Safeguarding Policy

Private Counselling Practice – Adults, Children and Young People

Practice name: Dandelion Therapy
Counsellor: Ali Husbands
Professional membership: BACP 393428
Policy owner: Ali Husbands
Policy version: 1.0
Date adopted: 24.10.2026
Effective date: 24.10.2026
Review date: 01.10.2027
Safeguarding lead: Ali Husbands – 07359 595005
Local authority: Milton Keynes

1. Purpose of this policy

This policy sets out how Ali Husbands will safeguard and promote the welfare, safety and dignity of adults, children and young people who access counselling services.

The policy establishes procedures for recognising, responding to, recording and reporting concerns about abuse, neglect, exploitation, self-harm, suicide risk and other circumstances in which a client or another person may be at risk of harm.

The policy applies to all counselling delivered by the practice, including face-to-face, telephone, online, individual and, where offered, family or joint sessions.

As an independent practitioner, the counsellor recognises that safeguarding is a professional and ethical responsibility. Being a sole practitioner does not remove the responsibility to act appropriately when a safeguarding concern arises.

This policy will be applied in conjunction with relevant legislation, statutory guidance, professional standards and local safeguarding procedures in England.

2. Professional and legal framework

The practice will work in accordance with applicable legislation, statutory guidance and professional requirements, including:

• The      British Association for Counselling and Psychotherapy (BACP) Ethical      Framework for the Counselling Professions 2026, from the date it becomes      mandatory for BACP members, and the applicable preceding framework during      the transition.
• The      Children Act 1989 and Children Act 2004.
• The      current statutory guidance Working Together to Safeguard Children.
• The      Care Act 2014, including the safeguarding of adults with care and support      needs.
• The      Mental Capacity Act 2005, where applicable.
• The      Human Rights Act 1998.
• The      Equality Act 2010.
• The      Data Protection Act 2018 and UK GDPR.
• Applicable      information-sharing guidance and relevant legal duties.
• Local      authority child protection and adult safeguarding procedures.

The practice will keep informed of changes to these requirements and update its procedures accordingly.

The BACP Ethical Framework informs professional judgement but does not replace statutory duties or legal advice where these are required.

3. Policy principles

The practice is committed to the following principles:

Safety and prevention: Taking reasonable and proportionate action to prevent abuse, neglect, exploitation and avoidable harm.

Client-centred practice: Respecting the rights, wishes, feelings, identity, dignity and individual circumstances of each client.

Empowerment and autonomy: Supporting clients to make informed choices and participate in decisions affecting their lives wherever possible.

Proportionality: Taking the least intrusive action consistent with managing the risk of harm.

Partnership: Working appropriately with clients, parents or carers, social care, healthcare professionals, schools, emergency services and other relevant agencies.

Accountability: Making defensible decisions, maintaining accurate records and documenting the reasoning behind safeguarding actions.

Confidentiality with appropriate limits: Protecting private information while recognising circumstances in which disclosure is justified, necessary or legally required.

Equality and inclusion: Recognising the additional barriers to disclosure and support that some people may experience, including disabled people, neurodivergent people and those facing discrimination, isolation or communication difficulties.

Professional integrity: Maintaining appropriate boundaries, competence, supervision and continuing professional development.

4. Definitions

For the purposes of this policy:

Child: Anyone under the age of 18.

Young person: A child or adolescent under 18. The term may also be used descriptively for older young adults where appropriate, but statutory child safeguarding procedures generally apply to those under 18.

Adult at risk: An adult who meets the relevant safeguarding criteria under applicable law and guidance. Under section 42 of the Care Act 2014, the local authority's enquiry duty applies where an adult has care and support needs, is experiencing or at risk of abuse or neglect, and because of those needs is unable to protect themselves from that abuse or neglect.

Safeguarding: Actions taken to prevent harm, protect people from abuse and neglect, promote welfare and respond to concerns about safety.

Abuse and neglect: May include physical, emotional, sexual, financial, discriminatory or domestic abuse, coercive control, neglect, exploitation, organisational abuse and other forms of mistreatment.

