Safeguarding is everyone's responsibility

Teenage Mental Health Ltd (TMH) is committed to safeguarding and promoting the welfare of all children, young people, and adults at risk who engage with our services. The safety, wellbeing, and best interests of those we support are central to everything we do.

We are committed to providing a safe, supportive, and therapeutic environment where concerns regarding the welfare or safety of any child, young person, or adult at risk are recognised, responded to promptly, and managed appropriately.

Every member of staff, volunteer, student, contractor, and associate working on behalf of TMH shares an individual responsibility to remain vigilant, recognise safeguarding concerns, respond appropriately, and seek advice or report concerns without delay.

This policy should be read alongside the TMH Confidentiality Policy, Data Protection Policy, Health & Safety Policy, Equality, Diversity & Inclusion Policy, and Therapeutic Services Contract.

 
Principles
 
1: Teenage Mental Health Ltd is fully committed to providing high-quality therapeutic services to children, young people, adults, and families. Safeguarding is central to everything we do and underpins all aspects of our work.
 
2: The welfare, safety and best interests of every child or young person are our first concern. We will always act to safeguard and protect those in our care. Our Code of Practice is outlined in Appendix 1.
 
3: The best outcomes for children and young people are usually achieved in partnership with their parents, carers and families. We will always endeavour to work openly, honestly and collaboratively in this way, unless doing so would place a child or another person at increased risk of harm.
 
4: All Teenage Mental Health Ltd staff will work in accordance with current safeguarding legislation. Where we believe a child, young person or adult is at immediate risk of experiencing, or is at risk of, abuse, neglect or significant harm, we will share information with the appropriate statutory agencies in accordance with our safeguarding responsibilities.
 
5: Any help offered should be in the best of the child or family and we will work openly and flexibly with parents/carers, children and other agencies to help ensure that the support provided is appropriate, proportionate and centred upon individual need.

6: We recognise some groups of children may be most vulnerable to abuse, neglect or exploitation than others. This policy applies equally to everyone, regardless of age, disability, gender identity, race, ethnicity, religion or belief, sexual orientation, or any other protected characteristic, as reflected within our Equality, Diversity & Inclusion Policy.  

7: Safeguarding will be put in place to maximise a child’s right to protection and children will know that they have the right to:

 ·         Be safe – Every child has the right to feel safe and to know that nobody has the right to take that safety away.

·         Protect their own bodies – Children need to know that their body belongs to them and that they have the right to personal boundaries.

·         Say NO – Children should know it is okay to say no if something feels wrong, unsafe, or makes them uncomfortable. Many children are taught to comply with adults without question, and some children, particularly those with additional needs or disabilities, may be especially vulnerable to this.

·         Ask for help – Children should know they can seek help from trusted adults if they are frightened, worried, being bullied, or feel unsafe.

·         Ask for help against bullies – Children should know they can seek support from trusted adults whenever they are frightened, worried, unsafe or experiencing bullying. They should understand that bullying is never something they should face alone. Children must be reassured that no matter what happens, you will not be angry with them and that they can talk about anything to you about any incident that frightens or confuses them or makes them unhappy.

·         To be believed – When children are told to go to an adult for help they need to know that they will be believed and supported. Feeling believed is often a crucial first step in protecting a child from further harm.

·         Not to keep secrets – Teach children that some secrets should never be kept, no matter if they promised not to tell. Particularly if someone is hurting them, making them feel unsafe, or asking them to keep something secret that worries them. Child abusers known to the child often say that a kiss or touch is ‘our secret’. This confuses the child who has been taught to keep secrets.

 Teenage Mental Health Ltd Safeguarding

& Child Protection Policy

Document Information

Document Title Safeguarding and Child Protection Policy

Organisation Teenage Mental Health Ltd

Document Creator Fiona Hannah, Dylan Pomietlo

Responsible Director Clinical Director

Approved By Teenage Mental Health Ltd Directorate & DSL

Version Version 2.0

Effective From August 2026

Review Date July 2027 (or sooner where legislation, statutory guidance or organisational need requires)

Classification Public Policy

Table of Contents

Teenage Mental Health Ltd Safeguarding and Child Protection Policy

1. Introduction

2. Principles

3. Keeping Children Safe and Safer Recruitment

4. Concerns About a Member of Staff

5. Safe Environment

6. Recognising and Responding to Concerns Safeguarding Decision Making

7. Responding to Safeguarding Concerns

8. Referrals to Statutory Agencies

9. Working with Other Agencies

10. Unexpected Endings and Multi-Agency Working

Appendices

Appendix 1 - Code of Practice

Appendix 2 - Protecting Children, Young People, Adults at Risk and Staff

Appendix 3 - Recognising Abuse and Other Safeguarding Concerns

Appendix 4 - Unexpected Endings of Therapy and Safeguarding Responsibilities

Appendix 5 - Safeguarding During Remote Therapeutic Sessions

Introduction

The purpose of this child protection policy is:
 
To ensure that all children, young people and adults at risk who engage with Teenage Mental Health Ltd.’s services are safeguarded and supported within a safe therapeutic environment.

This policy sets out the responsibilities of all Teenage Mental Health Ltd staff, associates, volunteers and students in recognising, responding to, recording and reporting safeguarding concerns. It also aims to ensure that children, young people, parents, carers and professionals understand our safeguarding responsibilities, how concerns will be managed, and what they can expect from our service.

Keeping Children Safe and Safer Recruitment

Teenage Mental Health Ltd is committed to maintaining the highest standards of safeguarding through safer recruitment, appropriate supervision and ongoing professional development.

All employees, therapists, associates, volunteers and students working on behalf of TMH will be recruited in accordance with our Safer Recruitment procedures. This includes:

• Appropriate Disclosure and Barring Service (DBS) checks where required.

• Verification of identity and relevant professional qualifications.

• Satisfactory references appropriate to the role.

• Health declarations where appropriate.

• Verification of professional registration where applicable.

• A probationary period for new employees where appropriate.

All staff will receive safeguarding training appropriate to their role as part of their induction and will undertake regular safeguarding updates throughout their employment. Safeguarding forms part of ongoing clinical supervision, line management and professional development.

Teenage Mental Health Ltd will ensure that appropriate risk assessments are undertaken where necessary to support safe working practices. Appendix 2 outlines expected professional boundaries and safe practice when working with children and young people.

Concerns About a Member of Staff

If any member of staff, volunteer, student, contractor, patient, parent or visitor has concerns regarding the behaviour or conduct of a member of staff towards a child, young person or adult at risk, these concerns must be reported immediately to the Designated Safeguarding Lead or, where appropriate, the Clinical Director.

