⚠️ DRAFT v0.1 — for clinical advisor + UK legal review. NOT clinical or legal advice. Must be validated by a UK-qualified clinical lead before use. Last updated: [PLACEHOLDER: date]

Faresay UK Clinical Governance Policy

1. Purpose and Scope

1.1 Purpose

1.1.1 This Clinical Governance Policy (the "Policy") sets out the framework through which Faresay seeks to assure the quality and safety of the clinical services delivered by independent mental-health professionals through the Faresay marketplace platform in the United Kingdom.

1.1.2 The Policy describes how clinical standards are set, how practitioners are verified and monitored, how clinical quality and safety are overseen, and how clinical risks, incidents, and complaints are managed. Its objective is to support safe, ethical, evidence-informed care while preserving each practitioner's independent professional clinical judgement.

1.1.3 Faresay provides the technology and marketing platform (software, discovery, scheduling, payments, client acquisition, and administrative support). Faresay does not provide clinical services, does not employ practitioners to provide clinical services, and is not a party to the clinical relationship. The practitioner provides the clinical service and owns the clinical relationship and the clinical record. This Policy is a governance and quality-assurance framework for the marketplace; it is not, and must not be read as, Faresay directing, controlling, or interfering with any practitioner's clinical judgement.

⚠️ COUNSEL: The boundary between (a) legitimate marketplace quality/safety governance and (b) Faresay being treated as the provider of clinical care matters for Faresay's intermediary characterisation, its duty of care and liability exposure, and any CQC regulated-activity question. The whole Policy must be reviewed by UK counsel to confirm it does not, in substance or appearance, make Faresay the provider of, or the controller of, clinical care rather than an intermediary that facilitates it. See uk-therapist-agreement.md and uk-legal-regulatory-brief.md (§1–§3, §7).

1.2 Scope

1.2.1 This Policy applies to:

all mental-health practitioners onboarded to and delivering services through the Platform ("Practitioners");
Faresay personnel and contractors involved in clinical governance, onboarding, verification, trust and safety, and support;
the clinical advisory function described in Section 3.

1.2.2 Territory. This Policy applies to Faresay's operations in the United Kingdom. Where a requirement differs across England, Scotland, Wales, and Northern Ireland (for example, the relevant social-work regulator, or safeguarding frameworks), this is flagged. Such nation-specific requirements are subject to validation by UK counsel and the clinical lead.

1.2.3 This Policy sits alongside and should be read with: the Therapist Agreement (uk-therapist-agreement.md), the Crisis / Safeguarding Policy (uk-crisis-safeguarding-policy.md), the Privacy Policy (uk-privacy-policy.md), the Security & Data Protection Policy (uk-security-data-protection-policy.md), and the Terms of Service (terms-of-service.md).

1.3 Status and ownership of this Policy

1.3.1 This Policy is owned by the Clinical Lead (see Section 3) and approved by [PLACEHOLDER: approving body — e.g. Faresay board / clinical advisory committee].

1.3.2 ⚠️ CLINICAL: This draft has been prepared without a UK-qualified clinical lead in post. Every clinical standard, threshold, and exclusion in this Policy must be reviewed, corrected, and validated by a UK-qualified clinical lead before the Policy is relied upon.

2. Definitions

In this Policy:

