Vulnerable Adults Protection Policy


Action on Alzheimer’s & Dementia (hereafter known as “AAD”) serves persons living with a diagnosis of dementia or cognitive decline and provides support to their care partners, both formal and informal. Those with a diagnosis of dementia or cognitive decline are considered ‘vulnerable adults’, as they may have difficulty communicating, making informed and rational decisions, and may rely on others to provide personal care and general support for daily living. As a result these persons are open to all forms of abuse and will be considered and referred to in this Policy as “vulnerable adults”.

It is further noted the term “associates” as used in this document includes the following: any AAD board member, volunteers, any paid contractor working in a capacity for AAD, or care partners for persons with dementia, attending AAD activities.

“Most responsible adult” as used herein is defined in hierarchal order as the a) Power of Attorney for Health Care b) Family/Friend identified by the competent patient c) Next of Kin d) formal care partner (if any)

AAD has adopted the following policy and procedures for several reasons, including to:

  • Safeguard from physical or emotional harm by our associates at our community activities/events.
  • To assure the vulnerable adult is safe at AAD organized events.
  • Raise awareness amongst all of our associates such that they know what to do if they are concerned about a vulnerable adult, whether the concern relates to: the person’s welfare at AAD events or something happening outside of AAD that a vulnerable adult discloses to someone they trust within AAD
  • Protect associates by giving them some practical, common sense guidelines to avoid placing themselves in situations where they are open to allegations which could seriously damage their lives and careers.
  • Protect AAD, by showing that we have taken ‘all reasonable steps’ to provide a safe environment.

AAD has taken the following steps:

  1. Adopted a policy statement that defines AAD’s commitment to providing a safe environment for vulnerable adults
  2. Produced a simple code of practice and procedures governing how AAD operates.

This covers the:

  • Safe recruitment of associates who will be in contact with vulnerable adults.
  • Good practice guidelines to ensure the safety and welfare of vulnerable adults at all times whilst at AAD organized events.
  • Handling of concerns, reports or allegations.

Action on Alzheimer’s & Dementia informs new associates of this policy at the point of onboarding and existing associates annually. All AAD associates have access to this policy and supporting procedures through the website and other means. AAD requires those with direct contact with vulnerable persons to be familiar with AAD policy and procedures.

Abuse is defined as actions to deliberately annoy, bother, cause trouble or touch someone without his or her consent. Actions may be considered abusive if they intentionally cause injury or a series of injuries, are neglectful, sexually molest and/or emotionally abuse another person. Abuse falls into four main categories; (a) physical, (b) neglect, (c) emotional or verbal, and (d) sexual.

Safeguarding vulnerable ADULTS Protection Policy Statement

It is the policy of AAD to reasonably safeguard vulnerable adults taking part in AAD events from all forms of harm. AAD will take all reasonable steps to ensure that, through appropriate procedures and training, those participating in AAD activities do so in a safe environment. We recognize that the safety and welfare of the vulnerable adult population is paramount and that all vulnerable adults, irrespective of sex, age, disability, race, religion or belief; sexual identity or social status, have a right to protection from abuse.

Staff and Volunteers

AAD requires criminal background check for AAD associates serving in positions involving training or supervising vulnerable adults or in positions of trust or authority over vulnerable adult’s welfare.

Good Practice GUIDELINES (see also appendix b below)

It is important to develop a culture within AAD where both vulnerable adults and associates feel able to raise concerns, knowing that they will be taken seriously, treated confidentially and will not make the situation worse for themselves or others.

Some vulnerable adults may be more vulnerable to abuse or find it more difficult to express their concerns. For example, a disabled child who relies on a caregiver to help them do things or get around may worry that they won’t be able to attend events any more if they report the caregiver. A vulnerable adult may not be able to express themselves or speak confidentially if they need an interpreter. A vulnerable adult who has experienced racism may find it difficult to trust an associate from a different ethnic background.

