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1 Re: Formal Complaint and Request for Investigation — Professional Conduct, Standards, Patient Safety and Fitness to Practise of a Psychologist in Scotland- Responsibility for the Regulation, Supervision, Professional Standards, Complaints and Fitness to Practise of Psychologists in Scotland To: Health and Care Professions Council (HCPC) Subject: Serious concerns regarding professional conduct, competence, patient safety, professional standards and fitness to practise I am making this complaint because I consider the matters described below to be sufficiently serious to warrant formal investigation rather than being treated solely as a routine service complaint. I ask that the concerns be considered separately under the appropriate procedures for: 1. professional conduct and standards; 2. competence and clinical practice; 3. patient/service-user safety; 4. compliance with professional duties and applicable standards; 5. clinical supervision and governance, where relevant; 6. the adequacy and accuracy of assessment, records and decision-making; 7. the handling of my concerns and any subsequent complaint; 8. whether the conduct raises questions concerning the psychologist's fitness to practise; and 9. whether there are any wider organisational or systemic issues requiring investigation. I respectfully request that this matter is not confined to an internal complaint about the service provided. Where the evidence raises a question about the psychologist's professional fitness to practise, I ask that the matter is referred to, or considered by, the appropriate regulatory authority. I also request confirmation of which organisation has responsibility for investigating each aspect of this complaint and that any evidence relevant to the concerns is preserved. I enclose/support this complaint with the relevant chronology, correspondence, clinical documentation and other evidence. Please acknowledge receipt of this complaint and confirm the reference number, the person or department responsible for investigating it, the applicable procedure, and whether any referral to the HCPC or another statutory body is considered necessary. Yours faithfully,
2 FORMAL SERIOUS COMPLAINT AND REQUEST FOR INVESTIGATION Re: Responsibility for the Regulation, Supervision, Professional Standards, Complaints and Fitness to Practise of Psychologists in Scotland Alleged unconsented psychological intervention; purported experimental treatment; professional misconduct; abuse of professional power; deliberate creation of dependency and psychological distress; safeguarding failures; cultural, racial and religious concerns; and potential criminal conduct To: Health and Care Professions Council (HCPC) Fitness to Practise Copies, where applicable, to: • Relevant NHS Scotland Health Board / employer of any psychologist concerned • Director/Head of Psychology or Psychological Services • Relevant Clinical Governance and Safeguarding Department • Police Scotland • Relevant local authority Adult Support and Protection service • Mental Welfare Commission for Scotland, where its statutory remit is engaged • Scottish Public Services Ombudsman, where an NHS/public-service complaints process has been exhausted
3 1. PURPOSE OF THIS COMPLAINT I submit this complaint as a serious request for regulatory, safeguarding and, where appropriate, criminal investigation concerning the conduct of individuals who are alleged to have represented themselves as psychologists, mental-health professionals, researchers, therapists or persons acting under psychological expertise. The complaint concerns conduct allegedly directed at an adult woman in Scotland over approximately two years and two months, involving what the individuals concerned described as “cold therapy” or a psychological intervention. The central concern is not simply that the intervention may have been clinically ineffective. The concern is that, if the evidence is substantiated, the activity may have involved: • psychological assessment and diagnosis without a recognised clinical relationship; • psychological intervention without valid informed consent; • involvement of unregulated third parties in purported treatment; • deliberate creation of distress and an abusive environment as an alleged therapeutic technique; • deliberate attempts to induce psychological dependency; • attempts to separate the individual from existing family and social relationships; • attempts to redefine the individual's identity and interpersonal relationships; • deliberate role-playing of parent/child relationships; • alleged attempts to induce a condition described by the group as “Stockholm syndrome” or comparable dependency; • deliberate restriction of the individual's ordinary life; • interference with employment and financial independence; • prolonged isolation; • alleged stalking and harassment; • repeated diagnostic labelling without adequate assessment; • disregard of relevant neurodevelopmental history; • alleged obstruction of access to independent ADHD assessment; • culturally and religiously insensitive or potentially discriminatory assumptions; • use of an allegedly experimental psychological model without appropriate ethical safeguards; • failure to provide an independent route for consent, withdrawal, complaint or review; • and conduct which may amount, depending upon the evidence, to professional misconduct, impairment of fitness to practise, safeguarding concerns and/or criminal conduct.
4 I therefore ask that this matter not be treated as an ordinary disagreement between a service user and a psychologist. If the allegations are substantiated, the issues concern the possible misuse of psychological authority and professional knowledge to create dependency, diminish autonomy and control an adult's environment. 2. STATUS OF THE COMPLAINT — FACTS, EVIDENCE AND MATTERS REQUIRING INVESTIGATION I recognise that the regulatory bodies and police must distinguish between established facts, allegations, interpretations and clinical conclusions. Accordingly, wherever this complaint describes conduct attributed to particular individuals, I ask that the relevant evidence be examined rather than assuming that the allegations are established. I do not ask the HCPC to accept a psychiatric diagnosis made by the complainant about any person involved. I ask instead that the HCPC independently establish: 1. who was involved; 2. what professional qualifications they possessed; 3. which individuals were registered with the HCPC; 4. what professional role each person claimed to have; 5. whether any Scottish psychologist was acting in a professional capacity; 6. what contact occurred; 7. whether a clinical relationship existed; 8. whether consent was obtained; 9. what assessment was conducted; 10. what diagnoses were made and on what evidence; 11. what treatment or intervention was proposed; 12. what evidence supported the intervention; 13. who designed it; 14. who supervised it; 15. who monitored risk; 16. what safeguards existed; 17. why unregulated third parties were involved; 18. what records were created; 19. whether the individual's objections and requests to stop were respected; and
5 20. whether the conduct raises questions concerning fitness to practise. 3. THE PERSON AFFECTED The individual concerned is an adult woman, approximately 35 years old, who is: • of Arab ethnicity; • Muslim; • a refugee; • highly educated, including postgraduate education; • qualified in personal training; • qualified in pre- and post-natal training; • qualified in training relating to chronic diseases; • and has a longstanding history of ADHD dating from childhood. These characteristics are relevant because the alleged intervention appears to have incorporated assumptions concerning her: • ethnicity; • religion; • language; • family; • mother; • childhood; • identity; • personality; • and interpersonal relationships. The complaint therefore asks that the possibility of intersectional discrimination and cultural stereotyping be considered rather than treating these characteristics as incidental background information. The HCPC's practitioner-psychologist standards expressly require practitioners to recognise the impact of culture, equality, diversity, protected characteristics and intersectional experiences, to understand equality legislation and to practise in a non-discriminatory and inclusive manner. (The HCPC)
6 4. HOW THE ALLEGED INTERVENTION BEGAN The alleged conduct did not begin as an ordinary clinical referral. The account is that an online group consisting of individuals presenting themselves as writers, YouTubers, personality specialists and/or psychological experts began taking an interest in the individual. The alleged conduct subsequently involved foreign psychologists or persons presenting themselves as psychologists, including individuals associated with the United States, Canada and Israel. Scottish psychologists allegedly became involved subsequently. A fundamental question is therefore: How did psychologists become involved with an adult who had not voluntarily entered into a clinical relationship with them? I ask the HCPC to establish: • whether any referral existed; • whether the individual requested psychological assessment; • whether she attended a clinical appointment; • whether she signed a consent form; • whether she agreed to psychological observation; • whether she agreed to third-party involvement; • whether she agreed to online monitoring; • whether she agreed to information about herself being collected; • whether she agreed to be diagnosed; • whether she agreed to any intervention; • and whether she ever agreed that people could attend or monitor her home.
7 5. ALLEGED STALKING, MONITORING AND NON-CLINICAL OBSERVATION The complaint alleges that the initial activity involved conduct directed towards the individual at or around her home and elsewhere, which she understood to be stalking and harassment. This is important because observing, following, contacting or monitoring a person without consent is not transformed into legitimate psychological treatment merely because someone later describes it as “studying their personality.” Section 39 of the Criminal Justice and Licensing (Scotland) Act 2010 creates an offence of stalking where the statutory requirements are met, including a course of conduct causing fear or alarm and the required intention or knowledge/reasonableness test. The statutory examples of conduct include following and contacting a person. (scts_judiciary) I therefore ask Police Scotland, where appropriate, to investigate the underlying conduct independently of any psychological explanation subsequently given for it. I also ask the HCPC to investigate whether any registered psychologist: • participated in such conduct; • encouraged it; • knew about it; • obtained information from it; • used information obtained through it for diagnostic purposes; • directed others to engage in it; • or attempted retrospectively to characterise it as psychological treatment. 6. ABSENCE OF A CLINICAL FRAMEWORK The alleged activity was not, at its commencement, a conventional clinical service. There was allegedly: • no formal referral; • no conventional clinical appointment; • no recognised treatment provider; • no agreed treatment plan; • no informed consent; • no independent assessment; • no documented risk assessment; • no clear clinician responsible for the person's welfare; • no independent complaints mechanism;
8 • no agreed right to withdraw; • no independent clinical review; • and no recognised framework authorising third parties to intervene in the individual's private life. This raises a fundamental regulatory question: What authority did the psychologists believe they possessed to diagnose, monitor or treat an adult who had not voluntarily entered into a therapeutic relationship with them? The HCPC standards require practitioner psychologists to respect service users' autonomy and obtain valid consent that is voluntary and informed, appropriately documented and proportionate to the circumstances. They also require practitioners to recognise their professional duty of care, power imbalance and appropriate professional boundaries. (The HCPC) 7. THE PURPORTED “COLD THERAPY” The group allegedly described its conduct as “cold therapy” or a treatment for the individual's alleged personality problems. The alleged intervention did not resemble ordinary supportive psychological treatment. It allegedly involved: • deliberate isolation; • restricting ordinary social and family relationships; • restricting employment or ability to work; • financial pressure; • deprivation of ordinary sources of assistance; • monitoring; • harassment; • deliberate emotional distress; • deliberate triggering; • creating an allegedly abusive environment; • attempts to induce dependency; • attempts to make the individual regard the group as her new family; • and attempts to make her abandon existing family bonds. I ask the HCPC to require the practitioners concerned to identify: 1. the recognised psychological model underlying “cold therapy”; 2. the published scientific evidence supporting it;
9 3. the professional body that recognises it; 4. the clinical indication for its use; 5. the qualifications required to administer it; 6. the treatment protocol; 7. the risk-assessment protocol; 8. the consent process; 9. the supervision arrangements; 10. the stopping criteria; 11. the safeguarding arrangements; 12. the independent review process; and 13. the evidence demonstrating that the intervention was proportionate and clinically justified. 8. ALLEGED EXPERIMENTAL NATURE OF THE INTERVENTION If the intervention was being used as an experiment, research project, personality experiment, behavioural experiment or other form of systematic investigation rather than established clinical care, this raises a separate set of ethical questions. The UK Policy Framework for Health and Social Care Research states that research must be scientifically sound and guided by ethical principles, that participants' rights, safety and wellbeing prevail over the interests of science and society, and that where consent is required it should be properly informed and documented. The Framework applies to health research in Scotland. (Health Research Authority) Accordingly, I ask: • Was this research? • If yes, where was the research protocol? • Who was the sponsor? • Who was the chief investigator? • Was ethical review obtained? • Was the appropriate research ethics committee involved? • Was the participant given research information? • Was informed consent obtained? • Was withdrawal permitted? • Were adverse events monitored? • Was participant safety assessed?
10 • Were the researchers appropriately qualified? • Were the activities registered or otherwise formally authorised where required? If the answer is that it was not research, then I ask the HCPC to establish on what recognised clinical basis the activity was nevertheless being conducted. The absence of a research classification cannot simply be used to avoid research ethics if the activity was in substance research. Conversely, the complaint does not assert that every novel therapeutic intervention is automatically “illegal experimentation”. The issue is whether the activity was properly classified, authorised, ethically justified, consented to and professionally conducted. 9. DELIBERATE CREATION OF AN ABUSIVE OR DISTRESSING ENVIRONMENT One of the most serious allegations is that the group deliberately sought to create an environment resembling abuse in order to trigger psychological responses. The alleged theory was approximately: create distress → trigger the person → reproduce an alleged childhood dynamic → create confusion/transference → induce attachment/dependency → establish bonding with the group → regard this as therapeutic → ultimately change the person's personality. If this is supported by communications from the participants, I ask the HCPC to treat it as a central issue. The relevant question is not simply whether “transference” exists as a psychological concept. The question is: Can a practitioner deliberately create or facilitate an abusive, frightening, isolating or dependency- producing environment and then rely upon the psychological attachment generated by that environment as part of the purported treatment? The HCPC standards require practitioners to protect service-user interests, respect autonomy, obtain voluntary and informed consent, exercise duty of care, recognise professional power, avoid abuse of that power and maintain appropriate boundaries. They also require reasoned decisions concerning initiation, continuation, modification or cessation of treatment. (The HCPC) 10. ALLEGED ATTEMPT TO CREATE DEPENDENCY The alleged objective was not merely therapeutic improvement. The group allegedly wanted the individual to: • bond with the group; • become emotionally dependent on them; • regard them as a replacement family; • reduce or abandon existing family bonds;
11 • normalise the group's alleged stalking/harassment; • accept the group as the primary source of emotional security; • and become unable or unwilling to function independently of the group. The group allegedly referred to “Stockholm syndrome” or comparable bonding/dependency as an intended outcome. If documentary evidence supports this allegation, I ask that the HCPC investigate whether the practitioners were deliberately using the professional relationship to create an emotional or psychological dependency. This is particularly serious in light of HCPC standards concerning power imbalance and the prohibition on abusing a health and care professional's position to pursue personal, emotional or financial relationships with service users. (The HCPC) 11. ATTEMPTED EROSION OF AUTONOMY, IDENTITY AND EXISTING RELATIONSHIPS The alleged intervention appears to have sought to alter not merely symptoms but the individual's: • sense of self; • family identity; • cultural identity; • interpersonal attachments; • understanding of her own history; • relationship with her biological family; • independence; • employment; • financial autonomy; • and ability to make decisions outside the group. The complaint is therefore concerned with what may amount to an attempted erosion of personal autonomy and psychological independence. I ask the regulator to examine whether psychological concepts, diagnostic labels or professional authority were used to make the individual doubt or abandon her own understanding of: • who she was; • who her family was; • what relationships she wished to maintain; • what treatment she wanted; • and whether she was entitled to refuse the intervention.
12 The HCPC's standards expressly identify service-user autonomy as part of professional practice and require practitioners to facilitate informed participation in assessment, diagnosis and treatment. (The HCPC) 12. ALLEGED MOTHER/CHILD ROLE-PLAY A particularly concerning feature is the alleged insistence that the adult woman should participate in a forced psychological “mother/child” dynamic. The group allegedly: • described the situation as resembling a mother-child household; • required the woman to adopt either a child role or mother role; • attempted to make older men assume parental or maternal roles; • described this as therapeutically necessary; • claimed it would create bonding; • and allegedly insisted that the individual's relationship with these strangers could be transformed into a parental relationship. One alleged participant was an approximately 65-year-old Israeli man with no children who allegedly attempted to assume the role of an “Arab mother” towards an adult Arab woman. I do not suggest that cultural difference or age difference by itself makes psychological treatment improper. The issue is whether a practitioner deliberately created a pseudo-family relationship with a vulnerable adult without valid consent and as a means of inducing dependency. I ask the HCPC to determine: • who proposed this technique; • what professional literature supports it; • whether it is recognised therapy; • whether it was consented to; • whether it was clinically indicated; • whether the person could refuse; • whether the participants were qualified; • whether the psychologists supervised it; • and whether professional boundaries were breached.