"Client" means an individual who books, accesses, or receives clinical services from a Practitioner via the Platform.
"Clinical Lead" means the qualified, suitably-registered senior clinician accountable for clinical governance at Faresay, as described in Section 3.
"Clinical Advisory Function" means the clinical advisory committee, panel, or named advisors supporting the Clinical Lead, as described in Section 3.
"Clinical Record" means the clinical notes, assessments, treatment plans, correspondence, and other professional records a Practitioner creates in connection with the care of a Client.
"Clinical Services" means the regulated or self-regulated mental-health, psychotherapy, or counselling services a Practitioner provides to Clients.
"DBS" means the UK Disclosure and Barring Service (and, where relevant, its equivalents: Disclosure Scotland and AccessNI in Northern Ireland).
"Practitioner" means an independent, suitably registered/accredited mental-health professional onboarded to deliver Clinical Services through the Platform.
"Professional Body" means the relevant statutory regulator or professional membership / PSA-accredited register for a Practitioner (see Section 18).
"PSA-accredited register" means a register accredited under the Professional Standards Authority's Accredited Registers programme.
"Routine Outcome Measure" / "ROM" means a validated, standardised measure used to track client symptoms, functioning, or progress over the course of care.
"Scope of Practice" means the range of clinical activities a Practitioner is qualified, trained, competent, and registered/accredited to perform.
"Telehealth" means the delivery of Clinical Services remotely by video, voice, or messaging.

3. Governance Structure and Accountability

3.1 Principle of clinical leadership

3.1.1 ⚠️ CLINICAL: Clinical governance at Faresay must be led by a qualified clinician, not by commercial or product staff. Faresay will appoint a Clinical Lead who is professionally responsible and accountable for the matters in this Policy.

3.1.2 The Clinical Lead must hold a current, valid, unrestricted UK registration/accreditation with a relevant Professional Body and have appropriate seniority and experience in mental-health practice and clinical governance. [PLACEHOLDER: named Clinical Lead, qualifications, registration number.]

3.2 Role of the Clinical Lead

3.2.1 The Clinical Lead is responsible for: owning and maintaining this Policy and related clinical standards; overseeing Practitioner onboarding, verification, and credentialing criteria (Section 4); defining scope-of-practice and exclusion criteria (Sections 6 and 15); overseeing quality assurance and outcome monitoring (Section 11); chairing or convening the Clinical Advisory Function; overseeing clinical incident review (Section 12) and the clinical complaints route (Section 13); and advising the business on clinical risk.

3.2.2 The Clinical Lead may delegate operational tasks but remains accountable for the clinical governance framework.

3.3 Clinical Advisory Function

3.3.1 ⚠️ CLINICAL: Faresay will establish a Clinical Advisory Function — a committee, panel, or set of named advisors — to support the Clinical Lead. Its composition, terms of reference, quorum, and meeting cadence are to be defined. [PLACEHOLDER: committee structure and members.]

3.3.2 The Clinical Advisory Function should, at minimum, include clinicians representing the main professional disciplines on the Platform (e.g. clinical/counselling psychology, psychotherapy, counselling, clinical social work). ⚠️ CLINICAL: confirm the appropriate disciplinary mix and whether independent (external) advisors are required.

3.3.3 Indicative responsibilities: reviewing and endorsing clinical standards and exclusion criteria; periodic case review and audit (Section 11); reviewing serious clinical incidents and trends (Section 12); and advising on emerging clinical risks and evidence.

3.4 Non-clinical roles

3.4.1 Faresay's trust-and-safety, onboarding/verification, support, data-protection, and engineering teams support clinical governance operationally (for example, by running verification checks and maintaining systems) but do not make clinical decisions. Clinical decisions about individual clients rest solely with the treating Practitioner.

3.4.2 A roles-and-responsibilities matrix is set out in Section 17.

4. Practitioner Onboarding and Verification

4.1 Principle

4.1.1 No Practitioner may deliver Clinical Services through the Platform until they have completed onboarding and verification and have been approved. Onboarding establishes that a Practitioner is appropriately qualified, registered/accredited, insured, and fit to practise.

4.2 Registration / accreditation verification

4.2.1 Faresay will verify that the Practitioner holds a current, valid, unrestricted statutory registration or accredited membership with the relevant UK Professional Body — e.g. HCPC for practitioner psychologists; membership of a PSA-accredited register (such as BACP, UKCP, or NCPS) for counsellors/psychotherapists, as applicable. ⚠️ CLINICAL: confirm the minimum acceptable registers/accreditations Faresay will accept, and whether unaccredited counsellors are excluded.

