Safeguarding concerns relating to the High Intensity Network (HIN) and Serenity Integrated Mentoring (SIM)

Please note: this statement comes with a trigger warning for discussion of sexual abuse, emotional abuse, police violence and abuse from mental health services

Serenity Integrated Mentoring (SIM) and interventions associated with the High Intensity Network (HIN) have been rolled out at pace and scale across NHS England. As we outlined in our preliminary coalition consensus statement, dated 21/04/21, SIM’s key intervention components include a co-ordinated withholding of potentially lifesaving treatment by multiple agencies (A&E, mental health, ambulance and police services)[1], and using SIM’s own words, the “coercive”[2] approach of a police officer as an interventionist. As of 2nd June 2021 The High Intensity Network appears to no longer be operating,[3] however we remain concerned about the continued operation of these teams in NHS services across England. Additionally, action has not been taken centrally to prevent services being provided broadly based on this model.

Safeguarding refers to protecting the health, wellbeing and human rights of a citizen to enable them to live safely and free from harm, abuse and neglect[4]. Upholding safeguarding of children, young people and adults is a collective responsibility and is integral to high-quality, safe and effective healthcare provision[5]. This statement outlines our concerns in relation to our understanding that the SIM model may be operating in contradiction to the fundamental principles of safeguarding; posing a risk to vulnerable adults; and may constitute institutional abuse. 

Safeguarding legislation 

The fundamental aim of safeguarding is to promote wellbeing; prevent abuse and neglect from occurring in the first place; and to take action if abuse and neglect has occurred[6]. NHS England safeguarding policies[7] assert it is a fundamental responsibility of every NHS-funded organisation as well as each individual healthcare professional to “ensure that the principles and duties of safeguarding children and adults are holistically, consistently and conscientiously applied; the well-being of those children and adults is at the heart of what we do”[8]. Additionally, safeguarding is a “collective responsibility. All employees are reminded of their professional duty of care as a registrant regardless of which NHS contract is used to deploy the functions they work to”[9]. Each healthcare interaction should be considered an opportunity to uphold safeguarding principles and duties to make every contact count towards protecting all patients[10].

Safeguarding policies within SIM Teams 

Information regarding SIM safeguarding policies appears to be absent from any HIN/SIM publications. The SIM Operational Delivery Guide[11] and SIM Master Task List[12], which both outline the processes and planning involved in setting up the SIM service, fail to mention safeguarding policies or the responsibilities of line managers to oversee assurance of compliance with safeguarding legislation[13]. It is unclear what – if any – safeguarding training SIM staff receive. We are concerned that the lack of robust safeguarding policies puts patients at risk of potential harm, firstly, from the service itself and secondly through potential failure to prevent or identify abuse patients may be experiencing from other individuals or agencies. In addition to this, we have safeguarding concerns about the HIN/SIM service and believe the treatment of patients under the service may constitute institutional abuse. 

Institutional abuse 

The Care Act (2014)[14] addresses institutional (or organisational) abuse as one of ten key types of abuse. In the Care and Support Statutory Guidance document, this is defined as: 

Including neglect and poor care practice within an institution or specific care setting such as a hospital or care home, for example, or in relation to care provided in one’s own home. This may range from one off incidents to on-going ill-treatment. It can be through neglect or poor professional practice as a result of the structure, policies, processes and practices within an organisation.”[15]

Additional examples of institutional abuse include authoritarian management; abusive and disrespectful attitudes towards people using the service; and lack of respect for privacy and dignity[16]. This guidance also refers to neglect and acts of omission including: ignoring medical emotional or physical needs and a failure to ensure access to appropriate care and support[17].

As discussed in our previous statements, we consider SIM teams to be operating in a manner which potentially breaches human rights and equality laws; potentially breaches privacy and data protection legislation; as well as being implemented without a sufficient evidence base. In view of this, we consider the way SIM is designed and operates as an intervention to be an example of institutional abuse. This demonstrates a lack of respect for the privacy of individuals as well as respect for their right to life and the NHS constitution[18] mandated responsibility to provide care. These occurrences are not one-off incidents of poor treatment rather are core components of the SIM model, suggesting institutional abuse. Additional potentially abusive practices within SIM teams will be discussed in further details through this statement. 