Safeguarding concern: Information, behaviour, circumstances or disclosures that indicate that a person may be experiencing harm or may be at risk of harm.

5. Roles and responsibilities

As a private counsellor, I retain responsibility for safeguarding decisions relating to my practice.

I will:

• Maintain      an up-to-date safeguarding policy and relevant contact information.
• Understand      local referral and reporting procedures.
• Recognise      and respond appropriately to signs and disclosures of abuse or neglect.
• Assess      immediate risk and take proportionate action.
• Refer      concerns to the appropriate statutory services.
• Seek      guidance from my clinical supervisor and relevant safeguarding      professionals.
• Maintain      accurate, factual and secure records.
• Undertake      safeguarding training appropriate to my client group and level of      responsibility.
• Maintain      professional indemnity insurance and other appropriate professional      arrangements.
• Review      my competence and suitability to work with particular client groups.
• Ensure      that safeguarding concerns about my own conduct or practice are not      concealed or ignored.

Where I am unavailable or unable to practise, I will have an appropriate plan for communicating service limitations and signposting clients to relevant support. I have a clinical executor in place who will contact clients on my behalf if I am unable to.

6. Safer practice and prevention

Before accepting a client, I will consider whether the presenting issues fall within my training, experience and professional competence.

I will explain the nature and limits of the counselling service, the complaints procedure, confidentiality arrangements and the circumstances in which safeguarding action may be necessary.

Initial assessment will consider, where relevant:

• The      client's immediate safety and wellbeing.
• Any      known safeguarding concerns.
• Current      or previous abuse, exploitation or neglect.
• Risk      of harm to self or others.
• The      client's support network and access to appropriate services.
• Relevant      communication, accessibility or additional support needs.
• Whether      counselling alone is an appropriate intervention.
• Whether      referral or joint working with other services is necessary.

Safeguarding concerns will be reviewed throughout the therapeutic relationship and not only at assessment.

I will maintain clear professional boundaries, avoid exploitation and inappropriate dual relationships, and take concerns about my own conduct seriously.

7. Safeguarding children and young people

7.1 Commitment to child protection

The welfare and safety of children and young people will be a primary consideration in decisions concerning their protection.

I will remain alert to signs that a child may be experiencing abuse, neglect, exploitation, domestic abuse, bullying, online abuse, sexual harm, criminal exploitation or other circumstances that may affect their welfare.

Concerns may arise from a child's disclosure, a parent's or carer's information, observations during counselling, information from another professional or other credible sources.

I will not require proof of abuse before seeking safeguarding advice or making an appropriate referral.

7.2 Recognising possible indicators

Possible indicators include, but are not limited to:

• Unexplained      injuries or repeated accounts of injuries.
• Significant      changes in behaviour, mood, attendance or presentation.
• Fear      of a particular person or reluctance to return home.
• Sexualised      behaviour or knowledge that is concerning for the child's age or      circumstances.
• Persistent      neglect of health, hygiene, nutrition or supervision.
• Disclosure      of physical, emotional or sexual abuse.
• Signs      of grooming, trafficking, exploitation or online coercion.
• Exposure      to domestic abuse or violence.
• Fear,      threats, controlling behaviour or inappropriate restrictions imposed by an      adult.
• Self-harm,      suicidal thoughts or other indicators of serious distress.

No single indicator necessarily establishes that abuse has occurred. Concerns will be considered in context and referred where appropriate.

7.3 Responding to a disclosure from a child

If a child discloses abuse or harm, I will:

1. Remain      calm, listen carefully and take the disclosure seriously.
2. Allow      the child to speak in their own words without interruption or pressure.
3. Reassure      the child that they have done the right thing by telling me.
4. Avoid      promising secrecy or making promises about outcomes.
5. Ask      only the minimum open, non-leading questions needed to understand      immediate safety.
6. Explain,      in language appropriate to the child's age and understanding, that I may      need to share information to help keep them or someone else safe.
7. Establish      whether the child is in immediate danger and whether they can safely leave      the session or return home.
8. Record      the disclosure accurately, distinguishing the child's words from my      observations and interpretation.
9. Contact      the appropriate children's social care service or police, depending on the      urgency and nature of the concern.
10. Seek      advice from my supervisor where appropriate, without delaying urgent      protective action.

