Safeguarding Policy

Safeguarding Policy

Introduction

The National College of Hypnosis and Psychotherapy and the National Society of Talking Therapies aim to create and maintain a safe environment where everyone we encounter will be valued and taken seriously.

For this policy, safeguarding encompasses:

• Preventing harm and abuse by demonstrating high standards of professional care. 
• Responding effectively to allegations of harm and abuse. 
• Working closely with other relevant agencies and their procedures. 
• Safe and responsible lone working. 
• Using learning to improve care for clients. 

Therapists contribute significantly to clients’ well-being, and safeguarding plays a vital role in defining that contribution. Therefore, appropriate confidentiality, boundaries around the therapeutic relationship, and mutual respect for skills and roles are essential elements of the therapeutic work. 

Who is this policy for?

This policy applies to all Members of the NCHP/NSTT who may be working in any private clinical practice where they may encounter adults and children who appear to be at risk. 

NCHP/NSTT supports trainees and members to work with other agencies in safeguarding. Trainees of the NCHP are taught explicitly throughout their training about safeguarding concerning their clinical practice in the following aspects of their core training:

• Ethical practice training.

• Equalities, diversities, and inclusion training.

• Psychopathology training.

• There is also specific safeguarding training for those intending to register with UKCP.

NCHP/NSTT works to make students, trainees, and members aware of the importance of their responsibilities to safeguard themselves in public and private practices. 

Safeguarding in Training:

The UKCP Standards of Education and Training say:

• Training courses shall have mechanisms for safeguarding the rights of students and trainees. This should include readily available consultation procedures, complaints and grievance procedures.
• Training organisations should be able to provide evidence that they have obtained informed consent from students and trainees who participate as patients or clients in practical and clinical teaching. This also applies to relevant experiential or group work incorporated into the training. 

 

To comply with these requirements and to minimise risk, we have the following procedures in place:

• NCHP interviews all applicants to ascertain their readiness for training.
• All those accepted onto our training complete a confidentiality and consent form to participate in practical training and are to let us know if there are any changes in circumstances.
• People volunteering and working with NCHP/NSTT are expected to provide their CVs and be screened through interviews and references. They are made aware of the Codes of Ethics and Practice and how to respond to safeguarding needs.
• Trainees and staff discuss and agree to group boundaries at the beginning of training.
• All students/trainees are made aware of our director of student experience (our safeguarding lead) and are encouraged to contact them should any issues arise.
• All NCHP/NSTT Members can contact the nominated safeguarding person within NCHP, Carlie Fairbrother, if they have concerns about another trainee, volunteer, team member or person within the NCHP or NSTT.
• NCHP/NSTT will update registered members on any legal changes relating to safeguarding as and when necessary. 

 

What is expected of trainees/members?

• All trainees/members are expected to demonstrate that they are aware of the relevant statutory framework, which sets out safeguarding principles for their client group(s) – and be confident that they can act following these principles.
• NCHP/NSTT requires trainees/members working in independently governed settings to take responsibility for finding out and working to the safeguarding principles and policies of the organisation. 
• Supervisors are responsible for ensuring that their knowledge is up-to-date and based on the relevant standards and statutory frameworks on all matters relating to safeguarding. 
• Clients and public members should be confident that NCHP/NSTT and its students, trainees, members, and team members meet the appropriate professional standards and will always endeavour to provide a safe, knowledgeable and accountable service. 

NCHP/NSTT recognises that safeguarding decision-making can be complex, and regular supervisory support is essential. Therefore, NCHP/NSTT adopted the guidelines of UKCP as a process to follow in safeguarding decision-making, and this is adapted below:

The seven principles of ethical practice (avoiding harm, benevolence, candour, competence, honesty, human rights and social justice and personal accountability) help frame responses to the ‘five steps’ approach below. It is recognised that each case will be unique, and the learning process will be continuous. 

1 – Be aware

Abuse may be:

• Physical.
• Psychological.
• Sexual.
• Financial.
• Material.
• Discriminatory.
• Involve neglect.

If working directly with a child or vulnerable adult, you may hear or see signs that reasonably indicate preliminary evidence that they or another person has suffered, is suffering or is likely to suffer actual abuse.

You may hear or see signs that reasonably indicate preliminary evidence that the client has inflicted, is inflicting or is likely to inflict actual abuse on a child or vulnerable adult. This is possible whether the client is an adult or a child. 

You may also become aware of possible abuse via other means, for example, in an enquiry email from a potential client. 

You have a responsibility to protect children, vulnerable adults, your client and yourself, but also consider: 

• Proportionality: What is the weight of the evidence pertaining to the signs? In the case of an adult client reporting historical abuse where there is no evidence or indication of present abuse, good practice would be that they should be facilitated to consider whether to report the matter or not rather than you deciding to report;
• There could also be circumstances when an adult client may disclose information about a present-day relationship that you may consider includes harmful or abusive elements. 

Remember, adults with capacity can make choices; sometimes, choices that you may consider harmful. 

Questions you could consider asking in this situation are: 

• How harmful? 
• Is it significant harm? 
• What might be the reasons a client would not want to report? 
• What might happen if you report it and the client denies it? 

