What Is a PiPoT? Concerns About People in Positions of Trust
A person in a position of trust (PiPoT) is someone who works with adults who have care and support needs, paid or unpaid, about whom a concern has been raised that suggests they may pose a risk to such adults. That can be true even when no particular adult has been harmed, and even when the concern comes from the person’s private life. It is a working label, not a defined legal term, so a PiPoT process is separate from a section 42 safeguarding enquiry and is handled by employers and partners within a local framework.
On this page
- 1What is a person in a position of trust (PiPoT) in adult safeguarding?
- 2Who counts as a person in a position of trust?
- 3Can a PiPoT concern come from outside work?
- 4What kinds of concern trigger a PiPoT process, and what does not?
- 5Who must have a PiPoT procedure?
- 6What is a PiPoT lead, and how is it different from the children’s LADO?
- 7How is a PiPoT process different from a section 42 safeguarding enquiry?
- 8What should an employer do when a PiPoT concern is raised?
- 9When must an employer refer someone to the DBS?
- 10What about the NMC, HCPC and Social Work England?
- 11How should information be shared, and what rights does the worker have?
- 12How should PiPoT decisions be recorded, and what are the possible outcomes?
- 13What is different in Wales and Scotland, and is anything changing nationally?
- 14Which training helps managers and staff understand PiPoT?
- 15Frequently asked questions
- PiPoT is a working term, not a legal definition. The statutory guidance (paragraphs 14.120 to 14.132) expects boards, partners and employers to have clear policies for allegations against people who work with adults.
- Private-life concerns can count. The guidance examples cover a worker who has harmed, or may pose a risk to, an adult or child, not only at work.
- It is not a section 42 enquiry. A PiPoT concern can arise with no identified adult at risk, and the two processes can run together.
- Suspension is not automatic, but DBS referral can be mandatory. A regulated activity provider must refer if it removes, or would have removed, someone for harm or risk of harm.
This guide is for care managers, HR advisers and safeguarding leads dealing with a concern about a colleague. It follows the Care and Support Statutory Guidance for England, with paragraph numbers checked on gov.uk on 29 October 2026, plus notes on Wales and Scotland. For the wider system, see what is safeguarding adults?
What is a person in a position of trust (PiPoT) in adult safeguarding?
The idea comes from chapter 14 (Safeguarding) of the Care and Support Statutory Guidance, issued under the Care Act 2014. A section headed “Allegations against people in positions of trust” runs from paragraph 14.120 to 14.132. Paragraph 14.121 explains why: there are “occasions when incidents are reported that do not involve an adult at risk, but indicate, nevertheless, that a risk may be posed to adults at risk by a person in a position of trust.”
The term is a working label. ADASS (the Association of Directors of Adult Social Services) says in its Top Tips for Directors that it has “no clear, legal definition within the Care Act or any other legislation”. Local frameworks fill the gap: Salford’s framework (version 4.0, June 2025) covers “a person who works with adults with care and support needs in a position of trust, whether an employee, volunteer or student (paid or unpaid)”.
Do not confuse it with criminal law. Sections 16 to 19 of the Sexual Offences Act 2003 create offences of abusing a “position of trust”, defined in section 21 by reference to people who look after persons under 18, such as in care homes and schools. That is a child-focused offence, not the PiPoT idea.
Who counts as a person in a position of trust?
The test is the role, not the job title. Paragraph 14.120 refers to “people who work, in either a paid or unpaid capacity, with adults with care and support needs”, and paragraph 14.122 mentions the “employer (or student body or voluntary organisation)”, so volunteers and students are in scope. Paragraph 14.112 includes “people employed by the adult”, which takes in personal assistants.
The Wales Safeguarding Procedures give the widest list we found, from social care and housing staff to faith leaders, sports coaches, drivers and personal assistants. The English guidance gives no such list, so check your Safeguarding Adults Board’s (SAB) framework. ADASS adds that a “person alleged to have caused harm” in an ordinary safeguarding case may also be a PiPoT.
Can a PiPoT concern come from outside work?
Yes. Paragraph 14.123 gives examples of concerns about a person who works with adults with care and support needs and has:
- “behaved in a way that has harmed, or may have harmed an adult or child”
- “possibly committed a criminal offence against, or related to, an adult or child”
- “behaved towards an adult or child in a way that indicates they may pose a risk of harm to adults with care and support needs”
None requires the conduct to have happened at work, and the first two are not limited to adults. Salford’s framework says it “is not just about concerns in people’s personal life” and that an allegation “can relate to both personal life and in a professional capacity”. The Welsh procedures add a fourth criterion: behaving “in their personal life in a way that may indicate they pose a risk within their identified employment/volunteering”.
