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Guidance on complaints for members and registrants

If a complaint or concern is raised against you

Introduction

This guidance is for all our members whether you are a Registrant on the CBT Register or not. It gives information on what happens if anyone raises a formal complaint about your conduct or fitness to practice, and your responsibilities if that happens. There are other documents that go with this guidance, which we expect all our members to read, understand and keep to, including: 

Having a complaint made about you can be stressful and difficult. We want to support our members, while recognising that our first priority must be to protect the public. 

When someone raises a concern or a complaint that you may have breached our Standards, we will follow our formal Complaints Procedure .

You must let us know if there is a complaint made about you. Our duty of candour means that you must be open and honest about such concerns. If you have an employer or other professional body, you must also let them know if you are aware a formal complaint is made about your conduct. 

Our Standards state that you must have indemnity insurance that covers the work that you do. If you have had a complaint made against you, your insurance company may require you to inform them. It is good practice to let them know as soon as possible if a concern has been raised.

You must cooperate fully with an investigation into your conduct or fitness to practice. 

Anyone can raise a concern or complaint about one of our members, and we will handle this according to our policy

Most complaints are resolved without legal proceedings, in some circumstances you may also want to seek legal advice and ensure that they are aware of our Standards and our Complaints Procedure. We are unable to make recommendations on legal assistance.

As a member, it is your responsibility to inform us if your contact details change. While we will primarily use the email address you have provided to contact you, we may also communicate with you by letter using the address on record.

What can I expect from BABCP if a concern or complaint is raised about me?

We will take all complaints seriously to protect the public, uphold standards, and maintain the reputation of the profession.

We will follow the Complaints Procedure.

As a member of BABCP, you can expect that any complaint made against you will be handled in a manner that reflects our commitment to equity, diversity, and inclusion (EDI). Our processes are designed to be accessible, fair, transparent, and free from discrimination. We strive to ensure that our Complaints Handling Team (CHT, which includes the Complaints Manager, Deputy and team), our Screening and Hearing panels, and legal assessors have received training on EDI to uphold our commitment to these principles within the complaints process. 

We support any reasonable adjustments you may require to fully participate in the complaints process. We will ensure that the language and terminology used in our communications and documents are inclusive and respectful of diversity.

As a member of BABCP, you can expect the BABCP Complaints Manager to have an impartial role in the complaints process.

All Hearing Panels convened to investigate complaints are independent and impartial. We will take steps to ensure that no one involved in the panel has any personal or professional connection with you that could create a conflict of interest. At the Screening Panel stage, we will also anonymize your details to further guarantee impartiality.

The Complaints Manager will keep you up to date with the progress of our investigation. As the central point of contact for everyone involved in the complaint, you can also expect them to answer any relevant questions you may have.

The Complaints Manager will also offer guidance on the procedures of the various Panel Hearings.

What should I do if I receive notification from BABCP that a complaint has been made against me?

When we receive a complaint, we take some actions before notifying you of the details of the complaint. The complaint or concern about your conduct or behaviour will already have been passed to our Complaints Manager and will have been discussed with the CHT as part of the triage process. 

The CHT will have contacted the person making the complaint, and will have carried out a risk assessment

The "reasonable prospect" threshold test will have been used by the CHT to determine whether a complaint should be investigated. This is based on whether there are reasonable grounds to suspect that a breach of the Standards has occurred, and whether the breach is serious enough that sanctions or consequences are likely to be applied.

When you have receive notification from the Complaints Manager, it means we have concluded that there is a case to answer and we will proceed with an investigation.

We will provide you with details about the nature of the complaint, including information about the complainant and the specific concerns raised, and explain what will happen next.

The Complaints Manager will ask you (or your formal representative) to respond to the complaint or concern being investigated and to provide any evidence you will rely on. 