Neglect and Acts of Omission 

A key SIM intervention component includes a “Response Plan” which coordinates the treatment given to an individual across multiple-agencies[19]. As discussed in our statement related to Human Rights concerns and the SIM model we have grave concerns that this may constitute a breach of Human Rights law in explicitly advocating withholding, or deterring people from using, services which might be life-saving. The Business Case for Commissioning SIM across NHS Trusts in England[20] states the following in relation to the impact a SIM Response Plan is expected to have on health care professionals:

Specifically, they can give doctors and nurses the confidence NOT to treat or respond in ways in which they would have felt compelled to before, such as:

  • Not requesting scans/x-rays/MRIs/blood tests
  • Not keeping the individual in the ED for observation
  • Not pursuing the individual if they decide to discharge themselves
  • Not requesting the police to find the individual or conduct a welfare check at home”[21].

We understand advocating for the withholding of treatments may constitute wilful neglect through intentionally ignoring physical needs and failure to provide medical care[22]. 

Wilful neglect refers to “a serious departure from the required standards of treatment and usually means a person has deliberately or recklessly failed to carry out an act that they were aware they were under a duty to perform”[23]. The Criminal Justice and Courts Act (2015), created two offences in relation to ill-treatment and wilful neglect[24]. This enshrines into law the obligation of both workers and organisations providing health and social care to prevent ill-treatment and wilful neglect. Guidance provided by The Crown Prosecution Service outlines ‘wilful neglect’ refers to an intentional act. 

The primary meaning of wilful is “deliberate”. Therefore, for example, someone who knows that the person in their care needs medical assistance and deliberately, that is by conscious decision, refrains from calling a doctor would be guilty of wilful neglect. Equally, a person who fails to provide medical care because he [sic] does not care whether it is needed or not is reckless and is also guilty.”[25]

Section 21 of the Criminal Justice Act (2015) refers to offences committed by care providers[26]. The scope of this includes a “breach of duty” which refers to instances where “the care provider’s activities are managed or organised in a way which amounts to a gross breach of a relevant duty of care owed by the care provider to the individual who is ill-treated or neglected”.[27] Therefore if an organisation routinely fails to address the fundamental needs and uphold the rights of those under their care, they could be liable for prosecution. Section 21(5) of the Act stipulates that liability cannot be evaded where the victim of ill-treatment or neglect has allegedly committed an offence[28]. 

It is our view that, in advocating withholding treatment or investigations such as X-rays and blood tests, SIM teams appear to be operating in a manner which breaches the duties they owe to those under their care and failing to meet their emotional, psychological and physical needs. We are concerned this may constitute wilful neglect at both an individual and organisational level. This further evidences our concerns that the ways in which the SIM model operates is institutional abuse and may constitute a criminal act in acts of wilful neglect. 

Psychological or emotional abuse 

Psychological or emotional abuse refers to a pattern of emotional maltreatment which has a significant impact on the individual[29]. The Care Act (2014)[30] and NHS outlines examples of this abuse including, intimidation, controlling behaviours and “an unreasonable and unjustified withdrawal of services or support networks”[31]. SIM documentation refers to using the “coercive” approach of a police officer[32], suggesting the officer is encouraged to behave in a way which could include intimidation and threats. The SIM pilot report includes a case study explaining where therapeutic support was removed from an individual in order to ensure she participated in the SIM programme.

Janet was encouraged to participate but reminded of the expectations that she needed to comply with the directions of the clinical staff. Janet refused to participate so the decision was made by the NHS (supported by PS Jennings) to postpone all therapeutic programmes. Janet was informed that all therapy had stopped and was invited to take some time out to reflect on what she needed to do. She was temporarily discharged from service to reinforce this message and boundaries.“[33]

The decision to remove therapeutic support from this individual appears to have been based, not on a lack of clinical need but as a way of ensuring she engaged with SIM. This action is using punishment to influence behaviour in a way which appears coercive; the use of sanctions and the withdrawal of things which hold meaning to the person in order to elicit the desired response appears emotionally manipulative. 

Furthermore, an example used in the SIM pilot report refers to a transgender man under the SIM program who was told he wouldn’t receive a referral to specialist services from his GP until he was behaviourally stable[34]. This contradicts guidance[35] and suggests the referral was withheld unnecessarily and used as an incentive or reward. Given the psychological impact of transphobia and gender dysphoria, using a referral for specialist treatment could be viewed as emotionally abusive. By positioning something which holds such significance for the individual – both practically and emotionally – as an incentive, the individual is placed in a vulnerable position. 

