THE ESTHER PRACTICE

Research Ethics and Participant Protection Policy

Governing standard for the Practice’s research, evidence-gathering and pattern-analysis activity

Document owner	The Esther Practice: Practice Lead
Version	0.3
Status	Approved
Effective from	1 November 2026
Review cycle	Annual, or earlier following a material change, significant incident or relevant change in law or guidance

Published on The Esther Practice website, theestherpractice.org.

Section 1: Purpose, Authority, Scope and Definitions

1.1 Purpose

This policy establishes the ethical standards governing how The Esther Practice (the Practice) invites, receives, protects, analyses, connects and uses accounts concerning institutional and relational mechanisms of harm, including racialised harm.

It exists to ensure that experience is not collected or used without adequate protection, a defined and legitimate purpose, meaningful participant agency and clear accountability.

1.2 Authority

This policy is approved by the Practice Lead and is binding on the Practice Lead, volunteers, associates and contractors undertaking work for or on behalf of the Practice.

Any partner organisation involved in the Practice’s research or evidence-gathering activity must agree in writing to comply with the parts of this policy relevant to its role. That requirement must be incorporated into the applicable partnership, funding, commissioning or data-sharing agreement.

This policy sits above project-specific protocols, consent forms and participant information. Those documents must be consistent with this policy and cannot reduce the protections it establishes.

This policy does not itself constitute formal institutional research-ethics approval. Where such approval is sought and obtained for a specific project, its nature, scope and source will be stated explicitly and separately. In its absence, the Practice will not claim or imply that such approval exists.

1.3 Scope

This policy applies to:

the research forms (Share Your Experience, the Parent and Carer Account and the Anonymous Questionnaire) and research interviews;
commissioning intake forms, to the extent set out in Section 3.1;
pattern-evidence and research projects;
adults, children and young people participating directly;
accounts contributed by parents and carers;
commissioned, funded, partnered and independently initiated work;
invitation, access to participation, collection, recording, transcription, analysis, aggregation, reporting, publication and secondary use;
The Practice Lead, volunteers, associates, contractors and partners acting within the scope of a project of the Practice.

It applies whether an account is contributed through a form, interview, recorded conversation, workshop or another participatory method.

Children and young people do not currently take part directly. Direct participation will not begin until the arrangements required by Section 3.6 and the independent review required by Section 8.3 are in place.

1.4 Boundaries

This policy:

governs the Practice’s research, evidence-gathering and pattern-analysis work;
does not govern counselling practice undertaken separately by the Practice Lead in a professional counselling capacity. The Practice Lead is a student member of BACP, and its Ethical Framework for the Counselling Professions underpins how the Practice Lead works. BACP does not oversee the Practice’s research;
governs the point at which research participation and separate counselling practice may interface, in accordance with Section 3.11; this policy does not thereby extend to govern the counselling relationship itself.
sits above project-specific protocols, consent forms and participant information, which must be read and applied consistently with it;
operates alongside, and not in place of, safeguarding, privacy, information-security, data-protection and complaints procedures;
requires the arrangements in this policy to be in place, and shown in the project records, before invitations to participate are issued or data collection begins;
prevents a school, commissioner, partner or funder from controlling which participant accounts are included, how the evidence is analysed or what findings are reached;
does not prevent participants from exercising the choices and rights provided by this policy;
does not claim that the Practice possesses formal institutional research-ethics approval unless that approval has been obtained and expressly stated.

1.5 Definitions

Account: a person’s description of something they have experienced, witnessed or understood, however it is collected.

Participant: an adult, child or young person who directly contributes an account or otherwise participates in an evidence-gathering activity of the Practice.

Person described in an account: a child, member of staff or other person who is described in, or could be identified from, an account they did not contribute. Being described in an account does not make a person a participant.

Parent or carer contributor: a parent or carer who contributes their own account, including their account of what they observed, what a child communicated to them and how an institution responded. Their contribution does not become the child’s direct account or make the child a participant where the child has not participated.

Practice Lead: the practitioner with overall responsibility for The Esther Practice, its methodology and its ethical conduct.

Pattern evidence: structured evidence produced by analysing accounts against the Practice’s pattern framework to identify repetition, connection or divergence across time, interactions, participants or institutional responses. Pattern evidence may arise within one longitudinal account or across multiple accounts. Its weight depends on the nature, consistency and extent of the supporting material.