All concerns will be taken seriously, managed sensitively, and responded to promptly in accordance with this policy, relevant legislation, and local safeguarding procedures. Where appropriate, referrals will be made to the Local Authority Designated Officer (LADO), Children's Social Care, Adult Social Care, the Police, or the relevant professional regulator.

Safe environment

All premises, facilities and equipment used by Teenage Mental Health Ltd (TMH) will be appropriately maintained, risk assessed, and reviewed to ensure they remain safe, suitable and fit for purpose.

When children, young people and families attend TMH, the level, suitability and competence of staffing will always be appropriate to the needs of those accessing our services. All therapeutic work will be delivered in accordance with the current BACP Ethical Framework for the Counselling Professions, and/or the ethical framework and professional standards of the therapist's relevant professional body where applicable.

Our therapeutic approach will always take account of the age, developmental stage, abilities, communication needs and individual circumstances of each child or young person. TMH will take all reasonable steps to provide a safe, supportive and appropriately supervised therapeutic environment.

Before therapy begins, TMH will obtain all information reasonably necessary to provide safe and appropriate care. This may include emergency contact details, information regarding parental responsibility, relevant medical information, GP details, educational setting, and any other information considered necessary for safeguarding or clinical purposes. Parents and carers will also be provided with appropriate information about our service before therapy commences.

Children will only be released into the care of a person with parental responsibility, or another individual authorised in advance by the parent or person with parental responsibility, unless exceptional safeguarding circumstances require otherwise.

Some children may seek comfort or reassurance through appropriate physical contact. Any physical contact should always be child-led where possible, appropriate to the circumstances, proportionate, respectful of the child's wishes and developmental needs, and consistent with professional boundaries. Staff should always remain mindful of how physical contact may be experienced or perceived by the child or by others.

Appropriate first aid provision will be available in accordance with the TMH Health & Safety Policy. All accidents, injuries and incidents will be recorded and managed in accordance with the TMH Health & Safety Policy and Accident Reporting Procedure.

Recognising and Responding to Concerns

Many concerns about children and young people arise through everyday therapeutic work. A child may appear unusually tired, withdrawn, anxious, distressed, unwell, injured, or behave differently from their usual presentation. In many cases, these concerns can be explored through open discussion with the child, their parents or carers, and other professionals where appropriate. Advice, guidance, or additional support may be offered where needed. Where appropriate, concerns, accidents, incidents, or significant observations will be recorded in accordance with TMH's record keeping and safeguarding procedures.

Occasionally, concerns may indicate that a child or young person is experiencing harm, abuse, neglect, exploitation, or another form of significant risk. Safeguarding concerns often emerge gradually rather than through a single incident, and staff should remain professionally curious, considering the wider context of a child's presentation, behaviour, relationships, and circumstances.

It is not the role of TMH staff to investigate safeguarding concerns or determine whether abuse has occurred. Rather, our responsibility is to recognise concerns, respond appropriately, maintain accurate records, seek advice where necessary, and share safeguarding information with the appropriate agencies when there is reason to believe that a child, young person, or adult at risk may be experiencing, or be at risk of, significant harm.

Staff should remain professionally curious, recognising that seemingly isolated observations or incidents may, when viewed collectively over time, indicate a wider safeguarding concern.

Children, young people, and adults may experience harm in many different ways, including but not limited to:

The following categories reflect the recognised statutory categories of child abuse. While this policy also applies to adults at risk, safeguarding concerns affecting adults will be considered in accordance with the Care Act 2014 and other relevant legislation, alongside the same safeguarding principles outlined throughout this policy. 

The following categories reflect the recognised statutory categories of child abuse. They are intended as an overview only. Further information regarding the recognition and indicators of abuse is provided in Appendix 3.

Physical abuse

Physical abuse involves causing physical harm to a child. It may include, but is not limited to, hitting, shaking, throwing, poisoning, burning or scalding, drowning, suffocating, or otherwise causing physical harm. Physical harm may also occur where a parent or carer fabricates, exaggerates, or deliberately induces illness in a child.

Neglect

Neglect is the persistent failure to meet a child’s, or a dependant's, basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. This may include failing to meet the child’s physical needs, such as not providing adequate food, clothing, shelter or supervision, failing to protect a child from harm or danger, failing to ensure access to appropriate medical care or treatment, or failing to respond appropriately to a child's emotional needs.
 
Sexual abuse

Sexual abuse involves forcing, coercing, manipulating or enticing a child or young person to take part in sexual activities, whether or not they understand what is happening or appear to consent. The activities may involve physical contact, including penetration or non-penetrative acts including assault by penetration or non-penetrative sexual acts. They may include non-contact activities, such as involving children in looking at, or in the production of pornographic material or watching sexual activities or encouraging children to act in sexually inappropriate ways.

Emotional abuse

Emotional abuse is the persistent ill treatment of a child such as to cause severe or persistent adverse effects on a child’s emotional development and wellbeing. It may include making the child feel that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person. It may feature age or developmentally inappropriate expectations being imposed on the child. It may involve causing the child to feel frightened or in danger frequently, or the exploitation or corruption of the child. Some level of emotional abuse is involved in all types of ill treatment of a child, though it may occur alone.

Other Safeguarding Concerns

In addition to the four recognised categories of abuse, TMH recognises that children and young people may also be at risk from a range of other safeguarding concerns, including but not limited to:

• Child sexual exploitation (CSE).

• Child criminal exploitation (CCE), including County Lines.

• Online abuse, grooming and exploitation.

• Bullying and cyberbullying.

• Domestic abuse.

• Harmful sexual behaviour.

• Self-harm and suicidal ideation.

• Missing education or persistent absence from education.

• Honour-based abuse, forced marriage and female genital mutilation (FGM).

• Radicalisation and extremism.

• Parental substance misuse or significant parental mental illness.

• Contextual safeguarding concerns arising outside the family home.

Concerns about a child may come to the attention of Teenage Mental Health staff in a number of ways, including but not limited to:
 
1: Through observation of the child. A child’s behaviour, emotional wellbeing, or interactions with others may indicate that it is likely that he/she is being abused.
 
2: Through a direct or indirect disclosure made by the child or young person.
 
3: Through information may be given by parents, carers, family members, schools, health professionals, other agencies, or members of the public.
 
4: Through unexplained injuries, repeated injuries, or injuries where the explanation appears inconsistent with the presentation.  
5: Through concerns arising from the behaviour of an adult or young person, or in the way the adult or young person relates to a child, alerts them or makes them feel uncomfortable in some way.
 