⚠️ COUNSEL: "Therapist" and "counsellor" are not statutorily protected titles in the UK. Confirm that mandating statutory registration (HCPC) or PSA-accredited-register membership is a sufficient and defensible vetting standard, and what additional checks counsel would require (DBS, identity, qualification verification). See uk-legal-regulatory-brief.md (§3).

4.2.2 Verification must capture and store, at minimum: the registering/accrediting body, registration/membership number, registration type and scope, issue and expiry/renewal dates, and current standing. [PLACEHOLDER: verification provider / method — e.g. primary-source verification against the regulator's / register's online check.]

4.3 References

4.3.1 Faresay will obtain and review [PLACEHOLDER: number] professional reference(s) appropriate to the role. ⚠️ CLINICAL: confirm reference requirements (number, source, whether clinical-supervisor references are required).

4.4 Background / DBS checks

4.4.1 Faresay will require an appropriate criminal-records / suitability check. ⚠️ COUNSEL / ⚠️ CLINICAL: confirm the correct DBS level for remote, non-regulated-activity mental-health work (basic vs standard vs enhanced), and whether the work meets the definition of "regulated activity" — this affects DBS eligibility and barred-list checks. Confirm the equivalent route in Scotland (Disclosure Scotland / PVG) and Northern Ireland (AccessNI). Do not assert a check level until confirmed.

4.5 Professional indemnity insurance

4.5.1 Each Practitioner must hold and maintain professional indemnity / professional liability insurance appropriate to their discipline and to the telehealth services delivered, at coverage limits no lower than [PLACEHOLDER: minimum limits]. Faresay will verify cover at onboarding and on renewal.

⚠️ COUNSEL / ⚠️ CLINICAL: Minimum coverage limits, whether telehealth is within the policy's scope, and any requirement for Faresay to be named/additional insured must be set with counsel and the clinical lead.

4.6 Fitness and declarations

4.6.1 At onboarding and on renewal, Practitioners must declare any past or pending fitness-to-practise proceedings, registration conditions/restrictions/suspensions, criminal matters, and material complaints or claims. Material non-disclosure may result in removal from the Platform.

4.7 Ongoing registration / sanction monitoring

4.7.1 Verification is not a one-time event. Faresay will operate ongoing monitoring of each Practitioner's continued eligibility, including:

monitoring registration/accreditation expiry and requiring evidence of renewal before lapse;
periodic re-verification of standing with each relevant Professional Body / register on a defined cadence ([PLACEHOLDER: e.g. at least annually, and on renewal]);
monitoring for disciplinary actions, sanctions, conditions, suspensions, or restrictions, including checks against the relevant regulator's / register's published actions. ⚠️ COUNSEL: confirm the permissible/required sources for monitoring sanctions across HCPC, the PSA-accredited registers, and the relevant social-work regulators.
monitoring lapses or changes to professional indemnity insurance.

4.7.2 On discovery of an expiry, sanction, restriction, or loss of insurance affecting a Practitioner's eligibility, Faresay will suspend the Practitioner's availability pending review by the Clinical Lead, and manage any client-continuity-of-care implications under Sections 6, 12, and the Crisis / Safeguarding Policy (uk-crisis-safeguarding-policy.md).

5. Standards of Care and Evidence-Based Practice

5.1 Practitioners are expected to deliver care that is consistent with current, recognised, evidence-based or evidence-informed practice for the presenting need and client population, within the limits of telehealth delivery.

5.2 Practitioners must comply with the ethical and practice standards of their Professional Body / register (Section 18), including standards specific to remote/telehealth delivery.

5.3 ⚠️ CLINICAL: Confirm whether Faresay will reference or require adherence to specific clinical guidelines (e.g. NICE guidance) or remain at the level of "consistent with the Practitioner's professional standards and competence." Avoid setting standards that could be read as Faresay directing clinical care.