13 13. TRANSFERENCE AND COUNTERTRANSFERENCE The group allegedly claimed that it would deliberately imitate abusive parental behaviour to cause the individual to experience transference and then bond with the group. The complaint does not dispute that transference and countertransference are recognised concepts in psychological practice. The issue is their alleged deliberate weaponization. In particular, the group allegedly attempted to: 1. manufacture an artificial parental environment; 2. deliberately trigger distress; 3. induce confusion; 4. create attachment to the people causing the distress; 5. encourage dependency; 6. then characterise that dependency as evidence that the intervention was succeeding. The complaint asks whether this represented a serious misuse of psychological concepts and professional authority. It is also relevant that the alleged environment did not correspond to the individual's actual childhood environment. 14. FAILURE TO ESTABLISH THE ACTUAL FAMILY HISTORY The group allegedly did not properly investigate the individual's actual relationship with her mother. Instead, they allegedly constructed their own theory about the mother-child relationship. This is particularly concerning because the proposed treatment allegedly depended upon reproducing similarities with the individual's childhood. If the group did not establish the factual history first, I ask: On what clinical evidence did they determine what should be reproduced? I ask the HCPC to investigate whether a full and accurate psychological assessment was ever performed. The HCPC has specifically identified failure to conduct a full/accurate assessment as a type of fitness- to-practise concern involving practitioner psychologists. Its published case material emphasises accurate assessment, informed decision-making, appropriate records and reasoned treatment decisions. (The HCPC)
14 15. CULTURAL, RACIAL AND RELIGIOUS DIMENSIONS The individual is Arab, Muslim and Arabic-speaking. The alleged intervention involved predominantly white, English-speaking individuals and allegedly attempted to impose a model of an “Arab mother” and Arab family dynamics without adequately establishing the individual's actual cultural and family experience. The complaint asks whether the practitioners: • relied upon racial or cultural stereotypes; • treated “Arab” or “Muslim” as a psychological category; • made assumptions about Arab mothers; • made assumptions about Muslim family structures; • ignored the individual's own account of her culture and family; • used her ethnicity or religion as part of the proposed psychological manipulation; • or deliberately exploited those characteristics. The HCPC standards specifically require practitioner psychologists to recognise cultural differences, intersectional experiences and protected characteristics, understand equality legislation and practise in a non-discriminatory and inclusive manner. (The HCPC) 16. POTENTIAL EQUALITY ACT 2010 ISSUES Race and religion or belief are protected characteristics under the Equality Act 2010. The Act contains protections concerning discrimination and harassment in the provision of services and exercise of public functions, although the precise application depends upon the legal status of the person/entity providing the service and the circumstances. Accordingly, I ask the appropriate body to determine whether any conduct falls within: • discrimination; • harassment; • victimisation; • discriminatory provision of services; • discriminatory exercise of a public function; • or other prohibited conduct under the Equality Act 2010. I do not ask the HCPC to assume that every unpleasant interaction constitutes unlawful discrimination. I ask that the evidence be examined to determine whether the individual's race, nationality, ethnic origin, religion or belief was a factor in the treatment she received.
15 This is particularly relevant if the alleged treatment deliberately relied upon stereotypes concerning Arab women, Muslim women, Arab mothers or family structures. 17. POTENTIAL HATE-CRIME AGGRAVATION I ask Police Scotland and, where appropriate, the Procurator Fiscal to determine whether any underlying criminal conduct was: • motivated by hostility based on race; • accompanied by such hostility; • motivated by hostility based on religion; • or otherwise falls within the hate-crime framework. The Hate Crime and Public Order (Scotland) Act 2021 provides statutory hate-crime aggravations and came into force on 1 April 2024. Race and religion are among the protected characteristics. The Scottish Government also expressly recognises that a person may experience hate crime intersectionally through more than one characteristic. (Scottish Government) The Scottish crime-recording guidance also states that where a crime is reported and is perceived to be motivated by hate, it should be recorded and investigated as such, subject to the applicable legal framework. (Scottish Government) I therefore request that the racial and religious dimension is formally recorded and assessed, rather than treated as irrelevant background. 18. HUMAN RIGHTS CONSIDERATIONS If any public authority, NHS body or other public-function body was involved, I ask that the relevant human-rights obligations be considered. Potentially relevant rights include: Article 3 — prohibition of torture and inhuman or degrading treatment If the evidence establishes treatment reaching the required threshold of severity, the alleged deliberate infliction of severe psychological distress, degradation or conditions causing serious suffering may require consideration under Article 3. I do not ask the HCPC to make a premature Article 3 determination; I ask that evidence relevant to that question is preserved and referred to the appropriate authority. Article 8 — private and family life Article 8 is potentially relevant to: • personal autonomy; • psychological integrity; • private life;
16 • family relationships; • home; • personal identity; • correspondence; • and freedom from unjustified interference. The alleged attempt to separate the individual from her biological family and replace those relationships with a group of strangers is therefore potentially relevant. Article 9 — freedom of thought, conscience and religion Because the individual is Muslim and the alleged intervention allegedly sought to interfere with identity, belief and relationships, Article 9 may also require consideration depending on the evidence. Article 14 — non-discrimination Where another Convention right is engaged, Article 14 prohibits discrimination in the enjoyment of Convention rights on grounds including race, religion and other protected status. The Human Rights Act 1998 makes it unlawful for a public authority to act incompatibly with Convention rights, subject to the statutory framework in section 6. (Legislation.gov.uk) These human-rights arguments should not be understood as automatically making every private individual's conduct a breach of the Human Rights Act. Their relevance depends significantly upon whether a public authority or public function was involved. 19. ALLEGED PROLONGED ISOLATION The individual reports approximately two years and two months of alleged isolation in connection with the purported intervention. The allegation is that the group prevented or discouraged ordinary avenues of assistance and attempted to restrict the person's ordinary life. The consequences allegedly included: • social isolation; • interference with employment; • financial difficulties; • loss of ordinary support; • family separation; • psychological dependency; • restriction of ordinary activities; • and deterioration of basic living conditions.
17 I ask the HCPC to investigate whether any registered psychologist knew of, encouraged, facilitated or failed to challenge these conditions. 20. BASIC WELFARE AND LIVING CONDITIONS A particularly serious allegation concerns the absence of adequate heating and gas for an extended period. The complaint alleges that the individual was left without heating for approximately seven months and was allegedly told, in substance, to adapt to cold conditions. If this occurred in connection with the purported psychological intervention, it raises a question of whether basic welfare needs were deliberately disregarded. I ask the relevant safeguarding authority to investigate independently: • housing conditions; • heating; • access to food; • access to healthcare; • financial resources; • ability to work; • social support; • and whether the person was being prevented or discouraged from seeking assistance. This should not be treated solely as a psychological dispute. 21. ALLEGED INTERFERENCE WITH EMPLOYMENT AND FINANCIAL INDEPENDENCE The alleged intervention reportedly involved restricting the individual's ability to work and creating financial dependency. I ask investigators to establish: • who imposed or encouraged any restrictions; • how they were communicated; • whether psychologists participated; • whether financial dependence was an intended outcome; • whether the group benefited financially; • whether the person was discouraged from working; • and whether any threats or coercion were involved.
18 The HCPC standards specifically prohibit abuse of professional position for personal, emotional or financial relationships and require appropriate professional boundaries. (The HCPC) 22. REPEATED DIAGNOSTIC CHANGES The alleged diagnoses reportedly changed repeatedly, including movement between diagnoses such as: • Narcissistic Personality Disorder; • Borderline Personality Disorder; • other personality formulations; • and subsequent return to previous diagnoses. I do not ask the HCPC to decide which diagnosis is correct. I ask it to establish: 1. who made each diagnosis; 2. their qualifications; 3. what assessment was conducted; 4. what diagnostic criteria were applied; 5. what evidence supported each diagnosis; 6. whether differential diagnosis was considered; 7. whether the individual was informed; 8. whether the diagnosis was documented; 9. why the diagnosis changed; 10. whether the changes reflected new clinical evidence; and 11. whether diagnoses were being changed retrospectively to explain the person's reaction to the intervention. The HCPC requires practitioner psychologists to make informed and reasoned decisions, including decisions to initiate, continue, modify or cease treatment, and to record the reasoning appropriately. (The HCPC) 23. ADHD AND NEURODEVELOPMENTAL HISTORY The individual has a longstanding history of ADHD dating from childhood and has reportedly been awaiting specialist assessment in Scotland since 2022. The complaint alleges that this information was dismissed and that attempts to obtain independent specialist assessment were obstructed or interfered with.
19 I ask investigators to establish: • what information concerning ADHD was available; • when it was communicated; • whether it was recorded; • whether it was considered in diagnostic formulation; • whether referral for independent assessment was made; • whether anyone discouraged or prevented assessment; • and whether personality-disorder theories were allowed to override relevant neurodevelopmental information without adequate clinical justification. The complaint does not assert that ADHD excludes any other diagnosis. It asserts that relevant clinical information should not have been disregarded without proper assessment and reasoning. 24. UNREGULATED THIRD PARTIES The alleged intervention involved people described as: • writers; • YouTubers; • online personality specialists; • foreign psychologists; • and other individuals whose professional status is unclear. I request that every individual involved be identified and classified. For each person, I ask investigators to establish: • full name; • claimed profession; • actual qualification; • registration body; • registration number; • country of registration; • whether the person was licensed to practise; • whether the person was providing psychological advice; • whether the person was diagnosing the individual; • whether the person was participating in treatment;
20 • whether the person was receiving information about the individual; • and what authority, if any, permitted them to participate. If an HCPC registrant knowingly involved unregulated persons in a purported therapeutic intervention, that should be investigated as part of the professional-conduct assessment. 25. CONFIDENTIALITY AND INFORMATION GOVERNANCE I ask investigators to establish whether personal, psychological, medical, family or other sensitive information about the individual was: • collected; • shared; • recorded; • published; • discussed online; • transmitted to third parties; • used by people who had no clinical role; • or retained without appropriate authority. HCPC standards require confidentiality and appropriate information/data governance, and the HCPC states that consent is ordinarily required before identifiable information is shared with third parties unless a recognised exception applies. (The HCPC) This should include investigation of: • online communications; • recordings; • videos; • social-media material; • private messages; • screenshots; • databases; • notes; • and any alleged psychological “case file”.
21 26. PROFESSIONAL BOUNDARIES AND DUAL RELATIONSHIPS The alleged arrangement appears to blur or eliminate the distinction between: • clinician; • researcher; • observer; • online personality; • friend; • family member; • persecutor; • therapist; • and alleged parental figure. This is particularly concerning because the alleged treatment reportedly required the individual to regard strangers as family members. The HCPC specifically requires practitioner psychologists to recognise power imbalance, maintain appropriate boundaries and understand the ethical and legal difficulties associated with dual relationships. Its standards also prohibit abuse of professional position to pursue personal, emotional or financial relationships with service users. (The HCPC) I ask that each relationship be mapped and investigated. 27. ALLEGED REFUSAL TO ACCEPT FEEDBACK OR STOP THE INTERVENTION The individual reportedly repeatedly indicated that the intervention was not working and that it was causing harm. The alleged response was to reinterpret resistance as evidence of the individual's personality pathology and continue the intervention. If established, this is particularly concerning. A treatment cannot safely become self-validating such that: “The treatment is working because the person agrees” and “The treatment is working because the person disagrees.” I ask the HCPC to investigate whether the practitioners had: • measurable treatment objectives; • outcome measures; • review points;
22 • independent review; • stopping criteria; • adverse-event monitoring; • and a genuine mechanism by which the person could say “no”. The HCPC requires psychologists to make reasoned decisions about whether to initiate, continue, modify or cease treatment. (The HCPC) 28. DURATION AND PROPORTIONALITY The alleged intervention continued for approximately 26 months. This duration is relevant not because there is a legally prescribed maximum duration for psychological therapy, but because the alleged intervention was: • unusually prolonged; • allegedly coercive; • allegedly isolating; • allegedly dependency-producing; • allegedly continuously intrusive; • and allegedly imposed without ordinary informed consent. I therefore ask the investigators to determine: What objective clinical evidence justified continuing the intervention for approximately 26 months, and what evidence demonstrated that continuing it was safe, proportionate and beneficial? 29. DELIBERATE PERSONALITY CHANGE VERSUS LEGITIMATE THERAPY The complaint is particularly concerned about the alleged distinction between helping an individual achieve their own therapeutic goals and attempting to reshape the individual's personality and identity according to a group's preferred model. I ask whether the alleged intervention sought to: • make the person dependent; • change her relationships; • replace her family; • alter her identity; • undermine her independent judgment; • make her accept the group's interpretation of her personality;
23 • or compel her to conform to the group's desired psychological role. If so, I ask whether this was compatible with the principles of: • autonomy; • informed consent; • dignity; • voluntary participation; • professional boundaries; • and service-user-centred care. 30. SAFEGUARDING The HCPC standards require practitioner psychologists to recognise signs of abuse and engage with safeguarding processes where necessary. (The HCPC) I therefore ask: If the psychologists knew that the individual was allegedly: • isolated; • without adequate heating; • financially restricted; • unable to work; • separated from family; • subjected to alleged stalking; • psychologically distressed; • dependent on the group; • and unable to obtain independent assessment, why was a safeguarding intervention not initiated? If the answer is that the psychologists themselves were responsible for creating or maintaining those conditions, I ask that this be treated as an especially serious matter.
24 31. POTENTIAL FITNESS-TO-PRACTISE ISSUES I ask the HCPC to consider whether the evidence raises questions under its current Standards of Proficiency and Standards of Conduct, Performance and Ethics. Potentially relevant areas include: • safe and effective practice; • professional conduct; • safeguarding; • protection of service-user interests; • autonomy; • valid consent; • duty of care; • abuse of professional power; • dual relationships; • professional boundaries; • treatment decision-making; • evidence-based reasoning; • equality and diversity; • cultural competence; • confidentiality; • communication; • accurate assessment; • record keeping; • and conduct capable of maintaining public confidence. The HCPC confirms that its standards of proficiency are threshold standards necessary to protect the public and that, where practice is called into question, the standards are considered alongside the standards of conduct, performance and ethics. (The HCPC)
25 32. REQUEST FOR INVESTIGATION OF EACH SCOTTISH PSYCHOLOGIST SEPARATELY I ask that the HCPC does not treat the group as a single entity. For every Scottish HCPC registrant alleged to have participated, I request a separate assessment of: A. Knowledge What did the psychologist know? B. Participation What did the psychologist personally do? C. Authority What professional authority did the psychologist believe they had? D. Consent What consent did the psychologist obtain? E. Evidence What evidence supported the psychologist's decisions? F. Supervision Who supervised the psychologist? G. Safeguarding What safeguarding assessment was undertaken? H. Boundaries What boundaries existed? I. Third parties Why were unregulated people involved? J. Risk What risks were identified? K. Outcome What evidence demonstrated benefit? L. Withdrawal What happened when the individual wanted the intervention to stop?
