August 2023: Deborah Laxton, Reference No: 00573620 Registrant ID:12364
Allegations
In the allegations below, ‘the Complainant’ refers to the witness […]. […]
Allegation 1
1.1 In the course of and/or after the therapeutic relationship, in Year 1 and/or Year 2 the Member breached professional boundaries in that she:
a. Touched, held and/or kissed the Complainant; and/or
b. Invited the Complainant to stay and meet her family after sessions; and/or
c. Invited the Complainant to become a Director in her Company.
1.2 The Member thereby failed to meet professional standards, including in particular by acting in a way which was inconsistent with the following paragraphs of the Ethical Framework for the Counselling Professions 2016:
33 (We will establish and maintain appropriate professional and personal boundaries in our relationships with clients by ensuring that:
a) these boundaries are consistent with the aims of working together and beneficial to the client;
b) any dual or multiple relationships will be avoided where the risks of harm to the client outweigh any benefits to the client;
d) the impact of any dual or multiple relationships will be periodically reviewed in supervision and discussed with clients when appropriate.
37 (We recognise that conflicts of interest and issues of power or dependence may continue after our working relationship with a client, supervisee or trainee has formally ended. We will exercise caution before entering into personal or business relationships with former clients and expect to be professionally accountable if the relationship becomes detrimental to the former client or the standing of the profession. They may also be discussed with any colleagues or managers in order to enhance the integrity of the work being undertaken).
Allegations 1.1 (a) and/or (b) and/or (c) amount to professional misconduct as defined in the Professional Conduct Procedure.
Allegation 2
2.1 The Member failed to ensure against the risk of dual or multiple relationships being created that could be potentially harmful to the client in that she accepted a financial loan from the Complainant on a date in or around April Year 2.
2.2 The Member thereby failed to meet professional standards, including in particular by acting in a way which was inconsistent with the following paragraphs of the Ethical Framework the Counselling Professions 2016:
36 (We will not exploit or abuse our clients in any way: financially, emotionally, physically, sexually or spiritually) and/or
37 (We recognise that conflicts of interest and issues of power or dependence may continue after our working relationship with a client, supervisee or trainee has formally ended. We will exercise caution before entering into personal or business relationships with former clients and expect to be professionally accountable if the relationship becomes detrimental to the former client or the standing of the profession.)
Allegation 2.1 amounts to professional misconduct as defined in the Professional Conduct Procedure.
Allegation 3
3.1 The Member failed to adequately maintain the confidentiality of her clients by permitting the Complainant to enter personal details of clients and therapy session notes on to the Member’s computer systems.
3.2 The Member thereby failed to meet professional standards, including in particular acting in a way which was inconsistent with the following paragraph of the Ethical Framework for the Counselling Professions 2016:
25 (We will protect the confidentiality and privacy of clients by:
a) actively protecting information about clients from unauthorised access or disclosure and
b) informing clients about any reasonably foreseeable limitations of privacy or confidentiality in advance of our work together)
3.3 The Member thereby failed to meet professional standards, including in particular acting in a way which was inconsistent with the following paragraph of the Ethical Framework for the Counselling Professions 2018:
55 We will protect the confidentiality and privacy of clients by:
a. actively protecting information about clients from unauthorised access or disclosure
b. informing clients about how the use of personal data and information that they share with us will be used and who is within the circle of confidentiality, particularly with access to personally identifiable information.
Allegation 3.1 amounts to Professional Misconduct as defined in the Professional Conduct Procedure.
Preliminary issues
Amendment of allegations
Prior to the hearing being opened, the Case Presenter (CP) applied to amend the allegations as follows:
• Number the second paragraph of the first allegation ‘1.2’.
• Extend the wording of the stem of allegation 1.1 to include the period after the end of the therapeutic relationship and add paragraph 37 of the Ethical Framework for the Counselling Professions 2016 due to lack of clarity over the timing of the alleged conduct in relation to the end of the therapeutic relationship.
• Add paragraph 55.a and 55.b of the Ethical Framework for the Counselling Professions 2016 to allegation 3 as paragraph 3 to address the proximity of the alleged behaviour to the transition from the 2016 to the 2018 ethical framework (1 July 2018).
The Panel also noticed that the references to the 2016 ethical framework were incorrect, and that ‘Ethical Framework for Good Practice in Counselling and Psychotherapy 2016’ should read ‘Ethical Framework for the Counselling Professions 2016’ throughout.
