Safeguarding procedure

At Peace and Minds, we are deeply committed to providing genuine, heartfelt, and completely confidential online and telephone counselling support to adults across the UK.

Our services are designed for individuals aged 18 and over who may be facing a wide range of challenges — including stress, burnout, anxiety, depression, trauma, and more.

We recognise that many of our clients may be vulnerable due to mental health needs, disabilities, or other life circumstances. This comprehensive Safeguarding Procedure is in place to protect their wellbeing, rights, and safety, in full alignment with UK law and professional best practices.

This procedure complies with:

  • Care Act 2014 (statutory duties for adult safeguarding in England; equivalent frameworks apply in Wales, Scotland, and Northern Ireland).

  • Mental Health Act 1983 (as amended by the Mental Health Act 2007), which governs the assessment, treatment, and rights of individuals with mental disorders, including compulsory detention, capacity assessments, and safeguards such as nearest relative rights, independent mental health advocacy, and community treatment orders.

  • Children Act 1989 and 2004 (while we do not work with children, these inform our overall safeguarding ethos — particularly if an adult client discloses concerns involving minors, prompting immediate referrals).

  • BACP Ethical Framework for the Counselling Professions (2018, with updates), including Good Practice in Action (GPiA) 030 on safeguarding vulnerable adults.

  • UK GDPR and Data Protection Act 2018 (for secure and transparent handling of sensitive personal data).

  • Online Safety Act 2023 (OSA), requiring risk assessments for potential online harms — though our 1:1, non-user-generated content model keeps risks low.

Safeguarding is a legal and professional requirement under the Care Act 2014 and the Children Act 1989 (and 2004). It applies to all practitioners, regardless of whether sessions are conducted online or by telephone. We adhere to the six key principles of adult safeguarding: Empowerment, Prevention, Proportionality, Protection, Partnership, and Accountability.

All therapists are BACP-registered (or equivalent) and receive regular training in safeguarding. We also work with trainee counsellors completing a BACP approved level 4 qualification and who must hold professional indemnity insurance and receive regular supervision and support in safeguarding.

1. Purpose and Scope

This procedure details how we identify, prevent, and respond to risks of harm, abuse, or exploitation — including online-specific risks such as digital disclosures, exposure to inappropriate content, or concerns about a client's safety in their home environment (e.g., ensuring sessions occur in a private, secure space free from coercion or interruption). It covers all aspects of our work, including individual counselling, initial consultations, and organisational services like employee wellbeing programmes.

We always prioritise client empowerment and self-determination (Making Safeguarding Personal) while upholding our duty of care. Vulnerable adults are those with care or support needs who may be at greater risk of abuse or neglect and unable to protect themselves (Care Act 2014 s.42). This includes individuals with mental health conditions, disabilities, age-related issues, or situational vulnerabilities (e.g., domestic abuse).

In contexts involving the Mental Health Act, we consider capacity and potential need for urgent intervention.

Under the Online Safety Act, we conduct ongoing risk assessments of our platforms to minimise any potential for harm, using secure, encrypted tools throughout.

2. Definitions

  • Vulnerable Adult: An adult (18+) with care/support needs who is at risk of abuse/neglect and unable to self-protect (e.g., due to mental health, disability).

  • Abuse/Neglect: Includes physical, emotional, sexual, financial, discriminatory, organisational, modern slavery, domestic abuse, self-neglect, and neglect. In mental health contexts, this may involve coercive control, medication misuse, or institutional harm.

  • Safeguarding Concern: Any indication of abuse/neglect, such as self-disclosure, observed signs, or third-party reports.

3. Responsibilities

  • All Staff/Therapists: Recognise signs of abuse, report concerns immediately, maintain confidentiality unless disclosure is necessary for protection, and document accurately. This includes monitoring online risks during sessions (e.g., signs of an unsafe environment).

  • Safeguarding Lead: James Harris, Managing Director oversees investigations, referrals, and training. Contact: james@peaceandmindscounselling.co.uk.

  • Organisational Partners: We collaborate on risk assessments and referrals, ensuring our employee programmes align with this procedure.

  • Training: Annual safeguarding training (e.g., SOVA Level 2/3), plus modules on GDPR/OSA and Mental Health Act awareness.

  • Professional Standards: All therapists receive regular professional supervision (at least 1.5 hours per month, per BACP guidelines), hold professional indemnity insurance, and maintain active membership in a recognised body (e.g., BACP, UKCP).