26 33. POTENTIAL CRIMINAL CONDUCT I ask that the professional complaint not prevent or delay consideration of possible criminal conduct. Depending upon the evidence, the relevant authorities may need to consider: • stalking under section 39 of the Criminal Justice and Licensing (Scotland) Act 2010; • threatening or abusive behaviour; • harassment; • offences involving financial conduct; • offences involving property or employment interference; • offences aggravated by racial or religious hostility; • and any other offence disclosed by the evidence. Section 39 stalking requires the statutory elements to be established and is not simply synonymous with the complainant feeling watched or distressed. (scts_judiciary) I therefore request an evidence-based criminal assessment rather than asking any regulator to make a criminal finding. 34. POTENTIAL RACIAL AND RELIGIOUS MOTIVATION The following matters should be investigated together rather than separately: • the individual's Arab identity; • refugee status; • Muslim faith; • Arabic-speaking family background; • alleged assumptions concerning Arab motherhood; • alleged attempt to impose an “Arab mother” role; • predominantly white/English-speaking participants; • alleged use of ethnic/cultural stereotypes; • and any communications demonstrating hostility, contempt, stereotyping or discriminatory intent. I ask whether the individual's race, ethnic origin, nationality or religion was: 1. a motivation for the conduct; 2. a factor in selecting her; 3. used to justify the intervention; 4. used in constructing the psychological theory;
27 5. used in degrading or controlling her; 6. or used to make the intervention more effective. 35. THE GROUP'S CLAIMED THEORY OF “HEALING” The group allegedly believed that: creating an environment resembling an abusive family relationship would reproduce childhood psychological patterns, create transference, cause the individual to bond with the group, and thereby change or “heal” the individual's personality. I ask the HCPC to require the practitioners concerned to provide the actual scientific and clinical basis for this proposition. In particular: • What peer-reviewed evidence supports deliberately creating abuse to produce therapeutic attachment? • What evidence supports deliberately inducing dependency? • What evidence supports replacing an individual's biological family with a therapist- controlled social group? • What evidence supports coercive isolation as treatment? • What ethical safeguards accompany the proposed method? • What recognised professional body endorses it? • What independent clinician could review it? • What mechanism allows a participant to refuse it? If the answer is that the method is an experimental hypothesis rather than an established treatment, the absence of appropriate consent and ethical review becomes especially important. 36. IDENTITY, AUTONOMY AND THE LIMITS OF PSYCHOLOGICAL INTERVENTION The complaint asks the regulator to distinguish between legitimate psychological treatment and an attempt to obtain control over an individual's identity. A psychologist may assist a person to understand themselves. That is fundamentally different from allegedly attempting to determine: • whom the person must regard as family; • which relationships they must abandon; • what identity they must adopt; • what psychological role they must perform;
28 • whom they must trust; • whom they must depend upon; • and how they must interpret their own experiences. The complaint asks whether the alleged intervention crossed that boundary. 37. REQUEST FOR PRESERVATION OF EVIDENCE I request that all relevant evidence be preserved, including: • emails; • text messages; • WhatsApp/Signal/Telegram or similar communications; • social-media messages; • YouTube material; • livestreams; • videos; • recordings; • screenshots; • psychological notes; • diagnostic formulations; • supervision records; • referral records; • consent forms; • treatment plans; • risk assessments; • safeguarding records; • complaints; • internal correspondence; • communications between Scottish and foreign psychologists; • communications between psychologists and online personalities; • communications concerning “cold therapy”; • communications concerning “Stockholm syndrome”; • communications concerning mother/child role-play;
29 • communications concerning the individual's Arab/Muslim identity; • communications concerning ADHD; • and any records relating to the alleged intervention. 38. QUESTIONS I ASK THE HCPC TO ANSWER I respectfully request written answers to the following: 1. Were any of the named Scottish individuals HCPC registrants? 2. If so, what was each person's registered profession and scope of practice? 3. Did any registrant assess, diagnose or treat the individual? 4. If so, when did the professional relationship begin? 5. What consent was obtained? 6. Where is the documentation of that consent? 7. What diagnosis or diagnoses were made? 8. What assessment supported each diagnosis? 9. What recognised treatment model was used? 10. What scientific evidence supported the treatment? 11. Was the intervention research? 12. If so, what ethical approval and consent arrangements existed? 13. If not research, what recognised clinical framework authorised it? 14. Who supervised the intervention? 15. What safeguarding assessment was undertaken? 16. Why were unregulated third parties involved? 17. Were appropriate professional boundaries maintained? 18. Was the individual permitted to withdraw? 19. Were objections treated as genuine feedback? 20. Were treatment outcomes independently assessed? 21. Was the individual's cultural and religious identity properly considered? 22. Were assumptions made about Arab or Muslim family relationships? 23. Was the individual's ADHD history considered? 24. Was independent ADHD assessment obstructed? 25. Did any registrant know about alleged stalking or harassment?
30 26. Did any registrant participate in or encourage it? 27. Did any registrant know about the alleged isolation and deprivation? 28. Did any registrant attempt to safeguard the individual? 29. Did any registrant encourage dependency upon the group? 30. Did any registrant encourage separation from biological family? 31. Did any registrant encourage mother/child role-play? 32. Did any registrant describe “Stockholm syndrome” or dependency as a therapeutic objective? 33. Did any registrant deliberately create distress or an abusive environment? 34. Did any registrant use diagnosis to justify continued intervention despite objections? 35. Does the evidence raise a question concerning fitness to practise? 36. Does the matter require referral to another statutory authority? 39. REQUEST FOR INDEPENDENT ASSESSMENT Given the allegations of diagnostic instability and possible conflicts of interest, I request that any clinical assessment of the individual arising from this complaint be conducted, if clinically necessary, by an independent appropriately qualified professional with no connection to the individuals or group complained about. I specifically request that the individual not be required to undergo further assessment by anyone who participated in the alleged intervention. 40. REQUEST FOR PROTECTION FROM FURTHER CONTACT OR INTERFERENCE If the evidence establishes that individuals involved in the alleged intervention continue to contact, monitor, approach, harass or otherwise interfere with the individual, I request that the relevant safeguarding and law-enforcement authorities assess what protective measures are available. The existence of a psychological explanation does not itself provide authority to continue unwanted contact with an adult. 41. CONCLUSION The central issue is whether a group of people, including individuals presenting themselves as psychologists, used psychological terminology, diagnostic labels and concepts such as transference, attachment and personality disorder to legitimise an intervention that allegedly involved: • unwanted surveillance; • stalking or harassment;
31 • diagnosis without proper assessment; • treatment without informed consent; • deliberate psychological distress; • isolation; • interference with employment and financial independence; • attempted separation from biological family; • attempted creation of dependency; • manipulation of identity; • imposed parent/child roles; • culturally and religiously loaded assumptions; • repeated diagnostic changes; • disregard of relevant ADHD history; • involvement of unregulated third parties; • and approximately 26 months of alleged intervention. If substantiated, this would raise questions extending well beyond whether the treatment was clinically successful. It would raise questions about autonomy, consent, safeguarding, professional boundaries, abuse of professional power, discrimination, cultural competence, psychological integrity, public safety and fitness to practise. I therefore request that this matter be treated as a serious public-protection and fitness-to-practise concern. I further request that the evidence concerning possible stalking, harassment, coercion, deprivation, financial interference and racial/religious hostility be referred to or considered by the appropriate Scottish authorities independently of the professional-regulatory investigation. Nothing in this complaint is intended to ask the HCPC to make findings outside its jurisdiction. Rather, I ask each competent authority to investigate the matters falling within its statutory remit and to cooperate or make appropriate referrals where evidence indicates that another authority has jurisdiction. Yours faithfully,
32 LEGAL AND REGULATORY FRAMEWORK The complaint relies, where applicable and subject to the precise facts, upon: • Health and Care Professions Council Standards of Proficiency for Practitioner Psychologists — including autonomy, valid informed consent, safeguarding, duty of care, professional power, boundaries, reasoned treatment decisions and equality/diversity. (The HCPC) • HCPC Standards of Conduct, Performance and Ethics — including valid consent, non- discrimination, appropriate boundaries, prohibition on abuse of professional position, confidentiality and public confidence. (The HCPC) • Equality Act 2010 — particularly the protections relating to race and religion or belief, subject to whether the relevant provisions apply to the particular service/provider/public- function context. (Legislation.gov.uk) • Hate Crime and Public Order (Scotland) Act 2021 — where an underlying criminal offence is aggravated by hostility based on a protected characteristic, including race or religion, and in relation to the specific statutory offences created by the Act. (Scottish Government) • Criminal Justice and Licensing (Scotland) Act 2010, section 39 — stalking, where the statutory elements are satisfied. (scts_judiciary) • Human Rights Act 1998 / European Convention rights — particularly where a public authority or public function is involved, with potentially relevant rights including Articles 3, 8, 9 and 14. Section 6 makes it unlawful for a public authority to act incompatibly with a Convention right, subject to the Act. (Legislation.gov.uk) • UK Policy Framework for Health and Social Care Research — where the alleged activity falls within the definition and scope of health/social-care research in Scotland, including requirements concerning scientific soundness, participant safety, informed consent and ethical governance. (Health Research Authority) • Mental Health (Care and Treatment) (Scotland) Act 2003 — relevant to the statutory framework governing compulsory mental-health treatment. The existence of a mental- health diagnosis does not, by itself, create a general private authority to impose compulsory treatment outside the statutory framework. (Legislation.gov.uk) The above legislation and standards should be applied by the competent authority to the facts established by investigation rather than treated as conclusions that every cited provision has necessarily been breached.
33 (a) what the alleged conduct potentially engages, (b) what the law actually requires, and (c) what would need to be proved. The table below therefore does not say that an offence or regulatory breach has been established; it identifies the strongest legal/regulatory routes for investigation. Alleged conduct Legal / regulatory framework How the described conduct potentially engages it Assessment Psychologists allegedly assessed/diagn osed an adult without her requesting or consenting to clinical assessment HCPC Standards of Proficiency – Practitioner Psychologists; informed consent; autonomy; professional duty of care Practitioner psychologists must respect autonomy and obtain valid, voluntary and informed consent. They must make informed and reasoned decisions about assessment and treatment. (The HCPC) Very serious regulatory concern if evidenced. The first question is whether a genuine professional relationship existed and, if so, what lawful/professiona l basis and consent existed. “Diagnosis” allegedly made through observation/sta lking rather than clinical assessment HCPC standards concerning assessment, evidence-based practice, professional judgement and record keeping A psychologist cannot simply assume that observing someone's behaviour gives them an adequate clinical assessment. The regulator should establish what assessment was actually undertaken and what evidence supported each diagnosis. Strong fitness-to- practise issue if the evidence shows inadequate assessment. Unconsented “cold therapy” imposed on the person HCPC consent/autonomy standards; professional standards; potentially common-law/public-law issues depending on provider Treatment requires a legitimate professional basis and valid consent. The crucial questions are whether consent existed, whether it was informed and voluntary, and whether withdrawal was possible. (The HCPC) Potentially one of the strongest regulatory allegations.
34 Deliberately creating distress/abusiv e conditions as a purported treatment HCPC duty of care, safe practice, safeguarding, treatment decision-making and professional boundaries If psychologists deliberately created harmful circumstances and then characterised the resulting distress as therapeutic, the regulator would need to examine clinical justification, evidence, risk assessment, consent, safeguards and stopping criteria. Potentially extremely serious. The evidence should focus on what they actually instructed/did, not merely the label “cold therapy.” Deliberately triggering the person to reproduce alleged childhood trauma HCPC safe/effective practice, consent, safeguarding, treatment justification Deliberately exposing a person to psychological distress would require a defensible clinical rationale, appropriate consent, risk assessment, monitoring and professional competence. Potentially serious misconduct, especially if there was no recognised protocol or independent clinical oversight. Attempting to create dependency on the group HCPC professional boundaries; abuse of professional position; autonomy; power imbalance HCPC standards require psychologists to recognise power imbalances and maintain appropriate professional boundaries. The standards also prohibit abuse of professional position for personal, emotional or financial relationships. (The HCPC) Extremely important regulatory issue if communications show dependency was deliberately intended. Trying to replace biological family with the group HCPC autonomy, boundaries, safeguarding, duty of care A psychologist's role is not ordinarily to make an adult dependent on the psychologist or a group as a substitute family. The regulator should investigate whether family separation was deliberately encouraged as part of treatment. Potentially very serious boundary/power issue.
35 “Stockholm syndrome” allegedly identified as a desired therapeutic outcome HCPC standards concerning autonomy, boundaries, safe practice and treatment justification If the group genuinely intended to create dependency through fear, isolation or coercion and then regarded the resulting attachment as therapeutic, that raises profound questions about whether the intervention was safe, ethical or clinically justified. Highly concerning if supported by written evidence. Do not rely on the label alone; produce the actual statements. Forced mother/child role-play with strangers HCPC professional boundaries, autonomy, consent, power imbalance The critical issue is not the role-play itself but whether it was imposed, whether the person could refuse, whether it was clinically justified, and whether it was used to create dependency. Potentially serious professional- boundary concern. Older men allegedly being made to act as a “mother” to the adult woman HCPC boundaries, cultural competence, consent, safeguarding If a psychologist deliberately arranged an artificial parental relationship to manipulate attachment, the regulator should examine the professional justification and whether the arrangement exploited vulnerability or power imbalance. Potentially serious if professionally directed or supervised. Deliberate isolation for approximately 26 months HCPC safeguarding, duty of care, autonomy; potentially criminal law depending on conduct Isolation itself is not automatically a crime, but deliberate restriction, threats, monitoring or coercive conduct can engage criminal law. HCPC standards require safeguarding and protection of service users. (The HCPC) Extremely serious if psychologists caused, encouraged or knowingly facilitated it.
36 Stalking / monitoring around the person's home Criminal Justice and Licensing (Scotland) Act 2010, s39 Stalking involves a course of conduct causing the victim fear or alarm, with the required intention/knowledge/reaso nableness elements. Scottish guidance expressly includes following, contacting, monitoring and other conduct. (Scottish Government) Potential criminal matter, not merely an HCPC complaint. Police should assess the evidence. Threatening or abusive behaviour Criminal Justice and Licensing (Scotland) Act 2010, s38 Section 38 covers threatening or abusive behaviour where the statutory requirements concerning fear/alarm and intention/recklessness are met. (Scottish Government) Potential criminal offence, depending on the specific conduct/evidence. Online stalking/harass ment s39 Criminal Justice and Licensing (Scotland) Act 2010; other communications offences may apply depending on content Scottish guidance expressly recognises online conduct as potentially relevant to stalking/harassment. (Scottish Government) Potentially criminal, particularly where there is a documented course of conduct. Interference with employment/w ork Criminal law depending on conduct; HCPC professional boundaries/safeguarding If psychologists deliberately interfered with employment to make the person dependent upon them, this could substantially strengthen the allegation of abuse of professional power. Important aggravating evidence, but the exact criminal offence depends on what was actually done. Financial coercion/depen dency Criminal law depending on conduct; HCPC standards concerning abuse of professional position Financial control can be highly relevant evidence of coercion and dependency. If a psychologist benefited financially or deliberately created financial dependency, the regulatory concern becomes substantially more serious. Potentially serious; evidence is crucial.
37 No heating/gas for approximately seven months allegedly as part of the “therapy” Adult Support and Protection; safeguarding; potentially criminal law depending on conduct If professionals knowingly caused or maintained circumstances in which an adult was deprived of basic necessities, this requires safeguarding assessment independently of the psychological dispute. Very serious safeguarding concern. Preventing access to independent ADHD assessment HCPC duty of care, autonomy, informed decision-making, scope of practice A psychologist should not substitute an unsupported personality formulation for relevant medical/neurodevelopment al assessment without proper clinical reasoning. Potential regulatory concern if obstruction can be proved. Existing ADHD history allegedly dismissed HCPC assessment/professional competence standards Relevant clinical information should be considered appropriately. The issue is not that ADHD makes another diagnosis impossible, but whether it was improperly disregarded. Potentially significant assessment/comp etence issue. Repeatedly changing diagnoses HCPC standards concerning assessment, clinical reasoning, treatment decisions and records Changes can be clinically legitimate, but investigators should establish what evidence caused each diagnostic change and whether diagnoses were being changed to explain the person's reactions to the intervention. Potentially serious if unsupported or circular. Using diagnosis to justify continuing harmful treatment HCPC autonomy, consent, duty of care and safe practice A particularly concerning pattern would be: resistance → diagnosis → diagnosis used to justify treatment → treatment causes further distress → distress interpreted as proof of diagnosis. Potentially serious misuse of diagnostic authority.
