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Crisis & Safeguarding Policy

DRAFT — for professional sign-off Faresay Ltd·25 June 2026

⚠️ DRAFT v0.1 (Practice Portal) — for clinical/safeguarding advisor + UK legal review. NOT clinical or legal advice. Must be validated by a qualified clinical/safeguarding lead (⚠️ CLINICAL) and counsel (⚠️ COUNSEL) before use. Last updated: [PLACEHOLDER: date]

Faresay Practice Portal — Crisis & Safeguarding Position

Read the pivot first. Faresay is now B2B SaaS software sold to therapists, not a care marketplace. See pp-uk-legal-brief.md. Under this model the therapist is the provider and the data controller, and therefore owns crisis management and safeguarding for their own clients. Faresay's role is narrow: it is not a crisis service, it surfaces UK crisis signposting in the product, it provides a lawful mechanism for emergency data-sharing, and it requires therapists to hold their own crisis and safeguarding protocols as a term of use.

This document replaces the marketplace Crisis & Safeguarding Policy (uk-crisis-safeguarding-policy.md) for the practice-portal direction. It applies to Faresay's UK operations and assumes an adults-only therapist client base. Where it and another Faresay document conflict on a safety-critical point, the more protective interpretation applies pending resolution.

⚠️ CLINICAL — Structural first draft. Faresay does not set clinical thresholds; therapists do, within their own protocols and professional standards. The product-side items (signposting wording, data-sharing mechanism) must still be reviewed by a qualified clinical/safeguarding advisor and counsel before operational use.

1. Where responsibility sits

1.1 The therapist owns crisis and safeguarding. As the provider, controller, and clinically responsible professional for their own clients, the therapist is responsible for identifying, assessing, responding to, escalating, documenting, and learning from any risk to a client's safety or the safety of others. Nothing in this document transfers clinical or safeguarding responsibility for any client to Faresay or makes Faresay a healthcare or crisis provider.

1.2 UK frameworks apply to the therapist, not Faresay. Statutory and professional safeguarding, public-interest-disclosure, and reporting duties — for example under the Children Act 1989 / 2004 and Working Together to Safeguard Children (and devolved equivalents), the Care Act 2014 (England) / Adult Support and Protection (Scotland) Act 2007 / Social Services and Well-being (Wales) Act 2014 and the Northern Ireland adult-safeguarding framework, together with the therapist's professional-body guidance (BACP / UKCP / NCS / BPS / HCPC) — fall on the therapist as the provider. ⚠️ COUNSEL / ⚠️ CLINICAL — confirm framework applicability per UK nation and that Faresay-as-software carries no provider-level safeguarding duty.

1.3 Faresay is software, not a provider. Faresay does not screen clients, does not assess risk, does not make crisis or referral decisions, and does not supervise the therapist's clinical judgement. Its role is limited to Sections 2–4. ⚠️ COUNSEL — confirm this preserves Faresay's processor characterisation and keeps it outside CQC regulated activity (see pp-uk-legal-brief.md §5–§6).

2. Faresay is not a crisis service

2.1 Core statement. Faresay and the portal are not an emergency service, crisis line, or suicide-prevention service. Communications through the portal are not monitored in real time for emergencies. The product is for non-urgent, scheduled use by a therapist and their clients.

2.2 How it is surfaced. This message, and the crisis signposting in Section 3, should appear clearly in the product — at minimum in client-facing surfaces (e.g. a standing message in the client interface) and in the platform notice the end-client sees. The therapist also reinforces it as part of their own informed-consent and contracting with the client (see pp-clinical-governance-policy.md §3.4). ⚠️ CLINICAL / ⚠️ COUNSEL — confirm placement and wording, and keep it synchronised with the SaaS platform notice / terms.

2.3 What this does not do. The "not a crisis service" statement governs expectations of the software's availability and monitoring. It does not switch off the therapist's professional duty of care during an active treatment relationship, nor their safeguarding and disclosure duties.

