1.1 To protect clients and other relevant persons from unprofessional or unethical behaviour by any member or trainee of the Bowlby Centre.
1.2 To protect members and trainees of the Bowlby Centre by the provision of a clear, independent and impartial procedure for the investigation and resolution of allegations of misconduct.
1.3 To protect the Bowlby Centre, it’s members, students and the profession of psychotherapy from unprofessional conduct by any member or student.
1.4 To ensure that complaints within the Bowlby Centre are managed in line with the UKCP policies, procedures and guidelines.
1.5 To encourage people to raise issues of concern at as early a stage as possible so that resolution can be explored and facilitated through learning and mediation before the breaches become severe enough to necessitate the use of the formal Complaints Procedure.
2.1 The Bowlby Centre recognises that it is important to have clear and fair procedures to deal with complaints about possible breaches of our Code of Ethics and Practice, our Code of Conduct and the UKCP Code of Ethics and Professional Practice. The Bowlby Centre welcomes any feedback which can help it to monitor and improve standards and sees any complaint as an opportunity for learning for the organisation.
2.2 If anybody (clients, trainees, Bowlby Centre members, members of the public) believes that the behaviour of a member of the Bowlby Centre, who is already registered with the UKCP, does not meet the standard required by the Bowlby Centre Code of Ethics and Practice and the Code of Conduct and the UKCP Code of Ethics and Professional Practice they can contact the UKCP at https://www.psychotherapy.org.uk/registers-standards/complaints/make-a-complaint
2.3 The UKCP Complaints Procedure deals with complaints about registered members only. If a client or anybody else believes that the behaviour of a trainee psychotherapist does not meet the standards required by the Bowlby Centre Code of Ethics and Practice and Code of Conduct and the UKCP Code of Ethics and Professional Practice they should approach the appropriate person as set out in sections 4-5. These complaints are managed by the Bowlby Centre.
2.4 The Bowlby Centre and the UKCP allow complaints from a third party if they have concerns that a therapist’s behaviour is breaching the Bowlby Centre or UKCP Codes of Ethics. The client’s consent is not required.
3. Complaints from a client or a concerned party about a registered Bowlby Centre member
3.1 If a client believes that their therapist’s behaviour has breached the Bowlby Centre Codes of Ethics and Conduct or the UKCP Code, it is recommended as a first step that they discuss the concern with the therapist in an attempt to resolve matters. If this is not possible or appropriate, or does not resolve the issue, the client can put a complaint in writing to the UKCP. There is a link to the complaint form above. Someone from UKCP will then be in touch with the complainant to discuss the matter.
3.2 It can sometimes be difficult to know if the therapist’s conduct has breached the appropriate Codes so a complainant can check with the UKCP as to the appropriate route for a complaint before submitting it formally.
3.3 Any complaint should be made as soon as possible and must be made within 3 years of the ending of the professional relationship that is the subject of the complaint. A complaint cannot be made where the complainant has made it clear that legal action is to be brought against the psychotherapist or where the psychotherapist is the subject of criminal proceedings in relation to the subject matter of the complaint.
3.4 A complaint against a psychotherapist who is a registered member of the Bowlby Centre may be made on one or more of the following grounds:
3.4.1 The psychotherapist’s behaviour has fallen short of the standard of conduct required by the Bowlby Centre Code of Ethics and Practice and Code of Conduct and the UKCP Code of Ethics and Professional Practice.
3.4.2 The psychotherapist has been convicted of a criminal offence relevant to the misconduct.
3.4.3 The psychotherapist’s ability to practice is seriously impaired due to a physical or psychological condition.
3.5 The Bowlby Centre is sensitive to the potential vulnerability of those who become party to complaints. The Ethics Committee, when informed, will take reasonable steps to identify a member of the Bowlby Centre to support the member being taken through the UKCP complaints process.
3.6 The UKCP and the Bowlby Centre will consider complaints from third parties in relation to concerns about a psychotherapist’s clinical practice.
3.7 If the UKCP does not take up the complaint the client can raise the matter with the Bowlby Centre by contacting the Chair of Ethics. Mediation may be offered as a process for resolving the matter.