In each of these examples behaviour change was created through removing medical treatment from the patient under the promise that if they change their behaviour they will be able to have this again. This is highly concerning and poses a risk of harm occurring to the patient both physically due to the removal of healthcare and emotionally in response to actions which may constitute psychological abuse. Access to healthcare is a fundamental right and it is our grave concern that SIM teams are inappropriately issuing and withdrawing healthcare as sanctions demonstrating a lack of respect and dignity.

In addition, the SIM model takes no account of distressing associations for some individuals with the exercise of pressure by police (arising for instance from previous experiences of compulsory detention or stop and search). We understand the SIM model would have disproportionate impact on individuals from minority groups due to previous experiences arising from a wider culture of discriminatory practices within the police force[36]. 

Complaints policies and procedures

Another key indicator of potential organisational abuse is a lack of robust complaints policies[37] as this prevents people using the service from speaking out if they were at risk. There is substantial evidence that SIM suggests and implements concerning policies regarding complaints. Namely, complaints from service users are not prioritised appropriately and the documentation instead attempts to remove credence from service user complaints, in one instance labelling these complaints as “malicious”[38]. For example, in the SIM Business Case, a section entitled “Legal and Reputational Risk Reduction” states that police officers can utilise their authority to suppress complaints against clinicians: 

SIM teams can also ensure that clinicians are better protected from legal threats and complaints with some volatile and litigious clients because the police officer can in many instances regulate the service user and simultaneously protect their clinical colleague by openly supporting and reinforcing their decision making.” [39]

The typing of service users as “volatile” and “litigious” suggests there is significant bias against complaints. This appears to equate “complaints” with “threats”, which demonstrates a concerning lack of understanding of what a complaint is, and also seems to be expressed exclusively from the point of view of the SIM officer, who may feel threatened, rather than the complainant. The police officer’s power to “reinforce” the decisions that led to these complaints, elsewhere referred to as “coercive”[40], appears to suggest that SIM police officers can and should suppress complaints when they are made and discourage them from being made at all. 

Other SIM documentation consistently fails to acknowledge the possibility of professional wrongdoing in instances where a complaint is made:

Making complaints against staff can often be a way in which service users (at times of stress) attempt to avoid consequences or responsibility. They can also be used in an attempt to distance themselves from the staff who are supervising them so that they do not have to continue with the programme.”[41]

The presumed reasons for complaints are entirely attributed to the service user and never to the possibility of behaviour from professionals. Regardless of incidences of ‘false accusations’, not taking complaints seriously is in breach of fundamental safeguarding legislation and risks harm to service users persisting and escalating. Additionally, this puts service users in a position of heightened vulnerability to abuse where it could be understood by staff that there is significant scope for reports of abuse to be dismissed as false accusations; organisational policies such as these could have the effect of increasing abuse of service users through ‘reassuring’ staff it will not be taken seriously. 

Service users at risk of abuse 

In addition to the statutory duty to protect individuals from potential abuse from within the service, safeguarding legislation is concerned with preventing, identifying and responding to abuse from members of the public or other agencies[42]. The complaints policies, as outlined in HIN/SIM literature, suggest reports of abuse from outside of SIM teams are encouraged not to be taken seriously. In the SIM Project Pilot Report, one of the behaviours listed as “pos[ing] a serious risk to members of the public”[43] is “Making accusations of rape or serious sexual assault, (later to discovered to be false).”[44] This point has an addendum which says, “*This does not mean that all allegations are false. Every allegation when made to Hampshire Constabulary is true until evidence shows otherwise.”[45] However, this appears to contradict the point it amends, as observing and documenting a pattern of allegations ‘discovered to be false’ in a certain group would appear to introduce bias into the handling of complaints of this nature received therein. 

There is evidence to suggest that those categorised as “high intensity users” are at increased risk of abusive relationships and sexual violence. In a presentation about how SIM began, a list of “typical” high intensity users includes “History of sexual abuse or violence”,[46] and the SIM Pilot Report states that all 8 service users included in the pilot “had a documented history of abuse, neglect, domestic violence or abandonment”.[47] Additionally, the SIM pilot report also states 80% of “high intensity users” had reported an incident to the police and 70% had been a victim of crime[48], indicating these individuals are at high risk of abuse. Therefore, the lack of attention regarding the allegations of rape demonstrated in this extract is especially concerning.

