Complaints Process

NCIP Complaints & Whistleblowing Policy and Process

NCIP Dealing with Complaints & Whistleblowing

The NCIP is a professional organisation holding an Accredited Register of Integrative Psychotherapists. This includes any or all of the following: psychotherapists, counsellors, hypnotherapists, and wellbeing coaches.  We are committed to promoting and providing high standards of safe and ethical conduct for all our members.

We are here to listen to the voices of therapists and clients, and to share viewpoints, opinions, and experiences of therapy (both positive and when occasionally things may have not gone as expected). It is important that everyone feels heard. The NCIP is also aware that occasionally some therapists may breach our Code of Ethics. In such a case, this needs to be dealt with fairly, transparently, and proportionately, to protect the public.

Complaints & Whistleblowing Procedure Protocol

The National Council of Integrative Psychotherapists (NCIP) is committed to maintaining high standards of professional conduct among its members. The Complaints Procedure is designed to address any complaints made against members in a fair, transparent, and efficient manner.

This process is used for a complaint or whistleblow against a member, volunteer, Accredited Training Provider, or member of NCIP staff.

Members of the Complaints Committee are externally trained for complaints handling and internally trained for the NCIP-specific Complaints Process & Protocol.

The NCIP, like most professional bodies, does not investigate cases that are over 24 months old.

Please note: A member who does not comply with the Complaints Process risks being removed from the NCIP register. Non-compliance to the complaints process is a breach of the NCIP's Code of Ethics (G. Compliance point 41)

Stages of the Complaints & Whistleblowing Process:

For a visual on the process of a complaint or whistleblowing against a Member/Accredited Training Provider/Volunteer/Staff, please Click Here.

For reference:

CoE - Code of Ethics

CoC - Code of Conduct

CC - Complaints Committee - The CC consists of volunteers who oversee complaints and whistleblowing, ensuring fair and thorough investigations.

CTO - Complaints Triage Officer - The CTO is a member of the Complaints Committee and helps rank the severity, nature, and validity of complaints against members, accredited trainers, volunteers, or staff using the Triage protocol (see below).

• To ensure unbiased decisions during triaging, the CTO does not participate in formal complaint investigations. Additionally, the CTO identifies and flags potential conflicts of interest in the triaging or investigation processes. 
• As the Complaints Committee Lead, the CTO is responsible for responding to initial complaint emails and coordinating with the involved member, accredited trainer, volunteer, staff member, and complainant.

Vexatious or Harassment Complaints 

The NCIP is unable to investigate complaints deemed to be vexatious or harassing. This applies to complaints perceived as being made in bad faith or those indicating malice, particularly as part of a broader pattern of stalking or harassment against a member.

Introduction to Triage Protocol

The Triage Protocol for the Complaints Triage Officer (CTO) at the National Council of Integrative Psychotherapists (NCIP) involves a ranking system to assess and categorise complaints based on their severity and risk level. This system ranges from 1 (no risk) to 5 (extreme risk requiring legal intervention).

Key to Triage Ranking System:

Level 1 (No Risk): Complaints with no apparent risk or harm to clients, colleagues, or the public. Minor professional conduct issues.

Level 2 (Low Risk): Complaints indicating low risk, possibly involving minor ethical or professional misconduct breaches.

Level 3 (Moderate Risk): Complaints with potential for moderate harm or significant professional standards breaches. Requires detailed investigation, especially if the client/trainee feels frightened or intimidated.

Level 4 (High Risk): Serious complaints suggesting substantial risk of harm or major ethical violations. Immediate action may be needed, e.g. temporary suspension.

Level 5 (Extreme Risk/Legal Intervention): Complaints indicating extreme risk, illegal activities, or emergency safeguarding issues. Requires immediate higher authority intervention, e.g. police, or social services.

Stage 1. Initial Complaint

• Receipt of Complaint: All complaints should be submitted in writing using the form provided on the Making a Complaint page. The Complaints Triage Officer (CTO) receives the complaint via the complaints email. Upon receipt, the complainant will be acknowledged formally by email and directed to the Complaints Procedure for information on how their complaint will be processed.
• Complaints Triage Officer (CTO) receives complaint: CTO receives the initial complaint form via email and acknowledges it within seven working days.

Stage 2. Triage Stage

• CTO Assessment: The CTO evaluates the complaint during the initial triage phase. This involves determining the nature of the complaint, checking if it falls within the NCIP’s remit, and classifying it appropriately. This assessment will be completed within ten working days from the acknowledgment of the email. For more details, refer to the NCIP Triage protocol (see above) which covers the assessment of a complaint's nature, validity, and severity.
• Vexatious or Harassment: During the initial assessment, the CTO also checks for vexatious or harassing content. If a complaint is deemed vexatious or harassing at this stage, the process will be terminated, and the complainant and the Member will be informed accordingly.

