⚠️ DRAFT v0.1 — for clinical advisor + legal review. NOT clinical or legal advice. Must be validated by a qualified clinical/safeguarding lead before use. Last updated: [PLACEHOLDER: date]
Faresay — Crisis & Safeguarding Policy
This policy sets out how Faresay and the Therapists who use the Faresay marketplace platform (the "Platform") identify, respond to, escalate, and learn from situations involving risk to a Client's safety or the safety of others, and how Faresay discharges its safeguarding responsibilities.
It must be read alongside the Clinical Governance Policy, the Terms of Service, the Privacy Policy, the Therapist Agreement, and the Security & Data Protection Policy. Where this policy and another Faresay document conflict on a safety-critical point, the more protective interpretation applies pending resolution by the Safeguarding Lead.
⚠️ CLINICAL — This document is a structural first draft. Every clinical threshold, screening criterion, escalation step, and exclusion criterion below must be reviewed, corrected, and signed off by a qualified clinical/safeguarding lead before any operational use. Do not rely on it as written.
1. Purpose & Scope
1.1 Purpose. This policy aims to: - (a) protect Clients, Therapists, third parties, and the public from foreseeable serious harm; - (b) make clear that Faresay is not an emergency or crisis service, and ensure that message is communicated consistently; - (c) give Therapists a clear, predictable framework for identifying and escalating risk; - (d) define safeguarding roles, responsibilities, and on-call expectations within Faresay; and - (e) ensure incidents are documented, reviewed, and used for learning, consistent with legal and professional obligations.
1.2 Who this applies to. This policy applies to: - all Therapists providing Clinical Services via the Platform (it is incorporated into the Therapist Agreement by reference — see clauses 6.6–6.7 of that agreement); - all Faresay staff and contractors involved in operations, trust & safety, support, or clinical governance; and - the design and operation of Platform features that touch on safety.
1.3 Territorial scope. Faresay currently operates in the United Kingdom and plans to expand into the United States (all 50 states + DC) on a cash-pay / out-of-network model (see CONTEXT.md). This policy covers UK obligations now and forward-looking US obligations for expansion. US-specific provisions are forward-looking and must be finalised before any US launch. ⚠️ COUNSEL / ⚠️ CLINICAL — Many obligations below vary by US state and by UK nation (England, Scotland, Wales, Northern Ireland); jurisdiction-specific addenda will be required.
1.4 Population scope. This draft assumes the Platform serves adults only and that minors are out of scope, consistent with the current assumption in the Terms of Service and Therapist Agreement. ⚠️ CLINICAL / ⚠️ COUNSEL — If services to minors are ever offered, this policy requires substantial additional child-safeguarding content (consent models, age thresholds — which vary by US state and within the UK, e.g. Gillick/Fraser considerations — verification, and dedicated child-protection escalation). The "safeguarding of children" provisions below currently address (a) risk disclosed about a child who is a third party (e.g. a Client's own child) and (b) future-proofing, not direct treatment of minors.
1.5 Relationship to clinical responsibility. Faresay provides the technology and marketing platform; the Therapist provides the clinical service and owns the clinical relationship, clinical judgement, and clinical record (see CONTEXT.md and Terms of Service §2). Nothing in this policy transfers clinical responsibility for an individual Client to Faresay or makes Faresay a healthcare provider. The Therapist remains the decision-maker on the clinical care of their Clients, within the framework this policy sets.
2. Faresay Is Not an Emergency or Crisis Service
2.1 Core statement. Faresay and the Platform are not an emergency service, crisis line, or suicide-prevention service. Bookings, messages, and other communications sent through the Platform are not monitored in real time for emergencies, and Therapists are not available for emergency, urgent, or crisis response. The Platform is intended for non-urgent, scheduled mental-health support.
