The Circle Line Safeguarding Process
Reviewed: 1st October 2024
Do No Harm
This policy is intended to assist The Circle Line (“TCL”), its clients, organisational partners and the Practitioners practising with our brand to deal with incidents where there is suspected risk of harm to self or another (“Safeguarding Issue”) and in doing so to uphold the ethical principles of the BACP and NCS Codes of Ethics with our no.1 priority being: do no harm.
Safeguarding Issues may come to the attention of TCL in one of these four ways:
A member of the public comes to us via our website or social media, in which case we will follow no.1 of this Process.
An employee of an organisational partner of TCL who in distress comes to us directly, in which case we will decide at our discretion whether to follow no.1 of this Process or Steps 2-5 and the Reporting provisions of this Process.
A colleague of an organisational partner of TCL comes to us regarding a Safeguarding Issue with another employee, in which case TCL will refer them to the HR team of their organisation and to our Crisis Conversations Guide.
Someone from the Human Resources/People team of an organisational partner of TCL (“HR”) may (where agreed in our business contract with the organisation) come to us for help with a Safeguarding Issue. In such cases we will follow no.2 of this Process.
1. Where a person at risk comes directly to us
It is usually possible for clients to book a session with a TCL Practitioner directly on the TCL platform to take place within the next 24-48 hours. Clients cannot usually secure a session on the same day as Practitioners’ need notice of sessions.
If a person contacts TCL for more urgent help with their mental health and we consider there may be a Safeguarding Issue, we will direct them to our list of Emergency Resources.
Where one of our practitioners is working with a client and believes there may be a Safeguarding Issue they will carry out a written Risk Assessment, create a Safety Plan with the client, and/or where appropriate call 999 for the emergency services, local NHS mental health crisis service, or local authorities.
Reporting to the Employer:
If The Circle Line becomes aware of or deals with a potential employee Safeguarding Issue that comes to us directly (not via HR) we may share with HR an anonymised Safeguarding Report.
If The Circle Line receives a Safeguarding Notice (see section 3 below) or any other client 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 there remains a Safeguarding Issue and disclosure may help ensure safety.
2. Where HR team comes to us
It is preferable for all that a person comes to TCL of their own volition and this is how TCL’s service is designed.
The exception is where HR activate TCL's Safeguarding Process. HR may do so only in cases of a Safeguarding Issue and in such cases TCL can be contacted between the hours of 9am and 6pm Monday to Friday and will follow these steps:
Step 1: Alert
HR shall email us at safeguarding@thecircleline.co.uk if they believe there may be a Safeguarding Issue and they would like TCL’s help.
We will aim to respond to HR’s email within 2 hours of receipt.
Based on HR’s account of the situation, TCL will offer our professional advice and assess as best we can the level of urgency and whether unsolicited outreach by TCL to the distressed employee is appropriate.
If both HR and TCL agree it is appropriate in the circumstances, HR will provide TCL with the employee’s name, address of their current location, email and phone number (compliance with GDPR being the organisation’s responsibility) and TCL will activate Steps 2-4 of this Safeguarding Process, as appropriate.
Step 2: Mobilisation
TCL will notify their Crisis Therapist pool that there is a potential Safeguarding Issue and establish how quickly a Crisis Therapist can be available.
TCL will check if the employee is already registered and their emergency contact, and if we deem appropriate contact them or pass these details onto the Crisis Therapist.
Once TCL receive a reply from a Crisis Therapist, we shall give the Crisis Therapist the contact details of the employee at risk and their emergency contact, if they’re registered.
If the client already has a therapist on The Circle Line: the crisis therapist will generally be a different therapist. (This reduces the disruption to the ongoing therapeutic relationship and helps prevent their usual therapist from being perceived as a “saviour”. TCL stepping in acts as a distancing layer to protect both.) TCL may notify the client’s usual therapist of the Safeguarding intervention if it deems appropriate.