5.4 Practitioners must keep their knowledge and skills current (see Section 10) and practise within their competence (Section 6).

6. Scope of Practice and Competence

6.1 Practising within competence

6.1.1 Practitioners must only provide Clinical Services that fall within their Scope of Practice — that is, services they are qualified, trained, competent, registered/accredited, and (where required) supervised to provide — and only with client populations and presentations they are competent to treat.

6.1.2 Practitioners must not work beyond their competence and must refer or signpost a Client elsewhere where the Client's needs fall outside the Practitioner's competence or outside what can be safely delivered on this Platform.

6.2 Presentations unsuitable for the Platform

6.2.1 ⚠️ CLINICAL: Faresay operates a private-pay telehealth marketplace. Certain presentations and acuity levels are not appropriate for this setting and must be excluded from, or escalated out of, Platform-based care. These include (indicatively, to be finalised by the Clinical Lead):

active suicidal or homicidal crisis, or imminent risk of serious harm to self or others;
presentations requiring urgent, emergency, or in-person crisis intervention or hospitalisation;
conditions requiring a level or intensity of care that telehealth cannot safely provide (e.g. acute psychosis requiring stabilisation, severe/high-risk eating disorders requiring medical monitoring, acute withdrawal/detoxification);
circumstances where the Client cannot be safely treated remotely (e.g. no safe, private environment; age limits).

6.2.2 The detailed clinical thresholds, screening, and the response when an excluded presentation is identified before or during care (including safe referral, escalation, and signposting to emergency services — 999, Samaritans 116 123, NHS 111, SHOUT 85258) are governed by the Crisis / Safeguarding Policy (uk-crisis-safeguarding-policy.md), which this Policy cross-references and must be read with. ⚠️ CLINICAL: ensure the exclusion list here and the screening/escalation pathways in the Crisis / Safeguarding Policy are mutually consistent.

7.1 Before Clinical Services begin, the Practitioner is responsible for obtaining the Client's informed consent to treatment, consistent with the Practitioner's professional and legal obligations.

7.2 Informed consent should cover, at minimum: the nature, format, and limits of telehealth delivery; the likely approach and any material risks/benefits and alternatives; confidentiality and its limits (including safeguarding disclosures — see uk-crisis-safeguarding-policy.md); how clinical records are kept and by whom; fees and the private-pay model; and arrangements for crisis/out-of-hours situations and what to do in an emergency.

7.3 ⚠️ CLINICAL / ⚠️ COUNSEL: Informed-consent content and documentation requirements differ by discipline. Confirm any UK-specific consent requirements and whether consent must be documented in a prescribed form. (Faresay serves adults only; if minors are ever served, capacity to consent must be assessed under Gillick competence / the Fraser guidelines — see Section 13.)

7.4 Consent to clinical treatment (the Practitioner's responsibility) is distinct from consent to data processing by Faresay as a platform, which is addressed in the Privacy Policy (uk-privacy-policy.md).

8. Clinical Record-Keeping Standards

8.1 The Practitioner holds the clinical record

8.1.1 The clinical record is owned and held by the Practitioner — not by Faresay. The Practitioner is the controller/custodian of the Clinical Record and is responsible for creating, maintaining, retaining, securing, and (where required) disposing of it in accordance with law and professional standards. See uk-therapist-agreement.md.

8.1.2 Faresay processes Client and platform data as a technology provider as described in the Privacy Policy (uk-privacy-policy.md) and Security & Data Protection Policy (uk-security-data-protection-policy.md); this is distinct from holding the Clinical Record.

⚠️ COUNSEL: The controller/processor (UK GDPR / DPA 2018) characterisation of Faresay versus the Practitioner for the Clinical Record and associated data must be confirmed with counsel, and may require a data-sharing / data processing agreement (and consideration of a joint-controller or controller-to-controller arrangement). See uk-security-data-protection-policy.md and uk-legal-regulatory-brief.md (§5).