As a therapist, you may consider that:

• There is a rationale not to report when the abusive behaviour is not significant but to work with the client so they are no longer in a harmful relationship. 
• An adult’s description of childhood events could be considered abusive in the current legislative context but would not have been at the time when the client was a child.
• Therapy can evoke a changing and complex kaleidoscope of ‘memories’, feelings and perceptions, which are multi-layered. 
• Experiences described may be actual, perceived, fantasy or exploration, a wondering or a ‘What if?’. 

Be aware that accounts offered by clients will need to be assessed against this landscape: 

• The effect of allegations on all involved (not just the client). 
• Your responsibility compared to that of others. 
• The implications where alleged abuse involves a professional. 

2 – Immediate Response

During a therapy session, you may become aware that a client shares or indicates a possible/probable safeguarding situation that meets the threshold of significant harm. This measure is defined as ‘the threshold that justifies compulsory intervention in family life in the best interests of the child’. This covers physical, sexual, and emotional abuse and neglect. (The Children’s Act 1989). 

Your response may be:

• To listen and be empathic when a client is telling you something serious. If it proceeds to be a complete or clear allegation, clarifying questions should not be asked.
• To show empathy without collusion and listen actively to what is being said without asking leading questions. 
• Where partial or unclear comments are made, to seek to clarify, but be aware that the client may be indicating that they are not ready to share more detail at this stage of the therapeutic work and should not be pressured to do so. By clarifying, you may contribute to a need to act after the session. Any response should be in the considered best interest of the child, adolescent, or adult at risk.
• To show an expression of concern: reassure but do not promise inappropriate confidentiality.
• Good practice is to make clear in an initial contract that where their safety or the safety of others is a concern, the therapist may need to talk with relevant people to ensure their safety. You may want to remind a client of this agreement. 
• To make the client aware of any statutory responsibilities that specific disclosures would invoke. 
• To provide support for the client to report (or similar). 

In the case of adults, the Care Act 2014 defines an adult at risk to be:

• Has needs for care and support (whether or not the local authority is meeting any of those needs) and;
• Is experiencing, or at risk of, abuse or neglect; and
• As a result of those needs is unable to protect themselves from either the risk of, or the experience of abuse or neglect.

Making a decision regarding whether an incident meets a threshold of significant harm can be complex and multifaceted, there are tools you can use to help this decision making process and you should familiarise yourself with your local safeguarding team’s guidance whilst also working in conjunction with your supervisor and your client where possible.

3 – Think

If working in an organisation such as the NHS, a school, college, or university or within an organisation in the private or voluntary sector, you have a responsibility to formally inform and consult the designated safeguarding person in that setting at the earliest opportunity.

• If in private practice, unless you are certain that no action needs to be taken, it is good practice to consult your supervisor to discuss your concerns. 
• By giving yourself time to discuss in supervision, you can separate yourself from the emotion of the moment so that you can see things clearly, which allows for consideration of the many things that may need to be taken into account.
• If your assessment of risk suggests that you need to take urgent action and you are not able to contact your supervisor in time, you could call the local authority designated safeguarding lead professional or local authority duty care officer who will have experience dealing with many cases and ask for advice on the case.

Note that once the client’s name is given, the person you have contacted will be required to take the case forward. In extreme circumstances where you perceive that someone is in imminent danger and that you are legally obligated to act, you would need to call the police. 

• It is helpful to have a pre-planned arrangement as to whom to call if your supervisor is unavailable.
• In all cases, full notes should be taken of your decisions, actions and reasons for them. 

4 – Act

Following the above steps, your actions may be:

• In the first instance, make a formal report to the designated safeguarding lead in your setting.
• To make a formal report of the case to an employee/other services.
• To discuss further with your client.
• In the first instance, make a formal report to the designated safeguarding lead in your setting.
• To make a formal report of the case to an employer/other service;
• To discuss further with your client.
• To formally contact children’s or adult services.
• To formally contact the police. 
• To do nothing – (the rationale for your decision should be recorded and, where appropriate, agreed with your supervisor).
• Should you continue to have a well-reasoned concern that has not been taken up by the setting in which you are working, you should take responsibility for reporting your concern to the relevant authority. 

But also consider: 

• How to respect the confidentiality of clients and treat information that does not need to be disclosed about them as confidential. 
• How do you ensure that clients are informed about how and why information about them is collected, stored and shared with others in relation to matters of safeguarding. 
• How and when you inform clients that a disclosure could trigger further action by a relevant body and that there would be the possibility of heightened risk to them by continuing to make such a disclosure. 

You can: 

• Share confidential information without consent if it is required by law, or directed by the court, or if the benefit to the child or adult that will arise from sharing that information outweighs both the public and the individual’s interest in keeping the information confidential. 
• Weigh the harm that is likely to arise from not sharing the information against the possible harm, both to the person and to the overall trust between yourself and your client, whether a child or an adult, from releasing the information.
• Discuss the case with the local authority safeguarding team if you are uncertain that the child or adult is at risk. They are the body that takes responsibility (ultimately passed to the courts) for any further action. In the first instance, you may want to withhold the personal details of the person at risk. In sharing concerns about neglect and abuse, you are not making a final decision as to how best to protect the individual. 

5 – Reflect

You may wish to review how you have dealt with a disclosure and the impact that it had on you as a practitioner by:

• Use of supervision.
• Reviewing your recording process.
• Reviewing your own support strategies and processes. 
• Noting your learning from the case.