The Panel took advice from the Clerk who referred them to Clause 4.12 of the BACP Professional Conduct Procedure 2018:
4.12 Amendment of allegations
At any stage before making its findings of fact and having considered any representations by the parties as to the appropriateness of doing so, the Panel may permit or direct the amendment of the allegations.
The Panel provided the Member the opportunity to make submissions in relation to the proposed amendments. She objected to the change to allegation 1.1 on the basis she had always been clear that she acted in the way described in 1.1.a-c but that the events happened after the end of the therapeutic relationship. She submitted it was unfair for the BACP to apply for amendment so late when she had been clear and consistent throughout. She had no objection to the amendment to allegation 3 or references to the 2016 ethical framework.
The Panel considered each party’s submissions. It decided that the amendment of allegation 1 would mean that the Member’s defence, while still applying to the alleged breach of paragraph 33 of the Ethical Framework for the Counselling Professions 2016, would not provide a defence to the added allegation under paragraph 37 of the Ethical Framework for the Counselling Professions 2016. The Panel agreed this was a significant detriment to the Member. However, it agreed that it would be contrary to the interests of justice to refuse the expansion of allegation 1 as the Member’s admissions (which the expansion would incorporate) were capable of amounting to serious misconduct. In relation to allegation 3, it agreed that the Member’s defence to the current allegation would apply to the whole of the amended allegation, so there would be no prejudice to her in making the amendment. The Panel decided the changes to references to the 2016 ethical framework were simple typographic corrections, were not objected to be either party and were not prejudicial to either party.
The Panel granted the application for amendment and directed the amendments of the allegations shown in red ink on pages 2 and 3 of this record of hearing.
Admissions
The Member admitted the facts alleged in paragraph 1.1(a)-(c) and, in part, the facts alleged in paragraphs 2.1 and 3.1. However, she denied that her conduct was inappropriate or a breach of the BACP Ethical Framework.
Evidence before Panel
In coming to its decision the Panel carefully considered the following:
• The BACP’s bundle of evidence and exhibits.
• The written and oral evidence of the original complainant […] and the BACP.
• The written and oral evidence and submissions from the Member.
• The Panel heard evidence from witness […] and the Member’s […], witness […].
• The BACP Professional Conduct Procedure 2018.
• The Ethical Framework for the Counselling Professions 2016 and 2018.
Summary of Evidence
The complaint, as summarised by the Investigation and Assessment Committee, stated:
1. The Complainant complains about Deborah Laxton, an individual Member of BACP;
2. The Member told the Complainant in a session on 22 December Year 1 that ‘God had given her a love’ for her, that the Complainant ‘needed a mum’ and that [the Member] ‘should be like a mum’ to her;
3. The Member said that God had told her to invite the Complainant to ‘become part of her family’;
4. There was a blurring of professional and ethical boundaries, due to physical ‘holding’, ‘kisses’, invites to stay for tea after therapy sessions, and an invite to become a director of the Member’s company;
5. The Member accepted a loan of […] from the Complainant when she was a client, blurring the Complainant’s roles as a client, director and a ‘family member’;
6. The Complainant and her housemate were asked by the Member to input the Member’s confidential client notes onto the BACPAC system. Both were given access to BACPAC’s system and inputted confidential client notes taken by therapy students and qualified counsellors, without having signed any confidentiality agreements. The Complainant stopped this as she was uncomfortable. The Complainant does not know if the Member maintained a paper copy of her own notes, and that the Member had deleted her notes entirely;
7. In Year 5, the Member insisted the parties have a one-year break in all contact, telling the Complainant that this was to comply with BACP guidelines as a therapeutic-break;
8. The Member told the Complainant that ‘if God wants [the Member] to give the money back, he will make it available [to them];
9. The Complainant has concerns regarding the safety of clients and students who meet the Member as the house in which counselling/training takes place is not insured, is not registered for business use nor has an adequate fire alarm system; and
10. The Complainant provided a list of dates of her therapy appointments, with appointments running to the end of February Year 2.
[…]
Decision and Reasons for Findings
On balance, having fully considered the above, the Panel made the following findings:
The Panel found that the Member and each of the two witnesses had given oral evidence that was plausible and consistent with their written statements. All appeared to be genuinely recounting their honestly held recollection of events. The Panel noted that […] recorded her first written account of events in her letter to the Member dated 20 November Year 5 (over three years after the events in the allegations) and later in her complaint to the BACP in […]. Accordingly, the Member and […] had not been asked to recollect these events, which took place in Year 1 – Year 2, until November Year 5, by which time the Member no longer had access to the clinical notes from her sessions with […].