6: Through observing harmful behaviour between children or young people, including bullying, harmful sexual behaviour, exploitation, coercion, or abuse.

7: Through patterns of attendance, repeated unexplained absences, sudden disengagement from therapy, or other changes which give rise to safeguarding concerns.

Barriers to Disclosure

There may be barriers to children telling, the power of relationships between adults and children should not be underestimated, nor should the deliberate and skilled way that abusers target their victims.

Children may be reluctant to disclose abuse because they:

1: Are scared because they have been threatened.
 
2: Believe they will be taken away from home.
 
3: Believe they are to blame.
 
4: Think that it happens to all children.
 
5: Feel embarrassed, ashamed or guilty.
 
6: Believe they will get themselves or someone else into trouble.
 
7: Want to protect the person(s) harming them.
 
8: Have communication difficulties or learning needs.
 
9: May not have the vocabulary or understanding to describe what happened.
10: Are afraid they won’t be believed.

11: Believe they have told maybe by dropping hints but haven’t been believed so don’t bother again.

Barriers for Adults

Safeguarding concerns should always be taken seriously. However, adults may also experience barriers which make it difficult to recognise or act upon concerns:
 
1: Sometimes it may be hard to believe what the child is saying.
 
2: It may be difficult that the suspicion may be about some that is known.
 
3: ‘The fear of getting it wrong’.
 
4: The fear of what consequences there may be for ‘getting it wrong’ for the child, for the family, and for themselves.
 
5: Misunderstanding the role of safeguarding services or fearing that intervention will automatically lead to family separation.
 
6: Assuming that somebody else will take responsibility.
 
7: Simply do not want to be involved.
 
8: Do not have the necessary information on what to do or who to contact.

Safeguarding Decision Making

Teenage Mental Health Ltd is committed to ensuring that all safeguarding concerns are considered carefully, proportionately, and always in the best interests of the child, young person, or adult at risk.

Safeguarding decisions made by TMH are guided by current legislation, statutory guidance, professional ethical frameworks, local safeguarding procedures where applicable, and our own clinical judgement and safeguarding policies. We recognise that different organisations and professionals may reach different conclusions regarding safeguarding thresholds or the most appropriate course of action. Where appropriate, TMH will seek consultation, share information, and work collaboratively with other agencies to promote the safety and wellbeing of those we support.

Where there is uncertainty regarding Teenage Mental Health Ltd.’s safeguarding responsibilities, decision-making processes, or thresholds for referral, individuals or organisations are encouraged to seek clarification from us before engaging with our services.

The welfare and safety of the child, young person, or adult at risk will always remain our overriding consideration.

Responding to Safeguarding Concerns

It is not the role of Teenage Mental Health staff to investigate allegations or determine whether abuse has occurred. Our responsibility is to recognise concerns, respond appropriately, maintain accurate records, seek advice where necessary, and share safeguarding information with the appropriate statutory agencies where there is reason to believe that a child, young person, or adult at risk may be experiencing, or be at risk of, abuse, neglect, exploitation, or significant harm.
All safeguarding concerns will be considered carefully, responded to promptly, and managed in accordance with this policy and the professional responsibilities of Teenage Mental Health Ltd.

Where a member of staff has a safeguarding concern, they should:

·         Take immediate action where necessary. If a child, young person, or adult is believed to be at immediate risk of harm, appropriate emergency action should be taken without delay, including contacting the Emergency Services (999) where necessary. Where concerns are less immediate but safeguarding action is required, advice should be sought from the Designated Safeguarding Lead (DSL), who will consider the most appropriate safeguarding response in accordance with this policy and current statutory guidance.

·         Listen, observe and reassure. Where concerns arise through observation or disclosure, staff should remain calm, listen carefully, avoid asking leading questions, and reassure the individual that they have done the right thing by speaking up. Staff should never promise absolute confidentiality where safeguarding concerns exist.

·         Record the concern accurately. As soon as reasonably practicable, staff should make a clear, factual record of the concern, including the date, time, those present, the exact words used where possible, observations made, and any actions already taken.

·         Report the concern promptly. All safeguarding concerns should be reported to the Designated Safeguarding Lead (DSL) or, in their absence, the Clinical Director or another appropriate senior member of staff as soon as reasonably practicable and, wherever possible, on the same working day complete the appropriate safeguarding documentation. All safeguarding concerns must be recorded using TMH's safeguarding recording procedures.

Initial safeguarding concerns may be discussed with an appropriate Clinical Peer, Senior Therapist, Line Manager, or other suitably experienced member of the Clinical Team where immediate statutory intervention is not considered necessary. This allows concerns to be explored, reflected upon, and managed proportionately whilst ensuring that appropriate clinical oversight is maintained.

Where concerns do not initially meet the threshold for referral to statutory safeguarding agencies, they should not be dismissed. They should be appropriately recorded, monitored where necessary, and brought to the attention of senior clinical staff. Any uncertainty regarding safeguarding thresholds or the appropriate course of action should always be discussed with the Designated Safeguarding Lead (DSL) or a member of the Directorate Team.

The Designated Safeguarding Lead (DSL) and the owning Clinical Director hold overall responsibility for safeguarding decision-making within Teenage Mental Health Ltd. They retain the final responsibility for determining safeguarding actions, referrals, information sharing, and risk management in accordance with current legislation, statutory guidance, professional ethical frameworks, and TMH safeguarding policies.

Where either the DSL or the owning Clinical Director is unavailable, responsibility will pass to another member of the Directorate Team to ensure that safeguarding decisions are not unnecessarily delayed.

Where no external referral is considered necessary, the rationale for this decision, together with any ongoing monitoring, review arrangements, or agreed therapeutic interventions, will be clearly documented.

Where safeguarding concerns can be appropriately managed within TMH, this may include continued therapeutic work, increased monitoring, consultation with parents or carers where appropriate, liaison with other professionals, or planned review discussions. All safeguarding decisions remain subject to ongoing review and may be escalated should new information become available or the level of risk change.

Referrals to Statutory Agencies

Where the Designated Safeguarding Lead (DSL), Clinical Director, or another member of the Directorate Team determine that the threshold for external safeguarding intervention has been met, a referral will be made to the appropriate statutory agency without unnecessary delay.

Depending upon the nature of the concern, this may include:

• Children's Social Care.

• Adult Social Care.

• The Police.

• The Local Authority Designated Officer (LADO).

• NHS Mental Health Services.

• Other relevant safeguarding agencies.

