Introduction
This document sets out CCPE’s policy and procedures relating to complaints and grievances about breaches of ethical standards. CCPE adheres to the ethical standards set by UKCP and BACP and by the CCPE Codes of Ethics and Practice for working with adults and for working with children. CCPE also expects therapists to follow the UKCP guidelines on safeguarding practices and procedures. These codes and guidelines are to be found on the UKCP, BACP and CCPE websites.
The policy and procedures in this document apply to all CCPE therapists and trainee therapists, encompassing those working with children and young people as well as those working with adults.
The document will be updated from time to time and the latest version will be available on on the CCPE website.
- Section 1 sets out procedures applying to complaints against qualified therapists who are full members of CCPE. All full members of CCPE are registered with UKCP. See definitions listed below.
- Section 2 sets out procedures applying to complaints against CCPE trainee therapists and pre-registrant graduates.
- Section 3 outlines the procedures that apply in the event of a student or staff member making a complaint against a member of CCPE training staff relating to an alleged breach of ethical standards. Please note that policy and procedures relating to concerns or appeals regarding the content, delivery or assessment of standards on student training courses are not within the scope of this document: they are set out in the CCPE Academic Policy in the Student Handbook.
- Section 4 outlines the responsibilities of supervisors and trainee supervisors in relation to complaints against trainee therapists, pre-registration graduates, and registered therapists.
Definitions
All CCPE full members are qualified therapists who have trained at CCPE and maintain their registration with UKCP. CCPE membership is renewable annually.
CCPE associate membership is available to former CCPE members who are no longer practising as therapists or who are non-clinical members of UKCP. Associate membership is also open to practising therapists who are members of another professional regulatory body.
CCPE students are those studying on courses leading to the CCPE Certificate in the Foundations of Counselling and Psychotherapy, the CCPE Diploma in Counselling and Psychotherapy, the MA in Transpersonal Counselling and Psychotherapy, or the MA in Transpersonal Child, Adolescent and Family Therapy. Student status is available for Diploma students for six years from the first year of their Diploma training and for MA students until their MA has been awarded. In exceptional cases, extensions to the duration of CCPE student status may be agreed by the CCPE management committee.
Trainee therapists are students who are seeing clients, in placement settings or through the CCPE clinic or in private practice. The clinical work of trainee therapists is conducted with the framework of the standards of education and training set by UKCP and BACP as reflected in a set of clinical agreements that can be found in the student section of the CCPE website. All trainee therapists and pre-registrant graduates are required to observe a minimum supervision ratio of one hour of supervision for every six client hours.
Pre-registrant graduates are graduates of CCPE Diploma or MA in Transpersonal Counselling and Psychotherapy who qualified (completed all their course requirements) within the previous twelve months and who are not yet registered with UKCP or other professional regulatory body. In the case of the MA in Transpersonal Child, Adolescent and Family Therapy, graduates may have pre-registrant graduate status for up to two years after qualifying, in order to allow sufficient time to meet all the requirements for registration. If still unregistered more than twelve months after qualifying (on the adult courses) or more than two years (on the MA in Transpersonal Child, Adolescent and Family Therapy), either through non-submission of a registration application, or after unsuccessful attempt(s) at registration, a graduate will no longer be covered by the CCPE complaints procedures. In exceptional circumstances the CCPE registration committee may extend the allowed time period in response to appeal made by a graduate.
Registrants are therapists who are qualified to work with adults and registered with UKCP or another professional regulatory body.
Child psychotherapist registrants are therapists who are qualified to work with children and young people under the age of 18 and registered with UKCP or another professional regulatory body.
Fundamental principles of the complaints policy
All members of CCPE and CCPE trainee and pre-registrant therapists must adhere to the UKCP ethical principles and code of conduct and the UKCP guidelines on safeguarding, and to the further elaboration of those principles set out in the CCPE Codes of Ethics and Practice. CCPE staff members and trainee therapists must also adhere to the BACP’s code of ethics. These codes and guidelines may be found on the UKCP, BACP and CCPE websites.