The Member and […] did, however, have access to and provided information drawn from the bank records of […], which showed the amount and date of payments received from […] and any annotation applied to those payments by […]. The Member and […] gave evidence consistent with the bank records.
[…] similarly had drawn information from her bank records and also from her diary from the time and her evidence was consistent with this contemporaneous information. The diary was an appointment diary rather than a journal, so did not contain a contemporaneous record of what happened at events from […] but did provide a contemporaneous record of […] scheduled events. […] stated that she annotated her therapy sessions with the Members with ‘appt’, which meant ‘appointment’. The Member gave evidence that she was […] for one date over the summer of Year 1 and, possibly, on holiday for another in August Year 1, which the Panel accepted. Nevertheless, the Panel found that […] diary was, on the balance of probabilities, an accurate record of the dates of […] appointments and other planned events with the Member from December Year 1 onwards, which was the relevant period for the allegations.
The Panel found that it was not disputed that the Member and […] saw each other for a therapy session on 22 December Year 1 and in some capacity on 3, 9, 13, 16 and 23 January Year 2 and 13 and 27 February Year 2. It was for the Panel to decide when during this period the therapeutic relationship ended.
The Member’s account was that on 22 December Year 1 she gave […] a choice between continuing therapy or becoming part of the Member’s plan to buy a house in […] and move her family and business there (the Vision). The Member said she explained, and believed […] understood that she could not continue as […] therapist if […] joined the Vision because it would be a dual relationship. Thus, the Member considered the end of the therapeutic relationship was 23 December Year 1 when […] called and accepted the offer to join the Vision.
[…] account was that the Member made the offer on 22 December Year 1 and […] accepted it on 23 December Year 1. […] said the Member had explained that she was taking a risk in offering [..] this opportunity but was putting her faith and calling ahead of the BACP’s professional standards (this prioritisation of the Member’s faith was accepted by the Member). […] said the Member had told her that if she was unhappy she could complain to the BACP. However, […] did not recall any discussion of dual relationships or being given a choice between seeing the Member as her therapist and joining the Vision. […] therefore considered the sessions annotated as appointments in her diary on 3, 9, 13, 16 and 23 January Year 2 and 13 and 27 February Year 2 to have been therapy sessions. […] recalled that she had pre-paid for a block of therapy sessions in November Year 1 and on 13 February Year 2 the Member had told her she no longer needed to pay for sessions and would be refunded for some because she was now part of the family. […] said she annotated the 13 February Year 2 appointment with this instruction and labelled the following appointment as ‘no payment’. […] said on 27 February Year 2 the Member told […] they no longer needed to meet ‘like this’ because […] was part of the family, and this was when […] considered the therapeutic relationship to have ended.
Both […] and the Member gave evidence that there was no plan to bring the therapy to an end prior to 22 December Year 1. The Member admitted there was no formal ending session on or following 22 December Year 1 and […] confirmed this, explaining that she would have recognised one as it would have been different and provided some finality.
Both […] and the Member agreed they saw each other in the Member’s therapy room in January and February Year 2. The Member said it was two friends meeting to talk about things and was different because […] entered through the Member’s house and they made drinks in the kitchen before going into the therapy room, which was only used because the lounge was filling with packing boxes. […] said that these were scheduled appointments that she recorded in her diary and brought issues to (as she had with sessions before Christmas) and that, until February Year 2, she was paying for them.
The Panel concluded that, while in the Member’s mind the therapeutic relationship was ended by […] decision on 23 December Year 1, objectively and in […] mind it had not. Without clear communication of the ending and with the removal of the professional boundaries, the Member created a situation where her understanding and that of her client, […] were diametrically opposed. The Panel found that, objectively, the advance payments for sessions beyond 22 December Year 1, the pre-booking and annotation in […] diary, the use of the Member’s therapy room and the lack of a planned or clearly communicated ending and clear and unequivocal ending session were powerful evidence of a continuing therapeutic relationship. This was further confirmed by […] and the Member’s description of the nature of the meetings and what was discussed.
The Panel found that the therapeutic relationship ended on 27 February Year 2.