4. Complaints from a client or any concerned party about a trainee psychotherapist
4.1 If a client or any concerned party believes that a trainee psychotherapist’s behaviour has breached the Bowlby Centre Codes of Ethics and Conduct, or feels the relationship is breaking down, it is recommended as a first step that the complainant raises their concerns with the therapist. If this is not possible or appropriate, or it does not resolve the issue, the complainant should put their concerns in writing to the Chair of Ethics Committee.
4.2 Ethics Committee will appoint an Investigator, who has no boundary issues with either party, who will contact the complainant and forward the complaint to the therapist within 14 days.
4.3 The Investigator will talk to and, if possible, meet with both parties to explore the issues raised within 28 days of being appointed. Time extensions throughout the process are at the discretion of the Chair.
4.4 If the Investigator finds that the trainee therapist has breached the Bowlby Centre or UKCP’s Codes of Ethics they will send a written report of the decision and reasoning, including which clauses of the Codes of Ethics have been breached, to the Ethics Committee within 14 days of the date of the determination. The Ethics Committee will take the results of the investigation to the Chair of the Clinical Training Committee within 14 days of its receipt to explore ways of dealing with any breaches or resolving the issues.
4.5 If the Investigator decides there is no case to answer they will inform Ethics Committee, the complainant, the trainee psychotherapist and their training supervisor.
4.6 Whatever decision is made on whether there has been a breach of the Codes, the Investigator can make recommendations to the parties, the Ethics Committee or the Clinical Training Committee concerning ways in which the issues raised by the complainant may be addressed.
4.7 An appeal against a decision that there is no case to answer may be made to the Chair of Ethics Committee by the complainant within 14 days of receipt of the decision. Ethics Committee will appoint an Appeal Panel made up of persons not involved in the investigation who do not have boundary issues with either party.
4.8 The Appeal Panel shall consist of 2 psychotherapists, one of whom shall be a member of Ethics Committee, and 1 lay member who is not a Bowlby Centre member and has a knowledge of psychotherapeutic practice. The panel will be chaired by the Ethics Committee member who will have the casting vote, when necessary.
4.9 The complainant and the trainee psychotherapist will be informed of the appointments to the Appeal Panel. Ethics Committee shall consider reasoned objections to proposed appointments but has the right to proceed to appoint panel members despite objections or in the absence of a response from the parties.
4.10 The role of the Appeal Panel is to:
hear the appeal from the complainant and clarify questions from both parties
decide whether further investigation is required and, if necessary, take reasonable steps to carry out that investigation
decide whether to uphold the appeal
determine what sanctions are to be imposed where an appeal is upheld
4.11 The standard of proof to be applied by the Appeal Panel will be balance of probability.
4.12 Within 21 days of confirmation of appointment the Appeal Panel will meet to determine what procedure it proposes to follow. It will consider the Investigator’s report and decide what, if any, further investigations are necessary. It will fix a date for the hearing, giving at least 28 days notice to the participants.
4.13 Both parties may be accompanied by a friend/colleague of their choice, subject to the agreement of the Appeal Panel which will not be unreasonably withheld. The friend/colleague will not be a lawyer or legal representative and will not have speaking rights, being there for support and consultation.
4.14 The hearing will be in private and the conduct of the meeting will be at the discretion of the Chair. There will be a minute taker or the meeting will be recorded.
4.15 The Appeal Panel will not announce a decision on the complaint at the hearing. A written report on their proceedings, decision and reasoning will be sent to Ethics Committee within 14 days of the end of the hearing.
4.16 Where the complaint has been upheld the Appeal Panel will consider which of the following directions are to be given:
to censure the trainee psychotherapist and/or warn them to exercise greater care in their practice
to direct extra therapy, supervision or training required, or a combination of these
to direct removal from training within the organisation
4.17 Directions under 4.16 are to be clear and specific with time limits or other conditions for the lifting of sanctions clearly spelt out.
4.18 The Chair of Ethics Committee will be responsible for sending a copy of the Appeal Panel decision and directions to the complainant, the trainee psychotherapist, the Chief Executive Officer and the Chair of the Trustees of the Bowlby Centre.
4.19 Ethics Committee will be responsible for the monitoring of the implementation of directions made and will report regularly to the Chair of the Executive Committee and the Trustees.