When you respond to us, you should:

  • Read and understand the complaint and review the concerns. It may be helpful to take notes on the specific points raised and any relevant information you have that may address the issues raised.
  • Respond promptly: We will provide you with a deadline for your response to the complaint. You must respond as soon as possible and within the timeframe given. You will be given a minimum of ten working days to respond. You can let us know of unavoidable delays to providing a complete response, and we will take this into account.
  • Prompt and professional responses: We expect responses to be professional, respectful, and evidence-based. The response must address each point raised in the complaint and provide any relevant information you have to support your position. If there are any points that you are unable to address or require further information to respond to, you should inform the Complaints Manager and let them know a reasonable time you need complete your response.
  • Seek support: It can be helpful to seek support from colleagues, your clinical supervisor, union representative or a legal professional who is familiar with our procedures. They may be able to provide you with guidance and support throughout the process. We will update you on the stages of the investigation and answer questions. This will also help you to decide the support that you need during the process.
  • Keep records: Keep a record of all correspondence and communications related to the complaint. This will help you to keep track of important details and ensure that you are following the proper procedures.
  • Regardless of the outcome of the complaint, it is an opportunity to reflect on your practice and consider whether any changes may be needed.
  • In addition, you will also be asked by the CHT to provide us with details about:

Any statutory regulator of which you are a registrant

Any other professional register of which you are a registrant

Any significant employer you are employed with

Your Clinical Supervisor and

Whether there are any legal proceedings concerning the same matters as the complaint

If you do not comply with our requests and do not provide a good reason, this will be added to the issues to be addressed with the complaint.

You must provide accurate and up-to-date information so that we can have a full understanding of your circumstances. 

We will keep you informed of the progress of the investigation, and will notify you of any decisions made by the CHT, Screening Panel or Hearing/Health Panel. 

If you have any questions or concerns about the investigation or the complaint, please do not hesitate to contact the Complaints Manager. They will be able to provide guidance and support throughout the process.

What happens after I have sent my response and further information to BABCP?

The CHT may request additional information from you, the complainant or third party sources, and may also ask for reports or for more time to investigate. 

If the CHT decides at this point that there is in fact no case to answer, or that there is no realistic prospect of reaching an adjudication, the process ends. You will be informed of this decision.

If the CHT determines that the complaint, even if true, would not result in any sanctions or consequences, the complaint will not be pursued any further. In such cases, if the issue did not breach the Standards but fell short of BABCP's expectations, the CHT may provide guidance or feedback to you about it, but the matter will not be pursued as a complaint.

After gathering all necessary information and evidence, if the CHT determines that there is a case to answer, they will compile a file containing all relevant material obtained during the investigation to date. The CHT will then refer the complaint to the Screening Panel for further review.

The Complaints and Resolution Manager will anonymise the details of both you and the complainant before referring the complaint to the Screening Panel.

You will not be required to attend a Screening Panel hearing. Please refer to the full complaints procedure if you require any details of the Screening Panel process.

This investigation will normally be completed within 30 working days of the triage decision. 

Timescales for each stage are set out in the formal complaints process, we will keep you informed if there are delays.

What happens if I am subject to complaints procedures or other proceedings elsewhere?

You must let us know if there is a complaint about you, criminal proceedings or a disciplinary process by another professional body. This might be the police, an organisation (such as BACP or UKCP), or a regulator (such as HCPC, NMC or GMC), or an employer (such as the NHS). If you do not let us know and do not provide a good reason, this will be included in the complaint.

If a police investigation or criminal court is involved, we will consider an Interim Suspension Order (see section 6 below), and our Complaints Process may be paused until the outcome is known.

We will also notify any other professional or regulatory bodies about the ongoing investigation and inquire if they are already handling a similar complaint. In such cases, we may wait for the outcome of their investigation or legal proceedings before proceeding with our own investigation.

When deciding whether to pause the complaints process, we will consider the interests of the complainant, you as the member, and the general public. If we do decide to pause, we may change our decision at any time and will keep you informed.

Finally, we reserve the right to use the decision of other organisations as evidence when determining the outcome of the complaint against you.

Am I able to continue to practise if a complaint is made against me and what happens if the complaint is serious?

You can continue to practise while we investigate the complaint, unless you are suspended.