Allegation 1 - UPHELD IN PART
Allegations 1.1(a)-(c) – PROVED IN PART
The Panel found that the facts alleged at allegations 1.1(a)-(c) (except for 1.1(a) ‘kissed the Complainant’) were all proved by way of […] evidence and the Member’s admissions. The Panel noted […] oral evidence that the touching was never sexual and there was ‘no kissing’ and found that element of 1.1(a) not proved.
The Panel considered whether the Member’s proved conduct took place during the therapeutic relationship (i.e. no later than 27 February Year 2 ). It noted […] account that there was a hug on 15 or 22 December Year 1 and the holding (Member sitting next to her and putting an arm around her) started at the next session; […] thought it more likely this was on 22 December Year 1 and 3 January Year 2. The Member said there was a hug (initiated by […]) on 22 December Year 1 and admitted sitting next to […] and putting an arm around her on one or more occasion when they met in January and February Year 2; but the Member considered it acceptable as they were now friends rather than client and counsellor. On either account, the Panel concluded that the touching took place before 27 February Year 2.
Both […] and the Member gave evidence that the Member invited […] to stay and meet her family on at least one occasion between Christmas Year 1 and 27 February Year 2. The Panel therefore found allegation 1.1(b) took place during the therapeutic relationship. It also found that it was not disputed the Member invited […] to visit her and her family over the Christmas Year 1 period, but […] declined.
[…] said she was invited to become a Director […] by the Member when […] was on holiday in […] in late January-early February Year 2. The Member did not dispute this. The Panel found that allegation 1(c) took place during the therapeutic relationship.
Allegation 1.2 – PROVED IN PART
The Panel then applied its above findings to paragraphs 33(a), (b) and (d) and 37 of the BACP Ethical Framework for the Counselling Professions 2016.
For the above reasons, the Panel found that, at the relevant time, […] was a client of the Member and paragraph 33 of the BACP Ethical Framework for the Counselling Professions 2016 applied to their relationship. The Panel agreed that, prior to 22 December Year 1 the Member had established and maintained professional boundaries that were consistent with the aims of working with […] and beneficial to […]. However, when she decided to place her faith and calling ahead of the BACP’s professional standards – on the Member’s evidence, an ethical dilemma she had not previously encountered or envisaged – she removed or undermined those professional boundaries fundamentally. This resulted in a blurred and confusing dual relationship for […] who, on the Member’s evidence, had unresolved therapeutic needs. This was inconsistent with the previous aims of working with […] and not beneficial to her as it put her in a position of over-dependence on the Member that led to […] suffering harm when the relationships ended. The Panel found the Member acted in contravention of paragraph 33(a) of the BACP Ethical Framework for the Counselling Professions 2016.
The Panel found it was undisputed that the Member invited […] into a relationship that was both business and personal in nature on 22 December Year 1 and again in January-February Year 2 when the Member invited […] to be a Director. The Member therefore failed to avoid dual relationships with […]. The Panel accepted that the Member believed the risks outweighed the benefits to […]; however, the Member failed to properly consider and assess the emotional and psychological risks to […] of the business and personal relationships. The Member did not discuss her ethical dilemma with her supervisor, colleagues or the BACP before entering into these dual/multiple relationships with […].
The Panel agreed that, objectively, the Member got whatever risk assessment she did fundamentally wrong and therefore failed to recognise that the significant risks to […] emotionally and psychologically outweighed the benefits. The Panel concluded the Member failed to ensure that her dual relationships with […] were consistent with their aims of working together and beneficial to […]; the Member had acted contrary to paragraph 33(b) of the BACP Ethical Framework for the Counselling Professions 2016.
The Panel found there was no evidence that the impact of the dual relationships on […] was ever reviewed between […] and the Member and accepted the Member’s evidence that she did not discuss it in supervision or with colleagues. It found the Member had acted contrary to paragraph 33(d) of the BACP Ethical Framework for the Counselling Professions 2016.
The Panel found that, at the relevant time, […] was not a former client of the Member and that the requirements of paragraph 37 did not apply to their relationship. Allegation 1.2 was found not proved in relation to a breach of paragraph 37 of the BACP Ethical Framework for the Counselling Professions 2016.