4.20 No award of costs or compensation can be made under this procedure.
4.21 Public statements will not be made in relation to complaints unless Ethics Committee take the view that greater harm would be done to those involved by failing to do so
5. Complaints about colleagues
5.1 If a member of the Bowlby Centre community believes that another member has spoken or behaved in a way that breaches the Bowlby Centre Codes of Ethics and Conduct or the UKCP Code they should, in the first instance, try to raise the matter with the colleague. If this is not possible or it does not resolve the issue to the complainant’s satisfaction they can take the matter to the UKCP (see link at 2.2).
5.2 Many people are reluctant to take the formal step of approaching the UKCP or Ethics Committee with an issue of concern, often feeling it does not warrant making a complaint. The Bowlby Centre wants to encourage people to explore such concerns with colleagues so the community can learn about the huge impact that thoughtless remarks, microaggressions and language which others experience as racist, sexist, homophobic or deeply disrespectful can have. Everybody has a lot to learn about their own internalised prejudices.
Anyone with such a concern can approach Ethics Committee or, if they prefer, a member of the Executive or senior Bowlby member to check first that there is no conflict of interest and then to explore the concern. They can then be supported to take the matter to the UKCP if there is a potential breach of the Codes of Ethics and Professional Standards or to write a statement about the concern to be sent to Ethics Committee.
5.3 Within 14 days of receiving the statement Ethics Committee must approach the person with the concern to ensure the statement is comprehensive and clear and to consider the process and possible outcomes. The process could include appointing an Investigator to manage the process, a mediated meeting, a learning programme, a written exchange, using an experienced intermediary, etc. If an Investigator is appointed it will be a person with no boundary issues with the 2 parties.
5.4 Within 7 days of completing that exploration Ethics Committee should send the agreed statement to the person responsible for the concern and talk with them to ensure it is understood. The process and possible outcome should be discussed with them and a process should be drawn up in writing for both parties to see within 14 days setting out what will happen and when. Ethics Committee can bring in other people to support the process with the agreement of both parties.
5.5 All communications should have clear timelines included.
5.6 The aim is to enable people to hear what hurt and offence has been caused by their speech/actions and for the other party to feel heard and believe that some greater understanding has been achieved.
5.7 If the person raising the concern does not feel resolution has been reached by the end of the process they can use the Bowlby Centre appeal process as set out in 4.7 – 4.21 or make a complaint against the organisation under Section 6.
5.8 Ethics Committee will source people with a wide range of skills who could undertake mediation, facilitation and support to these processes.
6. Complaints about the Bowlby Centre as an organisation
6.1 Complaints about the non-therapeutic practices and behaviours of the Bowlby Centre as an organisation and its representatives from clients, trainee therapists, members of the Bowlby Centre, members of the public and potential applicants for therapy or training should be addressed in writing/by email to the Chief Executive Officer of the Bowlby Centre (CEO).
6.2 The CEO will consider whether the complaint is an ethical issue and take advice from the Chair of Ethics as necessary. The CEO will appoint a Bowlby Centre member, not a member of Ethics Committee, to be the investigator and inform the complainant in writing within 14 days.
6.3 The investigator will meet the complainant and complete the investigation and send their investigation
report to the CEO and to the Chair of Ethics Committee where it was earlier determined that there was an ethical element of the complaint. This process should be completed within 28 days of the complainant being notified where possible.
6.4 The investigator and the CEO, or someone delegated with authority to do so by the CEO, and the Chair of Ethics Committee, if there is an ethical element, will determine the outcome of the complaint and inform the complainant of the outcome and any actions to be taken within 14 days of the receipt of the investigator’s report. The CEO has the final say in determining any outcome.
6.5 Where the complainant is not satisfied, they have the right to appeal to the Chair of Trustees within 14 days of receipt of the complaint response. The appeal should state why the complainant believes the complaint response is inadequate and what outcome they think would be appropriate.
6.6 The Chair of Trustees, or another Trustee to whom the task is delegated, will acknowledge the appeal and tell the complainant who will hear the appeal within 14 days.
6.7 The appeal will usually be a paper based decision although the Trustee can choose to meet or speak with the complainant, the CEO, investigating officer of Chair of Ethics Committee as part of the decision process.
6.8 The appeal decision will be given in writing to the complainant and copied to the CEO within 28 days from the acknowledgement of receipt. This decision is final. The letter will inform the complainant that if they are dissatisfied with the way in thick the complaint was handled or the outcome they can contact the CPJA within the UKCP.