4. Recognition of Abuse/Neglect

Signs may include unexplained injuries, withdrawal, fear, financial irregularities, self-neglect (e.g., poor hygiene or hoarding), or direct disclosures.

In therapy: reluctance to discuss topics, inconsistent accounts, or deterioration linked to abuse.

For online sessions: indicators of coercion, privacy breaches, or digital disclosures (e.g., sharing harmful content).

Under the Mental Health Act: identify if a client may require assessment for compulsory treatment (e.g., severe self-harm risk). We assess mental capacity (Mental Capacity Act 2005, integrated with the Mental Health Act where relevant): capacity is assumed unless proven otherwise, and we involve advocates if needed (e.g., independent mental health advocate or Power of Attorney).

5. Reporting and Response Procedure

We follow a four-stage process aligned with Care Act guidance and incorporating Mental Health Act considerations:

Stage — Actions — Timeline

i) Raise Concern

Therapist notes concern, discusses with client (if safe/appropriate), seeks consent for action. Report to Safeguarding Lead if risk of harm. For disclosures of abuse or risk: Respond empathetically, clarify limits of confidentiality, and explore client's wishes.

Immediate (within 1 working day)

ii) Lead Enquiry

Lead assesses proportionally (with therapist/supervisor input); involve client/advocate; check if s.42 criteria met or Mental Health Act thresholds apply.

Within 3-5 working days

iii) Safeguarding Plan

If needed, refer to local authority (adult safeguarding coordinator/police if crime) or Mental Health Act professionals (e.g., Approved Mental Health Professional). Develop plan with client (e.g., safety measures, referrals). Guidance on reporting: Contact local authority safeguarding team (via council website) or police (101/999); include necessary details while protecting confidentiality.

Within 28 days or sooner if urgent

iv) Review/Closure

Monitor outcomes, review plan, close if resolved.

Ongoing; formal review at 3-6 months

  • Urgent Risks: If immediate danger (e.g., suicidal intent, active abuse), call 999/101 or NHS 111. Confidentiality may be breached if justified (per BACP). For Mental Health Act scenarios, refer urgently if detention may be needed.

  • Self-Neglect: Address empathetically; refer if client unable to protect self.

6. Confidentiality, Consent, and Data Protection (GDPR Compliance)

Confidentiality is at the heart of our work, but may be limited if there is a risk of serious harm (e.g., to self or others, or abuse disclosures). Our client contract/counselling agreement clearly outlines these limits of confidentiality, including safeguarding exceptions, and requires informed consent to online therapy — with clients acknowledging inherent privacy and data security risks (e.g., potential for environmental interruptions or rare breaches).

  • GDPR: We process health data lawfully (contract basis for therapy; explicit consent/special category for health). Privacy Notice provided at intake details data use, rights (access/erasure), and storage.

  • Tech Protocols:

    We use various secure platforms to provide our service —

    • Calendly (scheduling): Acts as data processor with a DPA incorporating SCCs/UK Addendum; data primarily processed in the US (transfers via EU-US Data Privacy Framework/SCCs); secure and GDPR-committed for special category data.

    • Google Meet/Google Workspace/Admin (sessions and administration): Processor with Cloud DPA/SCCs; data regions configurable (EU/UK options available); end-to-end encryption for Meet; strong security features for sensitive health data, compliant with UK GDPR.

    • Squarespace (website, only as necessary): Processor with DPA/SCCs and certification under EU-US/UK Data Privacy Frameworks; processes data securely with compliance tools (e.g., cookie banners) for EU/UK users.

  • Digital records: Use encrypted platforms, secure transfer/storage (UK/EEA priority where possible; international transfers via adequacy decisions/SCCs). No recordings of sessions are made; retain/delete per policy.

7. Partnership and External Referrals

We partner with local authorities, NHS, charities (e.g., Mind, Samaritans), and police as needed. For organisational clients, we integrate with their safeguarding policies.

8. Monitoring and Review

  • Annual audits of procedures, incidents, and training.

  • Anonymous client feedback via surveys.

  • Biennial updates (or sooner after legislative changes, e.g., Mental Health Bill 2025).

If you have any concerns or queries, please contact our Safeguarding Lead immediately. We are here to provide a safe, supportive, and compassionate space for every client.

Last reviewed: 15/01/26