CTO Triage Level 1, 2, 3, & 4.  

 The Complaints Committee aims to conclude a full investigation within sixty working days. *

* Please note that this time frame of sixty working days is to provide a reasonable length of investigation. Please be aware that in some cases it may take longer due to the complexity of some complaints.

CTO Triage Level 5. 

• The Complaints Committee is unable to provide a timeframe due to the nature of the complaint and other authorities' involvement. 

Stage 3. Right to Respond

      Levels 1, 2 & 3 

• Notification to the Member: The member is notified of the complaint and given the right to respond to the Complaints Committee (CC). They receive a Respondent’s Allegation Response Form 
• and may submit any evidence to counter the complaint. They are also provided with information about the Complaints Process to understand the subsequent steps.
• Response Time: The member has fourteen working days to respond to the complaint.
• Investigation Timeline: The Complaints Committee aims to complete a full investigation within sixty working days.

      Level 4 Notification to the Member: 

• The CTO's report and initial complaint form are passed to the Complaints Committee (CC) for investigation and deliberation due to the severity of the complaint.
•  The CTO provided the member with a Respondent’s Allegation Response Form and issued a notice of temporary suspension. The member is given fourteen working days to respond. 
• The CTO contacts the Registrar with justification for temporary suspension.
• *The suspension term is subject to the length of the investigation & outcome.

      Level 5: If a crime has been alleged:  

• If a crime has been alleged, the CTO's report and the initial complaint/whistle-blow form must be sent to the appropriate authorities (Police/Social Services, etc.) to ensure safeguarding and non-collusion with possible criminal activity. 
• The Complaints Committee will be unable to continue with any investigation until the authorities are no longer involved.
• At this stage, the member is suspended from the register and sanctioned to remove all NCIP affiliation.
   

Stage 4. Opportunity for Informal Resolution 

      Levels 1 & 2. 

• The complainant is asked by the CTO via email if they wish to resolve the complaint informally with an option for mediation (if appropriate).

      Level 3. 

• Once the Member has responded, The CTO's report, initial complaint form, and the Member's response are passed to CC to begin an investigation.
• Investigations will include any known/potential conflicts of interest and will exclude the CTO.

      Level 4. If no serious safeguarding issues have been found by the CC or CTO: 

• Once the Member responds, the CTO sends The CTO's report, initial complaint form, and the Member's response to the CC to conduct a formal investigation.
• The Investigation will include any known/potential conflicts of interest and will exclude the CTO
• If serious safeguarding issues are found by the CC or CTO: Triage Level 5 is initiated.

 Stage 5. Informal Resolution - Investigation - Case Dropped

      Levels 1 & 2. 

• If there is a mutual agreement for informal resolution with or without mediation chosen, no further action in the complaints process is required and the process is ended here.
• If informal resolution is unsuccessful, the complaints process continues to the next stage. 

      Levels 3 & 4. 

• Once the investigation has been finalised, the Complaints Committee (CC) passes their investigation findings to the Complaints Triage Officer (CTO) for the final triage.  

      Level 5. 

• If the member is found not guilty or has charges against them dropped, the CTO and the CC will require Quality and Risk and Safeguarding to deliberate and decide on: 

1. a new triage level and a timeframe for a suspension lift.
2. conditions to support the member. 

• The CC will contact the Registrar with this information. 

Stage 6. 

      Levels 1 & 2. 

• Once the Member has responded, The CTO's report, initial complaint form, and the Member's response are passed to CC to begin an investigation.
• The Investigation will include any known/potential conflicts of interest and will exclude the CTO. 

      Level 3. CTO's Final Triage

• If the CTO's final triage is determined at level 4 or 5 (using the NCIP Triage protocol) the appropriate triage level is initiated at stage 3 (see CTO & CC Flow Chart).
• If the Final Triage has not changed from Level 3, then Stage 7 is initiated.

      Level 4. CTO's Final Triage

• If the CTO's final triage is determined at level 5, triage level 5 is initiated at stage 3.
• If the Final Triage has not changed from Level 4, stage 7 is initiated.

Stage 7. 

      Level 1.  

• Once the investigation is finalized, the Complaints Committee (CC) will send the final finding to the CTO. If no breaches of the Code of Conduct or the Code of Ethics are found, no further action will be taken. 
• The CTO will send emails to both the Member and the complainant closing the case with no further action to be taken.
• If minor breaches are found. Recommendations will be sent to the member.

      Level 2. 

• Once the investigation is finalised, the Complaints Committee (CC) passes the investigation findings to the CTO for the Final Triage.