 A programme which explicitly discourages people from calling emergency services has the potential for putting vulnerable people at risk of severe and catastrophic harm. For example, people under SIM-type programmes may be frightened to contact services if they or someone else is at risk; they may worry about potential repercussions[49] and not contact emergency services if experiencing abuse. Furthermore, this will have a disproportionate impact on minority groups including trans, Black, Asian and Minority Ethnic individuals who are already more afraid of reporting crime due to previous negative experiences with the police[50].It is our view that this presents a major safeguarding concern and could enable abuse to continue. 

To conclude, we have safeguarding concerns related to the way SIM teams are designed and operate which in our opinion open the door to institutional abuse due to potential human rights abuses, neglect, emotional abuse, lack of sufficient complaints procedure and lack of respect for privacy. Additionally we are concerned SIM services do not comply with their statutory duties to appropriately safeguard the vulnerable adults under their care. Given the patients SIM targets are likely to have experienced significant trauma and potentially be at increased risk of abuse, it is highly concerning these services do not appear to have any robust safeguarding policies to protect individuals from abuse and neglect either from the service itself or other agencies. 

In this context we ask: 

  • How do the NHS and other statutory partners which adopt SIM-type schemes reconcile its key elements with basic safeguarding principles?
  • What safeguarding policies do individual SIM teams have in place in the apparent absence of anything centrally developed or advised by the HIgh Intensity Network?
  • What additional training do SIM staff receive in relation to safeguarding vulnerable adults and children?
  • What external oversight has been conducted to ensure SIM teams or those operating under alternative names are operating safely and in line with professional guidance, and within the law?
  • What actions and measures are in place to ensure SIM teams are complying with safeguarding legislation, and to prevent development of a closed culture or occurrence of institutional abuse? 
  • What information has been given to safeguarding leads in local NHS trusts where  SIM and SIM-like models are operational? 

We will continue to provide further statements expressing our safeguarding concerns in relation to SIM-like models. This is a preliminary document and we continue to analyse and collate information relating to SIM and HIN. 

In solidarity,

The #StopSim Coalition

Copied to:
Sir Simon Stevens, CEO – NHS England, Lord David Prior, Chair – NHS England, Claire Murdoch, National Mental Health Director – NHS England, Martin Hewitt, Chair – National Police Chiefs’ Council, Sir Tom Winsor, Her Majesty’s Inspectorate of Constabulary and Fire and Rescue Service.

1 -SIM and High Intensity Network Business Case [Internet], p. 7. Available from https://highintensitynetwork.org/img/resources/SIM_and_High_Intensity_Network_-_Business_Case_(Commissioner)_v4.docx [archived from website deleted 28 May 2021; last accessed 11 May 2021]. 

2 -Paul Jennings. What is SIM and the High Intensity Network? [Internet]. 2019 Mar 26; Daresbury Park Hotel. Slide 30 of 65. Available from: https://www.slideshare.net/InnovationNWC/paul-jennings-high-intensity-network-sim [accessed 15 June 2021].

3 -John Pring. ‘Police emails show dodgy data was used to sell ‘unsafe’ mental distress scheme to NHS’. Disability News Service [Internet]. 3 June 2021. Available from: https://www.disabilitynewsservice.com/police-emails-show-dodgy-data-was-used-to-sell-unsafe-mental-distress-scheme-to-nhs/ [accessed 16 June 2021].

4 -About NHS England Safeguarding. NHS England [Internet]. Available from: https://www.england.nhs.uk/safeguarding/about/ [accessed 15 June 2021].

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7 -Safeguarding Children, Young People and Adults at Risk in the NHS: Safeguarding Accountability and Assurance Framework [Internet]. Available from: https://www.england.nhs.uk/wp-content/uploads/2015/07/safeguarding-children-young-people-adults-at-risk-saaf-1.pdf [accessed 15 June 2021].

8 -Safeguarding Children, Young People and Adults at Risk in the NHS: Safeguarding Accountability and Assurance Framework [Internet]. Section 3.1, p. 8.  Available from: https://www.england.nhs.uk/wp-content/uploads/2015/07/safeguarding-children-young-people-adults-at-risk-saaf-1.pdf [accessed 15 June 2021].