Not every private-life concern leads to disclosure. These examples come from local and regulator guidance, not rulings:
| Situation | Source of the concern | What the example concluded |
|---|---|---|
| A care home assistant is herself a victim of long-standing domestic abuse | Children’s Services, because of the couple’s children | Salford: disclosure not proportionate; she was encouraged to tell her employer herself |
| A home carer is alleged to be abusing her own mother | A neighbour’s safeguarding concern, then a section 42 enquiry | Salford: the council told the agency’s manager without her consent after she declined to |
| A social worker is reported to have assaulted their elderly father | An adult safeguarding referral | Social Work England: raise a concern at once, without waiting for the internal investigation |
What kinds of concern trigger a PiPoT process, and what does not?
Paragraph 14.120 says policies “should make a clear distinction between an allegation, a concern about the quality of care or practice or a complaint”. A PiPoT process is for allegations. Salford’s framework “does not cover complaints or concerns raised about the quality of the care or professional practice”, which belong in complaints and competence processes. The Welsh procedures add that a run of low-level concerns “could indicate issues relating to suitability and risk”.
A practical sort: does the information suggest harm, a possible crime or a risk to adults with care and support needs, and is the person in a role that brings them into contact with those adults? If both, escalate; if unsure, ask your safeguarding lead. The school equivalent is covered in our guide to low-level concerns in schools.
Who must have a PiPoT procedure?
The guidance spreads the job across several parties, and the wording matters because it mixes “need to”, “should” and “must”:
| Who | What the guidance says | Paragraph |
|---|---|---|
| Safeguarding adults boards | “need to establish and agree a framework and process” for how allegations “should be notified and responded to” | 14.121 |
| The local authority, its relevant partners and universal care and support providers | “should have clear policies in line with those from the safeguarding adults board” | 14.120 |
| Employers, student bodies and voluntary organisations | “should have clear procedures in place setting out the process, including timescales” | 14.126 |
“Relevant partners” are defined in section 6(7) of the Care Act 2014: district councils, NHS bodies, the chief officer of police, prisons and probation providers, and the minister for social security and employment. Independent care providers are not named, but fall under the “universal care and support services” and employer paragraphs.
This is statutory guidance, mostly phrased as “should”. Salford’s framework states that the Care Act “does not set out any primary legal duties on the local authority associated with managing allegations” against people in positions of trust. The hard legal duties around a case sit elsewhere: employment law, data protection and the barring referral duty below.
What is a PiPoT lead, and how is it different from the children’s LADO?
For children the structure is national. Working Together to Safeguard Children 2026 (paragraph 262 of its guide to multi-agency working) says local authorities should “designate a particular officer, or team of officers” to oversee allegations against people who work with children, “commonly referred to as the Local Authority Designated Officer (LADO)”. Paragraph 264 says that officer “should also be informed within one working day of all allegations that come to an employer’s attention”.
Adult safeguarding has no equivalent statutory post. ADASS says the Designated Adult Safeguarding Manager role “was removed as a requirement from the original Care Act draft guidance following consultation”, with an equivalent role considered best practice. Local arrangements therefore vary:
- Cumbria Safeguarding Adults Board issued an advice note for “Position of Trust Leads” in partner agencies.
- Salford routes referrals to a PiPoT inbox “overseen by a designated manager within the Safeguarding Management Team”.
- In Wales the LADO and a Designated Officer for Safeguarding handle allegations about both children and adults under Section 5 of the Wales Safeguarding Procedures.
The systems connect. Paragraph 14.124 says: “When a person’s conduct towards an adult may impact on their suitability to work with or continue to work with children, this must be referred to the local authority’s designated officer.”
How is a PiPoT process different from a section 42 safeguarding enquiry?
Section 42 of the Care Act applies where a local authority “has reasonable cause to suspect” that an adult has care and support needs, is experiencing or at risk of abuse or neglect, and cannot protect themselves because of those needs. It must then “make (or cause to be made) whatever enquiries it thinks necessary”. A PiPoT process can start with no identified adult at all.
| Section 42 enquiry | PiPoT process | |
|---|---|---|
| Trigger | Reasonable cause to suspect an adult with care and support needs is at risk of abuse or neglect | A concern that a worker may pose a risk to adults, possibly with no identified adult |
| Focus | The adult and what action to take | The worker’s risk to adults they support |
| Together? | Yes. Paragraph 14.128 says allegations “must not be dealt with in isolation”. Salford says a case may run through the police, a section 42 enquiry or the employer’s HR process, depending on the facts. | |
What should an employer do when a PiPoT concern is raised?