      Levels 3 & 4.

• Using the Sanction Criteria, all CC Members and the CTO meet to decide the appropriate sanction(s) and actions, using a majority voting system to decide the final verdict.
• All members in this meeting are equal voters.

Stage 8. Decision Sanction(s) & Appeal option

      Level 2. CTO's Final Triage.

• If the CTO's Final Triage is determined to be at levels 3, 4, or 5, the appropriate triage level is initiated at stage 3.
• If the Final Triage has not changed from Level 2, stage 9 is initiated.

      Level 3.

• The CTO reports redacted findings via email to both the Member and complainant.
• The CTO issues Sanction(s) and actions to the Member and gives the Member ten working days to respond to the decision.
• An Appeals Process is supplied to the Member in the same email. 
• If the Member decides to appeal, they are suspended for the duration of the appeals process, or until all sanctions have been fulfilled.
• If the Member accepts the sanction(s), the sanction/action period starts from the date of acceptance until the sanction has been fulfilled.
• The CTO contacts the Registrar with justification of sanction to action.
• The Complaints Process is ended here.

Stage 9.

      Level 2.

•  Using the Sanction Criteria, all CC Members and the CTO meet to decide the appropriate sanction(s) and actions, using a majority voting system to decide the final verdict.
• All members in this meeting are equal voters. 

 Stage 10. 

      Level 2.

• The CTO reports redacted findings via email to both the Member and complainant.
• The CTO issues Sanction(s) and actions to the Member and gives the Member 10 working days to respond to the decision.
• An Appeals Process is supplied to the Member in the same email. 
• If the Member decides to appeal, they are suspended for the duration of the appeals process, or until all sanctions have been fulfilled.
• If the Member accepts the sanction(s), the sanction/action period starts from the date of acceptance until the sanction has been fulfilled.
• The CTO contacts the Registrar with justification of sanction to action.
• The Complaints Process is ended here.

Right to Appeal: An appeal process is supplied to the member. A Complaint Review Process (conducted by the Appeals Committee) is supplied to the complainant. If the member requests an appeal, then the member will be suspended for the duration of the appeals process until the Appeals Committee reaches a final decision. 

Record-Keeping and Confidentiality

• Documentation: All documentation and communications about the complaint are to be securely stored.
• Confidentiality: Strict confidentiality must be maintained throughout this process, with information only shared with relevant parties.

Continuous Improvement

• Review of Procedures: Regular reviews of the Complaints Procedure should be undertaken to ensure its effectiveness and fairness.

Excluded Categories of Complaints

Sometimes it is not either appropriate or within the scope of the NCIP to become involved in a complaints process. The following are examples of exclusion:

• Therapies not covered by the NCIP.  Where there is no element of counselling, psychotherapy, hypnotherapy, or coaching involved in the complaint. This would apply to registered members who offer other non-related therapies and this was the main purpose of seeking their services (ie. homeopathy, naturopathy, aromatherapy, Reiki, etc.). For this reason, the NCIP strictly forbids the advertising of such adjunctive services on its site under the member’s listing. The complaint should therefore be directed toward the professional body for therapy under concern.
• Private life of therapists. This is not normally an area for complaint to the NCIP. The only exception here would be if the member were acting in a manner that would bring the profession into disrepute. 
• Disputes between therapists.  The only exceptions are where there is real evidence of client harm or a breach of the Code of Ethics.
• Family disputes and custody disputes. Unless there is a clear case of safeguarding concerns that are likely to impact practice or bring the profession into disrepute. 
• No impact on a client or anybody/thing else. Where there is no real or perceived threat of any harm.
• Overseas practice. ICIP (International Register) It is not within the scope of the NCIP to investigate complaints of international members where there are local or cultural variations to those within the United Kingdom, or there has been no breach of the Code of Ethics. For example, local restrictions in terms of gender, disability, marital status, age, religion, LGBTQIA+ status, etc.
• Advertising (ASA).  Members will be approached directly in terms of their advertising if there is a complaint against them. Notification is given in terms of misleading advertising and they will be given 14 working days to address this issue. If a member knowingly and repeatedly breaches advertising rules, then they may be reported to the ASA or be suspended. If their advertising breaches the Code of Ethics, then they will be investigated following the usual process.
• Couples Therapy or Group Therapy.  The NCIP cannot hear complaints regarding group or couples therapy without obtaining consent and evidence from all involved.
• Vexatious/Harassment. The NCIP cannot investigate “vexatious” or harassing complaints.  This means where a complaint is perceived to be acting in “bad faith” or where the complaint is made in a way indicating pure spite as part of a wider picture of stalking or harassment against a member.