Firewall: the protection that a contributor is never identified to their organisation, or to any organisation or person described in their account, for engagement, commissioning, analysis or reporting. The firewall does not override a disclosure that is strictly necessary under safeguarding or other legal obligations. Any such disclosure is handled in accordance with Section 4 and limited to the minimum information necessary.

Project records: the Privacy Notice, any data protection impact assessment and the Practice’s process records, which together show that the arrangements in this policy are in place before a strand of work begins.

Section 2: Ethical Principles and Decision-Making Test

2.1 Application of the principles

The principles in this section apply throughout the design, approval, delivery, analysis and publication of every research or evidence-gathering activity of the Practice.

Compliance is not established merely by obtaining consent. The Practice must also consider the purpose of the activity, the power relationships surrounding participation, the risks created by collecting or connecting accounts and the consequences of using the resulting evidence.

2.2 Core ethical principles

2.2.1 No extraction without protection

The Practice will not collect an account merely because it may be valuable to the Practice, a commissioner, a funder or a proposed output.

Before inviting participation, the Practice must be able to explain:

why the account is being sought;
how it may be used;
who may benefit;
what risks participation may create;
what protections are in place;
what choices remain available to the participant.

Where no adequate purpose, protection or accountable use can be established, the account will not be collected.

2.2.2 Direct voice and participant agency

People experiencing or witnessing harm are recognised as witnesses to their own environments.

Children, young people and adults must be given a meaningful opportunity to contribute directly where it is appropriate and safe for them to do so. An institution, professional, parent or carer must not automatically replace, reinterpret or speak over a person’s direct account.

Participant agency includes the ability to:

decide whether to participate;
understand the proposed uses of their contribution;
decline questions or activities;
seek clarification;
withdraw within the limits explained before participation;
raise concerns or make a complaint.

Participation does not give a participant control over the Practice’s independent analysis or the accounts of others. It does give them control over whether and on what agreed basis their own contribution enters the process.

2.2.3 Informed and continuing participation

Consent and assent are processes rather than single administrative events.

Information must be provided in a form the participant can understand and must accurately explain the activity, its risks, its intended outputs and the limits of confidentiality and withdrawal.

The Practice must revisit consent where:

the purpose or scope of the work changes;
a new use of an account is proposed;
identifiable or potentially identifiable material may be published;
participation moves into a materially different stage;
new information changes the risks associated with participation.

A signed form does not make participation ethical where understanding, choice or voluntariness is absent.

2.2.4 Protection must not become silencing

Safeguarding, confidentiality and risk management exist to enable safe participation. They must not be used as blanket reasons to exclude children, young people or other participants whose evidence may be difficult for an institution to hear.

Concern about organisational reputation, challenge, discomfort or potential criticism is not an ethical justification for suppressing an account.

Where participation creates a genuine risk, the Practice must first consider whether that risk can be reduced through changes to the method, timing, setting, level of identification or intended use. Participation will be prevented only where adequate protection cannot reasonably be achieved.

Section 3.6 applies to the participation of children and young people, and Section 4 to safeguarding.

2.2.5 Attention to power and racialised context

The Practice will examine the power relationships surrounding both the harm being described and the process through which evidence is collected.

Ethical decisions must consider:

the participant’s relationship with the institution concerned;
age, race, disability and other relevant aspects of identity or circumstance;
dependence on the institution for education, employment, services or protection;
the possibility of retaliation, disbelief, labelling or further disadvantage;
who controls the formal record;
whose account is treated as credible;
who carries the burden of proving what happened.

The Practice will not treat institutional accounts as inherently more objective or reliable than lived accounts. Nor will it treat any individual account as proving more than the evidence supports.

2.2.6 Purpose, necessity and proportionality

The Practice will collect and use only the material reasonably necessary for a defined purpose.

The likely value of the proposed work must be weighed against:

the emotional and practical burden of participation;
risks to privacy, safety and relationships;
the possibility of reidentification;
the consequences of connecting separate accounts;
the risk that participation reproduces the dynamics of extraction or disbelief being examined.