38 “You resist because you have the personality disorder” type reasoning HCPC evidence-based practice, professional judgement, autonomy This can become a self- sealing formulation in which disagreement itself is treated as evidence of pathology. Strong issue for independent regulatory examination. Unqualified YouTubers/writ ers allegedly participating in treatment HCPC professional responsibility, delegation/supervision, confidentiality and boundaries The regulator should establish who authorised them, what they did, what information they received and whether a registrant involved them in clinical activity. Potentially serious, especially if unregulated individuals performed psychological functions. Foreign psychologists involved from USA/Canada/Isr ael HCPC jurisdiction where an HCPC registrant participated; foreign regulatory law potentially relevant separately The HCPC can investigate its own registrants. Foreign practitioners may require referral to their own regulators depending on registration and conduct. Requires person- by-person investigation. Sharing psychological/p rivate information with online group members HCPC confidentiality/data- governance standards; UK GDPR/Data Protection Act 2018 where applicable HCPC standards require confidentiality and appropriate information/data governance. (The HCPC) Potential regulatory/data- protection issue if identifiable information was improperly shared. Using ethnicity/cultur e to construct the treatment HCPC equality, diversity and inclusion standards; Equality Act 2010 where applicable HCPC standards specifically require practitioners to understand protected characteristics, intersectionality and cultural differences and adapt practice accordingly. (The HCPC) Potential serious regulatory concern if Arab/Muslim identity was stereotyped or deliberately exploited. Assuming what an “Arab mother” would do without properly assessing the actual family HCPC cultural competence, assessment, equality/diversity The alleged treatment appears to have depended upon a theory of the individual's mother without establishing the factual family history. Potential competence + cultural-bias issue.
39 Using Muslim/Arab identity as part of psychological manipulation Equality Act 2010; HCPC EDI standards; potentially hate-crime law if criminal conduct is motivated by hostility Race and religion are protected characteristics. Whether Equality Act provisions apply depends on who provided the service and the legal context. Potentially significant, particularly if documentary evidence demonstrates discriminatory motivation. Racial/religious hostility accompanying criminal conduct Hate Crime and Public Order (Scotland) Act 2021 and statutory aggravations Scottish hate-crime law preserves aggravated offences based on prejudice concerning race and religion. (Scottish Government) Police/prosecutori al issue if an underlying offence exists. It is not enough that the victim belongs to a protected group; the statutory requirements must be satisfied. Trying to erase/redefine the person's identity HCPC autonomy, dignity, informed consent, professional boundaries; potentially ECHR Article 8 where a public authority is involved Psychological treatment should not be confused with a professional entitlement to control an adult's identity, family relationships or worldview. Very serious autonomy/bound ary concern if this was the actual objective. Trying to make the person abandon family and adopt strangers HCPC autonomy/boundaries; potentially Article 8 in public-authority context Deliberately dismantling existing relationships to make a person dependent on a treatment group would raise significant safeguarding and professional-boundary concerns. Potentially one of the strongest allegations. Deliberately creating an abusive environment and then calling the attachment “healing” HCPC duty of care, safe practice, consent, boundaries; potentially criminal law The legal question becomes whether the professionals knowingly created foreseeable harm and whether there was any legitimate clinical justification. Extremely serious if evidenced. Claiming this was a HCPC boundaries, autonomy, professional relationship A therapeutic relationship does not automatically become a family Important evidence of the alleged theory,
40 “home/family dynamic” relationship. Calling an imposed group dynamic a “home” does not create legal or clinical authority to control an adult. but not itself an offence. Calling an approximately 26-month intervention “therapy” HCPC treatment standards; consent; evidence-based practice The label does not determine legality. Investigators should examine what actually happened. The substance of the conduct matters, not the terminology. Allegedly conducting psychological experimentatio n without ethics/consent UK Policy Framework for Health and Social Care Research if the activity falls within its scope Health/social-care research is subject to ethical and governance requirements, including participant protection and consent. (Health Research Authority) Potentially serious if this was genuinely research. But first establish whether legally it constituted research. Deliberately experimenting on one individual to test a personality theory Research ethics framework + HCPC professional standards If the person was effectively being used as a research subject without being told, the research/ethics question becomes significant. Potentially very serious, subject to establishing that the activity falls within the research framework. No independent review or stopping mechanism HCPC safe/effective practice, risk management, treatment decisions A prolonged high-risk intervention should have rational review and stopping criteria. Strong regulatory concern if absent. Person repeatedly said it was harming them but group continued HCPC autonomy, consent, treatment continuation/modification/ cessation Continuing despite informed refusal can be highly problematic. Potentially one of the clearest consent/autonom y issues. Using “personality disorder” to invalidate complaints about the treatment HCPC professional conduct, assessment, autonomy, duty of care If diagnosis was used to prevent the person's objections from being taken seriously, this could constitute misuse of professional authority. Potentially serious.
41 Psychologists knowingly participating in the group while unregulated people carried out the alleged intervention HCPC professional responsibility and public protection A registrant cannot necessarily avoid responsibility by outsourcing conduct to online associates. The precise responsibility depends on what they knew, directed, authorised or supervised. Important fitness- to-practise question. Conduct allegedly continued for 2 years 2 months despite no improvement HCPC treatment decision- making and evidence- based practice Duration alone does not prove misconduct, but continuing a harmful intervention without evidence of benefit is highly relevant. Potentially serious when combined with the other allegations.
42 The overall legal assessment Priority Issue Why 1 — Critical Absence of valid informed consent If an adult was actually subjected to psychological assessment/treatment without voluntary and informed consent, this goes directly to HCPC autonomy, ethics and professional conduct. 2 — Critical Deliberate creation of dependency/isolation If psychologists deliberately tried to make the person dependent upon them and sever existing relationships, this raises major professional- boundary, safeguarding and autonomy concerns. 3 — Critical Deliberately creating distress/abuse as “therapy” Particularly serious if the group intentionally caused distress and then used the resulting attachment/dependency as the alleged therapeutic mechanism. 4 — Critical Stalking/harassment as part of the alleged intervention This potentially moves the matter beyond professional regulation into criminal investigation under Scottish law. (Scottish Government) 5 — Very serious Use of diagnosis as a mechanism of control Especially if diagnoses changed depending upon whether the person complied with the group's demands. 6 — Very serious Professional boundary violations Creating artificial parent/child relationships and attempting to replace biological family with therapists/group members could represent serious misuse of professional power. 7 — Very serious Safeguarding/basic-needs concerns Alleged prolonged isolation and lack of heating require consideration independently of the psychological allegations. 8 — Very serious Racial/religious dimensions Particularly if Arab/Muslim identity was deliberately incorporated into the alleged manipulation or used stereotypically. 9 — Serious Unregulated people participating in purported treatment Requires identification of who did what and what Scottish registrants knew or authorised. 10 — Serious Potentially experimental treatment Very significant if the activity was actually research/experimentation, particularly without consent or ethical governance.
43 11 — Serious Failure to consider ADHD/neurodevelopmental history Potential competence/assessment issue, particularly if independent assessment was actively obstructed. 12 — Serious Confidentiality/data sharing Important if private clinical information was circulated amongst online participants without proper authority. “The complainant asks the competent authorities to determine whether the alleged conduct constituted unconsented psychological experimentation, abusive or degrading treatment, coercive conduct, stalking, harassment, discriminatory conduct, safeguarding failure, or professional misconduct.”
44 PUBLIC-PROTECTION RISK, CURRENT FITNESS TO PRACTISE AND RISK TO OTHER SERVICE USERS 1. Request for a prospective risk assessment This complaint is not confined to the historical harm allegedly suffered by the individual. I ask the HCPC to assess whether the evidence raises a current risk to other service users and whether the practitioners concerned can presently be regarded as fit to practise without restriction. The alleged conduct extended over approximately two years and two months and, if substantiated, was not an isolated clinical error. It allegedly involved a sustained methodology incorporating deliberate psychological distress, isolation, dependency, manipulation of attachment, imposed family roles, repeated diagnostic formulations and continued intervention despite the individual's objections. The prolonged and allegedly deliberate nature of the conduct is relevant to whether the behaviour represents a continuing professional-risk issue. 2. Repetition and persistence I ask the HCPC to distinguish between: • an isolated error; • a single episode of poor clinical judgement; • a repeated pattern of poor practice; and • a deliberate and sustained treatment methodology. The complaint alleges the latter. The intervention allegedly continued for approximately 26 months and involved repeated application of the same underlying theory. I therefore ask: If the practitioners genuinely believed that the alleged methods were legitimate psychological treatment, what prevents those methods from being used again with another service user? This question is central to public protection. 3. Risk arising from the alleged treatment model itself The concern is not simply that one treatment decision may have been wrong. The concern is that the alleged treatment model itself may have incorporated: • deliberate creation of distress; • deliberate triggering; • isolation; • dependency; • erosion of existing relationships;
45 • manipulation of attachment; • parent/child role construction; • interpretation of resistance as pathology; • and prolonged continuation despite reported harm. If those features formed part of a deliberate treatment model, the risk cannot necessarily be treated as an isolated historic incident. I therefore request that the HCPC establish whether the practitioners continue to endorse, teach, recommend, supervise or use any such methodology. 4. Risk to other patients I ask the HCPC to consider whether other current or future service users may have been or may be exposed to similar practices. In particular, consideration should be given to whether the alleged methodology could disproportionately affect: • vulnerable adults; • people with trauma histories; • people with personality-disorder diagnoses; • neurodivergent people; • refugees; • migrants; • people from minority ethnic backgrounds; • people with limited family support; • people experiencing financial difficulties; • and people who are psychologically dependent upon professional support. The existence of these characteristics should not itself be treated as evidence of vulnerability. Rather, they are relevant to assessing whether the alleged methodology could create particular risks. 5. Insight and remediation I ask the HCPC to establish whether the practitioners have: 1. acknowledged the alleged harm; 2. recognised any breach of professional standards; 3. discontinued the alleged methodology; 4. undertaken relevant remediation; 5. undertaken independent professional supervision; 6. reviewed their consent procedures;
46 7. reviewed safeguarding procedures; 8. reviewed professional-boundary practices; 9. undertaken relevant equality, diversity and cultural-competence training; 10. ceased involving unregulated third parties; 11. demonstrated an ability to distinguish patient disagreement from psychopathology; 12. demonstrated that they can modify or terminate treatment when a patient reports harm; and 13. demonstrated that they can now practise safely without exposing other service users to the alleged methodology. 6. Continuing belief in the methodology A particularly important issue is whether the practitioners continue to believe that the alleged conduct constituted legitimate treatment. If they continue to believe that deliberate isolation, dependency, psychological triggering, forced family-role dynamics or deliberate creation of distress constitute appropriate treatment, I ask the HCPC to treat this as potentially relevant to current impairment, rather than merely historical conduct. The question is not whether a practitioner should be punished for a past mistake. The question is whether the practitioner presently has the insight, judgement and professional boundaries necessary to protect future service users. 7. Interim public-protection measures Given the seriousness, duration and alleged deliberate nature of the conduct, I request that the HCPC consider whether an interim order is necessary while the allegations are investigated. I ask the HCPC to consider whether unrestricted practice during the investigation could expose current or future service users to a risk of harm. Depending upon the evidence, I ask the HCPC to consider whether: • no interim restriction is necessary; • conditions of practice are sufficient; • restrictions concerning particular categories of patients or activities are necessary; • supervision requirements are necessary; • or suspension from practice is necessary pending investigation. I recognise that the HCPC must make this determination under its statutory framework and on the evidence available. I ask nevertheless that the public-protection issue is expressly considered rather than deferred until the conclusion of a potentially lengthy investigation.
47 8. Specific risk-assessment questions I ask the HCPC to answer or address the following: A. Recurrence What evidence exists that the alleged conduct will not be repeated? B. Insight Does the practitioner recognise why the alleged conduct would be unsafe or professionally unacceptable? C. Remediation What concrete remediation has occurred? D. Current practice Is there evidence that the practitioner currently uses any comparable methodology? E. Supervision Who currently supervises the practitioner and what safeguards exist? F. Patient selection Have other patients been exposed to the same or substantially similar intervention? G. Complaints history Are there other complaints, concerns, employer referrals or regulatory intelligence concerning similar conduct? H. Third parties Does the practitioner continue to work with unregulated individuals in relation to psychological treatment? I. Consent Have the practitioner's consent procedures been independently reviewed? J. Safeguarding Have safeguarding procedures been independently reviewed? K. Boundaries Has the practitioner received assessment or remediation concerning professional boundaries and power imbalance? L. Cultural competence Has the practitioner undertaken appropriate remediation concerning cultural, racial and religious stereotyping? M. Clinical evidence Can the practitioner demonstrate the scientific and clinical basis for the alleged methodology?
48 N. Treatment cessation Can the practitioner demonstrate that they will stop treatment when a service user reports harm or withdraws consent? 9. Risk of recurrence versus historic misconduct I understand that the HCPC's fitness-to-practise process is concerned with current impairment and public protection rather than simply punishment for historical conduct. However, the alleged historical conduct is relevant to current risk where it demonstrates: • a persistent pattern; • deliberate conduct; • serious harm; • exploitation of a service user; • lack of insight; • failure to remediate; • continuing endorsement of the methodology; • or a continuing risk that similar conduct may be applied to other service users. I therefore ask that the approximately 26-month period be considered not merely as one historical incident but as evidence potentially relevant to the practitioner's present professional judgement and ability to practise safely. 10. Wider investigation If the evidence indicates that other patients may have been exposed to substantially similar practices, I request that the HCPC consider whether it is necessary to obtain information from the registrant's employer, professional colleagues, supervisors or other relevant organisations. I also ask that the HCPC consider whether information-sharing with another regulator, public authority, safeguarding body or law-enforcement agency is necessary for public protection.
49 11. Public confidence The alleged conduct, if established, would potentially involve a profound departure from the ordinary expectations placed upon a registered healthcare professional. The issue is therefore not limited to competence. It potentially concerns whether the practitioner can be trusted to exercise professional power responsibly, respect autonomy, maintain boundaries, recognise harm and protect service users. I therefore ask that the HCPC expressly consider both: 1. the risk of harm to future service users, and 2. the public-interest implications of permitting unrestricted practice while serious allegations of this nature remain unresolved. 12. Requested outcome I respectfully request: 1. a formal fitness-to-practise investigation; 2. an explicit current-risk assessment; 3. assessment of whether the alleged conduct represents a repeatable methodology; 4. investigation of whether other service users may have been exposed to similar conduct; 5. assessment of the practitioner's current insight and remediation; 6. consideration of an interim order where the statutory test is met; 7. identification of any current restrictions or safeguards already imposed; 8. appropriate information-sharing with relevant public-protection bodies; and 9. a determination of whether the practitioners can safely continue unrestricted practice pending the outcome of the investigation. The overriding concern is future patient safety. If the allegations are substantiated and the methodology remains endorsed or capable of repetition, I ask the HCPC to treat that as evidence potentially relevant to current impairment and not merely as a historic complaint.