If there is a serious complaint made against you, your membership and registration may be temporarily suspended. The process for this is as follows: 

  • If the Screening Panel believes it is necessary for the public's safety, the public's interest, or your own good, they will inform the Complaints Manager of their concerns. The Complaints Manager will then refer the complaint to the Interim Suspension Panel. 
  • The Interim Suspension Panel will review the situation, considering if you have been accused of sexual misconduct, charged or convicted of a serious crime, suspended from another professional group, if your physical or mental health is affecting your work and could be harmful to others, or if you have failed to comply with a sanction. 
  • You will be informed about the suspension and given the opportunity to explain your side. 
  • The Interim Suspension Panel can suspend you for up to one year.
  • The suspension will be reviewed every three months or when new information becomes available. The panel may keep the suspension, end it, shorten it, or lengthen it if necessary. You have the right to appeal the decision. 
  • In emergency cases, the Complaints Manager may ask the Emergency Screening Panel to suspend you if they believe the public is in danger. The Emergency Suspension Panel must agree and will only approve the suspension if three members agree it is immediately necessary. 
  • The Emergency Suspension Panel will inform the Complaints Manager, who will then inform you about the suspension and give you a chance to explain your side. 
  • The Emergency Suspension will last for 21 days and cannot be extended. 
  • You also have the right to appeal this decision.

If a Panel has placed an Interim Suspension Order, you should not practice until the outcome of the complaint is decided. If a suspension is agreed this information may be shared with relevant bodies including, but not limited to insurance companies, police or statutory services. 

If your membership or accreditation is suspended and you continue to practice, BABCP will deem this as a failure to adhere to a sanction. If there is sufficient information to suggest that you or your practice presents a risk to the public, BABCP will seek legal advice in this matter, including possible referrals to the police. In addition, a sanction breach of this extent may lead to permanent removal from the CBT Register or expulsion from membership.

What are my confidentiality requirements during the complaints process?

If you are subject to a complaint, you will need to share information. We also recognise our duty to respect and protect confidentiality, even after the end of a professional therapy relationship. You must take this into account when dealing with a complaint, including relevant parties such as your Clinical Supervisor or your professional indemnity insurers. If you are accessing other support such as from colleagues, you will need to ensure that appropriate confidentiality arrangements are in place.

You will not be in breach of confidentiality when you are responding to us about a complaint. The person making the complaint gives permission for relevant and essential information to be shared as part of the process. 

When you provide information to us regarding the complaint, we will share it with the complainant and/or their representative. Please bear this in mind when considering how to communicate about the situation. 

You must only disclose information that is necessary and relevant to the complaint, although you may submit any documentation which you feel will help in the process. For example, you may submit a statement from your Clinical Supervisor or you may wish to disclose clinical notes or records. 

What are factors that could help me during a complaint investigation?

Our complaints process does take into account how you respond to any concerns or complaints which have been raised about you. This may help to resolve the complaint and investigation sooner. You can provide any information you feel may be relevant which could include your reflections, or any mitigating factors we should be aware of. We also take into account assessment of your fitness to practice where this is relevant. Factors that may help include:

  • If you co-operate fully with inquiries and provide all relevant information that is required, and admit any facts relating to concerns raised about you; 
  • If you have offered a full and honest apology where appropriate to the affected person; 
  • If you have acknowledged failures and errors in your practice to prevent recurrences;
  • If you have taken any steps to apologise for any harm caused; 
  • If you have taken any steps to prevent the conduct recurring;
  • If you have kept up to date with your Continual Professional Development needs, or you have other positive feedback or appraisals from your Clinical Supervisor; 
  • Any character references or testimonials you may have;
  • Any personal circumstances, including stress or ill health;
  • Any reflection and insight upon your actions, demonstrating that you have recognised the impact your actions may have had upon the person making the complaint about you;
  • Any other efforts you have made to put things right. This may include evidence you have kept your knowledge and skills up to date in order to improve the quality of your work to promote client safety.

What is a Hearing Panel and how many Panels are there?

A Hearing Panel is there to decide whether to uphold all or part of a complaint, based on the information gathered. They are supported by a legal assessor who makes sure that the formal process is followed. 

The following Panels will be responsible for making decisions at different stages of the Complaints Procedure:

  • The Screening Panel (part of the CHT), which decides whether complaints should be referred to the Hearing Panel;
  • The Interim Suspension Panel, which decides whether you should be suspended from membership whilst the outcome of a complaint is being considered; 
  • The Hearing/Health Panel, which decides if a complaint breaches the Standards and that you should no longer remain on the CBT Register or membership without restriction or conditions;
  • The Appeals Panel, which decides appeals against decisions of the Hearing/Health Panel;
  • The Restoration Panel, which considers applications for restoration to the CBT Register or membership.