8.2 Minimum record-keeping standards

8.2.1 Practitioners must keep clinical records that are, at minimum:

accurate, contemporaneous, and legible — created at or close to the time of the contact;
adequate — sufficient to support continuity and the clinical decisions made, including presenting issues, assessment, risk assessment, formulation/treatment plan, consent, session notes, and any referrals or safeguarding actions;
secure and confidential — stored to the security standard required by law and uk-security-data-protection-policy.md;
retained for the period required by the Practitioner's Professional Body and applicable UK law, and then securely disposed of.

8.2.2 [PLACEHOLDER: minimum retention periods] ⚠️ CLINICAL / ⚠️ COUNSEL: retention periods differ by discipline and client age (e.g. records for minors). Confirm the applicable UK standards, and whether Faresay's platform tooling stores any clinical content (and if so, under what agreement).

9. Clinical Supervision and Continuing Professional Development

9.1 Practitioners must maintain clinical supervision and continuing professional development (CPD) consistent with the requirements of their Professional Body / register, and must be able to evidence this on request.

9.2 ⚠️ CLINICAL: Some UK modalities/bodies require ongoing supervision (e.g. BACP's supervision requirement for counsellors). Confirm the minimum supervision and CPD standards Faresay will require, and whether trainee/pre-accredited practitioners are admitted at all and, if so, how supervision is evidenced.

9.3 Faresay does not act as the Practitioner's clinical supervisor and does not provide clinical supervision; responsibility for arranging adequate supervision rests with the Practitioner.

10. Quality Assurance and Outcome Monitoring

10.1 ⚠️ CLINICAL: Faresay will operate a clinical quality-assurance programme, overseen by the Clinical Lead and Clinical Advisory Function. The detailed design — including which measures, thresholds, and review cadences are appropriate and clinically valid — must be set by the clinical lead. Indicative components:

Routine Outcome Measures (ROMs): use of validated, standardised measures (e.g. [PLACEHOLDER: instruments — to be selected by clinical lead]) to track client progress, used as a clinical tool by Practitioners rather than as a performance metric imposed by Faresay.
Client feedback: structured post-session/episode feedback and satisfaction measures, and a clear route for clients to raise clinical concerns (Section 13).
Periodic case review / clinical audit: sampling and review of de-identified cases or anonymised practice data against agreed standards, by the Clinical Advisory Function.
Practitioner quality signals: monitoring of indicators such as cancellation/no-attend patterns, complaints, and incidents, used supportively and proportionately.

10.2 ⚠️ COUNSEL / ⚠️ CLINICAL: Outcome and case-review activity must be designed so it does not (a) make Faresay the provider of clinical care or override clinical judgement, or (b) breach client confidentiality / UK data-protection law. Confirm the lawful basis, de-identification approach, and consent position for any clinical-data use with counsel; confirm clinical validity with the clinical lead.

10.3 Quality-assurance findings feed into Practitioner support, this Policy's periodic review (Section 16), and the risk register (risk-register.md).

11. Incident Reporting and Management

11.1 A clinical incident is any event in connection with Clinical Services that caused, or had the potential to cause, harm to a Client or another person — including safeguarding concerns, serious adverse events, suspected boundary or ethical breaches, data incidents affecting clinical information, and "near misses."

11.2 Practitioners and Faresay personnel must report clinical incidents promptly through [PLACEHOLDER: reporting channel / form]. Faresay will maintain an incident log and triage incidents to the Clinical Lead.

11.3 The Clinical Lead (with the Clinical Advisory Function for serious incidents) will ensure each incident is reviewed, immediate client safety is addressed, root causes and learning are identified, and corrective actions are tracked to completion. Trends are reported into quality assurance (Section 10) and the risk register (risk-register.md).

