stage two. The complaint should then be given to a director in written form and the reasons for dissatisfaction at stage one should be included
Should a complaint be dealt with by a director, the complainant will be notified with a response within 7 days
Internet Safety policy
The internet has the potential to offer children and young people a wide range of opportunities – to learn, to develop new skills, to keep in touch with friends and make new ones and to have fun. However there are concerns about both inequalities of access to the technology and the possible threats to children’s safety that can exist online.
Threats to children’s safety
Threats can arise in the following ways:
- Children and young people inadvertently or deliberately accessing either illegal or inappropriate sexual or violent material – illegal material could involve children or adults.
- Targeting and grooming of children by predatory adults through chat rooms, possibly adults posing as children
- The abuse of children, in some cases in real time using web cams, in order to provide material for paedophile news groups
- The use of email, instant messaging etc to bully and harass other – this may be more likely to occur between children and young people
Whilst specialist services may be more likely to come across children and young people who have been involved in either the production or use of pornography, all services have a role to play in enabling children and young people to use the internet safely, for example by providing information.
Guidelines for staff when children/young people are accessing the internet on breaks or during activities:
- Place computers in public places where everyone can see what is being viewed
- Take an interest in internet use; talk to young people about what they’ve seen.
- Monitor time spent online to ensure it does not become excessive
- Educate young people to use the resource sensibly
- Help young people to become critical users; “…is this information true?”
- Warn young people about unsavoury sites and discuss the issues involved
- Contact the Internet Watch Foundation (www.iwf.org.uk) if anyone finds any material you believe to be illegal
- Report any concerns to Diane Price as soon as is appropriate
Medication/Personal Care policy
InDiGo staff are not permitted to administer any medication, if a child or young person requires medication they should take this before or after a break or activity takes place. If a child or young person needs to take medication on a break the parent/carer and staff member should fill in the appropriate form and pass this on to Diane Price.
InDiGo staff are not permitted to carry out personal care tasks such as pad changing, washing or toileting. Children and young people will be assessed on referral to InDiGo and parents/carers will be advised that any aspect of personal care must be completed before a break as staff cannot carry these tasks out.