A Hearing Panel is made up of a Lay Chair of the Panel and one BABCP member, and one other person who might either be a lay person or a BABCP member.

What happens at a Screening Panel?

If a complaint is raised against you, the Screening Panel will review it within 20 working days. If there are ongoing legal proceedings related to the complaint or if another regulator is investigating, the Screening Panel may pause the process until the outcomes are known.

The Screening Panel will make a decision based on the information and evidence provided. If you have failed to provide this, it will be recorded as part of the complaint.

If the Screening Panel decides it is unlikely that a Hearing or Health Panel would find you in breach of our standards, they may:

  • take no further action; 
  • send a letter of guidance. This will only be sent if it's not in the public interest for a more serious penalty to be applied;
  • send a letter of admonishment; 
  • suggest a meeting between you and the complainant to resolve the issue.

If the Screening Panel decides it is likely that you have breached our Standards, they may refer the complaint to a Hearing or Health Panel, or refer it to the Interim Suspension Panel.

The Screening Panel will explain the reasons for their decision. If the complaint is referred to a Hearing or Health Panel, they will state which of our Standards may have been breached. 

The Complaints Manager will send the complaint to the Hearing or Health Panel within 5 working days of the Screening Panels referral, and will inform the person who made the complaint and you. They will also inform your Clinical Supervisor and any other relevant regulator, professional body or employer which has not already been informed.

If the Screening Panel refers the complaint to a Hearing or Health Panel, they will also recommend whether the case should be heard in person, online, or a combination of both. You and the person making the complaint will be informed of the recommendation and have 20 working days to let us know if you agree. If you both do not agree, the Hearing or Health Panel will make the decision.

If the Screening Panel determines that the complaint can be resolved through the Consensual Disposal Mechanism (CDM), they will provide you with the terms of the resolution. CDM is a voluntary alternative to a formal Hearing Panel for resolving complaints if it is not in the public interest to refer the matter to a Hearing or Health Panel, and if the complaint is not being investigated by another regulatory body. The sanctions available through CDM are the same as those available through a formal hearing, and the outcome will be made public. However, if you do not agree to the sanction offered by the Screening Panel, the complaint will proceed to a Hearing/Health Panel.

Although CDM is a disciplinary decision, it is not a "plea bargain". The Screening Panel will only propose sanctions that they would have imposed at a Panel hearing. CDM provides an option to reach an appropriate resolution for both the complainant and you in the least stressful manner possible. The Panel will not offer a CDM if a Panel Hearing is required in the public interest

Would I be required to attend a formal Hearing and would this be face to face or remote?

If the complaint is passed to a Hearing Panel you would be required to attend a formal Hearing. 

This is unless you want the complaint dealt with by using the CDM as discussed above. 

If a complaint is referred to a Hearing Panel, the Complaints Manager will fix a date for the Hearing and send you a notice of this. You will be given 42 calendar days notice of the Hearing. We will try to ensure that the Hearing is held on a date which is suitable for you and everyone involved, taking into account the availability of panel members, witnesses and legal advisors.

The notice of the hearing will include:

  • Whether the Hearing is in person, remote or hybrid.
  • A statement from the BABCP setting out the basis for alleging that you have breached the Standards.

You are required no later than 35 calendar days before the date of the hearing, to let us know:

  • Whether you admit that you have breached the Standards 
  • Which facts in the Case you admit to and which facts you dispute
  • Whether or not you want the complaint dealt with by CDM. 

What happens at a Hearing Panel?

The burden of proof is on the BABCP to demonstrate that you have breached the Standards and whether it is no longer suitable for you to remain on the CBT Register or membership without conditions or restrictions.

The Chair of the Hearing Panel will determine the order of proceedings, which will typically include the Presenting Officer reading out the allegations and asking you to indicate whether the allegations and/or facts alleged are admitted. The Presenting Officer will present the case and call any witnesses, and you may respond to the Presenting Officer’s case and call any witnesses of your own. The Hearing Panel may invite closing submissions. 

The Complainant may, if they have not been called as a witness, give their own personal account of the complaint and any details relevant to any allegations.

