Our Policies

Pleaes see below for our policies regarding complaints and how we manage your data.

Our Complaints Procedure

We want to know if you are unhappy about any aspect of your experience at Thrive Counselling CIC and have procedures for you to use to raise issues when necessary. It is the policy of Thrive Counselling CIC to resolve as quickly and fairly as possible, any grievance anyone may have.

If you are unhappy about any aspects of your experience at Thrive Counselling CIC, as a first step, you should raise the issues with the Service Manager. In many cases, they will be the best person to help you. You can raise your complaint in writing, via email, or through a discussion with the Service Manager.

If you are unable to resolve matters to your satisfaction, it may be appropriate for you to use Thrive Counselling CIC’s formal complaints procedure.

Thrive Counselling CIC Complaint Procedures

Purpose

The purpose of this procedure is to provide a means by which a member of the public, or a therapist on placement or offering associate services, can bring a complaint against another staff member or placement student at Thrive Counselling CIC.

A grievance may be brought to Thrive Counselling CIC by any of the following:

Placement students
Tutors, supervisors, or consultants whose services are contracted by Thrive Counselling CIC
Thrive Counselling CIC staff and directors
The Community Board
Clients of Thrive Counsellign CIC

Complaint procedures may also be invoked by Thrive Counselling CIC or by a group within Thrive Counselling CIC against an individual within Thrive Counselling CIC.

Process

Complaints will normally be addressed to the Director of Thrive Counselling CIC. Advisors external to the CIC may be co-opted in from time to time.

A Thrive Director may decide that a senior member of the counselling or psychotherapy community may more appropriately deal with a matter. Thrive Counselling CIC’s external independent complaints reviewer is Andy Williams TSTA(P).

If the matter is referred to our external independent complaints reviewer (EICR) then:

Thrive Counselling CIC will advise the complainant that the matter has been passed onto the EICR
The EICR must have no connection with the complainant
The EICR will review the complaint, the actions taken to date, and the case, and then make a decision whether to uphold the complaint.

The EICR will inform the complainant of their decision at the earliest opportunity (see below).

All individuals involved in the complaint procedures must act in a manner that does not breach confidentiality. Written material relevant to the complaint should be dated, and all verbal communications relevantly recorded and dated.

The complaint procedure is investigative and with the guiding principle of establishing truth, justice, and fairness. This policy sets out the informal procedures, which may be followed initially to see if there are grounds for resolution. Formal procedures can be found below and may be followed by adjudication and the use of disciplinary procedures.

A formal complaint must be lodged within one year of the alleged event(s), which form the substance of the complaint. Normally procedures are completed within three months of the receipt of the formal complaint. Time boundaries must be clearly established at the outset and strictly adhered to throughout. Where time boundaries cannot reasonably be maintained, then all parties involved in the complaint should be informed and provided with a clear written explanation.

Initiating a Complaint

A person wishing to raise a complaint may have initial and confidential discussions on matters of procedure with a Thrive Director. If the complaint concerns a Thrive Counselling CIC staff member, the complainant is recommended to first speak with the Service Manager.

The purpose of the initial discussions is to inform the complainant of the relevant procedures. A copy of the appropriate Code of Ethics & Professional Practice and Complaint Procedures will be made available to the complainant.

After this initial meeting, the complainant may wish to pursue the complaint through the informal or formal procedure. In either case, the complainant will make a written statement of their complaint and send it to the Thrive Director. This written statement from the complainant will be acknowledged in writing by the Thrive Director within 10 working days.

All written communications between the complainant and the Thrive Director will be photocopied and made available to the person against whom the complaint is expressed.

Informal Procedures

Thrive Counselling CIC is not responsible for travel or any other expenses incurred either by the complainant or by the person against whom the complaint is expressed in connection with any stage of the complaint procedure.

When a complaint is received by a Thrive Director, informal procedures may be suggested in the first instance. A complaint may be brought on the following grounds:

Offensive or destructive behaviour, in-person or online, or through any means of communication
Behaviour that goes against natural justice
Unfairness
Discrimination, including hate speech

Informal procedures are not normally considered appropriate when a complaint alleges:

Professional misconduct
Failure to comply with the Codes of Ethics & Professional Practice.
A breach of criminal law
Behaviour that might bring Thrive Counselling CIC, the UK counselling and psychotherapy membership bodies, and the professions of counselling and psychotherapy into disrepute.