9 -Safeguarding Children, Young People and Adults at Risk in the NHS: Safeguarding Accountability and Assurance Framework. NHS England and NHS Improvement [Internet]. 2013, updated 2019. Section 4, p. 11.  Available from: https://www.england.nhs.uk/wp-content/uploads/2015/07/safeguarding-children-young-people-adults-at-risk-saaf-1.pdf [accessed 15 June 2021].

10 -About NHS England Safeguarding. NHS England [Internet]. Available from: https://www.england.nhs.uk/safeguarding/about/ [accessed 15 June 2021].

11 -South London and Maudsley NHS Foundation Trust, High Intensity Network. SLaM Operational Delivery Guide [Internet]. 2018. Available from: https://healthinnovationnetwork.com/wp-content/uploads/2018/06/SIM-Operational-Delivery-Guide.docx [accessed 15 June 2021]

12 -High Intensity Network Task List. Available from:  https://highintensitynetwork.org/img/resources/MASTER_TASK_LIST_Step_1-Step_4.docx [archived from website deleted 28 May 2021; last accessed 11 May 2021]. 

13 -Safeguarding Policy. NHS England and NHS Improvement [Internet]. 2014, updated 2019. Section 7, Roles and Responsibilities, p. 11. Available from: https://www.england.nhs.uk/wp-content/uploads/2019/09/safeguarding-policy.pdf [accessed 15 June 2021]. 

14 -Care Act 2014. UK Public General Acts. 2014 c.23. Available from: https://www.legislation.gov.uk/ukpga/2014/23/enacted [accessed 15 June 2021]. 

15 -Using the Care Act guidance. Care and Support Statutory Guidance. Department of Health & Social Care [Internet]. 2021. Organisational abuse. Available from: https://www.gov.uk/government/publications/care-act-statutory-guidance/care-and-support-statutory-guidance [accessed 15 June 2021]. 

16 -Types and indicators of abuse. Safeguarding adults. Social Care Institute for Excellence [Internet]. 2015, reviewed 2020. Types of organisational or institutional abuse. Available from: https://www.scie.org.uk/safeguarding/adults/introduction/types-and-indicators-of-abuse/ [accessed 15 June 2021]. 

17 – Using the Care Act guidance. Care and Support Statutory Guidance. Department of Health & Social Care [Internet]. 2021. Organisational abuse. Available from: https://www.gov.uk/government/publications/care-act-statutory-guidance/care-and-support-statutory-guidance [accessed 15 June 2021]. 

18 -The NHS Constitution for England. Department of Health & Social Care [Internet]. 2021. Available from: https://www.gov.uk/government/publications/the-nhs-constitution-for-england/the-nhs-constitution-for-england [accessed 15 June 2021].

19 -SIM London: South London & Maudsley NHS Foundation Trust Operational Delivery Guide [Internet]. 2018. Section 26, ‘Response Plans’. Available from: https://healthinnovationnetwork.com/wp-content/uploads/2018/06/SIM-Operational-Delivery-Guide.docx [accessed 15 June 2021].

20 -SIM and High Intensity Network Business Case [Internet], p. 7. Available from: https://highintensitynetwork.org/img/resources/SIM_and_High_Intensity_Network_-_Business_Case_(Commissioner)_v4.docx [archived from website deleted 28 May 2021; last accessed 11 May 2021].

21 -SIM and High Intensity Network Business Case [Internet], p. 7. Available from: https://highintensitynetwork.org/img/resources/SIM_and_High_Intensity_Network_-_Business_Case_(Commissioner)_v4.docx [archived from website deleted 28 May 2021; last accessed 11 May 2021].

22 -Types and indicators of abuse. Safeguarding adults. Social Care Institute for Excellence [Internet]. 2015, reviewed 2020. Types of organisational or institutional abuse. Available from: https://www.scie.org.uk/safeguarding/adults/introduction/types-and-indicators-of-abuse/ [accessed 15 June 2021]. 

23 -Protecting adults at risk in London: Good practice resource. Social Care Institute for Excellence [Internet]. 2012. Available from: https://www.scie.org.uk/publications/adultsafeguardinglondon/investigatingadultabuse/neglect.asp [accessed 15 June 2021].