2.2 How this is communicated to Clients. This message must be surfaced clearly and repeatedly, not buried. At minimum (⚠️ CLINICAL / ⚠️ COUNSEL — confirm placement, wording, and frequency): - (a) in the Terms of Service (see ToS §3, "NOT AN EMERGENCY OR CRISIS SERVICE"), which Clients accept at onboarding; - (b) on the onboarding / intake flow, as a distinct, acknowledged screen — not a buried clause; - (c) persistently within the messaging interface (e.g. a standing banner or footer stating the Platform is not monitored for emergencies and listing crisis resources — see §8); - (d) within any "report a concern" or help surfaces; and - (e) reiterated by the Therapist at the start of the therapeutic relationship as part of informed consent (see Clinical Governance Policy).
2.3 Wording must be consistent. The crisis-resource wording and numbers used across the Platform, the Terms of Service, and this policy must match. The authoritative list of resources is in §8 of this policy. ⚠️ COUNSEL / ⚠️ CLINICAL — Verify all numbers and service descriptions and keep them synchronised with Terms of Service §3.
2.4 What "not an emergency service" does not mean. This disclaimer does not relieve a Therapist of their professional duty of care to a Client during the course of a session or active treatment relationship (see §4), nor of mandatory-reporting and duty-to-warn obligations (see §6–§7). It governs Client expectations of the Platform's availability and monitoring; it does not switch off a clinician's professional and legal duties.
3. Risk Types Covered
This policy covers the following risk presentations. ⚠️ CLINICAL — definitions, indicators, and thresholds for each must be set by the Safeguarding Lead; the descriptions below are placeholders for scope, not clinical guidance.
3.1 Suicidality — suicidal ideation (passive or active), intent, plan, means, and history; acute and chronic risk.
3.2 Self-harm — non-suicidal self-injury and related risk, including escalation patterns and medical risk.
3.3 Risk of harm to others — threats or risk of violence toward identifiable or non-identifiable third parties, including homicidal ideation. Engages possible duty-to-warn / duty-to-protect obligations (see §7).
3.4 Domestic abuse — a Client experiencing or perpetrating domestic abuse (physical, sexual, psychological, coercive control, economic, or technology-facilitated abuse). ⚠️ CLINICAL / ⚠️ COUNSEL — Special caution: documentation, safety planning, and any external contact must not increase risk to a Client experiencing abuse; covert tech-facilitated monitoring of the victim must be assumed possible.
3.5 Safeguarding of children — concern that a child (typically a third party, e.g. a Client's child, in this adults-only model) is suffering or at risk of significant harm, abuse, or neglect. Engages mandatory / statutory reporting considerations (see §6).
3.6 Safeguarding of vulnerable / at-risk adults — concern that an adult with care-and-support needs is experiencing or at risk of abuse or neglect (sometimes "adult safeguarding"). Engages jurisdiction-specific adult-safeguarding and reporting frameworks (see §6).
3.7 Other acute risk — e.g. acute psychosis, severe disordered eating with medical risk, acute intoxication/overdose risk, severe deterioration. May indicate the presentation is unsuitable for the Platform (see §5 exclusion criteria).
4. Therapist Duty of Care & Responsibilities
4.1 Professional duty. Each Therapist remains bound by the duty of care, ethical codes, and standards of their regulator and professional body (e.g. in the UK: HCPC, BACP, UKCP, BPS, Social Work England / equivalents; in the US: state licensing boards and the relevant professional code). ⚠️ CLINICAL — confirm the applicable bodies and standards per jurisdiction.
4.2 Therapists must: - (a) screen for and remain alert to the risk types in §3 at onboarding and on an ongoing basis (see §5); - (b) hold and maintain competence in risk assessment and management appropriate to the populations they serve, and complete Faresay's required training (see §11); - (c) follow the escalation protocol in §5–§6 when risk is identified; - (d) comply with all mandatory-reporting, duty-to-warn/protect, and safeguarding obligations applicable in the jurisdiction where the Client is located (see Therapist Agreement §6.6); - (e) maintain confidentiality, disclosing only as permitted or required by law or to protect against serious harm (see §7 and Therapist Agreement §6.5); - (f) document risk, concerns, decisions, and actions contemporaneously in the clinical record (see §9); - (g) carry their own professional indemnity / malpractice insurance as required by the Therapist Agreement; and - (h) not take on, and promptly escalate/offboard, Clients whose presentation falls within the exclusion criteria (§5).