The Practice will not promise that participation will produce a personal remedy or direct benefit where that cannot be guaranteed.

2.2.7 Evidential integrity

The Practice will distinguish clearly between:

what a participant has reported;
what supporting material establishes;
what repeats within or across accounts;
what the Practice infers from the evidence;
what cannot be concluded.

Contradiction, uncertainty and evidential limitations will not be removed merely to produce a clearer narrative.

The Practice will apply its methodology consistently and will not alter findings to satisfy a participant, commissioner, funder, partner or institution.

2.2.8 Independence

No commissioner, funder, school, partner or participating organisation may:

select which accounts the Practice accepts;
require the identification of participants;
direct how accounts are coded or interpreted;
suppress findings it considers uncomfortable;
make payment or continued access conditional upon a particular conclusion.

Any restriction affecting the Practice’s independence must be identified before the work is agreed. If the restriction cannot be removed, the Practice will not proceed.

2.2.9 Accountability and challenge

The Practice must be able to explain and evidence how ethical decisions were made.

Participants must receive clear information about:

who is responsible for the work;
how to raise a concern;
how to make a complaint;
what review or escalation is available;
which matters the Practice can and cannot resolve.

Errors, unintended consequences and breaches must be acknowledged, recorded and addressed. Ethical accountability does not end when data collection is complete.

2.3 Ethical decision-making test

Before a strand of work begins, the Practice Lead must be able to answer:

What is the precise and legitimate purpose of the activity?
Why is participant involvement necessary?
Who may benefit, and is any claimed benefit realistic?
What burden or risk may participation create?
How do power, race, age and institutional dependence affect genuine choice?
Can participants understand what they are agreeing to?
How will children and young people be heard directly where they participate?
What information is necessary, and what can be left uncollected?
How will confidentiality, safeguarding and possible disclosures be managed?
Could participants, organisations or communities be identified when accounts are connected or published?
What control could a funder, commissioner, partner or institution attempt to exercise?
When and how may a participant withdraw?
What will happen to accounts that have already entered analysis?
Does the activity require external ethical, safeguarding, legal or data-protection advice?
Can the Practice justify proceeding if its decision is later challenged?

An unanswered material question is not treated as approval.

2.4 Decision before work begins

The Practice Lead decides whether the work:

proceeds: adequate protections are in place;
proceeds with conditions: it may begin only once specified conditions are met;
is paused: material information or protection is missing, and no invitation or data collection may begin;
is declined: the purpose cannot justify the risks, required protections cannot be established, or the conditions would compromise the Practice’s ethical standards or independence;
waits for advice: specialist or independent advice is needed before a decision can be made.

The decision, its reasons and any conditions are recorded in the project records.

Section 3: Routes into Participation, Consent, Assent and Withdrawal

3.1 Ethical participation

Participation must be voluntary, informed and based on a genuine choice.

No account may enter the Practice’s analysis or pattern-evidence process until the required participant information has been provided and the relevant consent or assent has been recorded.

Receiving an unsolicited account does not automatically authorise the Practice to analyse, aggregate or publish it. The Practice may respond to or temporarily hold unsolicited material only in accordance with its privacy, safeguarding and information-security requirements while appropriate consent is considered.

Consent to participate is distinct from the Practice’s lawful basis for processing personal data. Both must be addressed and explained to participants.

Commissioning intake forms completed by a leader considering commissioned work are not participant accounts. They are processed under legitimate interests, as described in the Privacy Notice, and may be coded in the back office once identifying details are removed. They are recorded as the leadership’s account, not as evidence of harm.

3.2 Invitation and access to participation

The routes through which people become aware of, approach or are invited to participate in the Practice’s work must be shown in the project records.

A person may enter a participation process by:

independently approaching the Practice;
completing a research form;
responding to a public invitation;
being informed about the opportunity by a community organisation, advocate or other intermediary;
receiving an invitation through an approved project partner or institutional gatekeeper.

The route into participation must not:

rely on explicit or implicit coercion;
suggest that participation is required to access education, employment, support or another service;
imply that participation will resolve an individual complaint or produce a particular outcome;
permit a school, employer or other institution to pressure someone to participate;
allow an institution to select only those people whose accounts it considers acceptable;
disclose who has accepted, declined or withdrawn unless disclosure is necessary and has an identified ethical and lawful basis.