AAD will promote good practices to minimize situations where adults are working unobserved or could take advantage of their position of trust. Good practice protects everyone — vulnerable adults and associates. These common sense guidelines are made available to everyone by being posted on our website

This following only covers the essential points of good practice when working with vulnerable adults.

  • Avoid spending any significant time working with the vulnerable person in isolation without the knowledge of the most responsible adult.
  • Do not take vulnerable adults to your home as part of your organization’s activity.
  • Do not accept money or assist in the withdrawal of money from a vulnerable adult’s bank.
  • Allow or engage in inappropriate touching of any form
  • Use inappropriate language with vulnerable adults
  • Make sexually suggestive comments to a vulnerable adult, even in fun
  • Fail to respond to an allegation made by a vulnerable adult
  • It may sometimes be necessary to do things of a personal nature for a vulnerable adult. These tasks should only be carried out with the full understanding and consent of the adult (where possible) and the most responsible adult. In an emergency situation which requires this type of help, care partners should be informed as soon as possible. In such situations it is important to ensure that any adult present is sensitive to the vulnerable adult and undertakes personal care tasks with the utmost discretion and respect.

One should never:

  • Engage in sexually provocative games
  • Allow or engage in inappropriate touching of any form
  • Use inappropriate language when interacting with persons living with dementia
  • Make sexually suggestive comments to a person living with dementia even in fun
  • Fail to respond to an allegation made by a person living with dementia; always act
  • Do things of a personal nature that a person living with dementia can do for themselves.

Anyone who is concerned about an individual living with dementia, either at one of our activities program or at home or a residential home, should inform a member of the AAD Board immediately, in strict confidence. The AAD Board will follow the attached procedures.

Any associate failing to comply with this Safeguarding policy and any relevant Codes of Conduct may be subject to disciplinary action.

Safeguarding Training

AAD will ensure that all associates working with those living with dementia have undertaken training appropriate to their role. This may be through formal training or an online course.

Training will be required on an annual basis for those roles that involve regularly training or supervising persons living with dementia or is a position of trust or authority over the vulnerable adult’s welfare and will address the following:

  • What abuse is and how to spot abuse
  • Reporting requirements and procedures
  • What “duty of care” means and how AAD fulfils that requirement
  • How client confidentiality of vulnerable persons is addressed
Handling Concerns, Reports or Allegations

A complaint, concern or allegation may come from a number of sources: the vulnerable adult, their family or care partner, or someone else within AAD. It may involve the behavior of a volunteer or employee, or something that has happened to the person outside of the charity programs, perhaps at home or at another location. The vulnerable adult may confide in associates they trust, in a place where they feel at ease.

An allegation may range from mild verbal bullying to physical or sexual abuse. If you are concerned that a vulnerable adult may be being abused, it is not your responsibility to investigate further but it is your responsibility to act on your concerns and report them to the appropriate statutory authorities. For guidance on recognizing abuse, see Appendix B.

Handling an allegation from a VULNERABLE ADULT 

People with dementia can be more vulnerable to abuse as they may struggle to discuss their feelings and experiences or remember what happened to them. Dementia can also make it harder to detect abuse


  • Stay calm, ensure that the vulnerable adult is safe and feels safe
  • Show and tell the vulnerable adult you are taking what he/she says seriously
  • Reassure the vulnerable adult and stress that he/she is not to blame
  • Be careful about physical contact, it may not be what the vulnerable adult wants
  • Be honest, explain that you will have to tell someone else to help stop the alleged abuse
  • Make a record of what the vulnerable adult has said as soon as possible after the event, using the vulnerable adult’s own words
  • Follow the vulnerable adult protection procedures laid out in this policy
  • If the person is able to communicate in a meaningful way, follow the general communication principles we advise. Things like:-
  • Minimize other distractions
  • Approach from the front & at the person’s eye level
  • Speak slowly and clearly
  • Maintain eye contact
  • Use short, simple sentences
  • Keep your tone of voice calm and friendly
  • Give the individual plenty of time to respond
  • Avoid asking too many questions
  • Simplify decisions the individual needs to make i.e. ‘Have they been treating you well here?’ ‘Has anyone hurt or upset you?’
  • Use physical contact such as holding the individual’s hand or putting your arm around them to demonstrate affection. Watch the individual’s body language to ensure they are comfortable with this.