The legal assessor will sit with the Hearing Panel to advise them on any points of procedure or law relevant to the decisions taken by the Panel. 

It's important for you to cooperate fully with the Panel during this process and to provide any relevant information that may assist in the Panel's assessment of the complaint. By doing so, you can help ensure that the Panel has all the information necessary to make a fair and accurate decision.

What happens after the Hearing Panel and what are Sanctions?

The Hearing Panel will make a decision on whether to uphold part or all of the complaint based on the information gathered, including the information provided by you. The Panel will review all the evidence and submissions, assess if the allegations are true based on their findings, and determine if any proven or admitted allegations amount to a breach of the Standards.

As a member of BABCP, it's important for you to know that the Hearing Panel will use the balance of probabilities as the standard of proof when evaluating a complaint against you. This means that the Panel must conclude that the complaint is more likely to be true than not to be true and related to a breach of BABCP Standards.

If the panel decides the complaint is not upheld, the matter is concluded. 

If the complaint is partly or fully upheld, the panel will then decide what action to take. 

In cases where a complaint is upheld by the Hearing Panel, different sanctions could be used to protect the public from risk of harm, maintain confidence in the profession, and set proper professional standards.

The sanction used will be fair and the minimum necessary to protect the public. In deciding on a fair sanction, the Panel will consider: 

  • The right thing to protect the public's health, safety, and well-being; 
  • Promote and maintain public confidence in the profession;
  • Promote and maintain proper professional standards;
  • Help protect your health, safety, and well-being, length of time passed since the incident took place;
  • Whether the actions were sexual in nature; 
  • Whether the actions were dishonest; 
  • Whether the behaviour discriminated against the Complainant under any of the protected characteristics of the Equality Act (2010).

The Panel will consider all available sanctions, starting with the least restrictive. The increasing order of seriousness is as follows:

  • Additional clinical supervision with defined goals for a specified length of time; 
  • A written reflection of the process and any immediate learning at the conclusion of the complaints process;
  • A formal report or oral statement showing what you learned from the experience;
  • Further training or a formal assessment by a specified date;
  • A written request for a specific change in practice;
  • A thorough audit of your practice;
  • A 'warning order' about your professional conduct, which warns of more severe punishment if you repeat the conduct within a certain time period;
  • Suspension from membership and the CBT Register for up to 18 months with specified conditions for re-entry to membership and the CBT Register; 
  • Removal from membership and the CBT Register for serious, reckless, deliberate, and/or malicious behaviour or actions.

Membership withdrawal would be an appropriate sanction in situations where there is deliberate harm to the Complainant or other members of the public, this may include:

  • Sexual misconduct (sexual harassment, inappropriate touching or advances, sexual exploitation, or any other behaviour of a sexual nature that is unprofessional or violates ethical standards);
  • Disregard for ethical or professional standards;
  • Abuse of position or trust;
  • Lack of insight or remorse for the behaviour;
  • Continuing problems, denial, reluctance to resolve failings;
  • Or any other factor the Hearing Panel considers necessary to protect the public.

In cases where a complaint raises concerns about your physical or mental health that could affect your ability to practice safely, the Complaints Manager may invite you to attend an assessment with a medical practitioner appointed by BABCP at our expense.

If a complaint is upheld and results in a serious sanction, BABCP will notify the Professional Standards Authority (PSA). 

Any action impacting the removal or changes to a member's registration elsewhere deemed relevant for BABCP shall result in a complaint being raised, irrespective of a direct complaint to BABCP.

What happens if I fail to comply with any Sanction?

If you do not comply with a sanction imposed under the Complaints Procedure, the Hearing Panel will ask you to explain why you have not followed the requirements. After considering your explanation, the Hearing Panel may decide to either extend the deadline for you to comply with the sanction if there is a valid reason to do so, or impose additional sanctions that they consider appropriate. 

How do I appeal a decision?

As the subject of a complaint, you have the right to appeal any decision made by the Screening Panel, Interim (or Emergency) Suspension Panel, or Hearing/Health Panel. To do so, you must lodge an appeal in writing with the Complaints Manager within 28 calendar days of the decision appealed against. Your appeal must specify the grounds for appeal and be accompanied by any supporting documentary evidence.

