Safeguarding Policy

Doing our best to keep you safe

Do No Harm

This policy is intended above all else to assist us as The Circle Line and the Practitioners practising with our brand to uphold ethical principle no.1 of the BACP and NCS Codes of Ethics: do no harm.

TCL response to potential emergencies where there is risk of injury to self or others

Steps to follow whether contact is by phone, email or live-chat, with target timings:

Step 1 (within 1 hour of receipt): Alert

  1. HR brief us or employee/colleague contacts us directly. 

2. TCL acknowledge receipt and telephone referrer to:

  • Clarify our understanding of the situation

  • Assess as far as is possible level of urgency and whether unsolicited outreach is appropriate

  • Get employee name & contact details.

3. Alert TCL team using “Emergencies” Slack channel.

4. Email or text distressed employee to ask whether they would like a counsellor to call them that day. If the answer is no, incident closed - move straight to Step 4. If the answer is yes, move to Step 2.

Step 2 (within 2 hours): Galvanising TCL Team

  1. TCL contact Emergency Therapist pool via WhatsApp to get first availability.

  2. Pass Emergency Therapist the contact details of employee at risk.

  3. Notify Clinical Supervisor of the incident/nature of the risk we are dealing with to assure robust clinical oversight and approval of our interventions.

Step 3 (within 4 hours): Employee Contact

  1. Therapist to call employee at risk the same day, within 4 hours if possible.

  2. Therapist to conduct Risk Assessment and co-create Safety Plan, if appropriate.

  3. Therapist to assess whether to dial 999 or involve local authorities.

Step 4 (next day): Reporting

  1. Complete Crisis Report with all actions & correspondence between HR, employee/colleague and TCL team.

  2. Send Crisis Report to TCL Supervisor for review and sign off.

  3. Anonymise Crisis Report and send to HR.

  4. Send discharge letter to client ending crisis intervention.

If the client does not already have a therapist on The Circle Line: the client can book ongoing sessions with the emergency therapist after the crisis intervention if the client chooses - but TCL must first discharge the client in writing and explain they can choose a different therapist or book in with the same emergency therapist if they want. 

If the client already has a therapist on The Circle Line: the emergency therapist must be a different therapist. (This reduces the disruption to the ongoing therapeutic relationship, helping prevent the therapist from becoming “saviour”.  TCL stepping in acts as a distancing layer to protect both.)

Urgent Access to Therapists

It is preferable for all that a client comes to TCL of their own volition.

It is usually possible for clients to book a session with a Practitioner directly on our platform to take place within the next 24-48 hours. They cannot usually secure a session on the same day as Practitioners’ need notice of sessions.

The exception is where TCL's Crisis Response has been activated - see process set out above. This applies only in emergencies where there's risk of harm to self or others.


Under Clause 6.5 of our Terms all sessions are confidential between Practitioner and client. This is a key ethical principle. 

A breach of the general duty of confidentiality is allowed only if:

– Practitioner is discussing and/or sharing their clinical work with a clinical supervisor;

– we/ the Practitioner is required by law to assist (e.g. in criminal proceedings); or

– we/ the Practitioner believe a Client is at risk of harming themselves or another.

Wherever possible, we/the Practitioner would obtain the client’s permission to breach the confidentiality rule and would discuss it with them first in a session. However, if we/the Practitioner feels there is a safety risk we and/orthe Practitioner may without the client’s permission contact TCL and/or the emergency contact the client has entered on The Circle Line platform, a local authority or 999 services.

It is important that trust is placed in the professional judgement and opinion of TCL and the therapist and their assessment of risk.

Practitioner Notice to The Circle Line of Safety Plan

Where the Practitioner has deemed the risk of harm requires a Risk Assessment and Safety Plan, the Practitioner may share these with TCL if appropriate by emailing the documents to using the title in the email “Safeguarding Notice”. 

  • The therapist and the Circle Line team agree to follow the specifics of that Safety Plan in terms of next steps and contact with the client.

  • They agree to support each other during the process including offering the Practitioner access to TCL Clinical Supervisors.

Reporting to the Employer

If the The Circle Line becomes aware of and deals with a potential emergency or suicide risk we will share with a member of the employer’s HR team our anonymised Crisis Response Report.

If The Circle Line receives a Safeguarding Notice or any other details from a therapist we are not obliged to notify or share with the client’s employer unless :

  • we have the client’s permission; or

  • we deem in our professional opinion that it is an emergency with risk of harm to employer or another.

Looking after our Circle Line Team

We are committed to the following measures to support our front-line team:

  • Training on handling suicide conversations and situations for all TCL employees.

  • We have a dedicated Emergencies channel in Slack.

  • We have created a Crisis Process template to follow in emergency situations.

  • We have a pre-prepared internal Crisis Log template to audit our care.

  • Following an emergency, we always do a team debrief .

  • Free therapy sessions are offered to everyone involved.


A client has free choice whether to attend any session and that choice must be respected. 

If a client does not attend a booked session and there are no obvious potential safety issues:

  • the Practitioner will wait 15 minutes and then try to make contact with the client - by text, email or phone call.

  • They will advise that they will stay in the session for a further 10 minutes.

If they have reason to believe there could be a safety issue, the Practitioner will evoke any safety plan agreed with the client / contract agreed and/or (if none) follow their usual safety procedures.

If a client does not attend booked sessions three or more times in a row TCL reserves the right to decline to offer further sessions.

Our Response to Longer-Term Crises

After briefing and supervisor/peer consultation, we offer an appropriate mix of facilitated consultation with a Psychiatrist, therapy (in-person or online), family support and reporting to HR.