Paragraph 14.122 says it “will be necessary for the employer (or student body or voluntary organisation) to assess any potential risk to adults with care and support needs who use their services, and, if necessary, to take action to safeguard those adults”. A sensible sequence is:
- Escalate. Paragraph 14.126 says any allegation “should be reported immediately to a senior manager within the organisation”.
- Protect adults now. Call 999 if someone is in danger, and involve the police early if a crime may have been committed; Salford’s framework says this avoids contaminating evidence.
- Assess and record the risk. The Welsh procedures say this may mean “support or restrictions” or “alternative duties”.
- Treat suspension as a decision, not a reflex. Acas says employers “should not use suspension automatically”. Salford says to take HR advice on suspension or alternative duties.
- Support the worker. Paragraph 14.112 says they “should be made aware of their rights under employment legislation and any internal disciplinary procedures”, and paragraph 14.126 expects employers to have their own sources of advice, including legal advice.
Paragraph 14.119 notes that internal disciplinary procedures and DBS barring decisions normally use the civil standard, “on the balance of probabilities”, so a dropped prosecution does not by itself end the employer’s duties. If the pattern points to a culture rather than one person, read our guide to organisational abuse.
When must an employer refer someone to the DBS?
Paragraph 14.127 says that if an organisation removes a paid worker or volunteer from work with an adult with care and support needs “(or would have, had the person not left first)” because they pose a risk of harm to adults, it “must make a referral to the Disclosure and Barring Service. It is an offence to fail to make a referral without good reason.”
The legal source is section 35 of the Safeguarding Vulnerable Groups Act 2006. A regulated activity provider holding the prescribed information must give it to the DBS if it withdraws permission for the person to engage in the activity (or “would or might have” done so, had they not otherwise ceased) because it thinks, among other grounds, that the person engaged in relevant conduct or that “the harm test is satisfied”. The harm test is that the person “may” harm a vulnerable adult or put one at risk of harm. Section 38 makes failing to provide the information “without reasonable excuse” an offence.
The DBS guidance says the duty applies “even when a referral has also been made to a local authority safeguarding team or professional regulator”, and that the duty “may not be triggered by temporary suspension”. If you let the person return there may be no duty, but dismissal or removal from regulated activity means you “would need to make a referral”. Where the conditions are not met, the DBS says an organisation may still refer in the interests of safeguarding.
What about the NMC, HCPC and Social Work England?
Paragraph 14.118 says employers “should report workers to the statutory and other bodies responsible for professional regulation such as the General Medical Council and the Nursing and Midwifery Council” where appropriate. The three regulators we checked take a similar line: manage it locally where you can, refer quickly if it is serious. A regulator referral does not replace a DBS referral.
- NMC: its Employer Link Service gives advice. “Managing concerns is often best done locally”, it says, but it can help if “a fitness to practise referral is fair and necessary”.
- HCPC: refer immediately if a concern is serious, including where the employee was dismissed or suspended because of your investigation, or resigned during it.
- Social Work England: “In most cases, you should conduct your own internal investigation before making a referral”, but where concerns are “particularly serious” refer immediately so it can consider an interim order.
How should information be shared, and what rights does the worker have?
Paragraph 14.131 sets the standard: “Decisions on sharing information must be justifiable and proportionate, based on the potential or actual harm to adults or children at risk and the rationale for decision-making should always be recorded.” Paragraph 14.132 says information should be shared only “where relevant and necessary, not simply all the information held”, with the people who need it, and “when there is a specific need”.
Paragraph 14.191 still cites the Data Protection Act 1998; current law is the UK GDPR and the Data Protection Act 2018. Schedule 1 of the 2018 Act has a safeguarding condition covering adults with care and support needs, which can relate to “a type of individual” as well as a particular person.
The worker keeps rights. Salford’s framework says the person “is entitled to ask to see any information held about them”, that it is best practice to seek their views and give “the right to reply” unless that increases risk, but that “if an adult with care and support needs is at risk, information can be shared without consent”. The Welsh procedures say the nature of an allegation “should not be withheld from the individual unless there are specific documented reasons”.
How should PiPoT decisions be recorded, and what are the possible outcomes?
Record the reasoning, not only the result. Paragraph 14.131 requires the rationale for information-sharing decisions to be recorded, and paragraph 14.180 says managers should look for “past incidents, concerns, risks and patterns”. Salford also requires “a clear record giving the rationale” where information is not shared, and in Wales a decision not to progress a report must be recorded against the worker.
England’s guidance does not prescribe outcome categories, so results depend on the local framework. Those we read include no further action, more supervision, disciplinary action, dismissal, and DBS or regulator referral. The Welsh procedures decide on the balance of probabilities between substantiated, unsubstantiated, unfounded and malicious, with a separate judgement of ongoing and transferable risk. An unsubstantiated allegation can still leave a real risk.