4.3 Scope of the Therapist's role in crisis. The Therapist is responsible for clinical risk decisions for their own Clients. The Therapist is not expected to provide emergency response in place of statutory emergency services; the appropriate action in an acute emergency is to direct the Client to emergency services and, where duties require and it is safe and lawful, to make contact with emergency or relevant authorities (see §5).
4.4 Availability and limits. Therapists must make their availability and response-time limits clear to Clients (the Platform is not monitored for emergencies; messages are not answered in real time). ⚠️ CLINICAL — define expected message-response windows and how Therapists communicate their boundaries.
5. Client Risk Screening, Ongoing Assessment & Exclusion Criteria
5.1 Screening at onboarding. Before or at the start of the therapeutic relationship, risk-relevant information should be gathered to determine whether the Platform and the matched Therapist are an appropriate setting for the Client. ⚠️ CLINICAL — The Safeguarding/Clinical Lead must define the screening instrument(s), questions, scoring, and decision rules. At minimum, screening should consider current and historical suicidality/self-harm, risk to others, acute psychiatric presentation, substance use, and the Client's location (for emergency routing and licensure — see §8.3 and CONTEXT.md).
5.2 Ongoing assessment. Risk is dynamic. Therapists must reassess risk throughout the relationship, in particular at transitions (intake, deterioration, major life events, medication changes, ending of therapy) and whenever risk indicators appear in session or in messages.
5.3 Exclusion criteria — presentations unsuitable for cash-pay telehealth. Certain presentations are not suitable for delivery via an unscheduled-monitoring, remote, cash-pay marketplace and should be excluded or referred to a higher level of care. ⚠️ CLINICAL — the Clinical/Safeguarding Lead must finalise this list; this cross-references and must remain consistent with the suitability/exclusion provisions in the Clinical Governance Policy. Indicative (placeholder) examples to be confirmed: - (a) acute, high, or imminent risk of suicide or serious self-harm requiring crisis or inpatient care; - (b) current intent or plan to seriously harm another person; - (c) acute psychosis, mania, or severe decompensation requiring urgent/specialist or in-person care; - (d) severe substance dependence requiring medically supervised detox/withdrawal; - (e) severe eating disorders with medical instability; - (f) presentations requiring a level of monitoring, frequency, or coordination the Platform cannot safely provide; - (g) [PLACEHOLDER: other criteria to be defined by the Clinical/Safeguarding Lead].
5.4 Action where exclusion criteria apply. Where a Client's presentation meets an exclusion criterion, the Therapist must not continue routine treatment as if the setting were appropriate; instead they must (in line with clinical judgement and §6 escalation): support the Client to access an appropriate level of care, signpost crisis/emergency resources (§8), document the decision (§9), and notify Faresay's Safeguarding Lead where required. ⚠️ CLINICAL / ⚠️ COUNSEL — abandonment risk: ending or declining care must be handled to avoid clinical abandonment and to meet professional/ethical "termination of care" rules in the jurisdiction (coordinate with Clinical Governance Policy and Therapist Agreement continuity-of-care provisions).
5.5 Matching and licensure gate. A Therapist must be licensed in the jurisdiction where the Client is located (UK; and in the US, the relevant state — leveraging PSYPACT / Counseling Compact / Social Work Licensure Compact per CONTEXT.md). Location is also needed for emergency routing (§8.3). ⚠️ COUNSEL — confirm licensure verification gates by jurisdiction.
