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Safeguarding policy

1. Purpose of this policy

KMJ Counselling is committed to promoting the wellbeing and safety of every child, individual and vulnerable person (hereafter referred to as ‘individual(s)’) who accesses its services.

The purpose of this policy is to:

  • protect individuals from abuse, neglect, exploitation and avoidable harm;
  • provide a clear framework for recognising and responding to safeguarding concerns;
  • explain the limits of confidentiality and the circumstances in which information may need to be shared;
  • ensure that safeguarding decisions are made in accordance with the best interests of the individual;
  • support safe, ethical and professional therapeutic practice;
  • provide clear procedures for responding to safeguarding concerns;
  • ensure that safeguarding practice is consistent with the requirements of the British Association for Counselling and Psychotherapy (BACP), relevant legislation and statutory guidance in England.

KMJ Counselling recognises that safeguarding is everyone’s responsibility and that individuals have a right to be listened to, respected and protected.

See also KMJ Counselling Working Agreement for details on Confidentiality, Record Keeping and GDPR.

2. Professional and legal framework

KMJ Counselling works in accordance with the relevant legislation, principles and requirements relevant to private counselling practice, including:

  • the BACP Ethical Framework for the Counselling Professions, specifically their guidance on safeguarding
  • Keeping Children Safe in Education 2026, where relevant to work undertaken within education settings;
  • the Children Act 1989; 2004
  • the Safeguarding Vulnerable Groups Act 2006;
  • the Equality Act 2010;
  • the Human Rights Act 1998;
  • the Data Protection Act 2018 and UK GDPR.

3. Safeguarding principles

KMJ Counselling will:

  1. Put the safety and welfare of individuals at the centre of safeguarding decisions.
  2. Take concerns seriously and respond proportionately.
  3. Listen to individuals and take their views seriously.
  4. Work in a way that promotes dignity, autonomy and respect.
  5. Recognise the importance of the an individual’s developmental stage, communication needs and individual circumstances.
  6. Work inclusively and without discrimination.
  7. Maintain appropriate professional boundaries.
  8. Work within the counsellor’s competence and seek appropriate supervision and consultation.
  9. Maintain accurate, factual and proportionate safeguarding records.
  10. Share information when necessary to protect an individual from harm, even where this means overriding normal expectations of confidentiality.
  11. Work collaboratively with appropriate parents/carers and other professionals where this is in the individual’s best interests and where it is safe and appropriate to do so.

4. Safer practice and professional boundaries

KMJ Counselling recognises that clear professional boundaries are an important part of safeguarding.

The counsellor will:

  • maintain clear therapeutic boundaries;
  • provide counselling only within their level of competence and training;
  • avoid inappropriate personal relationships with clients;
  • avoid unnecessary physical contact;
  • avoid private or inappropriate communication with young clients outside agreed arrangements;
  • use professional communication methods;
  • avoid social media connections with clients;
  • maintain appropriate records of significant safeguarding or boundary-related concerns;
  • consider the risks associated with online and remote counselling;
  • ensure that arrangements for the beginning and end of sessions are clear;
  • consider the physical environment and lone-working arrangements when counselling individuals.

5. Consent and working with children and young people

KMJ Counselling recognises that consent when working with vulnerable individuals requires careful consideration.

The counsellor will consider:

  • the individual’s age and developmental stage;
  • their understanding of counselling and its purpose;
  • their capacity to provide informed consent;
  • their wishes and feelings;
  • whether parental or carer consent is appropriate;
  • who has parental responsibility;
  • the individual’s best interests;
  • relevant legal and professional requirements.

Where parental consent is obtained, this does not mean that the individual’s privacy and therapeutic relationship are disregarded. The limits of confidentiality will be explained clearly to both the individual and parent/carer at the outset.

Individual’s who demonstrate sufficient understanding and capacity, particular care will be taken to respect their developing autonomy and confidentiality.

Where there is uncertainty about consent, parental responsibility, capacity or the appropriate balance between confidentiality and safeguarding, the counsellor will seek supervision and/or appropriate specialist advice.

6. Recognising safeguarding concerns

Safeguarding concerns may arise through:

  • something a individual tells the counsellor;
  • something observed by the counsellor;
  • information provided by a parent/carer;
  • information provided by another professional or person;
  • concerns arising from the individual’s behaviour, presentation or circumstances;
  • information disclosed through online communication;
  • concerns relating to another child or adult.

Possible indicators of abuse or neglect may include:

Physical abuse

  • unexplained or concerning injuries;
  • explanations that are inconsistent or change;
  • fear of particular people or situations;
  • repeated injuries.

Emotional abuse

  • persistent fear, humiliation or rejection;
  • controlling or coercive behaviour;
  • severe withdrawal or distress;
  • exposure to domestic abuse;
  • threats or intimidation.

Sexual abuse or exploitation

  • sexualised behaviour inappropriate to developmental age;
  • sexualised language or disclosures;
  • concerns about grooming;
  • inappropriate sexual contact;
  • online sexual exploitation or coercion;
  • sharing or being pressured to share sexual images.