50 Public-protection risk assessment Risk factor What your allegations potentially demonstrate Relevance to future patients Regulatory significance Alleged prolonged intervention Approximately 26 months rather than an isolated incident Suggests an alleged sustained pattern rather than an accidental or one- off lapse High Alleged repeated conduct The alleged methods were reportedly repeated over a prolonged period despite objections and alleged harm Raises the question whether the practitioner would repeat the methodology with another service user Very high Deliberate rather than accidental conduct The alleged isolation, triggering, dependency and role-playing were supposedly part of the treatment theory Deliberate conduct can be more predictive of future risk than an isolated clinical error Very high Persistence despite negative feedback The person allegedly repeatedly said the intervention was harmful/ineffective but it continued Raises concern about ability to recognise deterioration and modify/stop treatment Very high Self-validating treatment model Alleged resistance was interpreted as evidence of the person's disorder or need for further treatment Creates a potential mechanism by which future patients' objections could also be dismissed Critical if evidenced Creation of dependency Alleged attempt to make the patient dependent upon the group and replace existing relationships Potentially creates vulnerability to exploitation of future patients Critical if evidenced Professional boundary concerns Alleged parent/child roles and attempts to become the patient's “family” Suggests possible difficulty maintaining therapeutic boundaries Very high Use of unregulated third parties Writers/YouTubers/others allegedly participated in the purported intervention Future patients could potentially be exposed to people outside professional accountability Very high Potential lack of informed consent Alleged treatment without genuine voluntary and informed agreement Indicates potential inability/unwillingness to respect patient autonomy Critical if proved
51 Alleged deliberate psychological distress Distress was allegedly deliberately produced as part of treatment Creates obvious patient- safety questions if the methodology is repeatable Critical if evidenced Diagnostic instability Diagnoses allegedly changed repeatedly depending on the patient's responses Raises concerns about clinical reasoning and whether diagnoses were being used to explain resistance High Potential cultural stereotyping Alleged use of assumptions about an Arab/Muslim mother and family Could expose other minority patients to stereotyped formulations High Potential racial/religious targeting If race/religion actually formed part of the treatment methodology or motivation Raises concern about discriminatory practice with other protected groups Very high if evidenced Alleged interference with independent assessment ADHD assessment allegedly obstructed or discouraged Raises concern about whether patients could obtain independent clinical opinions Very high if proved Lack of independent oversight Alleged group operated its own theory without independent review Increases risk that unsafe practice could continue unchecked High Possible experimental methodology Alleged use of an unvalidated “cold therapy” model Future patients could potentially be exposed to an untested intervention Very high if established Possible research without research safeguards If the activity was actually research/experimentation, there may have been no proper research governance Raises risk to any future participants Critical if applicable Potential safeguarding failure Alleged awareness of isolation, deprivation and psychological distress without intervention Raises concern about ability to recognise and respond to vulnerable patients Very high Potential criminal conduct Alleged stalking/harassment and coercive behaviour Regulatory concern extends beyond clinical competence to character/conduct and public safety Very high if supported by evidence
52 Duration + repetition + deliberate methodology The combination is more significant than any individual incident Could indicate a reproducible practice rather than an isolated mistake Critical public- protection question The complainant does not ask the HCPC to prejudge the allegations. The complainant asks that the alleged conduct be risk-assessed on the basis that, if substantiated, it may represent a deliberate and repeatable treatment methodology rather than an isolated clinical error. In particular, the alleged methodology involves prolonged isolation, deliberate psychological distress, creation of dependency, manipulation of attachment, erosion of existing support relationships, imposed familial roles and continuation despite expressed objections. If the practitioners continue to believe that these methods constitute legitimate psychological treatment, the risk may not be capable of being adequately controlled through ordinary conditions of practice. The complainant therefore requests an explicit consideration of whether an Interim Suspension Order is necessary for public protection while the allegations are investigated, and, if the panel considers suspension disproportionate, that it identify what specific conditions could realistically prevent recurrence and how compliance would be independently verified.
53 Assessment: interim order vs remediation Issue What you describe Interim order? Remediation? My assessment Alleged conduct lasted ~2 years 2 months Sustained rather than isolated Yes — strongly relevant Yes Duration increases the importance of assessing whether this was a persistent methodology rather than a single error. Alleged deliberate treatment methodology “Cold therapy”, triggering, isolation, dependency, role manipulation Yes Yes If supported by evidence, this is more concerning than an accidental clinical mistake because it may be repeatable. Patient allegedly objected repeatedly Treatment allegedly continued despite objections Yes Yes Raises immediate questions about consent, autonomy and ability to recognise harm. Creation of dependency Alleged objective of bonding patient to group/replacing family Yes — very strongly Yes, but only after protection If true, this raises a direct risk of recurrence with vulnerable patients. Isolation from family/social support Alleged deliberate separation Yes — very strongly Yes Potential safeguarding/boundary risk. “Stockholm syndrome” allegedly treated as desirable Dependency/attachment allegedly regarded as therapeutic success Yes — potentially critical Yes If documented, this could indicate the underlying methodology is fundamentally unsafe rather than a one-off error. Parent/child role manipulation Adults allegedly forced into “mother/child” dynamics Yes Yes Significant boundary and power-imbalance concern. Unregulated people allegedly involved YouTubers/writers/others participating Yes Yes Need to establish whether registrants directed, authorised or supervised them. Repeated diagnostic changes NPD → BPD → other formulations Possibly Yes Diagnosis changes aren't inherently misconduct; concern arises if unsupported or used to explain away resistance. Patient's disagreement allegedly pathologised Resistance interpreted as evidence of disorder Yes — strongly Yes Potentially self-reinforcing clinical model: disagreement
54 becomes “proof” that treatment must continue. Alleged deliberate psychological distress Distress allegedly created intentionally Yes — very strongly Yes Particularly important if the practitioner still endorses the method. Potential experimental/unvalidated treatment Alleged treatment without recognised evidence/consent Yes Yes Requires independent assessment of the actual methodology and evidence base. Potential racial/religious manipulation Arab/Muslim identity allegedly incorporated into treatment Yes — if evidence supports it Yes Requires examination of cultural competence and discriminatory conduct. Failure to respect independent ADHD assessment Alleged interference with outside assessment Yes, depending on evidence Yes Relevant to autonomy and multidisciplinary practice. Basic-needs/safeguarding concerns Alleged prolonged isolation and deprivation of heating Yes — strongly Yes If professionals knowingly caused or facilitated this, immediate protection becomes especially important. Possible stalking/harassment Alleged surveillance/stalking around home Yes — potentially very strongly No, not as a substitute This may require police investigation in parallel; professional remediation cannot make alleged criminal conduct safe. Evidence of insight Currently unknown Critical Critical Lack of insight substantially weakens the case for conditions of practice. Evidence of genuine remediation Currently unknown Critical Critical Must be established, not assumed. Evidence the methodology has stopped Currently unknown Critical Critical If they still practise it, future risk is materially greater. Evidence they would repeat it If they continue to defend the methodology Very strongly supports interim protection Remediation may be insufficient without restriction Continuing belief in a harmful methodology is a major current-risk question. Independent supervision Unknown Relevant Yes Could support future safe practice, but would not necessarily be enough to manage immediate risk.
55 Independent clinical assessment of competence Unknown Yes Yes Particularly important where the alleged problem concerns fundamental clinical judgement rather than a technical mistake.
56 RISK ASSESSMENT: Question If answer is “yes” Effect Was the conduct deliberate? Yes ↑ risk Was it prolonged? ~26 months ↑ risk Was it allegedly repeated? Yes ↑ risk Was it presented as an actual treatment methodology? Yes ↑ risk substantially Was the patient allegedly prevented from rejecting the treatment? Yes ↑ risk substantially Was dependency allegedly the objective? Yes ↑ risk substantially Was isolation allegedly part of the methodology? Yes ↑ risk substantially Was psychological distress deliberately created? Yes ↑ risk substantially Were unregulated third parties allegedly involved? Yes ↑ risk Is there evidence the practitioners still believe in the methodology? If yes Major reason to question whether conditions can work Is there evidence of genuine insight? If no/unknown Against conditions Is there evidence of remediation? If no Against conditions Could a supervisor reliably prevent recurrence? If no Against conditions Can the alleged behaviour be restricted through a simple practice condition? If no Against conditions; suspension becomes more relevant Would ordinary patients remain safe while the practitioner continues treating them? If uncertain/no Interim protection becomes much more important
57 Subject: Urgent Request for Public-Protection Assessment, Interim Order and Investigation Dear Health and Care Professions Council, I am writing to raise a serious fitness-to-practise and public-protection concern regarding the conduct of psychologist(s) registered with the HCPC. I respectfully request that this matter be assessed as a high-risk fitness-to-practise concern and that consideration be given to an interim order while the allegations are investigated. The concerns described in my evidence are not limited to an isolated clinical error. They concern an alleged prolonged and potentially repeatable methodology, extending for approximately two years and two months, involving alleged psychological isolation, deliberate distress and triggering, creation of dependency, manipulation of attachment, imposed parent/child dynamics, attempts to replace the individual's existing support relationships, changing diagnostic formulations, and continuation despite the individual's objections and reports that the intervention was harmful. If substantiated, this raises a fundamental public-protection question: was this an individual error, or does it represent a treatment philosophy or methodology that the practitioners may apply to other service users? I therefore request the following, in order of priority: 1. An immediate current public-protection and recurrence-risk assessment. 2. A full independent fitness-to-practise investigation into the allegations, including consent, professional boundaries, clinical judgement, safeguarding, cultural/religious considerations and the involvement of unregulated third parties. 3. Consideration of an interim order. HCPC guidance states that an interim order may restrict or prevent practice while an investigation takes place where there is a sufficiently serious risk to service-user safety or the wider public interest. (The HCPC) 4. Specific consideration of interim suspension if the evidence indicates that the alleged methodology was deliberate, repeatable, remains endorsed, or cannot realistically be controlled through conditions of practice. 5. Conditions of practice only if they can demonstrably and independently control the identified risk. I do not believe that generic supervision or training should be assumed to be sufficient where the alleged concerns involve fundamental clinical judgement, professional boundaries, insight or an endorsed treatment methodology. 6. Investigation into whether other patients have been exposed to the same or substantially similar practices, particularly if the evidence indicates that this was a group methodology rather than an isolated interaction. 7. Assessment of current insight and remediation, including whether the practitioners recognise the alleged risks, have discontinued the methodology, have independently reviewed their practice and can demonstrate that similar conduct will not recur. I am not asking HCPC to prejudge the allegations or determine their truth before investigation. I am asking that the potential risk to other service users is assessed immediately. HCPC's own interim-
58 order guidance confirms that an interim-order panel considers risk while the facts remain under investigation; it does not determine whether the allegations are ultimately proven. (The HCPC) In my view, remediation should not substitute for immediate public protection. If the concerns are ultimately substantiated, remediation should depend upon demonstrable insight, cessation of the alleged practices, capacity to change and independently verifiable evidence of safe practice. The central question is therefore: If the alleged methodology was deliberate, prolonged and repeatable, and the practitioners continue to endorse it or cannot demonstrate genuine insight, what safeguards would prevent the same conduct from being applied to another vulnerable service user? I respectfully request that this question be expressly addressed in the regulatory risk assessment and that the possibility of an interim suspension be considered if conditions cannot adequately protect the public. Given the seriousness and potential repeatability of the allegations, I also request that any available regulatory intelligence concerning substantially similar complaints or concerns involving the practitioners or the alleged methodology be considered as part of the public-protection assessment, subject to the HCPC's legal and confidentiality requirements. Yours faithfully,
59 Required regulatory response — priority and recommended decision Priority Measure Required? Assessment in this case Recommended position 1 🔴 Immediate public- protection risk assessment YES — essential The allegations describe approximately 26 months of alleged conduct, potentially involving a deliberate methodology rather than an isolated mistake. Immediate assessment required. 2 🔴 Formal fitness-to-practise investigation YES — essential The allegations potentially concern consent, clinical competence, boundaries, safeguarding, professional conduct, discrimination and possible deliberate harm. Full independent investigation. 3 🔴 Interim-order consideration YES — strongly recommended The alleged conduct could represent a continuing/repeatable risk if the practitioners remain in unrestricted practice. An interim-order panel should be asked to assess the risk. 4 🔴 Interim suspension Potentially the strongest protective measure If evidence shows the methodology was deliberate, repeatable, still endorsed, or incapable of being safely controlled through conditions, conditions may not adequately protect patients. Specifically request consideration of interim suspension. 5 🟠 Interim conditions of practice Only if demonstrably sufficient Conditions require a realistic way of controlling the alleged risk. If the problem is fundamental clinical judgment, insight or treatment philosophy, ordinary supervision may not control it. Secondary option, not the preferred option on the allegations as presented.
60 6 🔴 Investigation into other patients YES — strongly recommended If this was a group methodology, there is a legitimate public- protection question about whether other patients experienced similar treatment. Investigate whether the conduct was repeated with others. 7 🔴 Determine whether the methodology is still being used/endorsed YES — critical Current endorsement would materially increase recurrence risk. Must be established before deciding whether conditions are adequate. 8 🔴 Assess insight YES — critical If the practitioners continue to regard the alleged conduct as legitimate therapy, the possibility of recurrence is substantially different from an acknowledged professional error. Independent assessment of insight. 9 🔴 Assess recurrence risk YES The alleged conduct was prolonged and supposedly intentional. The question is whether another service user could be subjected to it. Formal recurrence-risk assessment. 10 🟠 Remediation YES, but later Remediation is relevant if the practitioners can demonstrate insight and the deficiencies are genuinely remediable. Do not substitute remediation for immediate public protection. 11 🟠 Independent supervision/training Potentially Could form part of remediation, but supervision alone may not be sufficient for fundamental boundary/clinical- judgment concerns. Only after risk has been controlled and with objective verification. 12 🔴 Final determination of fitness to practise YES If allegations are substantiated, the regulator must determine whether the practitioner remains fit to practise and what sanction, if any, is necessary. Final decision based on evidence, insight, remediation and risk.
61 URGENT PUBLIC-PROTECTION REQUEST Request for Immediate Cessation, Interim Protection, Investigation and Remediation To: Health and Care Professions Council / relevant regulatory and safeguarding authorities Subject: Urgent request for cessation of alleged ongoing intervention, public- protection assessment, interim order and investigation Dear Sir/Madam, I am requesting an urgent public-protection response concerning allegations that registered psychologists, together with individuals who are not appropriately licensed or regulated as healthcare professionals, have subjected an adult to a prolonged purported psychological intervention without an appropriate clinical framework, informed consent or lawful professional basis. The allegations concern approximately two years and two months of alleged intervention, described by those involved as “cold therapy”. The alleged intervention reportedly involved stalking/surveillance, psychological manipulation, deliberate triggering, isolation, dependency- building, attempts to alter established family relationships, imposed parent/child dynamics, repeated diagnostic labelling and continued intervention despite the individual's objections and reports that the intervention was harmful. I request that the following actions be considered in the order set out below. 1. IMMEDIATE CESSATION OF THE ALLEGED INTERVENTION — NOW I request that any registered professional involved be directed, subject to the regulator's statutory powers, to cease any ongoing purported treatment, experimentation, observation, psychological intervention, diagnosis, behavioural manipulation, role-play or other intervention involving this individual pending appropriate independent assessment. The individual has withdrawn consent and does not consent to further participation in the alleged intervention. No further psychological intervention should be permitted to continue merely because the individuals involved believe that the person's resistance, distress or disagreement is itself evidence that their methodology is working. The alleged intervention should not continue while its legality, professional basis, consent, evidence base and safety are being determined. 2. IMMEDIATE PUBLIC-PROTECTION RISK ASSESSMENT — WITHIN DAYS I request an urgent assessment of whether the practitioners concerned currently present a risk to this or other service users. The assessment should specifically consider: • the alleged duration of approximately 26 months;
62 • whether the conduct was deliberate rather than accidental; • whether it constituted a repeatable methodology; • whether the methodology is still being endorsed; • whether the practitioners demonstrate insight; • whether the conduct involved professional-boundary violations; • whether genuine informed consent existed; • whether psychological distress was deliberately created; • whether dependency was deliberately encouraged; • whether existing family/social relationships were deliberately undermined; • whether unregulated third parties participated; • whether there are safeguarding concerns; and • whether other patients may have been exposed to comparable conduct. 3. URGENT CONSIDERATION OF AN INTERIM ORDER I request that the HCPC consider an interim order while the allegations are investigated. The question at this stage is not whether the allegations have been finally proven. The question is whether allowing unrestricted professional practice during the investigation could expose service users to an unacceptable risk. I specifically request consideration of interim suspension if the evidence indicates that: • the alleged methodology was deliberate; • it was prolonged and repeatable; • it continues to be endorsed or practised; • the practitioners lack sufficient insight; • or the risk cannot realistically be controlled through conditions of practice. If suspension is considered disproportionate, I request that the regulator identify specific, measurable and independently verifiable conditions capable of preventing recurrence. 4. INVESTIGATION OF THE ACTUAL PROFESSIONAL ROLES The investigation should identify each individual involved and establish precisely: • whether they are HCPC registrants; • their professional registration and scope of practice; • their role in the alleged intervention; • whether they diagnosed the individual; • whether they provided or directed treatment;
63 • whether they communicated treatment instructions; • whether they supervised other participants; • whether they authorised or facilitated the participation of unregulated individuals; and • whether they continue to have access to other patients. Professional responsibility should be attributed to each person on the basis of evidence rather than treating the entire group as one entity. 5. INVESTIGATION OF WHETHER THIS WAS A REPEATABLE METHODOLOGY This is particularly important for public protection. The regulator should establish whether the alleged “cold therapy” was: • an individual experiment; • an informal intervention; • an established treatment model; • a group-developed methodology; • something taught or recommended to others; or • something previously used with other service users. If substantially similar conduct has occurred with other patients, this should be investigated as a potential pattern of professional practice, rather than treating the present complaint as an isolated dispute. 6. INVESTIGATION OF CONSENT AND CLINICAL BASIS The investigation should establish: • what treatment was supposedly being provided; • who consented to it; • what information was provided before consent; • whether consent could be withdrawn; • whether withdrawal was respected; • what recognised clinical evidence supported the intervention; • whether appropriate clinical assessment was undertaken; • whether appropriate records were maintained; and • whether the intervention was research, treatment, experimentation or something else. If it was research or experimentation rather than ordinary clinical care, the appropriate research- governance and ethical requirements should also be examined.