I will not investigate allegations, conduct forensic interviews or confront an alleged perpetrator.

7.4 Referral to children's social care

Where there is reasonable concern that a child may be suffering or likely to suffer significant harm, I will refer the concern to the relevant local authority children's social care service promptly, completing a MARF (Multi Agency Referral Form).

Where a child is in immediate danger, or a crime requiring urgent police intervention is suspected, I will contact the police on 999.

For non-emergency police matters, I may contact 101 where appropriate.

If a referral is not accepted or I disagree with the response, I will consider the local safeguarding escalation procedure and seek further professional advice. I will not assume that making a referral transfers all responsibility for considering the child's immediate safety.

7.5 Parents and carers

Parents or carers will ordinarily be involved in decisions concerning a child where this is appropriate and safe.

However, I will not automatically inform a parent or carer of a safeguarding disclosure where doing so could:

• Increase      the risk of harm to the child.
• Place      the child at risk of intimidation, retaliation or coercion.
• Compromise      a police or social care investigation.
• Expose      the child to an alleged perpetrator.
• Undermine      an appropriate safeguarding response.

In these circumstances, I will seek advice from children's social care or the police about appropriate communication.

7.6 Children who may be at risk from adults or other children

Safeguarding concerns will be considered whether the alleged source of harm is a parent, carer, family member, professional, peer or another person.

I will not assume that abuse is less serious because the alleged perpetrator is another child or young person.

Where there is a concern about child-on-child abuse, sexual harassment, sexual violence, bullying, exploitation or coercive behaviour, I will consider the safety of all children involved and refer to the appropriate services.

8. Consent and confidentiality when counselling children

8.1 Consent and capacity

Before counselling a child or young person, I will consider their age, maturity, understanding, capacity to understand the proposed counselling and ability to make an informed decision.

I will explain counselling in an accessible manner and seek the child's meaningful participation and agreement.

For young people under 16, I will consider competence to consent in accordance with the applicable legal principles, including Gillick competence where relevant. I will also consider whether involving a person with parental responsibility is appropriate, lawful and in the child's best interests.

For 16- and 17-year-olds, I will consider their ability to give informed consent and the relevant legal framework.

The question of consent to counselling is separate from the question of whether information can or should be disclosed for safeguarding purposes.

Where parental consent or involvement is considered necessary, I will establish who has parental responsibility and consider any relevant court orders or restrictions.

8.2 Confidentiality with children

At the beginning of counselling, I will explain confidentiality and its limits to the child or young person in developmentally appropriate language.

I will explain these limits separately to parents or carers where appropriate.

I will not automatically disclose the content of a child's counselling sessions to their parents. Information will be shared in accordance with the child's rights, their capacity and consent, the agreed counselling arrangements, applicable law and safeguarding considerations.

Where information needs to be shared to protect a child or another person from harm, I will explain this to the child wherever it is safe and appropriate to do so.

I will consider the minimum information necessary to achieve the safeguarding purpose.

9. Safeguarding adults

9.1 Recognising abuse and neglect

I will remain alert to signs that an adult may be experiencing abuse, neglect, coercion, exploitation or other harm.

Potential concerns include:

• Physical,      sexual or psychological abuse.
• Domestic      abuse, stalking or coercive control.
• Financial      abuse, fraud or exploitation.
• Neglect,      self-neglect or failure to provide necessary care.
• Discriminatory      abuse.
• Modern      slavery, trafficking or exploitation.
• Abuse      by a professional, carer or organisation.
• Undue      influence, intimidation or isolation.
• Serious      risks arising from the person's living circumstances or support      arrangements.

An adult's age, disability, mental health difficulties or diagnosis will not, by itself, establish that they lack capacity or are unable to make decisions.