A safeguarding referral should contain all relevant factual information available at the time. However, referrals should never be delayed because every detail is not yet known or documented. Additional information can be shared with the receiving agency as it becomes available.

All safeguarding concerns, discussions, decisions, referrals, advice received, and actions taken will be recorded using TMH's safeguarding recording procedures and retained in accordance with our Record Keeping, Confidentiality and Data Protection Policies.

Where appropriate, TMH will remain involved following a safeguarding referral, continuing to provide therapeutic support whilst working collaboratively with other professionals, provided this remains clinically appropriate and in the best interests of the child, young person, or adult at risk.

Parents, carers, and where appropriate the child or young person, will ordinarily be informed before a safeguarding referral is made. However, this will not occur where doing so may place someone at increased risk of harm, prejudice a criminal investigation, or otherwise conflict with statutory safeguarding guidance.

Working with Other Agencies

Teenage Mental Health Ltd is an independent provider of psychological therapy and counselling services. We work collaboratively with families, schools, NHS services, Local Authorities, Children's Social Care, Adult Social Care, General Practitioners, and other professionals where appropriate to promote the wellbeing and safety of those accessing our services.

Our therapeutic services are voluntary. Families choose whether to engage with our service unless attendance forms part of another lawful arrangement. Where another agency recommends or supports a referral to TMH, the decision to engage with therapy ordinarily remains with the individual or those holding parental responsibility.

We remain committed to working openly, honestly and collaboratively with parents, carers and families wherever it is safe and appropriate to do so. We believe that positive outcomes are most often achieved through respectful partnership working. However, where sharing information with parents or carers would place a child, young person or another person at increased risk of harm, TMH will act in accordance with current legislation, statutory guidance, professional ethical frameworks, and this Safeguarding Policy.

TMH recognises that safeguarding thresholds, operational practices, and approaches to risk management may differ between organisations. While we will always work collaboratively with partner agencies wherever possible, safeguarding decisions made by TMH will be based upon current legislation, statutory guidance, professional ethical frameworks, our own safeguarding policies, and the best interests of the child, young person, or adult at risk. Where clarification regarding TMH's safeguarding responsibilities, decision-making processes, or referral thresholds is required, we encourage professionals, patients, parents, carers, and partner organisations to seek advice from us.

TMH is an independent therapeutic service and does not undertake statutory safeguarding investigations or complete statutory assessments on behalf of Children's Social Care or other agencies. Our role is to provide therapeutic support, contribute relevant clinical information where appropriate, and fulfil our safeguarding responsibilities through the recognition, recording, sharing and escalation of safeguarding concerns.

Where TMH is working alongside other agencies, the respective roles, responsibilities, information-sharing arrangements, and expectations of each organisation should be clearly understood wherever reasonably practicable.

 Unexpected Endings and Multi-Agency Working

The unexpected or unplanned ending of therapy may, in certain circumstances, require TMH to notify other professionals or agencies involved in a child's, young person's, or adult at risk's care.

This may be necessary where another organisation could reasonably believe that TMH continues to be providing therapeutic support when this is no longer the case, or where the ending of therapy may alter an existing safeguarding or support plan.

The purpose of sharing this information is not to disclose confidential therapeutic material, but to ensure that professionals involved in the individual's care have an accurate understanding of the support currently available. This helps reduce the risk of children, young people, or adults at risk inadvertently falling between services or gaps in safeguarding arrangements.

Any information shared will always be proportionate, limited to that which is necessary, and managed in accordance with TMH's Confidentiality Policy, Data Protection Policy, and statutory safeguarding responsibilities.

Safeguarding is not simply a procedure to be followed when concerns arise. It is a continual attitude of professional curiosity, compassion, responsibility and accountability that underpins every aspect of the work undertaken by Teenage Mental Health Ltd.

Every member of staff shares responsibility for creating a culture in which children, young people and adults at risk are heard, respected, protected and supported.

Through thoughtful clinical practice, collaborative working and proportionate decision-making, we seek to promote the welfare, dignity and best interests of every individual who engages with our services.

Appendix 1
 
Code of Practice

Teenage Mental Health will:

• Treat all children and young people with respect

• Provide an example of good conduct you wish others to follow

• Respect a young person’s right to personal privacy / encourage young people and adults to feel comfortable and caring enough to point out attitudes or behaviours they do not like.

• Recognise that well-intentioned actions may be interpreted differently by others and always act in a manner that can be openly explained and professionally justified. Recognise that special caution is required when you are discussing sensitive issues with children or young people.

• Challenge unacceptable behaviour and report all allegations/suspicions of abuse.

• Maintain clear, appropriate and professional boundaries at all times.

• Remain professionally curious where concerns arise regarding a person's welfare or safety.

• Report safeguarding concerns, allegations or suspicions promptly and in accordance with this policy.

• Work in accordance with applicable professional ethical frameworks, TMH policies, and current safeguarding legislation.

You must not:

• Have inappropriate physical or verbal contact with children or young people

• Form relationships that could compromise, or reasonably appear to compromise, professional boundaries.

• Allow yourself to be drawn into inappropriate attention seeking behaviour/make suggestive or derogatory remarks or gestures in front of children and young people.

• Jump to conclusions about others without checking facts

• Either exaggerate or trivialise child abuse issues

• Show favouritism to any individual or provide preferential treatment that cannot be professionally justified.

• Believe ‘it could never happen to me’

• Take a chance when common sense, policy, or practice suggests another more prudent approach

• Assume that safeguarding concerns could never arise within TMH or involve someone known to them

• Engage in behaviour that could reasonably be perceived as intimidating, exploitative, discriminatory or abusive.

• Ignore concerns because they appear minor in isolation.

• Take unnecessary risks where professional judgement, safeguarding policy or common sense indicate a safer course of action.

Appendix 2
 
Protecting Children and Staff
 
A: Contact with children
 
Staff should always maintain appropriate professional boundaries when working with children, young people and adults at risk. Wherever reasonably practicable, situations which may place either the patient or member of staff at unnecessary risk should be avoided.

As a general principle, staff should not:

• Spend excessive amounts of time alone with children, away from others.

• Take children alone in a car on journeys, however short.

• Take your children to your home.

• Arrange contact with patients outside agreed professional boundaries unless clinically justified and authorised.

• Communicate with patients through personal social media accounts or personal messaging platforms.

When it is unavoidable that these things happen, they should only occur with the full knowledge and consent from a member of the directorate team or DSL, and where appropriate the child’s parent or carer.
 
B: Relationships with children

You should make it clear to all your staff in your organisation that they should never:

• Engage in rough physical games including horse-play.