Neglect

  • persistent lack of appropriate care;
  • unmet medical, emotional or physical needs;
  • inadequate supervision;
  • persistent absence from education;
  • significant deterioration in wellbeing.

Other safeguarding concerns

KMJ Counselling will also remain alert to concerns including:

  • child criminal exploitation;
  • child sexual exploitation;
  • trafficking;
  • county lines activity;
  • online abuse;
  • bullying and cyberbullying;
  • harmful sexual behaviour;
  • domestic abuse;
  • forced marriage;
  • female genital mutilation;
  • radicalisation or extremist exploitation;
  • missing episodes;
  • substance misuse;
  • self-harm;
  • suicidal thoughts or behaviour;
  • eating difficulties where there is a safeguarding concern;
  • abuse or neglect of disabled children;
  • abuse occurring within the family or household;
  • risks associated with adults who have access to children.

The presence of one indicator does not automatically mean that abuse has occurred. The counsellor will consider the wider context, seek supervision where appropriate and take action based on the level of risk.

11. Responding to a disclosure

If an individual discloses abuse or another safeguarding concern, the counsellor will:

  1. Listen calmly and attentively.
  2. Take the disclosure seriously.
  3. Allow the individual to speak in their own words.
  4. Avoid expressing shock, disbelief or judgement.
  5. Avoid asking unnecessary or leading questions.
  6. Clarify only what is necessary to establish immediate safety and the nature of the concern.
  7. Avoid promising secrecy or absolute confidentiality.
  8. Explain what may need to happen next.
  9. Consider immediate safety and whether emergency action is required.
  10. Record the disclosure as soon as reasonably possible using the individual’s own words wherever practicable.
  11. Seek appropriate supervision or safeguarding advice.
  12. Make a referral or contact the appropriate safeguarding agency where required.

The counsellor will not attempt to investigate allegations themselves.

7. Immediate risk of serious harm

If a child or individual is believed to be at immediate risk of serious harm, the priority will be their immediate safety.

Depending on the circumstances, the counsellor may:

  • contact 999 where there is an immediate emergency or risk to life;
  • contact Wokingham Children’s Services/MASH;
  • contact the police where appropriate;
  • contact emergency health services where there is an immediate medical or mental health emergency;
  • contact an appropriate parent/carer where doing so is safe and appropriate;
  • seek urgent advice from the relevant safeguarding authority.

The counsellor will not delay necessary safeguarding action simply because a supervision session is not immediately available.

8. Safeguarding referrals

Where a concern meets the threshold for external safeguarding intervention, KMJ Counselling will make a referral to the appropriate local authority children’s social care/MASH service.

Where a referral is made, the counsellor will record:

  • the reason for the referral;
  • the information provided;
  • the agency/person contacted;
  • the date and time;
  • any advice received;
  • any agreed follow-up action.

9. Safeguarding concerns about parents, carers or other adults

A safeguarding concern may relate to a parent, carer, family member, peer or another adult who has access to the individual.

Where the concern relates to a parent or carer, KMJ Counselling will consider carefully whether informing that person could increase the risk to the individual.

The individual’s safety will take priority over maintaining ordinary communication arrangements.

Where appropriate, concerns will be shared with social services, the police or another relevant safeguarding agency.

10. Self-harm and suicidal ideation

Self-harm or suicidal thoughts will always be taken seriously.

The counsellor will assess the level of immediate risk within their competence and will use supervision and appropriate professional guidance.

Where there is evidence of immediate or serious risk, appropriate safeguarding and emergency procedures will be followed.

The individual will not be left to manage an immediate safeguarding or suicide risk alone.

Where necessary, information will be shared with parents/carers, emergency services, children’s social care, healthcare professionals or other appropriate services.

The counsellor will clearly explain to individuals at the outset that confidentiality cannot be guaranteed where there is a serious risk to their safety or the safety of another person.

11. Safeguarding records

Safeguarding concerns will be documented promptly, accurately and objectively.

Records should include, where relevant:

  • date and time;
  • the individual’s name;
  • what was disclosed or observed;
  • the individual’s words where possible;
  • relevant contextual information;
  • actions taken;
  • advice sought;
  • people/agencies contacted;
  • information shared;
  • decisions made and the rationale;
  • follow-up actions.

Records should distinguish between:

  • factual information;
  • the individual’s account;
  • professional observations;
  • professional judgement or interpretation.

Safeguarding records will be stored securely and separately or clearly identified within the client’s confidential records where appropriate.

Records will be retained and securely disposed of in accordance with KMJ Counselling’s privacy policy, record-retention arrangements, legal requirements and professional guidance.

12. Supervision

Safeguarding work will form part of ongoing clinical supervision.

The counsellor will discuss safeguarding concerns with their supervisor where appropriate, while maintaining the minimum necessary identifying information.

Supervision may be used to:

  • explore safeguarding concerns;
  • consider risk;
  • reflect on the counsellor’s response;
  • identify potential blind spots or assumptions;
  • consider appropriate referral routes;
  • consider the impact of safeguarding work on the therapeutic relationship;
  • ensure that the counsellor is working within their competence.