9.2 Responding to an adult's disclosure

When an adult discloses abuse or neglect, I will:

1. Listen      without judgement and take their concerns seriously.
2. Establish      whether they are in immediate danger.
3. Ask      what support they want and what outcomes matter to them.
4. Explain      the limits of confidentiality and discuss possible information sharing.
5. Consider      their ability to make the particular decision in question where capacity      is genuinely in doubt.
6. Explore      safety planning and appropriate sources of support.
7. Seek      consent for referrals and information sharing where appropriate and      lawful.
8. Contact      adult social care, the police or other relevant services where the      circumstances justify it.
9. Document      the concern, the person's wishes, my risk assessment and the reasons for      any action taken.

9.3 Adult autonomy and safeguarding

Where an adult has capacity to make the relevant decision, I will ordinarily respect their autonomy, including decisions others may consider unwise.

However, I will not assume that an adult's refusal of support automatically ends the safeguarding assessment.

I will consider whether there is a legal basis or compelling safeguarding justification for sharing information without consent, particularly where:

• There      is an immediate risk of serious harm.
• Other      adults or children may be at risk.
• There      are concerns about coercion, undue influence or impaired decision-making.
• A      serious crime may have occurred or may be occurring.
• A      legal obligation or other lawful basis for disclosure applies.

Where appropriate, I will seek advice from adult social care, the police, my supervisor or a relevant safeguarding professional. I will document the reasoning behind any decision to share or not share information.

9.4 Care Act 2014 referrals

Where the circumstances suggest that an adult meets the safeguarding criteria under section 42 of the Care Act 2014, I will contact the relevant local authority adult safeguarding service and provide the information needed for it to consider the concern.

The local authority determines whether its statutory enquiry duty applies. My responsibility is to identify concerns, respond appropriately and make a proportionate referral where indicated.

10. Self-harm, suicide and immediate risk

I recognise that clients may disclose suicidal thoughts, self-harm, thoughts of harming others or other situations involving significant risk.

I will assess concerns proportionately, considering the nature and immediacy of the risk, relevant circumstances, protective factors and the client's ability to access support.

Where appropriate, I will:

• Discuss      the risk openly and compassionately with the client.
• Develop      a collaborative safety plan.
• Identify      trusted people and professional support where suitable.
• Encourage      contact with the client's GP, NHS services or relevant specialist support.
• Seek      timely clinical supervision and professional advice.
• Consider      referral to crisis or emergency services.
• Record      the assessment, agreed actions and rationale.

If there is an immediate risk to life or serious injury, I will contact 999 or arrange urgent emergency assistance as appropriate.

For urgent mental health concerns that are not an immediate emergency, I may direct the client to NHS 111 and the relevant mental health crisis service, where available.

I will not rely solely on a client's promise not to self-harm as evidence that risk has been adequately managed.

Where there is a risk of harm to another person, I will consider the seriousness and immediacy of the threat, the information available, relevant legal obligations and whether disclosure to appropriate services is necessary and lawful.

11. Confidentiality and information sharing

Confidentiality is fundamental to counselling. It is not, however, absolute.

At the start of counselling, clients will receive an explanation of how their information is handled and the circumstances in which information may be disclosed.

Information may be shared, as appropriate and lawful, where:

• The      client gives informed consent.
• Disclosure      is required by law or a valid court order.
• Disclosure      is necessary and legally justified to protect the client or another person      from serious harm.
• A      safeguarding referral is necessary to protect a child or adult at risk.
• Another      lawful basis applies under relevant data protection legislation.

Before sharing information, I will consider:

• The      nature and urgency of the risk.
• The      purpose of sharing.
• The      legal basis and professional justification.
• Whether      consent can safely and appropriately be obtained.
• The      recipient's authority and need for the information.
• The      minimum information necessary to achieve the purpose.
• Whether      the client should be informed, unless doing so would be unsafe or      inappropriate.

I will share information securely with the appropriate service and record what was shared, with whom, when and why.

I will not delay an urgent safeguarding referral simply because consent has not been obtained, where the disclosure is otherwise justified.

12. Online and remote counselling

Where counselling is delivered online or by telephone, additional safeguarding arrangements will apply.

Before or at the start of remote work, I will establish:

• The      client's identity and age, where appropriate.
• Their      current location and a reliable contact number.
• An      emergency contact where appropriate and agreed.
• The      arrangements for responding if communication is interrupted during a      crisis.
• The      relevant emergency and safeguarding services for the client's location.