3. UK crisis signposting in the product

3.1 The portal displays standard UK crisis resources in the surfaces described in §2.2. ⚠️ COUNSEL / ⚠️ CLINICAL — verify and keep synchronised with the platform notice/terms:

United Kingdom - 999 — for any life-threatening emergency. - NHS 111 — for urgent (non-life-threatening) NHS help, including the NHS 111 urgent mental health option in many areas. - Samaritans — free on 116 123 (24 hours a day). - SHOUT — free 24/7 crisis text support: text 85258. - [PLACEHOLDER: nation/region-specific urgent mental health lines, confirmed before publication.]

3.2 If a client is outside the UK, they should be directed to local emergency services. ⚠️ CLINICAL — the therapist decides whom they can lawfully treat and where; signposting is generic.

4. Emergency data-sharing mechanism

4.1 In a life-at-risk emergency, the therapist (as controller), or Faresay acting on the therapist's instruction, may need to share limited personal data (e.g. identity, contact details, location if held, nature of risk) with emergency services or relevant authorities without prior consent to protect the vital interests of the client or another person.

4.2 Faresay provides the mechanism and lawful basis support for this — i.e. the product allows the necessary minimum data to be retrieved/shared, and the DPA and Privacy/Security policies reflect the carve-out. Faresay does not decide when to invoke it; that is the therapist's clinical and lawful judgement.

⚠️ COUNSEL — Confirm the lawful basis for emergency sharing (UK GDPR vital-interests / substantial-public-interest / legal-obligation conditions for special-category data), the minimum-necessary principle, logging/auditability, and how the carve-out reads against the DPA, Privacy Policy, and Security & Data Protection Policy. Confirm any precise-location capture is justified and assessed in the DPIA.

5. Therapist must hold their own crisis & safeguarding protocols (condition of use)

5.1 As a term of using the portal, each therapist warrants that they maintain and follow their own crisis and safeguarding protocols, appropriate to their practice and professional standards, including: - (a) risk screening at intake and ongoing reassessment of suicidality, self-harm, risk to others, domestic abuse, child and adult-at-risk safeguarding, and other acute presentations; - (b) an escalation pathway for imminent, elevated, and lower-level risk, including directing clients to emergency services (§3) and contacting authorities where their duties and lawful basis permit; - (c) confidentiality and public-interest-disclosure judgement (the UK has no statutory "duty to warn"; disclosure is permissive and proportionate) and safeguarding-referral routes to local-authority children's services / adult social care per the client's UK nation; - (d) suitability/exclusion judgement — declining or referring on presentations unsuitable for remote, non-real-time delivery, handled to avoid clinical abandonment; - (e) contemporaneous documentation of risk, decisions, disclosures, and actions in the clinical record they own; and - (f) their own professional indemnity insurance and CPD/competence in risk management.

⚠️ CLINICAL / ⚠️ COUNSEL — Faresay does not author these protocols or set the thresholds; it requires that the therapist has them. Confirm the contractual warranty wording (SaaS agreement) and whether Faresay should provide a non-binding reference template without thereby appearing to direct care.

6. Faresay's limited supporting role

6.1 Faresay does not provide clinical care, does not supervise therapists' clinical judgement, and is not a substitute for emergency services. If the platform itself were ever to surface a risk signal (e.g. a product feature flags content), Faresay's response is a non-clinical, product-safety/governance one — routing to the therapist and to its own legal/notification obligations — not a clinical intervention. ⚠️ CLINICAL / ⚠️ COUNSEL — any automated detection on sensitive mental-health content carries clinical, false-positive/negative, privacy, and liability risk and must be confirmed before building; default position is no real-time monitoring (§2.1).

6.2 Faresay may keep a minimal, secure governance log of any incident reported to it (for its own legal/learning obligations), distinct from the therapist's clinical record, consistent with the controller/processor split. ⚠️ COUNSEL — confirm what Faresay records vs the therapist, access controls, and retention.

7. Review

7.1 Reviewed at least annually, and after any material change in UK law or professional guidance. Crisis resources kept synchronised with the platform notice/terms. Owner: [PLACEHOLDER]. Next review: [PLACEHOLDER: date].

End of DRAFT v0.1 (Practice Portal). ⚠️ Not for operational use. Validate with a qualified clinical/safeguarding lead and counsel. Do not let any clause make Faresay the provider or controller of crisis/safeguarding care.