6. Crisis Identification & Step-by-Step Escalation Protocol
⚠️ CLINICAL — This protocol is a structural placeholder. The Clinical/Safeguarding Lead must define the actual clinical decision thresholds, who does what, timeframes, and jurisdiction-specific contacts before any operational use. The numbered steps below describe the shape of the process, not validated clinical instructions.
6.1 Identify. A Therapist (or, where a Platform safety signal is triggered, Faresay's Trust & Safety function) identifies indicators of acute risk (§3) — disclosed directly, observed in session, or surfaced via a risk flag (§8.2).
6.2 Assess severity and immediacy. The Therapist assesses whether the risk is: - Imminent / life-threatening (e.g. active attempt in progress, immediate intent and means, immediate danger to a child or another person); or - Elevated but not immediately life-threatening; or - Lower-level / chronic but requiring monitoring and planning. ⚠️ CLINICAL — define indicators and thresholds for each tier.
6.3 Immediate-danger pathway (imminent/life-threatening). - (a) Prioritise getting the Client/affected person to emergency help now: direct them to call emergency services (US 911; UK 999) or, where safe and within the Therapist's lawful authority and professional duty, contact emergency services on their behalf using the Client's location (see §8.3). - (b) Surface and provide crisis resources (§8). - (c) Where duty-to-warn/protect or mandatory-reporting obligations are engaged, follow §6.5 / §7 / §6.6. - (d) Stay with / maintain contact to the extent clinically appropriate and possible within the session. - (e) Notify Faresay's Safeguarding Lead / on-call per §6.7 and document per §9. ⚠️ CLINICAL / ⚠️ COUNSEL — Contacting emergency services without consent, and using location data to do so, has clinical, legal, and confidentiality implications that vary by jurisdiction; confirm lawful basis (and see the emergency data-sharing carve-out, §8.4).
6.4 Elevated-risk pathway (not immediately life-threatening). - (a) Conduct/complete a structured risk assessment and collaborative safety plan with the Client. - (b) Signpost crisis resources (§8) and agree what the Client will do if risk escalates. - (c) Consider increased session frequency, coordination with the Client's GP/primary care or other providers (with consent where required), and whether exclusion criteria (§5.3) now apply. - (d) Document and, where thresholds are met, escalate to the Safeguarding Lead (§6.7) and follow reporting duties (§6.6/§7).
6.5 Duty-to-warn / duty-to-protect trigger (risk to others). Where a Client presents a serious risk of harm to an identifiable third party, the Therapist must follow the duty-to-warn / duty-to-protect framework applicable in the Client's jurisdiction (see §7). ⚠️ COUNSEL — this is state-variable in the US and threshold-based in the UK.
6.6 Mandatory-reporting trigger (children / vulnerable adults). Where information indicates a child or vulnerable/at-risk adult is suffering or at risk of significant harm, the Therapist must follow the mandatory/statutory reporting framework applicable in the Client's jurisdiction (see §6 reporting detail in §7) and notify the Safeguarding Lead. ⚠️ COUNSEL / ⚠️ CLINICAL — reporting duties, recipients, and timeframes vary by US state and UK nation.
6.7 Internal escalation to Faresay. In parallel with clinical action, the Therapist notifies Faresay's Safeguarding Lead / on-call contact of a serious incident via [PLACEHOLDER: defined reporting channel — e.g. dedicated email, phone, in-app report], within [PLACEHOLDER: timeframe]. Faresay's role here is supportive and governance-focused (logging, support, pattern detection, learning, regulatory/notification obligations) — not to override the Therapist's clinical decisions for an individual Client. ⚠️ CLINICAL — define the threshold for mandatory internal escalation, the channel, and the timeframe.
6.8 Platform safety signals. Where a Platform feature (e.g. a self-harm keyword flag, §8.2) raises a signal independent of a Therapist, define how Trust & Safety triages it, what is automated vs human-reviewed, and how false positives and Client privacy are handled. ⚠️ CLINICAL / ⚠️ COUNSEL — automated risk detection on sensitive mental-health content carries clinical, false-negative/positive, privacy, and liability risks; confirm before building.