Step 3: Consent
A TCL Crisis Therapist will email or text the distressed employee as soon as they can to say their employer/colleagues are concerned about their safety and to ask whether they would like a counsellor to call them that day.
If the answer is no, incident closed - move straight to Step 5.
If the answer is yes, move to Step 4.
If there is no answer within [30 minutes], move to Step 4.
Step 4: Outreach & Risk Assessment
Crisis Therapist to call the employee. TCL will aim for the outreach call to be made within 2.5 hours of TCL’s acknowledgement of HR’s alert, however this is subject to our therapists’ immediate availability.
Crisis Therapist will conduct a Risk Assessment and co-create a Safety Plan with their client during the call, if appropriate.
Crisis Therapist will decide during their assessment whether to call 999 or involve local authorities or the local NHS mental health crisis team.
TCL will notify one of their Clinical Supervisors that a Safeguarding Issue has arisen to assure robust clinical oversight and approval of our interventions.
Step 5: Discharge, Reporting & Review
TCL will send (by email and post) a discharge letter to the distressed employee formally ending the Safeguarding intervention.
TCL will complete a Safeguarding Report recording all actions & correspondence between HR, the distressed employee (if it gets to this stage) and the TCL team.
We will send the Safeguarding Report to a TCL Supervisor for review and sign off.
TCL will anonymise the Safeguarding Report so the identity of the employee in distress is protected on file and then email the Report to HR.
TCL will conduct an internal debrief and review. This may or may not, as appropriate, involve HR.
Post-Intervention Care
After the Safeguarding intervention, the client can book further sessions with TCL with a different therapist or with the same Crisis Therapist if they choose. This will be explained in the discharge letter.
TCL will not follow-up with a reporting colleague(s) unless requested by HR and the appropriate fee for TCL is agreed for post-incident support and guidance/training.
TCL’s contact with a distressed employee involved in a Safeguarding Issue will end with the discharge letter (under Step 5) and the ongoing safety and duty of care, to the extent there is one, will be the responsibility and liability of the employer.
3. Practitioner Notice to The Circle Line of Safety Plan
Where a therapist has deemed there to be a Safeguarding Issue and carries out a Risk Assessment and Safety Plan, the therapist may share these with TCL if appropriate by emailing the documents to safeguarding@thecircleline.co.uk using the title in the email “Safeguarding Notice”.
The therapist and, to the extent relevant, The Circle Line team agree to follow the specifics of that Safety Plan..
They agree to support each other during the process including offering the therapist access to a TCL Clinical Supervisor.
4. Confidentiality
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:
– The 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 Safeguarding Issue, TCL and/or the Practitioner may without the client’s permission take appropriate action, usually by either contacting the emergency contact the client has given on The Circle Line platform, a local authority, NHS 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.
5. No-Shows
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 Safeguarding Issues:
the Practitioner will stay on the video call for 10 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 Safeguarding Issue, the Practitioner will evoke any Safety Plan agreed with the client and/or follow this Safeguarding Process.
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.
6. Longer-Term Crises
In non-urgent ongoing cases of severe mental health challenges, after briefing and supervisor/peer consultation, TCL can offer an appropriate mix of referral to a private Psychiatrist, psychotherapy, counselling or psychotherapy for affected family members, and reporting to and working with HR or Occupational Health teams. Long-term crisis work will incur additional ad-hoc fees for both professional consultation and treatment.
7. Supporting 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 the relevant TCL employees.
We have created a Safeguarding Process template to follow in crisis situations.
We have a dedicated Safeguarding channel in Slack.
We have a pre-prepared internal Safeguarding Log template to audit our care.
Following a Safeguarding Issue, we always do a team debrief.
Free therapy sessions are offered to all staff involved.
8. Remuneration
TCL charges an additional fee for Safeguarding work, post-intervention care and longer-term crises. The work involved requires extra support for our team and is extremely high-stress and high-risk. Because of the risk to both the Employer and TCL, TCL must also provide a full audit for each individual incident, in addition to providing the extra time and resource outside our normal service to ensure each matter is handled ethically and professionally.