Where an institution or community organisation facilitates access, its permission does not constitute consent on behalf of any participant.

Prospective participants must be given reasonable time to consider participation, ask questions and discuss their decision with a trusted person where they wish to do so.

Any payment, reimbursement, voucher or other recognition must be approved by the Practice Lead and recorded. It must not be of a kind or value likely to override free choice. A participant who withdraws will not lose payment or reimbursement already earned for their time or expenses.

3.3 Participant information

Before agreeing to participate, each prospective participant must receive information appropriate to the project and accessible to them.

The information must explain:

who the Practice is and who is responsible for the project;
why the person is being invited;
the purpose of the activity;
what participation involves and how long it is expected to take;
whether recording or transcription is proposed;
the reasonably foreseeable burdens, risks and potential benefits;
that participation is voluntary;
that questions may be declined and participation may be paused or ended;
how the account may be analysed, connected with other material and reported;
whether anonymised quotations may be used;
who may receive or access the resulting material;
the limits of confidentiality (Section 4.3);
how safeguarding disclosures will be handled (Section 4);
how personal information will be processed;
whether the participant’s organisation will know that they participated;
the available withdrawal options and their practical limits;
how to raise a concern or complaint;
that the Practice cannot guarantee an individual remedy, institutional response or other personal outcome.

Information must be available in formats suited to participants’ age, language, literacy, communication needs and disability. Accessibility support must assist understanding without directing the person’s decision or account.

3.4 Recording consent

Consent must be demonstrated through a clear affirmative action and recorded before participation begins.

Consent must not be:

inferred from silence or continued presence;
obtained through pre-selected options;
bundled into unrelated terms;
treated as permanent or unlimited;
accepted where there is doubt about whether the person understands what they are agreeing to;
obtained by someone whose authority or relationship creates avoidable pressure.

Where relevant, separate choices must be provided for:

participation in the activity;
audio or video recording;
transcription;
inclusion in pattern analysis;
use of anonymised quotations;
publication or dissemination;
future contact;
any proposed secondary use.

If recording is integral to a defined method, including research interviews, this must be explained before participation. A person who does not consent to recording must not be pressured to do so. The Practice must consider whether another appropriate participation route is available.

3.5 Adults’ participation

An adult must provide their own informed consent unless a project-specific ethical and legal review has established a valid alternative route.

Where there is reason to doubt whether a prospective participant can understand, retain, use or weigh the information required to decide, participation must pause. The Practice will not assume incapacity because a person is distressed, disabled, requires communication support or makes a decision others consider unwise.

The Practice will not include an adult who cannot provide their own informed consent unless the project has been designed specifically for such participation and the applicable legal, ethical and safeguarding requirements have been independently reviewed.

3.6 Children and young people

Children and young people must receive information addressed directly to them and adapted to their age, development, communication needs and the complexity of the proposed activity.

Age alone must not be treated as proof that a child either can or cannot make an informed decision. The Practice must consider whether the child or young person understands:

what they are being invited to do;
that participation is optional;
what will happen to their account;
who may see or hear the resulting material;
the limits of confidentiality;
that they may decline questions or stop;
the reasonably foreseeable consequences of taking part.

For participants under 16, the Practice’s usual requirement is:

permission from a person with parental responsibility; and
the child’s own informed and affirmative assent or consent.

Parental permission does not override a child’s refusal. The Practice will not proceed where a child communicates that they do not wish to participate, including through words, behaviour or another form of communication.

A mature child under 16 may sometimes be capable of giving their own informed consent. The Practice will not rely on that consent without parental permission unless the independent review under Section 8.3 establishes that doing so is appropriate, lawful and safer for the child. Independent safeguarding or legal advice must be obtained before this exception is used.

Young people aged 16 or 17 will normally be invited to provide their own consent. Family involvement may be encouraged but must not automatically override the young person’s privacy or decision.

The independent review under Section 8.3 must confirm the applicable requirements for the jurisdiction and circumstances in which the work will occur.

A school’s, local authority’s or other gatekeeper’s agreement does not replace the child’s decision or any required parental permission.

A parent or carer may contribute a separate account. That contribution must remain distinguishable from the child’s direct account.