The Thrive Director will appoint a mediator, who should have no connection with the complainant, or with the person against whom the complaint has been expressed. The mediator will normally be a senior member of Thrive Counselling CIC. In the interests of natural justice, the person against whom the complaint is expressed will be informed of the complaint. The mediator may arrange either separate or joint meetings with the complainant and the person against whom the complaint is expressed. The mediator will report the outcome to the Thrive Director in writing. Having completed their report to the Thrive Director the mediator will take no further part in any subsequent procedures.

This informal procedure should normally take place within 28 working days of the receipt of the written complaint.

Formal Procedure

If the complainant wishes to pursue a formal ethical complaint against a student or qualified counsellor or psychotherapist, then they must contact the individual’s membership body and follow their complaint procedures.

Appeal of Initial Complaint Process

If the complainant is unhappy with the decision reached by the mediator, they can appeal the decision, in writing, outlining any additional evidence concerning the complaint or any evidence regarding a breach of the complaint process. These are the only two grounds for appeal. The appeal will be acknowledged in writing and Thrive Counselling CIC will consider the appeal within 28 days.

The appeal will be considered by Thrive’s directors, the mediator and any other professionals as required. The complainant will be advised of the appeal outcome within 28 days of their written appeal.

External Independent Complaint Reviewer (EICR)

The complainant can ask the EICR to review the complaint

process. The complainant must write to Thrive Counselling CIC within 28 days of their appeal decision to ask for an external review.

The EICR will consider the complaint, including all documentation and evidence, and review the decisions made. The EICR will make a final decision regarding the complaint and their decision is final, with no further avenues of appeal.

The EICR will acknowledge receipt of the complaint and associated documents and will return their assessment, in the form of a written report and decision within 12 weeks to Thrive Counselling CIC and the complainant. The EICR is unable to consider any new information about the complaint.

Our Privacy Policy

GDPR provides increased protection for your personal data by imposing a framework of rules for organisations, which handle or process such personal data.

What personal information will you collect about me?

Name
Gender (or preferred identity)
Age
Date of Birth
Relationships & Children
Occupation
Address
Telephone/text number (plus permission to send texts & leave voice messages)
Email address
Counselling & psychotherapy history
Medical conditions relevant to counselling and psychotherapy
Prescribed medication

Mental Health services treatment

Use of alcohol and other non-prescribed substances

Criminal history
Session summaries

Outcome measures and assessments

How will my information be stored?

STORAGE METHODS

Format : Digital

Written notes (described below)

Mobile Phone:

We will store your contact information on our mobile devices. This allows us to contact you in case of emergencies.

Emails and Texts:

Your email address and correspondence will be stored on our email account if you contacted us in this way. Any email discussions will be stored. Your telephone number will also be stored, including call logs and any text messages exchanged. This includes messages through WhatsApp.

What documents will you keep?

Document Form: Digital

Client Information Form
Contract including GDPR Agreement

Assessment Tools such as HADS or PHQ-9
Brief Session Notes

How might you process or share my personal information?

EMERGENCIES

If your health is in jeopardy (provided we have your consent) we may share your contact information with an emergency healthcare service (e.g., Mental Health Crisis Team).

If we have become aware of your intent to cause harm to another person/organisation (e.g., terrorism), the law may require that we inform an authority without seeking your permission. In such a situation, the law may require that we share your personal information without your knowledge.

ERASING YOUR INFORMATION

When we have finished working together, we will erase electronic copies of your contact details within one month.

We will hold onto any digital and written information such as client notes, assessment forms and outcome measures, for up to seven years past the end of our working together. This is so that we have a reference of our work in situations such as you returning to therapy in the future. After this time has passed, we will destroy all information held.

YOUR RIGHTS

You have the following rights

To be informed of what information Thrive Counselling CIC hold (i.e. this document).
To see the information Thrive Counselling CIC hold about you (free of charge for the initial request).
To rectify any inaccurate or incomplete personal information.
To withdraw consent to Thrive Counselling CIC using your personal information.
To request your personal information be erased (though we can decline whilst the information is needed for us to practice lawfully and competently).

Our Digital Policy

This digital policy aims to address and contain the most likely eventualities that may arise by way of digital exposure, also with reference to maintaining privacy and data protection.

This document acknowledges the complex world of digital media and tries its best to address issues that may impact the therapeutic relationship.

Thrive Counselling CIC's media activities:

Please be aware that a part of the organisation's presence is in the public domain. Thrive Counselling CIC maintain an active social media presence. Online resources such as X, Facebook, and Instagram enable us to reach a broad swathe of people to whom we can communicate psychological concepts, ideas and theories that we hope can be useful in their lives. We hold a duty of care and confidentiality to our counselling & psychotherapy clients and supervisees as sacrosanct and consider our y media work to be related to, but completely separate from our clinical work.