64 7. INVESTIGATION OF DIAGNOSTIC PRACTICE The allegations include repeated changes in diagnosis and the use of diagnoses to explain the individual's responses to the intervention. The investigation should establish whether the diagnoses were based upon appropriate clinical assessment and evidence, or whether diagnostic labels were repeatedly changed to accommodate the group's evolving theory about the individual. The individual's established ADHD history and attempts to obtain independent assessment should also be considered where relevant. 8. INVESTIGATION OF BOUNDARIES, DEPENDENCY AND SAFEGUARDING Particular attention should be given to allegations that the intervention deliberately attempted to: • create dependency upon the group; • replace existing family relationships; • establish artificial parent/child relationships; • encourage attachment to members of the group; • deliberately trigger distress; • interpret resistance as evidence of pathology; • isolate the individual; or • make the individual dependent upon the alleged treatment group. If substantiated, these matters should be assessed not merely as questions of clinical disagreement but as potential professional-boundary and safeguarding concerns. 9. CULTURAL, RACIAL AND RELIGIOUS DIMENSION The investigation should establish whether the individual's Arab, Muslim and family identity was incorporated into the alleged intervention in a clinically appropriate manner or was instead used as part of a theory for manipulating attachment and identity. Any evidence of discriminatory treatment, racial or religious stereotyping, or deliberate targeting of protected characteristics should be assessed separately and appropriately. 10. INVESTIGATION OF OTHER SERVICE USERS If evidence indicates that this was a group methodology, I request that the regulator consider whether it is necessary and proportionate to establish whether other current or former service users may have been exposed to similar practices. This is essential to the public-protection assessment because the central concern is whether the alleged conduct could recur.
65 11. CURRENT INSIGHT AND REMEDIATION Remediation should be considered only after the immediate risk has been assessed and controlled. The practitioners should be required, where appropriate, to demonstrate: • genuine insight; • recognition of the alleged professional risks; • cessation of the alleged methodology; • understanding of informed consent; • appropriate professional boundaries; • safeguarding competence; • appropriate cultural competence; • evidence-based clinical practice; • ability to accept patient disagreement; • ability to recognise treatment-related harm; • willingness to modify or stop treatment where necessary; and • independent evidence that their future practice is safe. Completion of training courses alone should not be treated as proof of remediation. 12. FINAL FITNESS-TO-PRACTISE DECISION Following investigation, the regulator should determine: 1. whether the allegations are substantiated; 2. whether there is current impairment of fitness to practise; 3. whether the conduct represents a repeatable professional methodology; 4. whether other service users remain at risk; 5. whether the practitioners have demonstrated insight and remediation; 6. whether conditions can adequately protect the public; and 7. whether a more restrictive final sanction is required.
66 Requested sequence I respectfully request that the matter therefore proceed in the following order: IMMEDIATE CESSATION OF THE ALLEGED INTERVENTION ↓ PRESERVATION OF EVIDENCE ↓ URGENT PUBLIC-PROTECTION/RISK ASSESSMENT ↓ INTERIM-ORDER CONSIDERATION ↓ INTERIM SUSPENSION IF CONDITIONS CANNOT ADEQUATELY CONTROL THE RISK ↓ FULL INDEPENDENT INVESTIGATION ↓ INVESTIGATION OF OTHER POTENTIALLY AFFECTED PATIENTS ↓ ASSESSMENT OF CURRENT INSIGHT AND RECURRENCE RISK ↓ REMEDIATION WHERE GENUINELY APPROPRIATE ↓ FINAL FITNESS-TO-PRACTISE DECISION Closing request I emphasise that this request is not asking the regulator to prejudge the allegations. It asks the regulator to address the immediate public-protection question: If the alleged conduct represents a deliberate and repeatable psychological methodology, can these practitioners safely continue unrestricted practice while that methodology and their conduct are being investigated? Given the alleged duration, deliberate nature, potential dependency and safeguarding concerns, I respectfully request that this question be addressed as an urgent public-protection matter, rather than waiting until the conclusion of a potentially lengthy investigation. Yours faithfully,
67 Subject: Request for clarification regarding the alleged use of stalking, harassment and coercion as “psychological treatment” Dear Sir/Madam, I am writing to request clarification regarding a rather extraordinary proposition that appears to have been presented as psychological treatment. Could you please clarify when, exactly, Scottish healthcare services began providing “home treatment” by means of stalking, harassment, coercion, intimidation and other alleged criminal conduct, particularly where the individual concerned has not consented to such treatment and no recognised professional treatment procedure appears to have been followed? I would be grateful for the relevant policy, clinical guideline, statutory authority, professional standard or evidence base authorising such an approach. In particular: 1. When did stalking become healthcare? If following, monitoring, surrounding, intimidating or repeatedly approaching a person at or around their home is now considered a therapeutic intervention, could you please identify: • the Scottish clinical guideline authorising it; • the professional body that approves it; • the consent procedure required; • the safeguarding framework governing it; • the clinical evidence demonstrating its effectiveness; and • the circumstances in which a patient is entitled to refuse it? If there is no such framework, I would appreciate clarification as to why alleged stalking and harassment were represented as treatment at all. 2. How can alleged criminal conduct constitute psychological treatment? The alleged intervention included behaviour described as stalking, harassment, coercion, intimidation and deliberate interference with the individual's ordinary life. Could you please explain the clinical mechanism by which such conduct is supposed to “heal” or “fix” a person's personality? For example: How does being stalked make a personality healthier? How does harassment constitute therapy? How does coercion constitute informed consent? How does isolation constitute psychological safety? How does intimidation constitute treatment? If the answer is that these behaviours were supposedly being used deliberately as a therapeutic technique, I request the evidence base and professional authority for that proposition.
68 3. The “mother” intervention There is an additional question that is difficult to reconcile with ordinary clinical practice. The individual concerned is an adult woman in her thirties living independently. She was allegedly surrounded by a group of substantially older men who demanded that she participate in a purported “mother/child” relationship, including expectations that she would regard members of the group as a parental figure. Could you please explain: What recognised psychological treatment requires an adult woman living independently to form a forced parental attachment to a group of unrelated older men? And, more importantly: How is refusing to participate in that relationship a symptom requiring treatment, rather than an ordinary exercise of autonomy and personal boundaries? If the proposition is that forcing an adult to regard strangers as “family” is therapeutic, I would respectfully request the relevant evidence-based clinical protocol. 4. Abandoning ordinary human needs as “treatment” The alleged intervention also appears to have required the individual to disregard or sacrifice her own psychological, social and physical needs in order to accommodate the demands of the group. This raises an elementary question: How can depriving a person of security, independence, family relationships, social contact and basic stability be considered a treatment for a personality disorder? Healthcare normally begins with assessment of the person's needs and safety. It is difficult to understand how the opposite principle—deliberately creating insecurity and then describing the resulting distress as therapeutic progress—could constitute legitimate healthcare. 5. The particularly troubling circular logic There also appears to be a potentially circular proposition underlying the alleged methodology: The group causes distress → the person objects → the objection is interpreted as evidence of psychological pathology → the group increases the intervention → the resulting distress is interpreted as evidence that further intervention is required. If this is an accurate description of what occurred, could the relevant authority please explain how such a model can be distinguished from simply creating the problem and then using the resulting distress as justification for continuing the intervention? Where is the independent clinical assessment capable of breaking that circular reasoning?
69 6. Independent consent Finally, I would ask a very simple question. If an adult repeatedly says: “Stop. I do not consent to this. I do not want these people in my life. I do not want this treatment.” at what point does Scottish healthcare recognise that statement as withdrawal of consent, rather than interpreting it as another symptom of the alleged disorder? If the answer is that the person is not permitted to withdraw consent because their refusal is itself considered evidence of illness, I would ask the authority to explain the legal and ethical basis for that position. Request for a substantive response I therefore request clarification of the following: 1. When did Scottish healthcare authorise stalking or harassment as psychological treatment? 2. What professional procedure permits psychological intervention without informed consent? 3. What evidence demonstrates that alleged stalking, coercion or harassment improves personality functioning? 4. What clinical evidence supports deliberately creating an abusive or threatening environment as treatment? 5. What recognised treatment requires an adult woman to form a forced parental relationship with unrelated men? 6. How does deliberately undermining a person's existing family and social relationships promote psychological wellbeing? 7. How does forcing dependency upon the alleged treating group promote recovery rather than dependency? 8. What safeguards exist to prevent a purported therapeutic intervention from becoming stalking, harassment, coercive control or other unlawful conduct? 9. Who authorised this intervention, under what professional registration, and under which Scottish clinical framework? 10. What independent professional assessed whether the intervention was safe and clinically justified? 11. How was informed consent obtained and how was withdrawal of consent respected? 12. If the conduct was not authorised healthcare, why was it represented to the individual as psychological treatment?
70 I appreciate that these questions may sound unusual. Unfortunately, the circumstances being described are even more unusual. I am therefore asking for a straightforward answer: what Scottish healthcare policy, law, professional standard or evidence-based psychological treatment model makes stalking, harassment, coercion, isolation and forced dependency a legitimate means of treating somebody's personality? If no such framework exists, I request that this be stated clearly and that the matter be referred to the appropriate regulatory, safeguarding and/or law-enforcement authorities for independent assessment. Yours faithfully,
71 URGENT REQUEST FOR INVESTIGATION OF POSSIBLE POLITICAL, ETHNIC, RELIGIOUS OR IDEOLOGICAL MOTIVATION To: Health and Care Professions Council / Relevant Scottish Health and Safeguarding Authorities Subject: Request for investigation into whether ethnic, religious, national and potentially political identity was deliberately incorporated into an alleged psychological intervention Dear Sir/Madam, I am writing to request that the circumstances described in my complaint be investigated not only from the perspective of clinical practice, consent, professional boundaries and safeguarding, but also to establish whether ethnic, religious, national or political/ideological considerations may have influenced the alleged intervention. I wish to be precise about this point. I am not alleging that an individual's Israeli nationality, Arab ethnicity, Muslim identity or any other characteristic, by itself, establishes discriminatory or politically motivated conduct. Nor am I suggesting that an Israeli professional cannot ethically treat an Arab patient. The concern is substantially narrower and more serious: Was the individual's Arab, Muslim and cultural identity, and the Israeli identity of individuals involved, deliberately incorporated into the alleged psychological methodology and used to influence, destabilise, control, replace or manipulate the individual's identity, family relationships or psychological attachments? This is a question that I believe requires independent investigation. HCPC standards require practitioner psychologists to understand equality legislation, recognise the effects of cultural differences and protected characteristics on psychological wellbeing, recognise their own values and biases, and ensure that service users are treated appropriately with respect and dignity. The standards also require appropriate consideration of autonomy, consent and professional boundaries. (The HCPC) Why this question arises The alleged intervention was not simply a conventional therapeutic relationship between a psychologist and an adult patient. It is alleged that the group attempted to create an artificial “mother–child” or family relationship, to make the individual bond with members of the group, to undermine existing family attachments and to establish dependency upon the group. One of the alleged participants is an Israeli man, while the individual concerned is an Arab woman whose actual maternal relationship reportedly involved an Arab, Arabic-speaking mother and her own cultural and religious background. The question therefore arises: Why was an unrelated Israeli man considered an appropriate substitute for the individual's Arab mother, and was his Israeli identity deliberately selected or incorporated into the proposed psychological mechanism?
72 If the answer is that nationality was completely irrelevant, the practitioners should be able to explain why these identity differences were nevertheless incorporated into the alleged intervention. If, alternatively, the evidence demonstrates that these differences were deliberately used, the regulator should establish for what purpose and on what professional or scientific basis. Indicators requiring investigation Potential indicator Question for investigation Significance if supported by evidence Israeli/Arab identity explicitly discussed Did participants repeatedly discuss the individual's Arab identity and the man's Israeli identity in connection with the alleged treatment? 🔴 High Arab/Muslim identity treated as a problem Was her Arab or Muslim identity portrayed as something that needed to be overcome, replaced or “fixed”? 🔴 Very high Israeli identity deliberately used Was his Israeli identity deliberately selected because it was considered psychologically significant to the proposed intervention? 🔴 Very high Political subjects introduced Were Israel/Palestine, Arabs, Muslims, nationalism or related political issues deliberately incorporated into the intervention? 🔴 High Identity replacement Was she encouraged or required to abandon aspects of her existing cultural, family or religious identity in favour of the group's identity? 🔴 Very high Family replacement Was she instructed to replace her biological family with members of the group? 🔴 Very high Forced dependency Was psychological dependency on the group treated as a therapeutic objective? 🔴 Very high Use of cultural stereotypes Were generalisations made about Arab women, Muslims, Israelis or other groups? 🔴 High Different treatment based on identity Would the same intervention have been used with a patient of a different ethnic/religious/national background? 🔴 High Target selection Is there evidence that her identity was one of the reasons she was selected for the alleged intervention? 🔴 Very high Political/ideological beliefs of participants Did participants' political or ideological beliefs influence their clinical decisions? 🟠/🔴 Potentially high Lack of clinical rationale Can the practitioners provide a genuine evidence-based explanation for why these particular identities were relevant to treatment? 🟠 Significant
73 Identity destabilisation Was confusion regarding her identity, family or cultural relationships deliberately created as part of the alleged methodology? 🔴 Very high The alleged mother–child methodology requires particular scrutiny The alleged theory appears to have been that members of the group could somehow recreate or substitute a parental relationship, resulting in attachment, dependency and ultimately psychological “healing”. However, an unrelated Israeli man does not become psychologically equivalent to an Arab, Arabic- speaking mother simply because the group assigns him the role of “mother”. The two situations are fundamentally different in: • biological relationship; • childhood history; • language; • culture; • religion; • family history; • shared memories; • social environment; • attachment history; and • the individual's own understanding of who her mother is. If these differences were deliberately used to create confusion, attachment or dependency, that is a substantially different matter from ordinary therapeutic work with transference. I therefore request that the practitioners be asked to provide: 1. the recognised psychological theory underlying this approach; 2. the evidence supporting it; 3. the clinical rationale for selecting these particular individuals; 4. the reason the Israeli/Arab distinction was considered therapeutically relevant, if it was; 5. the consent procedure; 6. the safeguarding assessment; 7. the professional supervision arrangements; 8. the criteria for success or failure; and 9. the stopping criteria.
74 Possible political or ideological motivation I am not asking the regulator to assume that political motivation existed. I am asking that it be investigated because the alleged conduct potentially involved identity itself as the object of intervention. The distinction is important. There is a substantial difference between: “The practitioner treated an Arab patient while respecting her cultural identity.” and: “The practitioner's intervention deliberately used her Arab/Muslim identity, her relationship with her Arab mother, and the Israeli identity of another participant as instruments for psychological manipulation or identity change.” The second proposition, if supported by evidence, would warrant substantially more serious scrutiny. The investigation should therefore establish whether there is evidence of: • political discussions; • ideological objectives; • statements concerning Arabs or Muslims; • statements concerning Israel or Palestinians; • deliberate attempts to change the individual's national, ethnic, religious or cultural identification; • deliberate attempts to sever her connection with her family or community; • instructions to replace her existing identity with the group's identity; or • other evidence demonstrating that political or ideological beliefs influenced the alleged treatment.