11.4 ⚠️ CLINICAL / ⚠️ COUNSEL: Certain incidents trigger external reporting or notification duties — for example to a regulator / professional body, a local-authority safeguarding lead, an insurer, or (for personal-data breaches) the ICO and affected individuals. The mandatory external reporting matrix must be confirmed with counsel and the clinical lead, including any variation across England, Scotland, Wales, and Northern Ireland. Crisis events (e.g. risk to life) are governed by the Crisis / Safeguarding Policy (uk-crisis-safeguarding-policy.md).

11.5 Faresay will not retaliate against good-faith reporting of incidents or concerns.

12. Complaints Handling — Clinical Route

12.1 Faresay operates a clear route for Clients (and others) to raise concerns or complaints. Complaints are triaged into:

Clinical complaints — concerning the quality, safety, or conduct of clinical care — which are routed to the Clinical Lead / Clinical Advisory Function; and
Platform complaints — concerning the technology, billing, scheduling, or service — handled by Faresay's support/operations function.

12.2 Clinical complaints will be acknowledged within [PLACEHOLDER: timeframe] and investigated by, or under the oversight of, the Clinical Lead, with the Practitioner given a fair opportunity to respond. Outcomes, learning, and any actions (including referral to fitness-to-practise processes where warranted) will be recorded and fed into incident management (Section 11) and quality assurance (Section 10).

12.3 Clients retain the right to complain directly to the Practitioner's Professional Body / register, and Faresay will not obstruct this. Faresay will signpost the relevant body where appropriate. [PLACEHOLDER: complaints contact / address.]

12.4 ⚠️ COUNSEL: Confirm any complaint-handling requirements, timeframes, and record-keeping obligations applicable in the UK (including whether any ADR/ombudsman scheme applies), and how clinical complaints interact with Faresay's terms (terms-of-service.md). See uk-legal-regulatory-brief.md (§7).

13. Suitability / Exclusion Criteria for Onboarding Clients

13.1 The Platform is suitable for adults seeking telehealth mental-health care for presentations that can be safely treated remotely on a private-pay, planned-care basis. Faresay serves adults only.

13.2 ⚠️ CLINICAL: Client suitability screening and exclusion criteria must be defined by the clinical lead and aligned with Section 6 and the Crisis / Safeguarding Policy. Indicative exclusion/triage criteria for onboarding a Client:

individuals in acute crisis or at imminent risk of harm to self or others (route to emergency services / crisis pathways — 999, Samaritans 116 123, NHS 111, SHOUT 85258 — per uk-crisis-safeguarding-policy.md);
presentations requiring emergency, in-person, or higher-intensity care than telehealth can safely provide (see 6.2);
minors — the Platform currently serves adults only. [PLACEHOLDER: confirm whether under-18s are ever served; if so, age thresholds, parental/guardian consent, and additional safeguards.] ⚠️ CLINICAL / ⚠️ COUNSEL: serving minors materially increases clinical and legal complexity (capacity and consent assessed under Gillick competence / the Fraser guidelines, safeguarding, mandatory reporting). Confirm explicitly that the Platform does not serve minors at launch.

13.3 Where a prospective or current Client is identified as unsuitable, Faresay and/or the Practitioner will signpost to more appropriate services and follow the escalation steps in the Crisis / Safeguarding Policy where risk is present.

14. Audit and Periodic Review

14.1 Faresay will periodically audit compliance with this Policy, including: a sample audit of Practitioner verification and ongoing-monitoring records (Section 4); review of incident and complaint logs and actions (Sections 11–12); and review of quality-assurance outputs (Section 10).

14.2 This Policy will be reviewed at least [PLACEHOLDER: e.g. annually], and additionally on any material change to law, regulation, professional standards, the business model, or following a serious incident. Review is led by the Clinical Lead and approved by [PLACEHOLDER: approving body].

14.3 Material clinical risks identified through audit and review are recorded in the risk register (risk-register.md).

15. Roles and Responsibilities Matrix

⚠️ CLINICAL / ⚠️ COUNSEL: Indicative only. The allocation below must be confirmed with the clinical lead and counsel, in particular the boundary that keeps Faresay's role to non-clinical quality/safety governance rather than the provision or direction of clinical care. [PLACEHOLDER: named roles/owners.]