Keeping Boundaries:

The nature of an online presence can blur interpersonal boundaries, so it is important to be as clear as possible about how boundaries may be compromised. As a general rule, Thrive Counselling CIC keep clinical work in the consultation room as much as possible. However, the nature of the

digital world can sometimes stretch these boundaries,.

Data Protection:

If you are a client or supervisee, you will have been asked to sign a GDPR compliant data protection policy – a copy of which can be seen at the end of this document.

Email:

Thrive Counselling CIC are not currently using an e-mail encryption programme, so any emails sent to each other may be vulnerable to viruses or human error. For this reason, it is best to be thoughtful about what you include in emails to us, and which email address you choose to use with us. Often, it is best to rely on email for non-confidential communications like setting up appointment times and things like that. In an effort to keep confidential and psychological material “in the room” it is best avoided in emails unless we discuss it beforehand. Thrive Counselling CIC will always request your preferred email address from our welcome call. If you choose to communicate with us by email, be aware that all emails are retained in the logs of Internet Service Providers. Furthermore, they can be vulnerable to viruses and unintended forwarding or replication. If you are concerned about the confidentiality of your emails, you may wish to contact us by telephone instead.

We check emails only at fixed times during office hours – we do not read emails on weekends and holidays. We endeavour to respond to all emails within 24 hours upon opening them. If the Thrive Counselling team are away for an extended period, you will receive an automated response. Emails should never be used in the event of an emergency; in which case you should contact emergency services.

Text messages:

You may feel free to contact Thrive Counselling CIC by text message to alert us if you are running late for a session or for similar reasons. However, because of the lack of context of text messages, it is generally not the best method for communicating with us about more important matters, so please do phone and leave us a message.

Thrive Counselling CIC are unable to offer an emergency service, even by phone. Should you experience an emergency please contact either the emergency services or if you are feeling suicidal, ring The Samaritans: 116 123.

Telephone and Video Calls:

Thrive Counselling CIC offer telephone and online sessions. Our therapists use a variety of online video conferencing software packages. You will be advise of the platform used and given joining instructions. When engaging via video conferencing, we both agree not to record sessions, usless a separate agreement is made with your therapist. In this event. your therapist becomes the data controller of the recording. Please check with them for their data policy.

It is also crucial that you’re sure your environment from which you are conferencing is safe, secure, and private.

Social Media:

Thrive Counselling CIC maintain a public Facebook Page, and Instagram as a way of promoting psychological ideas through the media, and to make people aware of workshops, conferences, or other events that Thrive Counselling CICI may be taking part in, or that might be of interest to followers. We frequently send across relevant links and sometimes engage in public conversations on these topics. Despite our online presence, we would prefer any therapy relationship remain as much as possible in the therapy room, therefore we will not knowingly engage with clients over social media. Whether you follow us or not is of course to your discretion. Thrive Coounselling CIC acknowledge that there can be some overlap across social networks, and that this sometimes comes to light on Facebook. If this were the case, it would be something we would need to discuss.

Google:

Our therapists do not Google clients. Thriive Counselling CIC am aware, however, that clients will often Google prospective therapists as part of their process in choosing one. If you did so with us, and this produced any questions, we would be happy to address them with you. Going forward, we have found it is best to find out from each other what we need to know face-to-face.

General Data Protection Regulations

You have a right to know what information I keep about you. In addition to the information collected By Thive Counselling CIC on their Welcomer Call, therapists will also keep notes about your sessions together.

These notes are kept digitally on a password protected Google Drive and are not kept alongside information that identifies you. These notes are not shared with anyone other than anonymously within supervision or other professional confidential contexts. Under rare circumstances, notes can be subpoenaed in a court of law. Because of this, Thrive Counseleling CIC ask all therapists to keep brief, factual notes.

Thrive Counselling CIC will keep your notes for the period to which we are obliged which can be anywhere from 3 to 7 years, after which they will be destroyed. You have the right to request any information Thrive Counsellign CIC keep about you and these will be sent to you within one calendar month.

We also keep your contact information, email, phone number, address, and GP details in our digital contacts so we can contact you if necessary.

Emails may also be vulnerable to hacking or miss-sending by human error. If you would prefer not to communicate by email, please let us know. Otherwise, it is best to use email only for logistical purposes (changing session times, etc.).

You have the right to have the information Thrive Counselling CIC hold about you erased. If you would like us to delete your information, let us know. However, as above, we may need to retain your notes for a required period of time, after which they will be deleted. In general, we will only hold the minimum of information we need about you to carry out our duties and will regularly audit and clear such data.

Thrive Counselling CIC are registered with the Information Commissioners Office to hold such records.