Where immediate action is required, safeguarding action will not be delayed while waiting for supervision.

13. Training and continuing professional development

KMJ Counselling is committed to maintaining current safeguarding knowledge and competence.

The counsellor will undertake appropriate safeguarding training and keep their knowledge up to date.

Training will be refreshed in accordance with relevant professional, organisational and statutory requirements.

14. DBS and suitability to work with children

Where KMJ Counselling provides services that fall within the relevant eligibility or regulated activity criteria, the counsellor will maintain an appropriate DBS check.

The level of DBS check required will depend on the nature, frequency and circumstances of the work.

The counsellor will review DBS requirements when their role or services change.

15. Working with schools, colleges and other organisations

Where KMJ Counselling provides counselling within a school, college or other organisation, the counsellor will comply with the organisation’s safeguarding arrangements in addition to this policy.

This may include:

  • following the organisation’s safeguarding and child protection policy;
  • knowing who the Designated Safeguarding Lead is;
  • following the organisation’s referral procedures;
  • attending relevant safeguarding training;
  • complying with local reporting and information-sharing arrangements;
  • recording and reporting concerns in accordance with the organisation’s procedures.

Where there is a difference between this policy and the safeguarding procedures of the organisation in which the counsellor is working, the counsellor will seek clarification from the relevant safeguarding lead and/or supervisor.

16. Online counselling

Online counselling with young people will be undertaken only where it can be provided safely and appropriately.

Before beginning online work, the counsellor will establish:

  • the individual’s identity;
  • their location;
  • an appropriate contact number;
  • an emergency contact;
  • arrangements for what will happen if the connection is lost during a crisis;
  • the availability of an appropriate adult where required;
  • whether the physical environment is suitable and sufficiently private.

The counsellor will not rely solely on the individual’s location remaining unchanged during online work.

The individual will be asked to inform the counsellor if their location changes during a session where this could affect emergency safeguarding arrangements.

17. Professional boundaries and communication between sessions

Contact outside counselling sessions will be limited to agreed professional methods and purposes.

The counsellor will not use personal social media accounts to communicate therapeutically with young clients.

Where a individual communicates information suggesting a safeguarding concern outside a scheduled session, the counsellor will respond in accordance with this safeguarding policy rather than treating the communication as an ordinary therapeutic conversation.

The counsellor will maintain appropriate records of significant safeguarding communications.

18. Prevent and radicalisation

KMJ Counselling recognises that children and young people may be vulnerable to radicalisation or extremist exploitation.

Where concerns arise, the counsellor will:

  • listen without judgement;
  • avoid attempting to investigate the concern independently;
  • consider the child’s wider circumstances and vulnerability;
  • seek safeguarding advice;
  • follow appropriate local safeguarding and Prevent procedures where required.

Prevent concerns will be managed as safeguarding concerns and not as an assumption about a individual’s beliefs, identity or political views.

19. Equality, inclusion and anti-discrimination

Safeguarding practice will be inclusive and responsive to the individual needs of each individual.

Particular consideration will be given to communication and safeguarding needs associated with:

  • autism;
  • ADHD;
  • other forms of neurodivergence;
  • learning disabilities;
  • physical disabilities;
  • speech, language and communication needs;
  • mental health difficulties;
  • cultural or linguistic differences.

The counsellor will avoid assuming that behaviour, communication style or emotional presentation has a particular meaning because of a diagnosis or disability.

Reasonable adjustments will be made where appropriate to enable young people to participate safely and meaningfully in the counselling process.

20. Whistleblowing and professional concerns

If the counsellor becomes aware of unsafe practice, safeguarding failures or conduct by another professional that may place children at risk, appropriate action will be taken.

This may include raising concerns with:

  • the relevant safeguarding lead;
  • the organisation employing or commissioning the professional;
  • children’s social care;
  • the police;
  • the Local Authority Designated Officer;
  • the relevant professional or regulatory body.

The welfare of children will remain the primary consideration.

21. Review of safeguarding concerns

Following a significant safeguarding incident or referral, KMJ Counselling will review the response where appropriate.

The review will consider:

  • whether the child was kept safe;
  • whether action was timely;
  • whether information was shared appropriately;
  • whether supervision was accessed;
  • whether any changes to practice are required;
  • whether additional training is required;
  • whether this policy needs to be amended.

Any review will focus on learning and improving safeguarding practice rather than attributing blame.

22. Access to this policy

This policy will be available to clients and, where appropriate, parents/carers.

At the beginning of counselling with a individual, the counsellor will explain the relevant safeguarding and confidentiality arrangements in language appropriate to the individual’s age and understanding.

Individual’s will be encouraged to ask questions about confidentiality, safeguarding and what would happen if the counsellor became concerned about their safety.

23. Review and responsibility

This policy will be reviewed at least annually and sooner if there is a change in relevant legislation, a safeguarding incident or feedback received.

Last reviewed 06/10/2026