For children and young people, I will consider whether the environment is private, whether the child can speak freely and whether another person may be monitoring or influencing the session.

I will not assume that a child or adult is safe simply because they appear calm on screen.

I will use appropriate secure technology and take reasonable steps to prevent unauthorised access to sessions, communications and records.

If a client is located outside England, I will consider the safeguarding law and emergency arrangements relevant to their location and my professional responsibilities before proceeding.

13. Professional boundaries and safeguarding allegations

I will maintain appropriate boundaries in all professional relationships, including relationships with clients, parents, carers, colleagues, supervisors and other professionals.

I will not exploit clients financially, emotionally, sexually, physically or in any other way.

I will avoid inappropriate personal relationships, conflicts of interest and misuse of professional power.

If a client, parent, carer or another person raises a concern or allegation about my conduct, I will take it seriously and respond openly and professionally.

I will:

• Consider      whether anyone is at immediate risk.
• Take      proportionate action to prevent further harm.
• Seek      appropriate supervision and professional advice.
• Record      the concern and my response.
• Cooperate      with lawful investigations.
• Notify      my professional body, insurer or other relevant organisation where      required.
• Consider      whether a referral to the police, social care or another regulatory body      is necessary.

If an allegation concerns a person who works with children, I will consider whether referral to the local authority designated officer (LADO) or equivalent local arrangements is appropriate.

I will not investigate allegations against myself or another professional in a way that could compromise an independent investigation.

14. Clinical supervision and ethical decision-making

I will maintain regular clinical supervision appropriate to my workload, experience and client group.

Safeguarding concerns, ethical dilemmas and difficult decisions will be discussed in supervision as soon as reasonably practicable, subject to the need for immediate action.

I will use supervision to reflect on:

• The      client's welfare and expressed wishes.
• Risks      to the client or others.
• The      relevant ethical principles and legal requirements.
• Potential      conflicts between confidentiality, autonomy and protection from harm.
• The      possible consequences of acting or not acting.
• My      competence, emotional responses and potential biases.
• Whether      additional specialist advice or referral is required.
• The      effectiveness of the action taken.

Where an urgent safeguarding decision cannot wait for supervision, I will act on the information available, contact the relevant statutory service where necessary and seek supervision as soon as practicable afterwards.

Applying the BACP Ethical Framework 2026

From 3 November 2026, I will apply the BACP Ethical Framework for the Counselling Professions 2026 in accordance with its requirements.

In particular, I will:

• Consider      ethical responsibilities across all relevant professional relationships,      not only the therapeutic relationship with the client.
• Work      collaboratively with clients where appropriate and take their perspectives      into account.
• Record      the rationale for significant ethical and safeguarding decisions.
• Use      supervision and reflection to review those decisions and identify learning      needs.
• Maintain      professional accountability and respond openly when something has gone      wrong.
• Review      the implications of digital technology and AI for confidentiality, safety,      professional boundaries and responsible practice.

Where ethical principles appear to conflict, I will identify the competing considerations, prioritise safety where justified, consider less intrusive alternatives and document why the action taken was proportionate.

15. Artificial intelligence, digital technology and confidentiality

I will use digital technology in a way that protects clients' privacy, dignity, safety and trust.

I will not enter identifiable client information, counselling notes, disclosures or safeguarding records into public AI tools or other unapproved services.

I will not use AI to make autonomous safeguarding decisions, determine whether a disclosure is credible, replace clinical judgement or substitute for consultation with appropriate professionals.

Where any AI or digital tool is considered for a legitimate practice purpose, I will assess its confidentiality, data protection, security, accuracy and professional implications before use.

I will be transparent with clients about relevant uses of technology where appropriate and ensure that any processing of personal data has a valid legal basis and meets applicable data protection requirements.

I will not record sessions, use transcription tools or share session material with third parties without appropriate consideration of informed consent, confidentiality, security and the applicable legal framework.

16. Recording and storing safeguarding concerns

I will maintain clear, factual, timely and secure records of safeguarding concerns and actions taken.