CCPE encourages all its members and students to seek to resolve any relational difficulty in the first instance through informal discussion between the parties. Allowing space for the complainant to express fully the nature of their concerns, and listening attentively and non-defensively with empathy for the complainant’s experience can help open a way forward into improved understanding and informal resolution of difficulty. In the event of a complaint or grievance that the parties have been unable to resolve informally, the procedures set out in this document apply.
In line with UKCP policy, any complaint about a breach of ethical principles or professional misconduct must be lodged within three years of the events taking place.
CCPE is not responsible for travel or any other expenses incurred either by the psychotherapist complained against or the complainant.
Section 1: Complaints against qualified therapists
A) Full Members of CCPE
All full members of CCPE are qualified psychotherapists registered with UKCP. As such, any complaints brought against them are dealt with by the UKCP Complaints and Conduct Process. See https://www.psychotherapy.org.uk/ukcp-members/complaints/how-to-make-a-complaint/
CCPE offers its full members informal collegiate support during what can be a stressful time when a complaint is being investigated by UKCP. This is provided by a panel of volunteers who offer a safe and confidential space to support the CCPE member. The support is available both to therapists and to supervisors who may be affected by an alleged complaint. This service is provided free of charge and CCPE makes rooms available rent-free for support meetings held outside peak hours (ie up to 4.00pm on Mondays to Fridays)CCPE’s Complaints and Ethics Committee is responsible for maintaining the panel of volunteers and providing training on the complaints process if required. Requests for support should be made to CCPE’s UKCP administrator.
B) Qualified therapists registered with another regulatory body
Therapists who are registered with another professional regulatory body eg BACP are bound by the rules and procedures of that organisation. Any complaints brought against them are dealt with by the organisation with which they are registered. CCPE Associate Members who are in active clinical practice fall into this category, with any complaints being dealt with by their regulatory body.
C) Qualified therapists not registered with a professional regulatory body
Unregistered therapists would need to have recourse to the courts of law in the event of any complaint.
Section 2: Complaints against CCPE trainee therapists and pre-registration graduates
A) When CCPE trainee therapists or pre-registrant graduates see clients in a recognised placement setting, then, in the event of any complaint against the therapist by a client, responsibility for dealing with the complaint rests with the placement and not with CCPE. Any trainee therapist against whom a complaint is made, must however ensure that their CCPE year tutor is notified in order for any training implications to be monitored. Placements also will be expected to notify CCPE in line with CCPE’s placement agreements.
B) When CCPE trainee therapists or CCPE pre-registrant graduates see clients, either through the CCPE Referral Clinic or through private referral, then the CCPE Complaints and Ethics Committee has responsibility for investigating any complaint raised by a client.
a. The client should in the first instance notify CCPE’s Operations Manager in writing with brief details of the complaint. She will acknowledge receipt and notify both the respondent (ie the therapist against whom the complaint is being made) and the Complaints and Ethics Committee.
b. The Complaints and Ethics Committee shall first decide whether the matter falls within the scope and remit of the complaints process (ie whether the complainant alleges a breach of UKCP, BACP and/or CCPE Ethical Principles and Code of Conduct).
c. The next step, where the issue is accepted as falling within the remit of the Complaints and Ethics Committee, is for the Committee to appoint a Complaints Case Officer who will assess the viability of seeking informal resolution through encouraging dialogue between complainant and therapist. In this process the trainee therapist or pre-registrant graduate will be encouraged to seek guidance and support from their supervisor. Informal dialogue may take the form of a facilitated discussion or mediation between parties where the facilitator is an experienced UKCP therapist (and, in the case of mediation, trained in mediation skills).
d. If the issue remains unresolved after facilitation/mediation, or if such informal dialogue is not appropriate in a specific case, the Complaints Case Officer will invite the complainant to document the issue formally in writing within fourteen days; and the respondent to reply within fourteen days thereafter. The Case Officer will review the issues and may offer suggestions aimed at resolving the complaint.