• Engage in sexually provocative games or behaviour.

• Form relationships which blur professional boundaries.

• Use sexually suggestive, discriminatory, intimidating, humiliating or derogatory language.

• Let allegations a child makes be ignored or unrecorded.

• Carry out tasks of a personal nature which the child or young person can reasonably undertake themselves, unless required because of disability, illness or an emergency.

• Accept or request gifts, money or other benefits that could reasonably compromise, or be perceived to compromise, professional boundaries. Any gift offered by a current or former patient or family should be discussed with a Clinical Peer, Senior Therapist, the Designated Safeguarding Lead (DSL), or a member of the Directorate Team before acceptance wherever reasonably practicable. As a general principle, only modest tokens of appreciation offered at the planned ending of therapy should be considered acceptable.

• Share personal contact details with patients or families unless authorised as part of their professional role.

C: Restraint

Physical Intervention

Teenage Mental Health Ltd does not provide physical intervention or restraint as part of its routine therapeutic practice.

Where there is an immediate risk of serious harm to a child, young person, adult at risk, member of staff or another person, staff should prioritise de-escalation wherever possible and seek emergency assistance where appropriate.

Physical intervention should only ever occur where it is immediately necessary to prevent serious injury and where no safer alternative is available. Any such incident must be proportionate, reasonable, lawful, and recorded immediately in accordance with TMH's Incident Reporting and Safeguarding Procedures.

Following any physical intervention, the incident should be reviewed by the Designated Safeguarding Lead and Directorate Team.

This reflects reality.
 
D: Intimate care

Intimate care should always be carried out or supported by parents or carers wherever possible.

Occasionally, a child or young person may require assistance with personal care because of age, disability, illness or an unforeseen circumstance.

Any personal care should:

• be provided only where necessary;

• respect the dignity and wishes of the individual;

• be proportionate to the situation;

• wherever possible be undertaken with the knowledge of parents or carers; and

• be appropriately recorded where significant assistance has been provided.

Parents or carers should be informed as soon as reasonably practicable where personal care has been provided unexpectedly.

E: Relationships of trust

‘The inequality at the heart of a relationship of trust should be ended before any sexual relationship begins’ Caring for Young People and the Vulnerable? Guidance preventing abuse of trust (Home Office 1999).

This statement recognises that genuine relationships do occur between the different levels of staff and participants in a group but that no intimate relationship should begin whilst the member of staff is in a ‘position of trust’ over them.
 
All TMH staff occupy positions of trust when working with children and young people.

Staff must recognise the professional responsibility that accompanies this position and ensure appropriate professional boundaries are maintained at all times.

Relationships which exploit, abuse or compromise that position of trust are wholly unacceptable and may constitute serious professional misconduct and, in some circumstances, a criminal offence.

The existence of legal consent to sexual activity does not remove safeguarding responsibilities or professional boundaries.

Staff must never enter into intimate or sexual relationships with current patients or any individual where a professional relationship continues to exist.

In certain circumstances the ‘abuse of trust’ is a criminal offence under the Sexual Offences Act 2003 and other relevant legislation.

Supervision of Children and Adults at Risk

Appropriate supervision is one of the most effective ways of safeguarding children, young people and adults at risk whilst they are attending or participating in services provided by Teenage Mental Health Ltd.

The level of supervision required will always depend upon the individual's age, developmental stage, presentation, vulnerabilities, independence, and the nature of the therapeutic activity being undertaken.

General Supervision

• Children, young people and adults at risk should be appropriately supervised whilst attending TMH services, according to their individual needs and circumstances.

• Staff should know, wherever reasonably practicable, who is present within the building, who is responsible for their supervision, and any known safeguarding or clinical risks requiring additional consideration.

• Patients should not ordinarily be left unsupervised unless this forms part of an agreed therapeutic intervention, has been appropriately considered, or is otherwise deemed safe and appropriate by the responsible clinician.

• Where parents or carers leave a child or young person within TMH premises, responsibility for supervision remains with the parent or carer unless alternative arrangements have been explicitly agreed with TMH.

• TMH recognises that, on occasion, young people under the age of 16 may attend appointments independently where this has been agreed with those holding parental responsibility, forms part of an agreed care plan or is otherwise unavoidable. In such circumstances, staff will take reasonable steps to promote their safety whilst they are on the premises.

• Where children, young people or adults at risk remain in reception or other communal areas before or after appointments, staff should remain aware of their presence and respond appropriately should any safeguarding, welfare or behavioural concerns arise.

• Children, young people and adults at risk should never knowingly be left in circumstances where there is a foreseeable risk to their safety or wellbeing.

Therapeutic Activities

Where TMH undertakes therapeutic work outside the traditional consulting room environment, appropriate planning should be undertaken beforehand.

• Appropriate risk assessments should be completed where required.

• Parents, carers or those holding parental responsibility should be informed where appropriate.

• Staff should ensure that suitable supervision and safeguarding arrangements are in place before activities commence.

• Any departure from usual therapeutic practice should be clinically justified and capable of being openly explained and professionally defended.

• Where activities are disrupted or circumstances change unexpectedly, staff should reassess any risks and make appropriate alternative arrangements to maintain safety.

Staff Responsibilities

All staff should:

• Exercise reasonable professional judgement at all times.

• Remain professionally curious regarding any changes in presentation, behaviour or circumstances.

• Seek advice whenever they are uncertain about appropriate supervision arrangements.

• Report and record any safeguarding or supervision concerns promptly in accordance with this policy.

Appendix 3

Definitions of Abuse

Recognising Child Abuse

Abuse, neglect and exploitation can affect any child, young person or adult at risk, regardless of age, gender, disability, ethnicity, religion, culture, sexual orientation or family circumstances.

Recognising child abuse is not easy, and it is not your responsibility to decide whether or not child abuse has taken place or if a child is significantly at risk. You do, however, have a responsibility to act if you have a concern. The following information is not designed to turn you into an expert, but it will help you to be more alert to the signs of possible abuse.

The presence of one or more indicators does not necessarily mean abuse has occurred. Equally, the absence of obvious signs should not automatically lead to concerns being discounted. Safeguarding concerns often develop gradually and may only become apparent when a wider pattern of information is considered over time.

Teenage Mental Health Ltd recognises that safeguarding requires careful consideration of the individual, their circumstances, and the wider context in which concerns arise. Decisions should always be proportionate, evidence-informed, and made in the best interests of the child, young person or adult at risk.

Physical abuse

Most children will collect cuts, bruises and minor injuries throughout everyday life. These are most commonly found on bony areas of the body such as elbows, knees and shins and are often consistent with normal play and development.