Area	Practitioner	Clinical Lead	Clinical Advisory Function	Faresay (non-clinical: trust & safety / ops / engineering)
Clinical decisions for individual clients	Owns / accountable	— (no individual-case direction)	—	—
This Policy & clinical standards	Comply	Owns / maintains	Advises / endorses	Supports operationally
Onboarding & verification (Section 4)	Provide evidence	Sets criteria; approves exceptions	Advises	Runs checks operationally
Ongoing registration/sanction monitoring (4.7)	Keep credentials current; disclose	Reviews flags; suspends eligibility	Advises	Runs monitoring; suspends availability operationally
Scope of practice / exclusions (Sections 6, 13)	Works within competence	Defines criteria	Endorses	Implements platform controls
Informed consent (Section 7)	Obtains & documents	Sets standard	Advises	Provides supporting tooling
Clinical records (Section 8)	Owns / holds / retains	Sets minimum standards	Advises	Provides secure platform tooling only
Supervision & CPD (Section 9)	Arranges & evidences	Sets minimum requirement	Advises	Verifies evidence
Quality assurance & outcomes (Section 10)	Participate	Owns programme	Conducts case review	Provides data tooling
Incidents (Section 11)	Report; act on client safety	Reviews / oversees	Reviews serious incidents	Logs; triages
Complaints — clinical (Section 12)	Respond	Oversees clinical route	Reviews	Triages; handles platform complaints
Audit & review (Section 14)	Cooperate	Leads	Participates	Supports

16. References to Professional and Ethical Frameworks

16.1 ⚠️ CLINICAL / ⚠️ COUNSEL: The list below is indicative and must be confirmed and completed by the clinical lead and counsel — including which bodies/registers Faresay will recognise, and the correct, current standards for each discipline.

16.2 United Kingdom (indicative).

HCPC (Health and Care Professions Council) — statutory regulator of practitioner psychologists (and others).
BACP (British Association for Counselling and Psychotherapy) — PSA-accredited register, ethical framework, and accreditation for counsellors/psychotherapists.
UKCP (UK Council for Psychotherapy) — PSA-accredited register and standards for psychotherapists.
NCPS (National Counselling and Psychotherapy Society) — PSA-accredited register for counsellors/psychotherapists.
BPS (British Psychological Society) — professional body / practice guidance for psychologists.
Social Work England — statutory regulator of social workers in England, with equivalents in the other UK nations: SSSC (Scottish Social Services Council) in Scotland, Social Care Wales in Wales, and NISCC (Northern Ireland Social Care Council) in Northern Ireland.
PSA-accredited registers — more broadly, registers accredited under the Professional Standards Authority's Accredited Registers programme.
[PLACEHOLDER: other relevant bodies — e.g. BABCP — and which Faresay recognises.]

16.3 Practitioners remain bound by the ethical and practice standards of the body that registers/accredits them, in addition to this Policy. Where this Policy and a Practitioner's professional standards conflict, the Practitioner must comply with their professional/legal obligations and raise the conflict with the Clinical Lead.

CONTEXT.md — shared fact sheet (source of truth).
uk-legal-regulatory-brief.md — UK legal & regulatory brief (structuring reference and open questions for counsel).
uk-therapist-agreement.md — Practitioner contractual terms (credentialing, records, fee characterisation).
uk-crisis-safeguarding-policy.md — crisis, risk, safeguarding, and escalation pathways (cross-referenced throughout).
uk-privacy-policy.md and uk-security-data-protection-policy.md — data protection and security.
terms-of-service.md — client-facing terms.
risk-register.md — risk capture and tracking.

End of DRAFT v0.1. ⚠️ This document must be validated by a UK-qualified clinical lead (and, for the points flagged ⚠️ COUNSEL, by UK counsel) before use.

UK Clinical Governance Policy