e. In the event of the issue continuing to be unresolved, the Complaints Case Officer will liaise with the Operations Manager to convene a formal panel including two qualified therapists and an independent lay chair, and will set a hearing date. The aim will be wherever practicable to hold the hearing within two months of setting up the panel. The members of the panel will be screened to ensure that there are no dual relationships in relation to the parties to the case. Members of the Complaints and Ethics Committee will not be appointed as members of formal panels but the Complaints Case Officer may be invited to attend. Both the complainant and the respondent may bring to the hearing a supportive person of their choosing, and may call upon witnesses of their own choosing.
f. The members of the formal panel, who will receive in advance copies of the formal written complaint and response, will decide on the following matters:-
i. If the alleged behaviours have been proven or admitted;
ii. Whether these behaviours breach UKCP’s or BACP’s Ethical Procedures and Code of Conduct or any other relevant CCPE protocol;
iii. What sanctions if any should be applied.
g. The formal panel will provide a reasoned decision in writing within three weeks of the hearing, if not given on the day of the hearing itself. The decision of the panel is final.
Section 3: Complaints by CCPE students or staff against CCPE staff members
This section of the procedure gives guidance about complaints relating to breaches of the UKCP, BACP and/or CCPE Ethical Principles and Code of Conduct. Concerns about any other aspect of CCPE course content, delivery or assessment fall within the scope of CCPE’s Academic Policy and should be raised following the procedures set out in the CCPE Student Handbook.
In the event of a CCPE student or staff member having an ethical concern about the behaviour of a member of training staff (lecturer, facilitator, supervisor, year tutor, or Management Committee member), the procedures are as follows:
a) CCPE encourages the student to speak in the first instance to their year tutor who will seek to help the complainant and respondent resolve the issue informally.
b) In the event of inability to reach informal resolution through the year tutor, and the student wishing to take further a complaint about a breach of ethics alleged against a CCPE training staff member, the matter should be referred by the student to the CCPE Complaints and Ethics Committee for mediation.
c) In the event of mediation failing to secure resolution, then the Complaints and Ethics Committee, in consultation with the Director of Operations, will convene a formal panel including an independent lay chair as described at Section 2Bd above.
Please note that these procedures do not include the office staff: they are managed by the Director of Operations and any ethical concerns should be raised directly with her.
Section 4: Responsibilities of Supervisors
The professional responsibility for client work carried out by students in placement settings outside CCPE rests with the placement. CCPE group supervision is given in the context of training and assessment only, and is supportive to placement and private supervision.
CCPE, as the training organisation, holds professional responsibility for student /trainee client work conducted through the CCPE clinic and privately, provided prior written approval has been obtained from the student’s Supervisor, Head of Year and Heads of Clinic and Supervision. CCPE’s professional responsibility for client work terminates when a student has completed all course requirements and graduates.
The responsibility of supervisors is limited. Supervisors are generally responsible for the supervision they give, not the therapy itself. However, should there be a complaint, the supervisor may be called upon to discuss the supervision given and must co-operate fully and in good faith.
Supervisors who work for placements must follow the relevant placement policies and procedures and agree directly with their placements the level of their clinical responsibility.
Supervisors who supervise students working with clients through the CCPE Referral Clinic are responsible for the supervision they give, not for the therapy itself. In line with the clinic’s three-way agreement, supervisors must co-operate fully and in good faith should there be a complaint. In the event of a student/trainee therapist transferring a CCPE clinic referral off-site to become a private client, the responsibility remains with CCPE until the student /trainee graduates.
Supervisors who supervise student /trainees working with private clients (not placement and not CCPE Referral Clinic), likewise, may be called upon to cooperate should a complaint be made. CCPE holds professional responsibility until graduation only.
CCPE, as provider of the supervision training on the CCPE Diploma in Supervision, is professionally responsible for a trainee supervisor’s work with students/trainees’ clients.
May 2022