Allegation 2 - UPHELD IN PART
Allegation 2.1 – PROVED
The Panel found it was not in dispute that […] offered a loan in January Year 2, which the Member did not decline, and they mutually undertook the necessary work to put the loan in place between January Year 2 and April Year 2 when the funds were transferred. This included […] receiving independent legal advice and the structure of the loan […] being in accordance with […] lawyer’s recommendation. Accordingly, the Panel concluded the Member agreed to enter into a dual relationship (therapeutic and financial) in January Year 2 but that it didn’t come into effect until transfer of the funds in April Year 2. The Panel found that there was potential for the dual relationship to be harmful to […] and, on the Member’s on account, the Member recognised some of the risks of harm (in particular financial). It accepted the Member took steps to ensure […] would not be in financial difficulties because of the loan and ensured she saw the property and took independent legal advice before the funds were transferred. As this was over a three-month period, there was, effectively, a cooling off period for […] after she made the offer when she could have withdrawn it. […] told the Panel she had no reason to withdraw the offer in that period as the relationships were working.
The Panel concluded that the Member recognised the financial relationship could, potentially, be harmful to […] and either failed to assess or inadequately assessed the emotional and psychological risks to […] of this financial relationship and their interdependence. The Panel found allegation 2.1 proved.
Allegation 2.2 – PROVED IN PART
The Panel then applied its above findings to paragraphs 36 and 37 of the BACP Ethical Framework for the Counselling Professions 2016.
The Case Presenter submitted that BACP was offering no evidence in relation to the exploitation and abuse alleged under paragraph 36 of the ethical framework. The Panel agreed that the evidence showed a mutual desire by […] and the Member to facilitate the Member’s Vision and a shared faith and complementary calling. It found the loan was offered by […] without any evidence of a course of coercive conduct by the Member. […] was clear the Member had been entirely professional until the offer on 22 January Year 1 and […] made the offer, without prompting, the following month.
The Panel therefore accepted the BACP’s submission and found the Member’s conduct was not in breach of 36 of the BACP Ethical Framework for the Counselling Professions 2016.
In considering whether the Member had breached paragraph 37 of the ethical framework, the Panel relied on its earlier finding that the therapeutic relationship ended on 27 February Year 2. It found that the financial relationship was envisaged in January Year 2, before the end of the therapeutic relationship, but started on transfer of the funds in April Year 2 as before that point either party could have withdrawn. The Panel found the Member had accepted she acted in breach of paragraph 37 and, while she had exercised some financial caution, had not exercised caution about the emotional and psychological risks to […]. It found the Member had acted contrary to paragraph 37 of the BACP Ethical Framework for the Counselling Professions 2016.
Allegation 3 – NOT UPHELD
Allegation 3.1 – NOT PROVED
On the evidence of […] and the Member, the Panel found the Member had not allowed […] to enter personal details of the Member’s own clients, as the Member carried out this work herself. The Panel also found that […] had, in the first half of Year 3, entered personal details of other clients of […], a company of which the Member, […] and […] were the Directors, and the Member was aware […] had done this.
The Panel noted that the example forms provided by the Member were post-GDPR (General Data Protection Regulation) and […] and the Member’s evidence was that this activity took place pre-GDPR, which came into force in March […]. However, it accepted […] evidence, as data controller and administrator for […], that the notification that Directors could have access to clients’ records was on the client contract and information used at the relevant time. […] described the steps he put in place to ensure that only authorised people (the Directors) had access to the client records software (called BACPAC). He and […] confirmed he had proved […] with training on BACPAC and she required a log in to access the secure software and received data to input to BACPAC via a secure […] email address.
The Panel noted BACP’s submissions about […] being an inappropriate person as she was a former client but discounted this. The evidence available indicated she was a well-respected professional with an understanding of confidentiality and had received appropriate training. Critically, she was a Director […] and therefore authorised to access client data at the relevant time.
The Panel therefore concluded that the Member had adequately maintained client confidentiality and found allegation 3.1 not proved.
As the Panel had not found the facts alleged proved it did not need to consider Allegations 3.2 and 3.3.
Professional Misconduct – NOT PROVED
The Panel went on to consider whether the Member's actions that it had found proved in relation to Allegations 1 and 2 amounted to Professional Misconduct (as defined by the BACP Professional Conduct Procedure 2018). In doing so, the Panel considered the following criteria set out in BACP Protocol 14 for when suspension or withdrawal or membership may be an appropriate sanction:
• The Member has knowingly and deliberately behaved in a way to cause harm to the Complainant or other members of the public;
• The Member has been dishonest or lacked integrity;
• The complaint involves sexual misconduct;
• The Member has shown a blatant disregard for professional standards;
• The Member has abused their position or another’s trust;
• The harm to the Complainant is particularly severe;
• The Member has shown a complete lack of insight into, or remorse for, their behaviour; and
• Any other factors the Decision Maker considers warrant withdrawal of membership.