Some injuries, however, may be more difficult to explain or appear inconsistent with the explanation provided. Particular concern may arise where injuries are repeated, occur in unusual locations, appear in various stages of healing, or where there is an unexplained delay in seeking appropriate medical attention. It is important to recognise that bruising and injuries may present differently depending upon a person's skin tone, age or medical conditions, and specialist advice may sometimes be required.

Physical abuse may also become apparent through changes in a child's emotional presentation, relationships or behaviour. In many cases these changes are subtle and develop gradually over time rather than appearing following a single incident.

Possible physical signs may include:

• Unexplained bruising, marks or injuries.

• Injuries inconsistent with the explanation provided.

• Bruising reflecting hand marks, finger marks or grip marks.

• Bruising to areas where accidental injuries are uncommon, such as the cheeks, ears, neck, upper arms, thighs, abdomen or back.

• Burns, including cigarette burns or immersion burns.

• Bite marks.

• Fractures or repeated unexplained injuries.

• Scalds.

• Frequent attendance with injuries.

• Delayed presentation for medical treatment.

Changes in behaviour or emotional presentation may include:

• Fear of parents or carers being approached.

• Fear of going home or of particular adults.

• Hypervigilance or exaggerated startle responses.

• Flinching when approached or touched.

• Aggressive behaviour or frequent emotional outbursts.

• Withdrawal or becoming unusually quiet.

• Anxiety or persistent worry.

• Depression or low mood.

• Reluctance to get changed or wearing clothing that conceals injuries.

• Running away from home.

• Difficulty trusting adults.

• Increased emotional dysregulation.

• Sudden deterioration in school attendance or engagement.

• Increased perfectionism or excessive compliance.

• Behaviour that appears unusually watchful or fearful.

Sexual Abuse

Sexual abuse affects children and young people of all ages, genders and backgrounds. Those responsible are most commonly people already known to the child or family and frequently occupy positions of trust.

Usually, in cases of sexual abuse it is the child’s behaviour which may cause you to become concerned, although physical signs can also be present. In all cases, children who talk about sexual abuse do so because they want it to stop. Children don’t always disclose abuse immediately and may only reveal small pieces of information over time. Every disclosure, however uncertain or incomplete, should be listened to carefully and taken seriously.  

Possible physical signs may include:

• Pain, soreness or itching in the genital or anal area.

• Bruising or bleeding around the genital or anal area.

• Sexually transmitted infections.

• Vaginal discharge or recurrent infections.

• Pregnancy.

• Stomach pain with no obvious medical explanation.

• Pain or discomfort when walking or sitting.

• Recurrent urinary infections.

Changes in behaviour or emotional presentation may include:

• Sudden changes in behaviour or personality.

• Withdrawal or isolation.

• Anxiety or panic.

• Nightmares or sleep disturbance.

• Fear of specific people or places.

• Running away from home.

• Sexual knowledge beyond developmental expectations.

• Sexualised language, drawings or behaviour.

• Bedwetting or regression.

• Eating difficulties, including overeating or restrictive eating.

• Self-harm or suicidal thoughts.

• Saying they have secrets they cannot tell.

• Substance misuse.

• Sudden unexplained access to money or gifts.

• Online secrecy or concerns regarding online relationships.

• Difficulty maintaining appropriate boundaries.

• Dissociation or appearing emotionally detached.

• Persistent shame, guilt or self-blame

  Neglect

Neglect is often the most difficult form of abuse to recognise because it usually develops over time rather than through a single event. It may affect every aspect of a child's physical health, emotional wellbeing and development, whether it is a single event or continued over time.

Neglect may arise through the persistent failure to meet a child's physical, emotional, educational or medical needs. Emotional neglect can be particularly difficult to identify and may present through the absence of appropriate emotional warmth, responsiveness or support.

Possible physical signs of abuse may be:

• Persistent hunger or food-seeking behaviour.

• Poor hygiene.

• Being consistently dirty or unwashed.

• Inappropriate clothing for the weather.

• Poor growth or being significantly underweight.

• Untreated medical or dental conditions.

• Repeated failure to attend medical appointments.

• Persistent tiredness or fatigue.

Changes in behaviour which can also indicate neglect may include:

• Frequently appearing tired.

• Poor concentration.

• Developmental delay.

• Low self-esteem.

• Emotional withdrawal.

• Excessive independence for their age.

• Taking on caring responsibilities beyond their years.

• Few or no friendships.

• Poor school attendance.

• Frequently mentioning being left alone or unsupervised.

• Difficulty trusting adults.

• Reduced emotional expression or appearing emotionally "flat".

• Feeling responsible for meeting the needs of parents or siblings.

• Persistent anxiety regarding home life.  Frequently appearing tired.

Persistent anxiety regarding home life. The examples and indicators described within this appendix are intended to support awareness and should not be regarded as definitive evidence that abuse, or neglect has occurred. Many children and young people may display one or more of these indicators for a variety of reasons unrelated to safeguarding, including bereavement, family separation, the birth of a sibling, parental conflict, physical illness, neurodevelopmental differences, significant life events, or emotional and mental health difficulties. Equally, some children experiencing abuse or neglect may display very few outward signs.

Safeguarding at Teenage Mental Health Ltd is always centred upon the welfare, safety and best interests of the child or young person. Whilst concerns must always be recognised, explored and, where appropriate, acted upon, safeguarding decisions are made thoughtfully, proportionately and with careful consideration of the wider context, the available information, and the needs of everyone involved. Wherever reasonably possible, we seek to work openly and collaboratively with children, young people, parents, carers and partner agencies, recognising that supportive relationships are often fundamental to achieving safe and positive outcomes.

No single indicator should be considered in isolation. Safeguarding concerns should always be viewed alongside the individual's presentation, history, relationships, developmental stage and circumstances. Where uncertainty remains, concerns should be discussed and reviewed in accordance with this policy rather than dismissed or ignored.

Facts about abuse:

• Most children who experience abuse are harmed by someone they know, trust or have an established relationship with.

• Many incidents of child abuse, neglect and exploitation are never reported. As a result, recorded cases are likely to represent only a proportion of the true prevalence.

• Disabled children and young people, and those with additional needs, are recognised as being at increased risk of abuse, neglect and exploitation. They may be more reliant on others for care, experience communication barriers, or find it more difficult to disclose concerns.

• False allegations of abuse made by children are uncommon. Many children delay disclosing abuse, minimise what has happened, or later withdraw allegations due to fear, shame, guilt, pressure, or loyalty towards the person harming them.