The Appeals Panel will not hear any new allegations and will only consider the original complaint. If you wish to appeal a decision, you can do so on the following grounds: 

  • The decision, or part of it, was incorrect;
  • There was a failure in the procedure that was significant to the decision and made it unsafe or unjust;
  • New evidence has come to light that was not available at the time of the Hearing Panel and could have had an impact on the decision;
  • You believe the decision on the sanction was excessively harsh.

The Appeals Panel will review the evidence and decisions made by the Hearing/Health Panel to ensure that due process was followed and that the decisions made were fair and proportionate based on the evidence presented. The Chair of the Appeal Panel will determine the procedure to be followed at the appeal.

If the Appeals Panel determines that there is no realistic prospect of success, the appeal will be dismissed, and you will be informed of the decision and the reasons behind it. If the Appeals Panel decides that there is a realistic prospect of success, an appeal hearing will be conducted, and all parties to the original complaint, including the complainant, will be notified. The Appeals Panel may limit the scope of the appeal to particular issues.

The Appeals Panel may dismiss or grant the appeal, replace the whole or any part of the Hearing Panel's decision with one of its own, uphold the Hearing Panel's sanction, substitute its own sanction, or order that any sanction be lifted. In cases where the appeal is against a sanction, the Appeals Panel can review all of the Panel's findings to determine whether the sanction is proportionate and fair.

If you fail or refuse to attend an appeal, the Panel may decide to proceed with the hearing in your absence, or adjourn the hearing to a new date. A copy of the Appeals Panel's decision and reasons will be provided to you and the complainant. The burden is on you to convince the Appeal Panel that one or more of the grounds of appeal should be upheld. If you remain dissatisfied, you may raise your concerns with the PSA.

How long will the Complaints Process take? 

We aim to consider cases as quickly as possible, although this can vary according to the investigation and complexity of the issue. We aim to:

  • Have a case considered by the CHT within 30 working days of receiving it.
  • Hold a Screening Panel Hearing within working 20 days of the case being referred to it by the Complaints Manager

You will be given at least 42 working days notice if you are required to attend a Hearing Panel.

The CHT will keep you informed of the stage of investigation and any delays.

The overall timescale of the Complaints Process can vary depending on the complexity of the case and the availability of the parties involved. However, we aim to resolve complaints as efficiently as possible while ensuring a fair and thorough investigation is conducted.

If at any point during the Complaints Process there are delays, we will inform you of the reasons for the delay and provide you with an updated timeframe for the resolution of the complaint. 

We understand that the Complaints Process can be a difficult and stressful time, and we will endeavour to provide you with support and guidance throughout the process. If you have any concerns or questions about the Complaints Process, please do not hesitate to contact us.

Equality and diversity statement

BABCP is committed to promoting equity, equality, inclusion and diversity (EDI), and works to ensure that its processes are accessible, fair, transparent and free from discrimination. We expect that everyone who is acting for us within our Complaints Procedures uphold these values. To uphold our commitment to EDI, we strive to ensure that our CHT, hearing panels, and legal assessors have received training on these issues. We will also provide any reasonable adjustment you may require to fully participate in the complaints process, and take steps to ensure that the language and terminology used in our communications and documents is inclusive and respectful of diversity.

Could details of any complaint be published on the BABCP website?

Some outcomes may be published according to the Complaints Procedure, if it is deemed in the public interest. You can also find out more on how we publish the outcomes of complaints in section 38 of the full Complaints Procedure.

Will BABCP cover any of my expenses if I have to attend a Panel Hearing?

BABCP are not responsible for travel or other expenses incurred by any party in connection with any stage of any complaint.

How can I give any feedback on the complaints process? 

At the end of your case, we will provide you with a feedback form to help us improve our process. We are committed to constantly improving our service and welcome any feedback you have to offer.

If you are unhappy with the way we have handled your complaint, please contact us at ComplaintsManager@babcp.com or follow our organisational complaints procedure to file a complaint. We take all complaints seriously and will work to resolve any issues you may have.

We take all feedback seriously and use it to continuously improve our complaints process. If you have any concerns or suggestions at any point during the process, please do not hesitate to contact us using the details provided. Your feedback is essential to help us maintain the highest standards of professionalism and fairness in our procedures.

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