Category: Uncategorized

Grey Matters Centre and the Integration Centre, where applicable.

1. Purpose, scope and responsibilities

Every complaint about therapy at Grey Matters Centre (GMC) and Integration Centre, where applicable, is acknowledged within 3 working days and receives a written response within 20 working days. Safeguarding concerns are acted on the same day. In this policy, references to GMC include the Integration Centre where applicable.

All therapists at GMC are self-employed. They hire rooms from GMC and contract directly with their clients. GMC also promotes them on its website and social media, so it has a duty to take concerns seriously, act on risk and keep its marketing accurate.

GMC cannot investigate a therapist’s clinical judgement, order a refund or award compensation for a therapist’s services. Those matters sit with the therapist, their professional body or the courts.

This policy covers current and former clients, anyone acting for a client with their consent and the parent or guardian of a client under 18. Complaints should be made within 12 months of the event or of becoming aware of it; GMC may accept later complaints where there is good reason.

This draft is not legal advice. It should be checked by a solicitor and GMC’s insurer before adoption.

2. Principles and definitions

GMC handles complaints fairly, confidentially and without penalty to the person complaining.

• Accessible: complaints can be made in person, by phone, by email, by letter or on the complaint form (Appendix B). GMC makes reasonable adjustments under the Equality Act 2010, such as help writing a complaint down.
• Fair: the client and the therapist are both heard before any decision. Nobody investigates a complaint about themselves.
• Confidential: information is shared only with those who need it to resolve the complaint or to keep someone safe.
• No detriment: complaining will not affect a client’s access to GMC or to any other therapist at the centre.
• Timely: GMC keeps to the timescales in section 5 and explains any delay in writing.
• Learning: GMC reviews complaints each year to improve its service.

3. Safeguarding and serious concerns

A complaint that suggests anyone is at risk of harm is treated as a safeguarding matter first and a complaint second. The DSL must be told the same day.

Examples include:

• sexual, romantic or inappropriate personal contact between a therapist and a client
• physical, emotional or financial abuse or exploitation by a therapist
• a disclosure that a child or an adult at risk is being harmed
• a client at immediate risk to their life or safety
• a therapist appearing to work while impaired by alcohol or drugs
• any allegation of a criminal offence

What to do

1. If anyone is in immediate danger, call 999.
2. Listen, stay calm and write down what was said in the person’s own words with the date and time. Do not question in depth or investigate.
3. Do not promise to keep the information secret. Explain who it will be shared with and why.
4. Tell the DSL the same day. If the DSL is unavailable, tell the deputy or contact the relevant agency directly.
5. The DSL decides on referral, normally within 24 hours:
   1. a child under 18 → local children’s social care
   1. an allegation against a therapist who works with children → the Local Authority Designated Officer (LADO)
   1. an adult at risk → the local adult safeguarding team under the Care Act 2014
   1. a possible crime → the police (999 or 101)
6. The DSL notifies the therapist’s professional body and takes advice on whether a referral to the Disclosure and Barring Service is required.
7. GMC pauses the therapist’s room hire and marketing while the matter is looked into. This is a protective step, not a finding of fault.
8. The DSL records every decision with its reason and stores the record securely.

Information may be shared without consent where it is needed to protect someone from serious harm or to prevent or detect a crime. UK GDPR and the Data Protection Act 2018 permit this. GMC records why the information was shared.

Once everyone is safe, the complaint continues through section 5 unless the police or the local authority ask GMC to pause.

4. Which route a complaint takes

Risk is checked first. Every other complaint follows one of three routes depending on what it is about.

Where a complaint touches more than one route, GMC handles each part on its own route and sends one combined response.

5. Complaints procedure

The formal procedure has three stages after optional early resolution. A client can start at stage 1 and never has to approach the therapist first.

If more time is needed the Complaints Lead writes to the client before the deadline, explains why and gives a new date.

The written outcome states:

• what was complained about
• what GMC found or what the therapist said
• any action GMC has taken or will take
• how to request a review
• where to go next if the client remains unhappy

External routes are open after stage 3 or at any time:

Unreasonable behaviour: GMC will not tolerate abuse of staff or therapists. Where contact becomes persistently unreasonable or abusive, the Complaints Lead may limit it to one channel and will explain this in writing. The complaint itself is still answered.

6. Centre actions, confidentiality and records

GMC’s own decisions about a therapist are limited to room hire and marketing. They are proportionate to the concern and are written into every therapist’s agreement (Appendix A).

Fairness to therapists: the therapist is told about the complaint (with the client’s consent), can respond in writing and receives GMC’s decision in writing. They may ask Louise Fenton to reconsider once within 10 working days.

Marketing accuracy: any inaccurate claim on the website, social media or a therapist profile is corrected within 2 working days of being identified. GMC checks each therapist’s listing against their professional body’s register every quarter and follows the CAP Code for advertising claims.

Confidentiality and data: GMC is the data controller for the complaint records it holds; each therapist is the controller for their own client records. Complaints often include health information, which is special category data under UK GDPR. Access is limited to the Complaints Lead, the DSL and the reviewer.

Records: every complaint is entered in a secure complaints log with the date received, route, actions, timescales met and outcome. Complaint files are kept for 6 years after closure, then securely destroyed. Safeguarding records may need to be kept longer; the DSL takes advice.

Review: Louise Fenton reviews the complaints log each year for themes and shares lessons with therapists without identifying anyone. This policy is next reviewed by 22 October 2027.

Appendices

Appendix A: Clauses for therapist agreements

Every therapist agreement requires the therapist to:

• hold current membership of a recognised professional body and give GMC their registration number
• hold professional indemnity insurance and provide a copy each year
• hold an enhanced DBS check where they work with children or adults at risk
• complete safeguarding training and follow this policy
• give clients their own complaints procedure and professional body details at the start of therapy
• tell GMC within 5 working days of any complaint to their professional body, any restriction on their practice or any police investigation
• respond to GMC about a complaint within 10 working days
• accept that GMC may pause marketing, suspend room hire or end the agreement under section 6

Appendix B: Complaint form fields

• Name and contact details, with preferred contact method
• Therapist’s name (if relevant)
• What happened, with dates
• What outcome the client is looking for
• Consent to share details with the therapist (yes or no)
• Is anyone at risk now? (yes or no)
• Any support or adjustments needed to take part

Appendix C: Contacts to complete