  • Rush into actions that may be inappropriate
  • Make promises you cannot keep (e.g. You won’t tell anyone)
  • Take sole responsibility — consult someone else (ideally an AAD director/Compliance officer) so that you can begin to protect the vulnerable adult and gain support for yourself

You may be upset about what the vulnerable adult has said or you may worry about the consequences of your actions. However, one thing is certain you must act and not ignore it.

Recording and Handling Information

If you suspect that a vulnerable adult may have been the subject of any form of physical, emotional or sexual abuse or neglect, refer the allegation to the Registrar of Abuse, Ageing and Disability office at the Ministry of Health and the Police within 24 hours. It is their duty to handle the situation correctly and appropriately within the requirements of the law.

Listen to and keep a record of anything the vulnerable adults tells you or that you have observed and pass the information on to the statutory authorities (included in Supporting Documents).

All information must be treated as confidential and only shared with those who need to know. The protection of the vulnerable person is the most important consideration.

If the allegation or suspicion concerns someone within AAD, only the vulnerable adult’s most responsible adult, another AAD Board member, the relevant authorities should be informed. If the alleged abuse took place outside an AAD event, the Police or Ageing and Disability Services will decide who else needs to be informed, including the vulnerable adult’s most responsible adult. It should not be discussed by anyone within the organization other than the person who received or initiated the allegation and, if different, the AAD Director/Compliance Officer.

Confidential information must be stored securely. It is recommended that it should be retained for at least 7 years and destroyed by secure means.

Co-operation with Authorities

If AAD is contacted by the Police or another stakeholder concerning information received or a complaint made by or about an associate, you are advised to co-operate fully with official requests for factual information, but do not express any personal opinions on the person’s conduct. See also ‘Handling the Media’ below.

Referral to Authorities

If AAD permanently dismisses or removes an associate from involvement with AAD activities, or would have dismissed them if they had not resigned, because they have harmed a vulnerable person or placed them at risk of harm, AAD will refer them to Ageing and Disabilities office at the Ministry of Health, and/or the Bermuda Police Service, and/or other stakeholders as appropriate.

Handling the media

If there is an incident which attracts media interest, or if you are contacted by the media with an allegation concerning an associate, do not respond and contact an AAD Board member immediately.

Reporting Procedures

If you are uncertain what to do at any stage, contact an AAD member.

  1. Ensure that the is safe
  2. If the vulnerable adult requires immediate medical attention call ambulance and inform attendants there is a vulnerable adult protection concern
  3. Make a record of anything the vulnerable adult has said and/or what has been observed, if possible with dates and times
  4. Report your concern by submitting a Referral Form (included in Supporting Documents) as soon as possible to an AAD Board member.
  5. The AAD Board will decide on the appropriate action to be taken
  6. If the alleged is a minor poor practice, determine disciplinary procedure, including possible temporary suspension
  7. If the alleged is serious poor practice or alleged vulnerable adult abuse, contact the Police
  8. The AAD board member will report any vulnerable adult protection issues to the Executive and will securely store a copy of the incident report for a minimum of seven years.
Useful Contacts

Local Resources 911 — if in immediate danger or for the Sexual Assault Response Team

Bermuda Police Service
441-295-0011 or 441-247-1678

Child and Family Services
or 441-294-5882

Centre Against Abuse Men’s Hotline

Women’s Resource Centre
441-295-3882 (main)
441-7273 (hotline)

Ageing and Disabilities Services Ministry of Health
Ja-Mae Smith
441 278 6527

Bermuda Islands Association of the Deaf

Family Centre

Registrar of Abuse
Keeona Belboda

Centre Against Abuse Women’s Hotline

Mid Atlantic Wellness Institute

Safeguarding and Protection Referral Document

Reporting For Vulnerable Persons Document