75 The central public-protection question The issue is ultimately not whether Israeli and Arab people can have normal professional relationships. Of course they can. The issue is whether professional power was allegedly used to manipulate a person's ethnic, religious, cultural or national identity, particularly where the intervention is also alleged to have involved dependency, isolation, coercion and attempts to replace existing relationships. This should be considered alongside the HCPC requirement that practitioners understand cultural differences and protected characteristics, recognise their own potential biases, respect service-user autonomy and practise within appropriate legal and ethical boundaries. (The HCPC) I therefore respectfully request that this aspect of the complaint be treated as an investigative question requiring evidence, rather than dismissed either as irrelevant to clinical practice or assumed to establish political motivation without evidence. Requested determination I request that the investigation specifically determine: Was the Israeli/Arab distinction incidental to the alleged intervention, clinically relevant and appropriately handled, culturally incompetent or discriminatory, or deliberately incorporated into a political/ideological or identity-manipulation methodology? If evidence establishes that political, ethnic, religious or ideological considerations influenced the practitioners' clinical judgement, I request that this be considered in the assessment of professional conduct, safeguarding, current risk, insight, recurrence risk and fitness to practise. Most importantly, if the alleged methodology was designed to erode the individual's existing identity, sever established relationships and create dependency upon the group, I request that the regulator consider whether this represents a continuing and potentially repeatable risk to other service users. I respectfully request an independent investigation and a written explanation of how these issues have been considered. Yours faithfully,
76 I request that the investigation specifically examine whether the alleged intervention operated as a self-reinforcing treatment loop in which the individual's adverse responses to the intervention were repeatedly reinterpreted as evidence supporting the intervention. In particular, I request investigation of whether refusal was characterised as 'resistance'; emotional distress as 'therapeutic activation'; deterioration as evidence that the treatment was reaching the underlying pathology; rejection of the imposed parent/child relationship as evidence of an attachment disorder; and increasing dependency upon the group as evidence of successful bonding. If these interpretations occurred, the concern is that the methodology may have become effectively self-validating: the more the individual objected, suffered or deteriorated, the greater the justification for continuing and intensifying the intervention. Such a model creates a serious risk that treatment-related harm could be mistaken for therapeutic progress and that withdrawal of consent could be mischaracterised as pathology requiring further treatment. I therefore request that the practitioners identify the objective criteria by which they determined that the intervention was beneficial, the evidence demonstrating improvement, the criteria by which they would have concluded that their hypothesis was incorrect, and the circumstances in which they would have stopped the intervention because of harm, lack of consent or lack of therapeutic benefit. If no meaningful outcome could have falsified their theory because refusal, distress and deterioration were all capable of being interpreted as evidence that treatment should continue, this should be independently assessed as a potential failure of clinical reasoning, risk management, informed consent and professional judgement. The investigation should also determine whether the alleged methodology remains in use, whether other service users have been exposed to it, and whether the practitioners presently demonstrate sufficient insight to recognise the potential danger of interpreting a patient's suffering as evidence that the intervention is working.
77 ORIGINAL DIAGNOSIS / THEORY ↓ INTERVENTION ↓ PERSON EXPERIENCES DISTRESS ↓ ┌────────────┴────────────┐ ↓ ↓ REFUSES DETERIORATES ↓ ↓ “RESISTANCE” “THERAPEUTIC CRISIS” ↓ ↓ “PROVES THE PROBLEM” “TREATMENT IS WORKING” ↓ ↓ └────────────┬────────────┘ ↓ TRY HARDER ↓ INTENSIFY TREATMENT ↓ MORE DISTRESS ↓ MORE DETERIORATION ↓ INTERPRETED AS SUCCESS ↓ TRY HARDER ↓ REPEAT
78 Letter: Concern Regarding an Alleged Self-Reinforcing Treatment Loop To: Health and Care Professions Council / Relevant Scottish Regulatory and Safeguarding Authorities Subject: Urgent concern regarding alleged reinterpretation of refusal, distress and deterioration as evidence of successful treatment Dear Sir/Madam, I am writing to request that the investigation specifically examine whether the alleged intervention developed into a self-reinforcing treatment loop, whereby the individual's refusal, emotional reactions, deterioration and attempts to obtain independent assistance were repeatedly interpreted as evidence that the intervention was working, rather than as possible evidence that it was inappropriate, ineffective or causing harm. I believe this issue is central to understanding both the alleged duration of the intervention and the potential risk to the individual. I am not asking the regulator to assume that these allegations are established. I am asking that they be independently investigated. 1. Refusal allegedly became “resistance” The individual reportedly repeatedly communicated that she did not want the intervention, rejected the imposed relationships and wanted the conduct to stop. The concern is that, rather than treating these statements as potentially meaningful expressions of refusal and withdrawal of consent, they were allegedly interpreted as “resistance” or evidence of the person's supposed psychological disorder. The alleged reasoning appears to have been: “She is refusing the intervention because of her psychological problem; therefore the refusal demonstrates that she needs the intervention.” If this occurred, it creates a circular problem. The person says “stop”. The response becomes: “Your refusal proves that you need us to continue.” The intervention therefore becomes capable of overriding the very objection that should cause it to be reconsidered. This is particularly concerning because valid consent must be voluntary and informed, and a person's ability to participate in decisions concerning their care must be respected. HCPC standards require registrants to work in partnership with service users and support them to make informed decisions. HCPC Standards of Conduct, Performance and Ethics
79 2. Emotional distress allegedly became “therapeutic activation” The individual reportedly experienced substantial emotional distress during the alleged intervention. The concern is that this distress may have been interpreted as evidence that the intervention was successfully reaching an underlying psychological problem. The alleged reasoning would therefore be: Distress → underlying problem has been activated → treatment is working → continue. However, distress can have many possible causes. It may indicate that difficult therapeutic material has been appropriately addressed, but it may also indicate: • that the intervention is inappropriate; • that the person does not consent; • that boundaries have been crossed; • that the person is frightened; • that the intervention is worsening their condition; or • that the person requires a completely different form of assessment or treatment. The existence of distress cannot, by itself, establish therapeutic success. I therefore request that an independent clinician determine whether the individual's reported emotional deterioration was objectively consistent with therapeutic benefit or whether it was more consistent with an adverse consequence of the alleged intervention. 3. Deterioration allegedly became evidence that the treatment was working A particularly serious concern is the alleged reinterpretation of worsening functioning as a necessary stage of treatment. If the person's health, emotional stability, social functioning or ability to live independently deteriorated, the alleged explanation reportedly included concepts such as the person's “old personality” breaking down or deeper psychological material being activated. This creates the following loop: Treatment → deterioration → deterioration interpreted as therapeutic progress → treatment continued → further deterioration → further treatment. If that occurred, the treatment would effectively be using its own adverse consequences as evidence supporting continuation. The appropriate clinical response to significant deterioration should instead be to ask: Is the treatment helping, is it harming the person, or is another explanation responsible for the deterioration?
80 HCPC standards require practitioners to make reasoned decisions about whether to initiate, continue, modify or cease treatment and to evaluate intervention plans appropriately. HCPC Standards of Proficiency: Practitioner Psychologists 4. Emotional expressions allegedly became diagnostic evidence I am also concerned about the possibility that ordinary emotional responses to the alleged circumstances were interpreted as confirmation of the diagnosis. For example: Fear could allegedly become evidence of pathology. Anger could become evidence of personality disorder. Crying could become evidence that the intervention had reached deeper psychological material. Desperation could become evidence of dependency. Repeated objections could become evidence of resistance. This creates a significant risk of pathologising the person's response to the intervention itself. The regulator should therefore establish whether the practitioners considered alternative explanations for the person's behaviour, including the possibility that her emotional responses were reactions to the intervention rather than manifestations of the condition they were attempting to treat. 5. Seeking independent help allegedly became evidence of treatment failure The individual reportedly attempted to obtain assistance from people outside the group. If those attempts were interpreted as evidence that she was avoiding treatment, unable to form the desired attachment, or demonstrating further pathology, this could have created another self- reinforcing loop. The alleged sequence would be: Person seeks independent help → group interprets this as avoidance/resistance → group increases intervention → person becomes more dependent upon the group → dependency is interpreted as successful bonding. This requires particular scrutiny because the objective of psychological care should not ordinarily be to make a person increasingly dependent upon the people providing the intervention. The regulator should therefore establish whether the alleged objective was ultimately greater autonomy and functioning, or whether dependency upon the group itself became regarded as evidence of therapeutic success.
81 6. The alleged mother–child relationship created another circular loop The alleged intervention reportedly attempted to create an artificial mother–child relationship between the woman and an unrelated older man. The woman reportedly rejected this relationship and stated that the person was not her mother. If that rejection was interpreted as an attachment problem requiring the group to try harder, the alleged loop would be: “You are not my mother.” ↓ “You cannot form the attachment.” ↓ More attempts to impose the relationship. ↓ Greater distress and rejection. ↓ “Your attachment problem is even stronger.” ↓ More attempts. This is particularly important because the rejection of an imposed relationship cannot safely be assumed to demonstrate that the person needs that relationship more strongly. The regulator should establish the evidence base for the proposition that an unwilling adult can or should be made to develop a parent–child attachment to an unrelated person, and what safeguards were used to prevent coercion or dependency. 7. The overarching concern: a system in which nothing could prove the treatment wrong Taken together, these alleged interpretations create a much more serious methodological concern. If: • acceptance was interpreted as success; • refusal was interpreted as resistance; • distress was interpreted as therapeutic activation; • deterioration was interpreted as psychological breakthrough; • dependency was interpreted as successful bonding; • seeking outside help was interpreted as avoidance; • and rejection of the imposed relationship was interpreted as attachment pathology, then almost every possible response from the individual could be interpreted as justification for continuing. In that circumstance, the intervention could become effectively unfalsifiable. There would be no meaningful point at which the practitioners would have to conclude: “Our theory may be wrong.” That is the issue I believe requires independent examination.
82 8. “Try harder” and escalation The alleged result appears to have been a further escalation: Treatment does not produce the desired result → therefore try harder. But if “try harder” produces greater distress, and that distress is then interpreted as evidence that treatment is working, the cycle becomes: More intervention → more distress → distress interpreted as success → justification for more intervention. This is potentially dangerous because the person's suffering becomes the mechanism through which the intervention justifies its own continuation. The question for the regulator should therefore be: What specific outcome would have caused the practitioners to stop? If the answer is unclear, or if every negative outcome was capable of being reinterpreted as evidence that the treatment needed to continue, that should be considered in assessing the practitioners' clinical reasoning, insight and risk. 9. Request for independent assessment I respectfully request that an independent practitioner, who has had no involvement in the alleged intervention, assess: 1. whether the alleged methodology is recognised and evidence-based; 2. whether the proposed parent–child/transference model has a legitimate clinical basis; 3. whether the individual's refusal was properly treated as refusal; 4. whether emotional distress was appropriately distinguished from therapeutic progress; 5. whether deterioration was properly recognised and investigated as a possible adverse effect; 6. whether objective outcome measures existed; 7. whether predetermined stopping criteria existed; 8. whether independent clinical review occurred; 9. whether the intervention became self-reinforcing; 10. whether the practitioners demonstrated appropriate insight; 11. whether the same methodology may have been used with other service users; and 12. whether the practitioners currently present a risk of repeating the alleged conduct.
83 10. Conclusion My concern is therefore not simply that the alleged treatment failed. The more serious concern is that the alleged treatment may have contained a mechanism whereby failure was repeatedly converted into evidence of success. If a person says: “Stop.” and the answer is: “Your resistance means we must continue,” and if the person becomes distressed and the answer is: “Your distress means the treatment is working,” and if the person's condition deteriorates and the answer is: “The deterioration means the treatment is reaching the underlying problem,” then the system risks becoming incapable of recognising its own harm. That is precisely why I request an independent assessment rather than further reliance upon the interpretations of the people who designed or conducted the alleged intervention. The fundamental question should be: Was the person becoming healthier, safer and more autonomous—or was the person's increasing distress and dependency being reinterpreted as proof that the intervention was successful? If the latter is supported by evidence, I request that this be treated as a serious issue concerning clinical reasoning, informed consent, safeguarding, professional boundaries, treatment safety, insight and potential risk to other service users. Yours faithfully,
84 URGENT COMPLAINT: CONCERN THAT AN ALLEGED “THERAPEUTIC” METHOD MAY HAVE BEEN USED TO LEGITIMISE COERCIVE, HARMFUL AND NON- CONSENSUAL CONDUCT To: Health and Care Professions Council / Relevant Scottish Health and Safeguarding Authorities Subject: Request for independent investigation into alleged misuse of psychological terminology, coercive conduct and a self-validating “treatment” model Dear Sir/Madam, I am requesting an urgent and independent investigation into allegations concerning an individual who is alleged to have presented himself as capable of psychologically treating or “fixing” another person, despite concerns regarding his professional status, the absence of an appropriate clinical framework, the lack of valid consent, and the nature and duration of the alleged intervention. The central concern is not simply that an unconventional treatment may have been attempted. The concern is that conduct may have been carried out first, and then labelled “treatment”, “therapy”, “healing”, “attachment work”, “transference” or “personality treatment” in order to give the conduct a therapeutic explanation. If established, this would represent a profoundly different situation from legitimate psychological treatment. Scottish Government guidance states that psychological therapies should be delivered by appropriately trained professionals and emphasises clinical governance, evidence-based practice and appropriate standards of care. (Scottish Government) HCPC standards require valid, voluntary and informed consent, partnership with service users, respect for dignity and attention to safety. (The HCPC) I therefore ask that the alleged conduct be examined independently rather than accepted at face value because the individuals involved described it as “treatment”. PAGE 1 — THE PERSON, THE ALLEGED METHOD AND THE THERAPEUTIC LABEL 1. The individual proposing the alleged “treatment” The complaint concerns an individual who, according to the information available to me, has reportedly been diagnosed with narcissistic personality disorder and psychopathy. I do not ask the regulator to rely upon those diagnoses as proof that the person is dangerous or incapable of professional practice. A diagnosis, by itself, does not establish misconduct. However, it is relevant to the investigation if the person's own reported characteristics, beliefs and behaviour are allegedly reproduced within the treatment model that he claims will “fix” other people. The alleged methodology appears particularly concerning because the person reportedly believes that he can treat narcissistic characteristics through a process involving control, psychological
85 pressure, dependency, destabilisation, manipulation of relationships and imposed interpersonal dynamics. The question therefore becomes: Is the alleged “treatment” actually treating the person's alleged psychological difficulties, or is it reproducing the very interpersonal behaviours that are supposedly being treated? If someone claims to cure controlling behaviour by exercising greater control over another person, this requires a substantial evidence base and independent clinical justification. Simply calling the conduct “therapy” cannot establish that it is therapeutic. 2. Alleged transformation of conduct into “treatment” The alleged sequence is particularly important. First, conduct occurs which the individual experiences as unwanted, frightening, intrusive, controlling or harmful. Second, the conduct is given a therapeutic explanation. For example: • control becomes “therapy”; • psychological pressure becomes “treatment”; • forced dependency becomes “bonding”; • emotional destabilisation becomes “therapeutic activation”; • distress becomes “progress”; • refusal becomes “resistance”; • isolation becomes “removal of unhealthy attachments”; • attempts to obtain independent assistance become “avoidance”; • an imposed relationship becomes “transference”; • deterioration becomes “the old personality breaking down”. This is the central concern. The terminology may be changing the description of the conduct without changing what the conduct actually does to the person. A person being frightened does not become therapeutic merely because someone calls the fear “activation”. A person being controlled does not become therapy merely because the controller calls it “treatment”. A person becoming dependent does not automatically constitute successful therapeutic attachment.