Where participation continues over time, the Practice must reconsider the young person’s understanding and seek their direct consent when their age, capacity or legal position changes materially.

3.7 Continuing consent and assent

Consent and assent must remain active throughout participation.

The person conducting the activity must:

check that the participant still wishes to continue;
respond to signs of discomfort, confusion or distress;
allow breaks;
permit questions to be declined;
stop a recording or activity when requested;
avoid treating completion as more important than the participant’s welfare or choice.

A participant may change their mind without having to justify the decision.

Distress does not automatically invalidate consent. The Practice must consider whether the participant remains able and willing to continue and whether continuing would be ethical. Where this is uncertain, the activity must pause.

3.8 Withdrawal

Before participation begins, the Practice must explain, where relevant, the distinction between withdrawing from:

the current activity;
future participation or contact;
further use of identifiable material;
the use of attributed or anonymised quotations;
inclusion in continuing analysis;
processing of personal data.

The project-specific participant information must state any withdrawal deadline and explain what can happen at each stage of the work.

Before an account has been irreversibly anonymised or incorporated into collective published findings, the Practice will take reasonable steps to remove it from further analysis when requested.

Withdrawal may no longer permit the removal of material that:

has been irreversibly anonymised so that it can no longer be linked to the participant;
has already been incorporated into published aggregate findings;
cannot be removed without exposing or altering another participant’s account;
must be retained or acted upon because of a safeguarding or legal obligation.

The Practice must not anonymise or aggregate material prematurely for the purpose of defeating a foreseeable withdrawal request.

Withdrawal does not reverse a safeguarding action already taken or require the Practice to destroy a record that it is legally required to retain.

The consequences of withdrawal for personal-data processing depend on the lawful basis being used. These must be explained accurately in the applicable privacy information and must not be confused with withdrawal from participation.

Rights over personal data that continue after a withdrawal deadline are set out in Section 5.10.

3.9 Changes to the project or proposed use

Fresh information and renewed consent must be sought where a material change affects what the participant originally agreed to.

Material changes include:

a substantial change to the project’s purpose;
a new category of recipient;
a new form of publication;
increased identification or reidentification risk;
linkage with a new dataset or source;
use in a different project or context;
a change to recording or retention arrangements;
a change that materially affects risk.

Where renewed consent cannot be obtained, the Practice must not proceed with the new use unless the project-specific ethical and data-protection review establishes another ethical and lawful basis. The reason must be documented.

3.10 Participation records

The Practice must maintain an auditable record of:

the participant information provided and its version;
when and how consent or assent was obtained;
the choices agreed to;
who conducted the consent process;
any parental permission obtained;
accessibility or communication measures used;
any renewed or modified consent;
any withdrawal request and how it was addressed.

Consent records must be protected and accessed only by those who require them for an authorised purpose.

3.11 Movement Between Research Participation and Counselling Support

3.11.1 Research to counselling

Where a support need is identified during a research form, a research interview or any other research activity of the Practice, the person conducting the activity must pause the activity in accordance with Section 4.12 and consider the participant’s needs separately from continuing the research process.

The participant must be offered:

The Practice’s support information, provided regardless of any other action taken, containing national support services, how to find local services, and Christ-centred resources where the Practice holds them, offered without requiring the participant to share or disclose their own faith position; and
where appropriate and within the Practice Lead's current professional competence and qualification, the option of counselling support from the Practice Lead; or, where this is not appropriate or the Practice Lead is not yet qualified to provide it, referral to a more appropriate service or practitioner.

Until the Practice Lead holds a recognised counselling qualification, this route defaults to signposting and referral. The Practice Lead's own counselling details may be shared with a participant only once that qualification is held, and only as one option among those offered. A participant is under no obligation to take up the Practice Lead's service, and declining it does not affect their research participation, the analysis of their account, or any other aspect of their relationship with the Practice.

The support information must be reviewed regularly to confirm that listed services and contact details remain current.

3.11.2 Counselling to research

A person who is a counselling client of the Practice Lead may be invited to consider participating in the Practice’s research only once the Practice Lead is appropriately qualified and the governance for this route has been established and approved. Any such invitation must be made through a separately governed, genuinely voluntary consent process, independent of the counselling relationship.