7. Confidentiality Breach Thresholds, Duty-to-Warn & Mandatory Reporting
7.1 General principle. Client confidentiality is a core duty (see Therapist Agreement §6.5, Privacy Policy). It may be lawfully overridden only where permitted or required to prevent or reduce a risk of serious harm, or where the law requires disclosure. Disclosure should be the minimum necessary to address the risk, made to the appropriate recipient, and documented (§9).
7.2 United States — duty to warn / duty to protect (Tarasoff line of authority). ⚠️ COUNSEL — State-variable. Following Tarasoff and its progeny, many US states impose a duty to warn and/or protect identifiable third parties from a Client's serious threats; some states make it mandatory, some permissive, some have no statute, and the trigger, the discharge mechanism (warn the victim, notify police, initiate hospitalisation, etc.), and the immunity provisions differ state by state. The applicable rule is generally that of the state where the Client/Therapist is situated. Counsel must produce a per-state matrix of duty-to-warn/protect obligations and safe-harbour steps before US launch, and the Platform/training must reflect each state's rule.
7.3 United Kingdom — confidentiality-breach thresholds. ⚠️ COUNSEL / ⚠️ CLINICAL — UK practitioners may breach confidentiality to prevent serious harm, broadly under common-law public-interest disclosure, data-protection conditions for processing special-category data, and professional-body guidance (e.g. GMC/BACP/HCPC-aligned principles, ICO guidance). Counsel/clinical lead must define the threshold ("real and serious risk of serious harm"), who may be told (e.g. police, the at-risk person, GP), and how to record the justification — and note variation across England, Scotland, Wales, and Northern Ireland.
7.4 Mandatory reporting — children. ⚠️ COUNSEL / ⚠️ CLINICAL — In the US, child-abuse mandatory-reporting laws apply to therapists in all states but differ by state (who must report, what triggers it, to whom, and timeframes). In the UK, the framework is statutory and nation-specific (e.g. local-authority children's services / multi-agency safeguarding hubs; police; relevant working-together guidance). Counsel/clinical lead must specify the recipient, trigger, and timeframe for each jurisdiction.
7.5 Mandatory / permitted reporting — vulnerable & at-risk adults. ⚠️ COUNSEL / ⚠️ CLINICAL — US adult-protective-services reporting duties vary by state (some mandatory for certain professionals, some permissive). In the UK, adult-safeguarding duties run through local-authority adult social care (e.g. Care Act 2014 in England and equivalents in the other nations). Specify recipients, triggers, and timeframes per jurisdiction.
7.6 Domestic abuse. ⚠️ COUNSEL / ⚠️ CLINICAL — Reporting and information-sharing in domestic-abuse contexts is sensitive and jurisdiction-specific; disclosure can increase danger to a victim. Define safe practice, lawful basis, and any mandatory elements per jurisdiction; do not contact a victim's household or share information in ways that could be intercepted by an abuser.
7.7 Conflict of duties. Where the obligations of the Client's jurisdiction, the Therapist's licence, professional ethics, and this policy appear to conflict, the Therapist should apply the most protective lawful course and seek guidance from the Safeguarding Lead and, where time permits, their own professional/legal advisers. ⚠️ COUNSEL.
8. Emergency Resources & Safety Features
8.1 Crisis resources to surface. The following resources must be displayed in the surfaces described in §2.2. ⚠️ COUNSEL / ⚠️ CLINICAL — Verify, localise, and keep synchronised with Terms of Service §3.
United States - 988 Suicide & Crisis Lifeline — call or text 988. - 911 — for any life-threatening emergency. - [PLACEHOLDER: state/territory-specific or population-specific crisis resources to be added per jurisdiction.]