Records will include, as appropriate:

• The      date and time the concern arose or was disclosed.
• The      identity of the person raising the concern.
• The      client's relevant words, using direct quotations where possible.
• Objective      observations, clearly distinguished from opinion.
• Relevant      background and immediate safety concerns.
• The      risk assessment and any safety planning.
• The      client's wishes and views.
• Advice      sought and from whom.
• Referrals,      disclosures and information shared.
• The      reasons for decisions, including a decision not to refer or share      information.
• Follow-up      actions and outcomes known to me.
• Relevant      supervision and reflective practice.

I will avoid speculative, judgemental or unnecessary personal comments.

Records will be stored securely, with access restricted to authorised persons. Retention and deletion will follow the practice's data protection and records management arrangements, taking account of legal obligations, professional guidance, the client's age and the circumstances of the case.

Where a safeguarding record concerns a child, I will consider the implications of parental access requests, the child's confidentiality and any risks that disclosure could create.

17. Training and continuing professional development

I will maintain safeguarding knowledge and skills appropriate to the needs of the clients I work with.

This will include:

• Safeguarding      children training relevant to my role.
• Safeguarding      adults training relevant to my role.
• Training      in recognising and responding to abuse and neglect.
• Risk      assessment and crisis response.
• Confidentiality,      information sharing and data protection.
• Consent      and capacity where relevant.
• Online      safeguarding where remote counselling is offered.
• Updates      to BACP ethical guidance and relevant legislation.

I will keep a record of relevant training and continuing professional development and identify further learning needs through supervision and policy review.

I will not accept work beyond my competence and will seek specialist advice or make an appropriate referral when required.

18. Working with other professionals

I recognise that effective safeguarding may require cooperation with other professionals and agencies.

Where necessary and appropriate, I will work with children's social care, adult social care, GPs, mental health services, schools, the police and other relevant services.

I will communicate in a factual, proportionate and respectful manner, sharing information on a lawful basis and maintaining appropriate confidentiality.

Where a referral is made, I will record it and, where appropriate, follow up to establish whether further action is needed.

I will not assume that another professional has acted simply because I have sent an email or left a telephone message. Where the concern is urgent, I will use a communication method appropriate to the risk.

19. Complaints, incidents and learning

Clients will be informed how to raise concerns or make a complaint about the counselling service.

Any safeguarding incident, near miss, data breach or concern about unsafe practice will be reviewed to identify appropriate remedial action and prevent recurrence.

Where an incident has caused or may have caused harm, I will consider my professional responsibilities concerning candour, communication, support for those affected and notification to relevant bodies.

I will cooperate with appropriate investigations and take reasonable steps to remedy any harm arising from my practice.

Learning from incidents, supervision and updated guidance will inform future practice and policy revisions.

20. Emergency and safeguarding contacts

The following details must be completed and checked before the policy is adopted.

Service

Contact details

Emergency services

999

Non-emergency police

101

Local authority children's social care

www.milton-keynes.gov.uk/children-youngpeople-and-familes.   01908 253169

Local authority adult safeguarding

www.milton-keynes.gov.uk/adult-social-care  01908 691691

Local authority designated officer (LADO)

[lado@milton-keynes.gov.uk 01908 254307

NHS 111

111, subject to service availability

Clinical supervisor

Tracey Oak

BACP

www.bacp.co.uk

ICO

www.ico.org.uk

If a client is in immediate danger, I will prioritise emergency assistance over routine consultation or administrative procedures.

21. Policy review and approval

This policy will be reviewed at least annually and sooner if there are significant changes to legislation, statutory guidance, professional requirements, the nature of the service or a safeguarding incident that identifies a need for improvement.

The review will consider:

• Changes      to the BACP Ethical Framework.
• Relevant      statutory safeguarding guidance.
• Feedback      from supervision and continuing professional development.
• Changes      in service delivery, including online work.
• Learning      from incidents, complaints or referrals.
• The      accuracy of emergency contacts and local referral procedures.

Policy approval

Name: Ali Husbands

Signature: 

Date: 24.10.2026

Next review date: 01.10.2027