Counselling must not become conditional on research participation. Declining, delaying or withdrawing from research participation does not affect the counselling relationship in any respect. Where a client is invited into research, this policy's Section 3 requirements on informed consent, and Section 5's requirements on data separation, apply in full to their research participation from that point forward.

3.11.3 Records

Information arising from a counselling relationship must not enter a research case record, and information arising from research participation must not enter a counselling record, without the specific, separately obtained consent of the person concerned, except where a safeguarding or legal obligation under Section 4 requires disclosure.

3.12 Interpreters, communication supporters and support workers

A participant may be supported by an interpreter, a communication supporter, a support worker or a person they trust, such as a friend, family member or advocate.

Support is requested or agreed by the participant wherever possible. It is not imposed by an institution, a parent or carer, or the Practice.
The supporter’s role is to help the participant understand, take part and be understood. A supporter must not answer for the participant, direct the account, or filter or change what the participant says. An interpreter interprets everything said, in full.
Before the activity, the Practice considers whether the supporter’s presence could create a conflict of interest, pressure or a safeguarding risk, including where the supporter is connected to the institution or to a person described in the account.
An interpreter or support worker engaged by the Practice is bound by written confidentiality and data-protection terms under Section 5.8. A supporter chosen by the participant is asked to keep what is said confidential but cannot be bound in the same way, and the participant is told this.
The supporter’s role and its limits are explained during consent. The participant’s choice about support is recorded under Section 3.10.
Anything a supporter says in their own right is removed from the transcript before analysis. An interpreter’s rendering of the participant’s words is the participant’s account and is marked as interpreted.
If a supporter’s presence appears to stop the participant speaking freely, or creates a risk, the activity is paused. The participant is offered the chance to continue without that supporter or at another time, and the reason is recorded.

Section 4: Safeguarding, Disclosures and Limits of Confidentiality

4.1 Safeguarding responsibility

The Practice has a responsibility to consider the safety and welfare of people participating in its work and of other people who may be affected by information disclosed through that work.

Safeguarding responsibility applies throughout:

project design;
invitation and access to participation;
consent and assent;
forms, interviews, workshops and recorded conversations;
analysis and connection of accounts;
reporting, publication and follow-up.

Safeguarding must protect participants without unnecessarily excluding them, suppressing their accounts or transferring control to the institution being examined.

The Practice is not a statutory safeguarding authority and does not investigate allegations of abuse or determine whether an offence has occurred. Its role is to receive accounts appropriately, assess immediate safeguarding implications and refer concerns through the appropriate route where necessary.

4.2 Safeguarding arrangements before participation

Before invitations to participate are issued or data collection begins, the Practice must have in place, and show in the project records:

the named person responsible for safeguarding decisions;
an alternative or external source of safeguarding advice;
the applicable local safeguarding pathways and contact details;
arrangements for emergencies and concerns arising outside normal working hours;
the procedure for responding to disclosures;
whether DBS clearance is required and whether the appropriate clearance is current;
whether additional training, expertise or supervision is required;
how participants will be informed about confidentiality and its limits;
how safeguarding records will be separated from research and analytical material;
any risks arising from the setting, including one-to-one, remote or group participation.

Where the Practice Lead also holds responsibility for the research and the safeguarding decision, arrangements must exist for obtaining external advice where the decision is complex, disputed or could materially affect a participant.

No activity involving children or young people may begin while a required safeguarding arrangement remains unresolved.

4.3 Confidentiality and its limits

The Practice will treat participant accounts as confidential and will not disclose identifying information merely because an account is critical of an individual or institution.

Confidentiality is not absolute. Information may need to be shared where this is necessary and lawful to:

protect a child from harm;
protect an adult at risk from harm;
respond to an immediate threat to life or safety;
comply with a court order or another applicable legal obligation;
report a matter where a specific legal reporting duty applies.

These limits must be explained before participation in language the participant can understand.

The possibility of a safeguarding disclosure does not give the Practice, a school, a partner or a funder general access to a participant’s account.

4.4 The firewall

The firewall remains in force where a safeguarding concern arises.

A safeguarding concern does not permit the Practice to identify a participant to their organisation for commissioning, engagement, analytical or reputational purposes.