24 -Ill-treatment or wilful neglect offences – Sections 20 to 25 of the Criminal Justice and Courts Act 2015. Crown Prosecution Service [Internet]. 2017. Available from: 

https://www.cps.gov.uk/legal-guidance/ill-treatment-or-wilful-neglect-offences-sections-20-25-criminal-justice-and-courts [accessed 15 June 2021].

25 -Ill-treatment or wilful neglect offences – Sections 20 to 25 of the Criminal Justice and Courts Act 2015. Crown Prosecution Service [Internet]. 2017. Available from: 

https://www.cps.gov.uk/legal-guidance/ill-treatment-or-wilful-neglect-offences-sections-20-25-criminal-justice-and-courts [accessed 15 June 2021].

26 -Ill-treatment or wilful neglect offences – Sections 20 to 25 of the Criminal Justice and Courts Act 2015. Crown Prosecution Service [Internet]. 2017. Available from: 

https://www.cps.gov.uk/legal-guidance/ill-treatment-or-wilful-neglect-offences-sections-20-25-criminal-justice-and-courts [accessed 15 June 2021].

27 – Ill-treatment or wilful neglect offences – Sections 20 to 25 of the Criminal Justice and Courts Act 2015. Crown Prosecution Service [Internet]. 2017. Available from: 

https://www.cps.gov.uk/legal-guidance/ill-treatment-or-wilful-neglect-offences-sections-20-25-criminal-justice-and-courts [accessed 15 June 2021].

28 – Ill-treatment or wilful neglect offences – Sections 20 to 25 of the Criminal Justice and Courts Act 2015. Crown Prosecution Service [Internet]. 2017. Available from: 

https://www.cps.gov.uk/legal-guidance/ill-treatment-or-wilful-neglect-offences-sections-20-25-criminal-justice-and-courts [accessed 15 June 2021].

29 -Types and indicators of abuse. Safeguarding adults. Social Care Institute for Excellence [Internet]. 2015, reviewed 2020. Available from: https://www.scie.org.uk/safeguarding/adults/introduction/types-and-indicators-of-abuse/ [accessed 15 June 2021]. 

30 -Care Act 2014. UK Public General Acts. 2014 c.23. Available from: https://www.legislation.gov.uk/ukpga/2014/23/enacted [accessed 15 June 2021].  

31 -Abuse and neglect of vulnerable adults. NHS [Internet]. Available from: https://www.nhs.uk/conditions/social-care-and-support-guide/help-from-social-services-and-charities/abuse-and-neglect-vulnerable-adults/ [accessed 15 June 2021]. 

32 -Paul Jennings. What is SIM and the High Intensity Network? [Internet]. 2019 Mar 26; Daresbury Park Hotel. Slide 30 of 65. Available from: https://www.slideshare.net/InnovationNWC/paul-jennings-high-intensity-network-sim [accessed 15 June 2021].

33 -Paul Jennings. SIM Project Pilot Report 2013-2015 [Internet]. p. 44. Available from: https://highintensitynetwork.org/img/resources/SIM_Pilot_Report_2013.doc [archived from website deleted 28 May 2021; last accessed 11 May 2021]. 

34 -Paul Jennings. SIM Project Pilot Report 2013-2015 [Internet]. p. 47. Available from: https://highintensitynetwork.org/img/resources/SIM_Pilot_Report_2013.doc [archived from website deleted 28 May 2021; last accessed 11 May 2021].

35 -Gender dysphoria services: a guide for General Practitioners and other healthcare staff. NHS England & Department of Health [Internet]. p. 4.  Available from: https://www.nhs.uk/Livewell/Transhealth/Documents/gender-dysphoria-guide-for-gps-and-other-health-care-staff.pdf [accessed 15 June 2021]. 

36 -Discriminatory policing in the UK: How Coronavirus made existing inequalities even worse. Liberty [Internet]. 2020. Available from: https://www.libertyhumanrights.org.uk/issue/discriminatory-policing-in-the-uk-how-coronavirus-made-existing-inequalities-even-worse/ [accessed 15 June 2020]. 

37 -Identifying and responding to closed cultures: Guidance for CQC staff. Care Quality Commission [Internet]. p. 9. Available from: https://www.cqc.org.uk/sites/default/files/20200623_closedcultures_guidance.pdf [accessed 15 June 2021]. 