United Kingdom - 999 — for any life-threatening emergency. - 111 — for urgent (non-life-threatening) NHS help. - Samaritans — free on 116 123 (24 hours a day). - [PLACEHOLDER: nation-specific resources / text services to be added — e.g. text-line services; confirm before publication.]
If the Client is outside these countries, direct them to their local emergency services. ⚠️ CLINICAL — define handling for Clients located outside supported jurisdictions.
8.2 Risk flags. The Platform may provide features to flag risk (e.g. a Therapist-set risk indicator on a Client record, or detection signals on messages). ⚠️ CLINICAL / ⚠️ COUNSEL — Define what flags exist, who sets/sees them, how they affect care and matching, how privacy is protected, and the risk of automated detection (false positives/negatives). Any automated scanning of clinical/message content must have a confirmed lawful basis and be assessed for clinical safety before deployment.
8.3 Location capture for emergencies. To enable emergency routing (correct emergency number; ability to direct or send help to the right place; correct duty-to-warn/reporting jurisdiction), the Platform should capture the Client's location/jurisdiction. ⚠️ COUNSEL / ⚠️ CLINICAL — Confirm what location data is collected (self-declared jurisdiction vs precise geolocation), when, lawful basis, retention, and how it is used in an emergency; precise real-time geolocation has significant privacy implications and must be assessed in the DPIA / privacy review (see Privacy Policy and Security & Data Protection Policy).
8.4 Emergency data-sharing carve-out. In a life-at-risk emergency, Faresay and/or the Therapist may need to share limited personal data (e.g. identity, location, contact details, nature of risk) with emergency services or relevant authorities without prior consent to protect the vital interests of the Client or another person. This carve-out must be reflected in, and operated consistently with, the Privacy Policy and the Security & Data Protection Policy. ⚠️ COUNSEL — Confirm the lawful basis (e.g. UK GDPR vital-interests / public-interest / legal-obligation conditions for special-category data; and, in the US, HIPAA's permitted disclosures to avert a serious and imminent threat and state-law equivalents), the minimum-necessary principle, and logging requirements.
9. Documentation & Record of Concerns
9.1 Clinical record. The Therapist must contemporaneously document risk assessments, safety plans, disclosures, decisions (including the reasoning for any confidentiality breach or report), actions taken, and who was contacted, in the clinical record they own (see CONTEXT.md, Therapist Agreement). ⚠️ CLINICAL — define minimum documentation standards and templates.
9.2 Faresay record of concerns. Faresay should maintain a secure safeguarding incident log / record of concerns capturing reported serious incidents, escalations, and outcomes, accessible only to authorised safeguarding/governance personnel. ⚠️ CLINICAL / ⚠️ COUNSEL — define what Faresay records vs what stays in the clinician's clinical record (to respect the controller/processor split in Privacy Policy §1), access controls, and retention.
9.3 Retention & security. Records of concern are highly sensitive special-category data and must be retained and secured per the Privacy Policy and Security & Data Protection Policy, for the retention period set there. ⚠️ COUNSEL — confirm retention periods (UK + US state law).
9.4 Auditability. Escalations, reports, and emergency data-sharing decisions should be time-stamped and auditable to support post-incident review (§10) and any regulatory inquiry.
10. Safeguarding Leads, Roles & On-Call Expectations
10.1 Safeguarding Lead. Faresay will designate a Safeguarding Lead (and a Deputy) with defined responsibilities for this policy, incident oversight, escalation support, liaison with authorities where appropriate, and learning. ⚠️ CLINICAL — The Safeguarding Lead should be (or be advised by) a suitably qualified clinical/safeguarding professional. Confirm the required qualification, the appointment, and named contacts. - Safeguarding Lead: [PLACEHOLDER: name / role / contact] - Deputy Safeguarding Lead: [PLACEHOLDER: name / role / contact] - Clinical Lead / Advisor: [PLACEHOLDER: name / role / contact] (see Clinical Governance Policy)
10.2 Trust & Safety function. [PLACEHOLDER: team/role] triages Platform safety signals and non-clinical reports and escalates to the Safeguarding Lead per §6.8.