What is different in Wales and Scotland, and is anything changing nationally?
Wales. Section 5 of the Wales Safeguarding Procedures is shown as last updated in June 2026, and Care Inspectorate Wales announced the revision on 10 July 2026. It covers children and adults in one process, defines a person in a position of trust as someone holding “a role involving authority, influence, power or responsibility”, and says it is “not legislation or statutory guidance” but best practice.
Scotland. We searched the 19 pages of the Scottish Government’s Adult Support and Protection (Scotland) Act 2007 Code of Practice (28 July 2022) for “position of trust” and found nothing, and no section equivalent to the English paragraphs. Barring runs through the Protection of Vulnerable Groups (Scotland) Act 2007, whose section 2 referral ground applies “whether or not in the course of” the person’s role. We have not verified how Scottish partnerships route worker concerns, so ask your local adult protection committee. Northern Ireland is not covered.
National change. A National Adult Safeguarding Board was set up after Baroness Casey’s March 2026 recommendations. Its terms of reference include overseeing an urgent review of adult safeguarding legislation, including “work to update the Care and Support Statutory guidance on safeguarding”. We found nothing saying the PiPoT paragraphs will change, but chapter 14 is in scope, so check gov.uk for updates. Our guide to Safeguarding Adults Reviews covers the review side.
Which training helps managers and staff understand PiPoT?
Nexis CPD courses are CPD-accredited awareness training, not Ofqual-regulated qualifications. They cannot replace your board’s framework, your HR procedures or legal advice on a live case, and we have not seen PiPoT listed as a named topic on these pages, so check each syllabus. Three courses fit most care employers:
Together they cost £18 rather than £27 under the pay-for-2-get-3 offer. If you train 5 or more staff, team places cost £6 a course place, with places lasting 12 months.
Safeguarding Adults (Advanced) Level 2
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Frequently asked questions
What does PiPoT stand for?
PiPoT stands for “person (or people) in a position of trust”. Safeguarding adults boards use it for anyone working with adults with care and support needs, paid or unpaid, about whom a concern suggests a possible risk to those adults.
Is there a law that requires a PiPoT procedure?
Not as such. The Care and Support Statutory Guidance (paragraphs 14.120 to 14.132) says boards need to agree a framework and partners and employers should have clear policies. Separate legislation creates hard duties, such as the barring referral duty in section 35 of the Safeguarding Vulnerable Groups Act 2006.
Can an employer be told about something a worker did in private?
Yes, where it suggests a risk to adults the worker supports. The guidance says sharing must be justifiable and proportionate, limited to what is relevant and necessary, and the reasons recorded. Many private-life concerns will not justify disclosure.
Does an employer have to suspend someone when a PiPoT concern is raised?
No. The employer must assess the risk and act if necessary. Acas says employers should not use suspension automatically, and Salford’s framework says to take HR advice on suspension or alternative duties.
Who do I contact with a PiPoT concern?
Start with your senior manager or safeguarding lead, then follow your Safeguarding Adults Board’s PiPoT framework, which names the route into adult social care. Call 999 if an adult is in immediate danger. Concerns about suitability to work with children go to the local authority designated officer.
Must an employer tell the DBS about a PiPoT concern?
Only when the legal conditions are met. A regulated activity provider must refer if it withdraws permission for the person to work in regulated activity (or would have, had they not left) and thinks they caused harm or meet the harm test. Failing to refer without reasonable excuse is an offence.
Does the worker get to know about the allegation?
Usually, at the earliest safe stage. Salford’s framework says to seek their views and give a right to reply unless that increases risk, and the Welsh procedures say the allegation should not be withheld without documented reasons.
What is the children’s equivalent of a PiPoT process?
It is the allegations process run by the local authority designated officer (LADO). Working Together to Safeguard Children 2026 says the designated officer should be informed within one working day of allegations that come to an employer’s attention.
General information, not legal advice — check your local Safeguarding Adults Board’s PiPoT framework and take HR and legal advice on individual cases. Based on chapter 14 of the Care and Support Statutory Guidance, the Care Act 2014, the Safeguarding Vulnerable Groups Act 2006, DBS and Acas guidance, Working Together 2026, the Wales Safeguarding Procedures, the Scottish Code of Practice and the NMC, HCPC and Social Work England employer guidance, as checked on 29 October 2026. Nexis CPD courses are CPD-accredited awareness training: they are not Ofqual-regulated qualifications and do not replace your own safeguarding procedures, your Safeguarding Adults Board’s framework or legal advice.