38 -Paul Jennings. SIM Project Pilot Report 2013-2015 [Internet]. p. 64. Available from: https://highintensitynetwork.org/img/resources/SIM_Pilot_Report_2013.doc [archived from website deleted 28 May 2021; last accessed 11 May 2021].

39 -SIM and High Intensity Network Business Case [Internet], p. 16. Available from: https://highintensitynetwork.org/img/resources/SIM_and_High_Intensity_Network_-_Business_Case_(Commissioner)_v4.docx [archived from website deleted 28 May 2021; last accessed 11 May 2021].

40 -Paul Jennings. What is SIM and the High Intensity Network? [Internet]. 2019 Mar 26; Daresbury Park Hotel. Slide 30 of 65. Available from: https://www.slideshare.net/InnovationNWC/paul-jennings-high-intensity-network-sim [accessed 15 June 2021].

41 -SIM London: South London and  & Maudsley NHS Foundation Trust Operational Delivery Guide [Internet]. 2018. Section 40, ‘Informing Risk Managers and Professional Standards Teams’, p. 21. Available from:https://healthinnovationnetwork.com/wp-content/uploads/2018/06/SIM-Operational-Delivery-Guide.docx [accessed 15 June 2021].

42 -Safeguarding Children, Young People and Adults at Risk in the NHS: Safeguarding Accountability and Assurance Framework [Internet]. Available from: https://www.england.nhs.uk/wp-content/uploads/2015/07/safeguarding-children-young-people-adults-at-risk-saaf-1.pdf [accessed 15 June 2021].

43 -Paul Jennings. SIM Project Pilot Report 2013-2015 [Internet]. p. 20. Available from: https://highintensitynetwork.org/img/resources/SIM_Pilot_Report_2013.doc [archived from website deleted 28 May 2021; last accessed 11 May 2021].

44 -Paul Jennings. SIM Project Pilot Report 2013-2015 [Internet]. p. 21. Available from: https://highintensitynetwork.org/img/resources/SIM_Pilot_Report_2013.doc [archived from website deleted 28 May 2021; last accessed 11 May 2021].

45 -Paul Jennings. SIM Project Pilot Report 2013-2015 [Internet]. p. 21. Available from: https://highintensitynetwork.org/img/resources/SIM_Pilot_Report_2013.doc [archived from website deleted 28 May 2021; last accessed 11 May 2021]..

46 -Paul Jennings. SIM: How It All Started. Isle of Wight NHS Trust and Hampshire Constabulary [Internet]. 2015. Slide 7 of 24. Available from: https://www.iow.gov.uk/azservices/documents/2880-04-PJ-PB-SIM-MENTORING.pdf [accessed 15 June 2021].

47 -Paul Jennings. SIM Project Pilot Report 2013-2015 [Internet]. p. 19. Available from: https://highintensitynetwork.org/img/resources/SIM_Pilot_Report_2013.doc [archived from website deleted 28 May 2021; last accessed 11 May 2021].

48 -Paul Jennings. SIM Project Pilot Report 2013-2015 [Internet]. p. 24. Available from: https://highintensitynetwork.org/img/resources/SIM_Pilot_Report_2013.doc [archived from website deleted 28 May 2021; last accessed 11 May 2021]. 

49 -See SIM and High Intensity Network Business Case [Internet], p. 7. Available from https://highintensitynetwork.org/img/resources/SIM_and_High_Intensity_Network_-_Business_Case_(Commissioner)_v4.docx [archived from website deleted 28 May 2021; last accessed 11 May 2021]; see also Paul Jennings. SIM Project Pilot Report 2013-2015 [Internet]. pp. 38, 78. Available from: https://highintensitynetwork.org/img/resources/SIM_Pilot_Report_2013.doc [archived from website deleted 28 May 2021; last accessed 11 May 2021]; see also Paul Jennings. What is SIM and the High Intensity Network? [Internet]. 2019 Mar 26; Daresbury Park Hotel. Slide 30 of 65. Available from: https://www.slideshare.net/InnovationNWC/paul-jennings-high-intensity-network-sim [accessed 15 June 2021].

50 -Discriminatory policing in the UK: How Coronavirus made existing inequalities even worse. Liberty [Internet]. 2020. Available from: https://www.libertyhumanrights.org.uk/issue/discriminatory-policing-in-the-uk-how-coronavirus-made-existing-inequalities-even-worse/ [accessed 15 June 2020].