86 A person's deterioration does not automatically constitute psychological progress. 3. Alleged absence of a genuine therapeutic framework I request that investigators establish whether there was actually: • a recognised therapeutic modality; • a qualified practitioner-patient relationship; • a treatment plan; • a documented diagnosis; • informed consent; • a documented risk assessment; • clinical supervision; • independent review; • objective outcome measures; • treatment goals; • stopping criteria; • procedures for withdrawal of consent; • safeguarding arrangements; and • an independent clinician able to terminate the intervention. The Scottish National Specification for Psychological Therapies and Interventions emphasises that services should reduce risks of harm, provide appropriate governance, enable feedback and complaints, and ensure staff have appropriate skills, training and experience. (Scottish Government) The question should therefore not simply be: “Did he believe this was therapy?” It should be: “Was this actually a clinically legitimate intervention, delivered within an appropriate professional and safeguarding framework?” PAGE 2 — THE SELF-REINFORCING LOOPS 4. The “NO” → “RESISTANCE” → “TRY HARDER” loop The individual reportedly objected to the alleged intervention. The alleged response was not: “The person has withdrawn consent. We must stop.”
87 Instead, the objection was allegedly interpreted as resistance caused by the person's personality. The cycle therefore becomes: Person says NO ↓ NO is labelled resistance ↓ Resistance is attributed to the diagnosis ↓ Diagnosis is used to justify continuing ↓ Person says NO again ↓ The stronger NO is interpreted as stronger resistance ↓ The intervention is intensified This is extremely important because it potentially turns refusal into a mechanism for continuing rather than stopping the intervention. 5. The distress → “success” loop The person reportedly became increasingly distressed. Instead of the distress necessarily triggering reassessment, the alleged interpretation was that the treatment was reaching something deeper. The cycle becomes: Intervention ↓ Distress ↓ “The treatment is activating the problem.” ↓ Therefore the treatment is working ↓ Continue
88 ↓ Greater distress ↓ “We have reached something even deeper.” ↓ Continue again This creates the possibility that the intervention's adverse effects become evidence supporting the intervention. That is the precise issue that requires independent clinical scrutiny. 6. The deterioration → “breakthrough” loop The alleged individual reportedly experienced substantial deterioration in ordinary functioning. If the response was: “The old personality is breaking down,” rather than: “The person is deteriorating; we need to stop and reassess,” then deterioration itself becomes therapeutically meaningful. The resulting loop is: Person deteriorates ↓ Deterioration is called therapeutic progress ↓ Treatment continues ↓ Person deteriorates further ↓ Further deterioration is interpreted as evidence that deeper treatment is necessary ↓ Treatment is intensified This is potentially dangerous because there is no obvious point at which worsening becomes evidence against the treatment.
89 7. The dependency → “bonding” loop The alleged methodology also reportedly involved attempts to create an intense bond or dependency between the individual and the group. This raises another circular mechanism: Person becomes dependent ↓ Dependency is called successful bonding ↓ More dependency is encouraged ↓ Person becomes increasingly isolated from independent sources of support ↓ Increased dependence on the group ↓ This is then cited as evidence that the “bonding treatment” is working. This requires particular scrutiny. A therapeutic relationship should not simply be judged successful because the patient becomes increasingly dependent upon the people providing the intervention. 8. The imposed mother–child relationship The alleged intervention reportedly attempted to create a mother–child dynamic between an adult woman and an unrelated older man. The woman reportedly rejected this. If the rejection was then interpreted as an attachment disorder requiring the group to try harder, another loop arises: “You are not my mother.” ↓ “You have an attachment problem.” ↓ Attempt to impose the relationship ↓ Greater rejection
90 ↓ “The attachment problem is deeper.” ↓ Try harder ↓ Greater distress ↓ “The treatment is reaching the underlying issue.” This creates an especially serious concern about whether transference terminology was being used to rationalise a relationship that the person did not voluntarily want. The investigation should establish precisely what recognised clinical model was being relied upon and whether the alleged conduct falls within that model at all. PAGE 3 — GASLIGHTING, MISLABELLING AND PUBLIC PROTECTION 9. Concern regarding alleged therapeutic gaslighting I use the term “gaslighting” cautiously, because it is ultimately the evidence that should determine whether such conduct occurred. However, I am concerned that the alleged methodology may have repeatedly caused the individual to question the meaning of her own experiences. For example: “You are frightened.” “That proves the treatment is working.” “You want this to stop.” “That proves you are resisting.” “You are becoming worse.” “That proves we are reaching the deeper problem.” “These people are strangers.” “That proves you have attachment problems.” “I need independent help.” “That proves you are avoiding treatment.” The concern is that the person's ordinary interpretation of events was repeatedly replaced with the group's interpretation. This can become particularly harmful if the group presents itself as having superior knowledge of the individual's own mind and uses the person's disagreement as evidence that the person is psychologically incapable of understanding what is happening.
91 10. The alleged contradiction at the centre of the methodology There appears to be a fundamental contradiction requiring investigation. The person allegedly claims to be treating narcissism. Yet the alleged method reportedly involves: • insisting that the practitioner knows what is best; • overriding the individual's interpretation of her own experience; • refusing to accept disagreement; • imposing relationships; • demanding dependency; • interpreting objections as pathology; • and treating the practitioner's interpretation as authoritative. If established, this raises the question: Is the practitioner actually teaching the person to become less controlling and less dependent—or is he demonstrating and imposing the very interpersonal dynamics he claims to be treating? It is not sufficient to say: “I am behaving this way deliberately because it is therapeutic.” A therapeutic claim requires evidence, appropriate professional competence, consent, safeguards and a legitimate clinical rationale. 11. The crucial question of whether the “treatment” is merely a justification I therefore request that the investigation specifically consider the possibility that: The therapeutic explanation may have been applied retrospectively to conduct that was already coercive or harmful, thereby allowing that conduct to be described as beneficial rather than examined as potential abuse or misconduct. The distinction is critical. If someone behaves in a controlling manner and says: “I am controlling you to teach you about control,” the explanation does not itself establish therapeutic legitimacy. If someone deliberately creates distress and says: “I am distressing you to heal you,” the explanation does not itself establish therapeutic legitimacy.
92 If someone creates dependency and says: “I am making you dependent so that you can learn attachment,” the explanation does not itself establish therapeutic legitimacy. Each proposition requires independent evidence and clinical justification. 12. Request for investigation and immediate protection I respectfully request that the regulator investigate: 1. Who was involved and what professional qualifications or registrations they held. 2. Whether any person was presenting themselves as a psychologist or healthcare professional without appropriate registration. 3. The precise nature of the alleged “treatment”. 4. The evidence base supporting it. 5. Whether valid and ongoing consent existed. 6. Whether the person could freely withdraw. 7. Whether refusal was interpreted as pathology. 8. Whether distress was interpreted as therapeutic progress. 9. Whether deterioration was interpreted as therapeutic breakthrough. 10. Whether dependency was treated as evidence of successful treatment. 11. Whether transference terminology was used to justify imposed relationships. 12. Whether appropriate professional boundaries were maintained. 13. Whether there was independent clinical supervision. 14. Whether objective outcome measures existed. 15. What stopping criteria existed. 16. What would have caused the practitioners to conclude that they were wrong. 17. Whether the same methodology has been used with other individuals. 18. Whether the practitioners currently continue to endorse the methodology. 19. Whether they demonstrate insight into the potential harm. 20. Whether interim public-protection measures are necessary while the allegations are investigated. HCPC standards specifically require valid voluntary and informed consent, respect for service users, attention to safety and action where professional conduct places people at unacceptable risk. (The HCPC) They also emphasise appropriate professional boundaries and responsible communication. (The HCPC)
93 13. Final request The central question I ask the authorities to answer is not: “Did this person call what they were doing therapy?” The question is: “Was what they were doing actually legitimate, evidence-based, consensual and professionally governed psychological treatment?” And if the evidence shows that harmful conduct was repeatedly given therapeutic names in order to justify continuing it, I ask that the matter be considered as a serious public-protection and fitness- to-practise concern, rather than simply as an unusual therapeutic disagreement. The alleged pattern is particularly concerning because it potentially contains a mechanism for concealing its own failure: Control is called treatment. Refusal is called resistance. Distress is called activation. Deterioration is called progress. Dependency is called bonding. Seeking outside help is called avoidance. Rejection of the imposed relationship is called attachment pathology. And the continuation of the intervention is then presented as evidence that the treatment is necessary. If that pattern is substantiated, the issue is considerably more serious than a treatment that simply did not work. It would raise the possibility that the language of treatment was being used to legitimise and perpetuate conduct that should instead have triggered consent review, safeguarding intervention, independent assessment and cessation. I therefore respectfully request an independent investigation, immediate assessment of current risk, consideration of interim public-protection measures where the statutory criteria are met, and assessment of whether other service users may have been exposed to the same methodology. Yours faithfully,
94 Assessment of the alleged conduct of the group of psychologists: Alleged conduct of the psychology group Similarity to coercive/abusive dynamics Professional/regulatory concern Risk significance Psychologists allegedly became involved with an individual who had not consented to being treated or assessed by them 🔴 Very high HCPC standards require valid, voluntary and informed consent before care, treatment or other services are provided. Psychologists must also promote and protect service-user interests. (The HCPC) 🔴 Immediate concern Allegedly observing, contacting, monitoring or stalking the individual outside a legitimate clinical relationship 🔴 Very high Potential boundary violation and potentially a criminal matter, depending on the evidence. It would require investigation rather than being treated as legitimate psychological practice. 🔴 Immediate Continuing after the person repeatedly said “stop” or rejected the intervention 🔴 Very high A refusal cannot simply be re- labelled as a psychological symptom to justify continuing. Appropriate practice requires partnership with the service user and valid consent. (The HCPC) 🔴 Immediate Describing refusal as “resistance” or evidence of a personality disorder 🔴 Very high Creates a potentially self- confirming system in which the patient's refusal is prevented from functioning as a genuine objection. 🔴 Immediate Treating fear, distress or deterioration as evidence that the intervention is “working” 🔴 Very high Raises serious questions about clinical judgement, safeguarding, monitoring of outcomes and ability to recognise harm. Practitioner psychologists are required to practise safely and effectively and to protect service- user interests. (The HCPC) 🔴 Immediate Continuing or escalating the alleged intervention after deterioration 🔴 Very high Raises the question whether the practitioners have adequate insight and whether they can 🔴 Immediate
95 recognise when their intervention is harmful. Calling coercive behaviour “therapy”, “treatment”, “bonding” or “healing” 🔴 Very high Professional terminology cannot itself create a legitimate therapeutic relationship, consent or clinical justification. 🔴 Immediate Attempting to make the person dependent upon the group 🔴 Very high Potential abuse of professional power and trust. HCPC standards specifically require professionals to recognise the power held in their position and maintain appropriate boundaries. (The HCPC) 🔴 Immediate Encouraging the person to abandon or replace existing family relationships with the group 🔴 Very high Raises serious safeguarding and boundary concerns and potentially undermines autonomy and independent sources of support. 🔴 Immediate Creating a purported “mother–child” relationship with an unrelated adult 🔴 Very high Raises questions concerning inappropriate dual/personal relationships, boundary violations, power imbalance and the absence of a legitimate therapeutic framework. Practitioner- psychologist standards expressly address consent, duty of care, dual relationships, power imbalance and boundaries. (The HCPC) 🔴 Immediate Deliberately creating an environment intended to trigger distress and then interpreting that distress as therapeutic progress 🔴 Very high Requires independent assessment of whether the methodology has any legitimate evidence base, appropriate safeguards or outcome-monitoring mechanism. 🔴 Immediate Repeatedly changing diagnoses to explain the person's responses to the intervention 🔴 High Raises concerns about diagnostic reliability, confirmation bias, clinical reasoning and whether diagnoses are being used retrospectively to justify conduct. 🔴 High
96 Dismissing the person's existing medical information and attempts to obtain independent assessment 🔴 High Raises concerns about autonomy, appropriate referral, scope of practice and whether independent clinical assessment was improperly obstructed. 🔴 High Psychologists allegedly working together with non- psychologists/online personalities in carrying out the methodology 🔴 Very high Requires examination of who was actually providing psychological intervention, what authority they had, what supervision existed and whether registered professionals facilitated or endorsed conduct outside appropriate professional boundaries. 🔴 Immediate Psychologists allegedly observing the conduct of others but failing to intervene or challenge it 🔴 Very high HCPC standards require professionals to safeguard service users and raise concerns where colleagues' conduct places people at risk. (The HCPC) 🔴 Immediate Multiple psychologists allegedly adopting the same methodology 🔴 Very high This changes the concern from possible individual misconduct to a potentially repeatable professional practice requiring investigation. 🔴 Immediate The alleged intervention continuing for an exceptionally prolonged period despite alleged deterioration 🔴 Very high Raises questions about clinical governance, review, proportionality, outcome measurement, supervision and insight. 🔴 Immediate Allegedly refusing meaningful external scrutiny or alternative professional assessment 🔴 Very high Particularly concerning if practitioners cannot demonstrate willingness to review their own hypotheses and respond to evidence of harm. 🔴 Immediate Alleged racial, cultural or religious assumptions being incorporated into the intervention 🔴 High / potentially very high Psychologists must recognise the effects of personal values, biases and beliefs and must not allow them to detrimentally affect service users. BPS standards also emphasise respect for cultural, ethnic, religious and other differences. (The HCPC) 🔴 High An Arab/Muslim woman allegedly being 🔴 Very high Requires investigation of cultural competence, stereotyping, 🔴 High / immediate
97 subjected to a forced psychological narrative involving strangers being treated as parental figures informed consent, personal boundaries and whether the individual's identity was being overridden rather than respected. Psychologists allegedly continuing to endorse the methodology after being told it is causing serious harm 🔴 Very high Raises a fundamental fitness-to- practise question concerning insight, judgement and ability to protect future service users. 🔴 Immediate
98 Risk assessment of the alleged behaviour: Alleged behaviour Concern relevant to sexual/coercive violence Concern about sadistic or coercive traits Regulatory significance Repeatedly continuing after the woman says NO/STOP 🔴 Very serious 🔴 Very serious Indicates possible disregard for autonomy and boundaries Treating refusal as “resistance” rather than refusal 🔴 Very serious 🔴 Very serious Creates a mechanism for overriding consent Deliberately producing fear or distress and calling it treatment 🔴 Very serious 🔴 Very serious Particularly concerning if distress is intentionally produced Continuing when the person's condition allegedly deteriorates 🔴 Very serious 🔴 Very serious Raises questions about insight, judgment and recognition of harm Calling suffering “progress” or “breakthrough” 🔴 Very serious 🔴 High Potentially permits harm to continue without an effective stopping mechanism Attempting to make the person dependent upon the group 🔴 High 🔴 High Potential exploitation of psychological power and dependency Isolating the person from family and alternative sources of support 🔴 High 🔴 High Can increase vulnerability and reduce ability to escape or seek independent help Attempting to impose unwanted mother/child roles 🔴 High 🔴 High Raises serious concerns about personal and professional boundaries Manipulating the person's understanding of their own feelings 🔴 High 🔴 High Can undermine autonomy and ability to recognise abuse Repeatedly changing the explanation/diagnosis to accommodate the person's reactions 🟠 Significant 🟠 Significant May indicate a self- confirming methodology rather than objective assessment Group members reinforcing each other's interpretation 🔴 High 🔴 High Raises concern about collective
99 normalisation of harmful conduct Continuing an alleged methodology for a prolonged period despite objections 🔴 Very serious 🔴 Very serious Raises significant future-patient safeguarding concerns Allegedly using psychological concepts to justify control 🔴 High 🔴 High Potential misuse of professional knowledge and authority Alleged stalking/harassment outside a clinical relationship 🔴 Very serious 🔴 Very serious Potentially criminal as well as professionally improper, depending on evidence Any sexualised conduct, sexual humiliation, sexual threats or sexual activity without free agreement 🔴 Extremely serious 🔴 Extremely serious Would require immediate consideration of police involvement as well as regulatory action