The Panel found that the allegations did not involve dishonesty, lack of integrity or sexual misconduct by the Member. While it acknowledged […] had suffered emotional and psychological harm, the Panel accepted she had not suffered financial harm and assessed the overall harm as falling below the above threshold. The Panel noted the shared faith and complementary calling between […] and the Member, the Member’s previous professional conduct with […] over an extended period and […] initiation of the loan offer without coercion. The Panel agreed that the evidence indicated the Member had not intended to cause […] harm, but that it resulted from an inadequate assessment of risk and failure to use the advice resources available to her such as her supervisor and the BACP. The Panel concluded the Member had knowingly decided to place her faith ahead of her professional standards; this was a poor ethical decision based on inadequate risk assessment rather than a blatant disregard for the BACP professional standards. It found that the Member had, through her submissions and oral evidence, demonstrated insight into and remorse for her behaviour.
The Panel further considered whether the value of the loan and the length of time that […] and the Member will continue to be financially linked was an ‘other factor’ that would warrant withdrawal. It decided that because steps were taken to ensure […] was not put in financial difficulties as a result of the loan, she was now accessing alternative therapy and a […] plan was in place, these factors did not indicate withdrawal or suspension of membership were warranted.
The Panel therefore concluded that the allegations proved or proved in part (Allegations 1 and 2) did not amount to Professional Misconduct as defined in the BACP Professional Conduct Procedure 2018.
Decision
The Panel was unanimous in its decision that there had NOT been Professional Misconduct. However, the Member had failed to comply with the Professional Standards, specifically that the Member had acted contrary to s 33(a), 33(b), 33(d) and 37 of the BACP Ethical Framework for the Counselling Professions 2016.
Sanction
The Panel reconvened on […] to consider what, if any, sanction was appropriate in this case. It reminded itself of its findings above and took into consideration the Member’s submissions on sanction dated […] and the testimonial of […] attached thereto. It also considered the guidance within BACP Protocol on Sanctions (PR14) and reminded itself of its powers of sanction under Article 5.12 of the BACP Professional Conduct Procedure 2018. It accepted the Clerk’s advice that, as it had not found that the Member’s conduct amounted to Professional Misconduct (as defined in the BACP Professional Conduct Procedure 2018), it should limit itself to the sanction powers of a Practise Review Process panel (i.e. not consider suspension or withdrawal of membership).
On […], the Investigation and Assessment Committee imposed an Interim Suspension Order (ISO) on the Member’s membership for a period of 12 months; it was due to expire on […]. However, the Member’s membership of the association lapsed in […]. As a result, there was no requirement for the ISO to be considered further.
The Panel observed that the Member’s submissions focused predominantly on the impact of the incidents in question and this complaint, on herself and her business; there was limited recognition and acceptance of the impact on the Complainant and the reputations of the BACP and counselling professions.
The Panel decided, had the Member still been a member of the BACP, it would have considered it appropriate and proportionate to impose the following sanction:
1. Within 4 weeks of the date of this letter, the Member is to provide the BACP with evidence of successful completion of a total of 12 hours of continuous professional development (CPD) relating to:
a. Establishing and maintaining professional boundaries and issues around dual relationships (minimum 6 hours); and
b. Understanding and assessing risk and harm in therapeutic relationships (minimum 6 hours).
2. Within 4 weeks of completing the above CPD, provide the BACP with:
a. A personal statement demonstrating specific changes/improvements in her practice that:
i. reflects on what went wrong with the Complainant, shows acceptance of responsibility for what went wrong;
ii. recognises the harm caused to the Complainant and to the reputations of the BACP and counselling professions; and
iii. details what she has changed to prevent repetition of what went wrong.
b. A genuine and sincere letter of apology that acknowledges the harm caused to the Complainant and accepts responsibility for that harm.
c. Confirmation that she has discussed her CPD, personal statement and letter of apology in supervision.
(Where ellipses [ . . . ] are displayed, they indicate an omission of text)