• Children who disclose abuse often fear the consequences of telling someone, including not being believed, getting into trouble, or making the situation worse for themselves or those they care about.

• Abuse, neglect and exploitation can have profound and long-lasting effects upon a child's emotional, psychological, physical, social and educational development. Without appropriate support, these effects may continue well into adulthood.

• Children's Social Care will only consider removing a child from their family where this is considered necessary, proportionate and lawful, and where there is reason to believe the child is suffering, or is likely to suffer, significant harm. Wherever possible, support is provided to help families remain safely together.

• Child sexual abuse occurs across all communities, cultures, ethnicities, religions, professions and socio-economic groups.

• Child sexual abuse is an abuse of power, trust and vulnerability. Responsibility always lies with the person causing the abuse.

• In many reported cases of child sexual abuse, the person responsible is already known to the child or family.

• Whilst the majority of identified perpetrators of child sexual abuse are male, women can also sexually abuse children. Safeguarding concerns should never be dismissed based upon assumptions about a person's gender.

• A child is never responsible for the abuse they experience.

• There are often no obvious physical or behavioural signs that abuse has occurred. Safeguarding concerns should therefore be considered in the wider context of the child's presentation, history and circumstances.

• Bullying, including cyberbullying, remains one of the most common concerns reported by children and young people.

• Bullying can have significant short and long-term emotional, psychological and physical consequences, including anxiety, depression, self-harm, reduced self-esteem and school avoidance.

• In some circumstances, persistent bullying may contribute to suicidal thoughts or behaviours.

• Children living in households where there is domestic abuse may experience significant emotional harm, anxiety, trauma and, in some cases, physical injury, whether or not they witness the abuse directly.

Parental mental illness, problematic alcohol or drug use, domestic abuse, or other significant family difficulties do not automatically place a child at risk of abuse. However, where these factors affect parenting capacity or a child's safety, wellbeing or development, they should be carefully considered as part of any safeguarding assessment.

Other Safeguarding Concerns

Teenage Mental Health Ltd also recognises that safeguarding concerns extend beyond the four recognised categories of child abuse and may include:

• Child Sexual Exploitation (CSE).

• Child Criminal Exploitation (CCE), including County Lines.

• Domestic abuse.

• Online abuse, grooming and exploitation.

• Bullying and cyberbullying.

• Harmful sexual behaviour.

• Honour-based abuse.

• Forced marriage.

• Female Genital Mutilation (FGM).

• Radicalisation and extremism.

• Modern slavery and human trafficking.

• Missing education or persistent absence from education.

• Self-harm and suicidal ideation.

• Parental mental illness.

• Parental substance misuse.

• Young carers.

• Contextual safeguarding concerns.

These concerns should always be considered alongside the individual's presentation, circumstances, developmental stage, and any other relevant information.

Behaviour as Communication

Teenage Mental Health Ltd recognises that children and young people often communicate distress through changes in behaviour, relationships, emotional regulation, engagement, attendance, or presentation rather than through direct disclosure.

Such changes do not necessarily indicate abuse or neglect. However, they should encourage thoughtful reflection, appropriate enquiry, and, where necessary, further discussion or assessment. Safeguarding concerns should always be considered in the wider context of the individual's life, experiences, strengths and vulnerabilities.

Appendix 4

Unexpected Endings of Therapy and Safeguarding Responsibilities

Teenage Mental Health Ltd recognises that all therapeutic work reaches an ending. Many endings are planned, collaborative and form an important part of the therapeutic process. Others may occur unexpectedly or prematurely for a variety of reasons, including changes in personal circumstances, practical difficulties, emotional factors, disengagement from therapy, family decisions, safeguarding concerns, or other unforeseen events.

Unexpected therapeutic endings are, in themselves, often clinically meaningful. Whilst many occur for entirely understandable or practical reasons, the circumstances surrounding an ending may sometimes provide important information regarding a person's welfare, emotional wellbeing, engagement with support, or wider safeguarding needs.

The majority of therapeutic endings, whether planned or unexpected, will not require information to be shared outside of Teenage Mental Health Ltd. However, where the nature, timing or circumstances surrounding an ending give rise to safeguarding or welfare concerns, TMH may have a professional or legal duty to share limited information with appropriate individuals or statutory agencies.

Teenage Mental Health Ltd remains fully committed to maintaining confidentiality in accordance with our Confidentiality Policy, applicable data protection legislation, and the professional ethical frameworks governing our services. However, confidentiality is not absolute and may be lawfully overridden where safeguarding responsibilities, legal obligations, or the prevention of serious harm require information to be shared.

This reflects our continuing duty of care and our responsibility to help ensure that children, young people and adults at risk do not inadvertently fall between services where safeguarding, welfare or mental health concerns remain.

Examples of circumstances where TMH may consider sharing limited safeguarding information include, but are not limited to:

·         A child, young person or adult at risk is unexpectedly withdrawn from therapy where this gives rise to new or increased safeguarding or welfare concerns.

·         Therapy ends suddenly whilst significant safeguarding concerns remain unresolved.

·         Repeated unexplained absences, persistent disengagement, or a pattern of non-attendance creates concerns regarding the individual's safety, wellbeing, or continued access to appropriate care.

·         A child or young person repeatedly expresses a wish to continue therapy, but attendance is consistently prevented for reasons that appear to place the child's therapeutic, emotional or mental health needs secondary to the priorities or preferences of others, and this raises safeguarding or welfare concerns.

·         A parent or carer repeatedly fails to prioritise a child's identified therapeutic or mental health needs without reasonable explanation, particularly where this forms part of a wider pattern of unmet needs or professional concern.

·         Another professional or organisation may reasonably believe that TMH continues to be providing therapeutic support when this is no longer the case, and this misunderstanding may adversely affect safeguarding, welfare, educational planning or wider care arrangements.

·         TMH believes another agency should review its own safeguarding, welfare, educational or support arrangements following the unexpected ending of therapy or significant changes in engagement.

·         A child, young person or adult at risk makes disclosures, expresses concerns, or demonstrates a significant deterioration in presentation shortly before an unexpected ending that indicates further safeguarding consideration may be required.

Where information is shared, it will always be:

• Necessary and proportionate.

• Limited to the minimum information required.

• Shared only with appropriate individuals or agencies.

• Recorded appropriately within TMH's clinical and safeguarding records.

• Consistent with current legislation, statutory guidance, professional ethical frameworks, and TMH policies.