10.3 On-call expectations. ⚠️ CLINICAL / ⚠️ COUNSEL — Decide and document whether Faresay offers any out-of-hours safeguarding contact, the response-time expectation, and the limits of that contact. Critically: an on-call channel must not be presented to Clients as an emergency or crisis line — doing so would contradict §2 and could create reliance and liability. Any internal on-call is for Therapist/staff escalation and governance, not Client emergency response. Confirm scope, staffing, and SLAs.
10.4 Limits of Faresay's role. Faresay does not provide clinical care, does not supervise the clinical judgement of independent Therapists, and is not a substitute for emergency services. Its safeguarding role is governance, support, logging, learning, and meeting its own legal/regulatory obligations.
11. Therapist Training Requirements
11.1 Required training. Before onboarding and periodically thereafter, Therapists must complete and attest to Faresay's required training on this policy, covering: identifying and assessing the risk types in §3; the escalation protocol (§6); confidentiality-breach thresholds, duty-to-warn/protect, and mandatory reporting in the jurisdiction(s) they serve (§7); use of Platform safety features (§8); and documentation (§9). ⚠️ CLINICAL — define the curriculum, format, assessment, and refresh cadence.
11.2 Jurisdiction-specific knowledge. Therapists must be familiar with the duty-to-warn/protect and mandatory-reporting rules of every jurisdiction in which they hold themselves out to treat Clients. ⚠️ COUNSEL / ⚠️ CLINICAL — Faresay should provide a per-jurisdiction reference (the §7.2 matrix) but the Therapist remains professionally responsible.
11.3 Competence. Therapists must only accept Clients within their competence and must keep risk-management skills current per their professional body's CPD requirements. ⚠️ CLINICAL.
11.4 Records. Faresay should record training completion and attestations as part of credentialing (see Clinical Governance Policy).
12. Post-Incident Review & Learning
12.1 Review of serious incidents. Serious safeguarding/crisis incidents should be reviewed by the Safeguarding Lead (with the Clinical Lead and, where appropriate, the Therapist) to identify what happened, whether this policy and the escalation protocol were followed, what worked, and what should change. ⚠️ CLINICAL — define what counts as a "serious incident" requiring review, and the review method and timeframe.
12.2 Learning loop. Findings should feed back into training (§11), this policy, the Clinical Governance Policy, screening/exclusion criteria (§5), and Platform safety features (§8). Themes and trends should be reviewed periodically.
12.3 Support & a just culture. Reviews should support a just, learning-oriented culture (supporting Clients, Therapists, and staff affected by a serious incident) rather than being purely punitive, while preserving accountability where standards were not met. ⚠️ CLINICAL.
12.4 External duties. ⚠️ COUNSEL / ⚠️ CLINICAL — Confirm any external reporting/notification duties arising from a serious incident (e.g. to regulators, professional bodies, data-protection authorities for any associated breach, or coroner/medical-examiner processes), per jurisdiction.
13. Review Cadence
13.1 This policy will be reviewed at least annually, and additionally after any serious incident (§12), after any material change in law or professional guidance, and before entering a new jurisdiction. ⚠️ CLINICAL / ⚠️ COUNSEL — confirm cadence and owner.
13.2 Owner: [PLACEHOLDER: Safeguarding Lead]. Next review due: [PLACEHOLDER: date].
13.3 Version control. Material changes should be versioned and the "Last updated" date refreshed. This is DRAFT v0.1 and must not be operationalised until validated by a qualified clinical/safeguarding lead and reviewed by counsel.
⚠️ DRAFT v0.1 — Not for operational use. Validate with a qualified clinical/safeguarding lead (⚠️ CLINICAL) and legal counsel (⚠️ COUNSEL) before publication or reliance. Keep crisis resources synchronised with the Terms of Service.