Wherever it is safe, lawful and appropriate to do so, TMH will seek to discuss information sharing with the child, young person, parent or carer before information is disclosed. However, this may not be possible where doing so could place someone at increased risk of harm, prejudice a safeguarding enquiry or criminal investigation, or otherwise conflict with our safeguarding or legal responsibilities.

Every safeguarding decision relating to an unexpected therapeutic ending will be considered individually. Decisions will take into account the wider context, the available information, the views and wishes of those involved where appropriate, the professional judgement of TMH clinicians, and, above all, the welfare and best interests of the child, young person or adult at risk.

Appendix 5

Safeguarding During Remote Therapeutic Sessions

Teenage Mental Health Ltd recognises that remote therapy, whether delivered by telephone or secure video consultation, can provide an effective and accessible way of delivering psychological support. Whilst remote working offers many benefits, it also presents additional safeguarding, confidentiality and risk management considerations that require careful planning and professional judgement.

Remote therapy will only be offered where it is considered clinically appropriate, therapeutically beneficial, and safe for the individual concerned. Decisions regarding the suitability of remote working will always remain subject to ongoing review throughout the course of therapy.

Before commencing a remote appointment, therapists will, wherever reasonably practicable:

• Confirm the identity of the patient.

• Confirm the patient's current location and an appropriate contact telephone number in case the session is unexpectedly interrupted, or emergency assistance becomes necessary.

• Establish, where appropriate, whether anyone else is present within the property or may reasonably be able to hear the conversation.

• Consider whether the environment appears sufficiently private, safe and appropriate for therapeutic work.

• Review whether remote therapy continues to be clinically appropriate for the individual's current presentation and level of risk.

• Confirm that the patient understands the limitations of remote working, including what will happen should the session be interrupted, should safeguarding concerns arise, or should emergency assistance become necessary.

Teenage Mental Health Ltd primarily uses WhatsApp for remote video consultations where appropriate. WhatsApp benefits from end-to-end encryption, helping to protect the confidentiality and security of therapeutic communications. Alternative platforms may be used where clinically appropriate or where individual circumstances require.

Where safeguarding concerns arise during a remote session, therapists will respond in accordance with this Safeguarding Policy. This may include pausing or ending the session, contacting a parent or carer where appropriate, consulting with a Clinical Peer, Senior Therapist, the Designated Safeguarding Lead (DSL), Clinical Director, or another member of the Directorate Team, contacting emergency services, or sharing safeguarding information with appropriate statutory agencies where legally, ethically, or professionally required.

Where concerns arise that a patient can no longer safely or effectively engage in remote therapy, TMH may recommend that future appointments take place face-to-face or that alternative arrangements for support are considered.

Additional Safeguarding Considerations During Remote Therapy

Therapists will remain mindful of the additional safeguarding considerations that can arise when working remotely, including but not limited to:

• A patient being unable to speak freely because another person is present.

• A patient appearing to be coached, monitored or influenced by another individual.

• Domestic abuse, coercive control, exploitation or other safeguarding concerns that may be less visible than during face-to-face work.

• Difficulties accurately assessing emotional presentation, risk or environmental factors remotely.

• Sudden loss of communication during a session where significant safeguarding concerns have been identified.

• The use of technology in a manner that compromises privacy, confidentiality or the therapeutic process.

Where concerns arise regarding the safety, privacy or effectiveness of remote therapy, therapists will exercise professional judgement to determine whether the session should continue, be rearranged, converted to a face-to-face appointment, or whether safeguarding procedures should be initiated.

Confidentiality During Remote Therapy

Patients are encouraged to participate in remote appointments from a private and appropriate environment wherever reasonably practicable and to minimise interruptions wherever possible.

Teenage Mental Health Ltd cannot guarantee the privacy of the environment chosen by the patient and encourages patients, parents and carers to carefully consider who may be able to hear, observe or influence the therapeutic conversation.

Neither therapists nor patients should record therapy sessions without the prior knowledge and explicit agreement of all parties and the express authorisation of Teenage Mental Health Ltd.

Clinical Observations During Remote Therapy

Remote therapy provides a different therapeutic perspective from face-to-face work and may occasionally offer clinically relevant information regarding an individual's environment, relationships, presentation or wellbeing.

Therapists will remain professionally curious regarding any significant changes in presentation, interruptions, reluctance to speak openly, environmental observations or interactions with others that may become apparent during remote sessions. Such observations will always be considered thoughtfully, proportionately and alongside all other available information. They should not automatically be interpreted as evidence of safeguarding concerns but may contribute to the overall clinical formulation and safeguarding assessment where appropriate.

As with all safeguarding decisions undertaken by Teenage Mental Health Ltd, any concerns arising during remote therapy will be considered individually, proportionately and in the wider context of the individual's presentation, circumstances, therapeutic relationship and available information. The welfare and best interests of the child, young person or adult at risk will always remain the overriding consideration.

Working with Patients Located Outside the United Kingdom

Teenage Mental Health Ltd recognises that some patients may be temporarily or permanently located outside the United Kingdom whilst receiving remote therapeutic services.

Before commencing, or continuing, therapy where a patient is ordinarily resident or physically located outside the United Kingdom, the responsible therapist, together with Teenage Mental Health Ltd where appropriate, will consider whether it is lawful, safe, clinically appropriate and professionally appropriate to provide therapy within that jurisdiction.

This assessment should include, where reasonably practicable:

• Whether the therapist's professional indemnity insurance provides appropriate cover for work within the country or jurisdiction in which the patient is located.

• Whether local laws, professional regulations or licensing requirements permit the provision of remote psychological therapy by a UK-based therapist.

• The patient's exact location whilst receiving therapy and any relevant changes to this during the course of treatment.

• Appropriate emergency contacts and the availability of local emergency services.

• Local safeguarding procedures and statutory agencies that may need to be contacted in the event of significant risk or safeguarding concerns.

• The patient's understanding of how safeguarding, confidentiality and emergency responses may differ from those available within the United Kingdom.

• Whether the therapist considers that appropriate safeguarding arrangements can reasonably be established before therapeutic work commences.

Where adequate safeguarding arrangements, emergency procedures, legal authority or insurance cover cannot reasonably be established, Teenage Mental Health Ltd reserves the right to decline, postpone or discontinue remote therapy until such matters have been satisfactorily resolved.

Patients receiving therapy whilst outside the United Kingdom are expected to inform TMH if their country of residence or physical location changes during the course of therapy, as this may affect legal, insurance, safeguarding or emergency response arrangements.

The ability to provide therapy remotely across international borders will always be secondary to the therapist's ability to provide safe, lawful, ethical and appropriately safeguarded care.