Where disclosure is necessary for safeguarding or legal reasons:

only the minimum necessary information may be shared;
information must be shared only with the person or body able to act on the concern;
the institutional subject of an account must not automatically be the recipient;
the analytical account must not be disclosed in full unless this is strictly necessary;
the decision and its justification must be recorded.

Where the institution or a person within it is implicated in the concern, the Practice must not route the disclosure through that institution if doing so could increase risk, expose the participant or compromise the appropriate safeguarding response.

4.5 Responding to a disclosure

When a participant discloses information that may indicate a safeguarding concern, the person receiving it must:

listen without expressing disbelief, blame or shock;
avoid interrupting unnecessarily;
avoid leading questions or attempting to investigate;
clarify only what is necessary to understand immediate safety and the required next step;
not promise secrecy or a particular outcome;
explain, as far as possible, what may happen next;
check whether anyone is in immediate danger;
allow the participant to pause or end the activity;
record the participant’s words as accurately as possible;
notify the person responsible for safeguarding without avoidable delay.

The participant should not be required to repeat their account unnecessarily. Where an existing recording or written submission accurately captures the disclosure, any additional questioning must be limited to what is necessary for safety and referral.

The original account must not be rewritten to make it fit a safeguarding category or institutional process.

4.6 Assessing the concern

Not every account of institutional, relational or racialised harm automatically requires an external safeguarding referral. Equally, harm must not be downgraded to an equality, conduct or complaints issue merely because it occurred within an institution or involved racialised behaviour.

The safeguarding assessment must consider:

the nature and seriousness of the reported harm;
whether the harm is current, continuing or likely to recur;
whether a child, adult at risk or another person may presently be unsafe;
the age, circumstances and expressed wishes of the participant;
whether the person alleged to have caused harm continues to have access to children or adults at risk;
whether coercion, retaliation or institutional pressure may be present;
whether the concern relates to a person working or volunteering with children;
whether a specific legal or professional reporting obligation may apply;
whether obtaining consent to share could increase risk;
whether specialist advice is required.

Historical information must not be dismissed solely because the event occurred in the past. The Practice must consider whether the information indicates a current risk to the participant or others.

The outcome may be:

no safeguarding action, with reasons recorded;
continued monitoring or clarification;
discussion with the participant about available support;
confidential consultation with a safeguarding adviser;
referral to children’s social care or adult safeguarding;
consultation or referral to the relevant Local Authority Designated Officer;
contact with the police or emergency services;
another legally or professionally required action.

4.7 Sharing information

Where it is safe and appropriate, the Practice will seek the participant’s agreement before sharing safeguarding information and will explain:

what information is proposed for sharing;
why it may be shared;
with whom;
what may happen next.

A participant’s objection must be considered seriously but does not create an absolute prohibition where sharing is necessary to protect a child or another person from harm or to meet a legal obligation.

The Practice may decide not to seek consent or not to inform the participant before sharing where doing so could:

place the participant or another person at greater risk;
alert a person alleged to have caused harm;
lead to intimidation, retaliation or destruction of evidence;
obstruct an appropriate safeguarding or criminal process;
otherwise make the safeguarding response less effective.

Any information shared must be:

necessary for the safeguarding purpose;
proportionate to the level of risk;
relevant and limited to what the recipient needs;
as accurate and current as reasonably possible;
shared promptly where delay could increase risk;
transmitted securely.

The Practice must record decisions both to share and not to share, including the information considered, advice obtained, reasons for the decision, recipient, date and information disclosed.

4.8 Immediate danger

Where the Practice reasonably believes that a person is in immediate danger or requires urgent medical or police assistance, emergency services must be contacted without delay.

An emergency response must not be delayed solely to obtain consent, complete internal documentation or consult a partner organisation.

Only information necessary to enable the emergency response should be disclosed.

4.9 Children and young people

A child or young person must be told, in an age-appropriate way, that the Practice may need to seek help if information indicates that they or someone else may be unsafe.

The Practice must not automatically disclose a child’s account to a parent or carer. Before involving a parent or carer, the Practice must consider:

the child’s wishes and understanding;
the nature and immediacy of the concern;
whether the parent or carer may be implicated;
whether disclosure could increase risk or lead to retaliation;
whether another trusted adult or statutory service is more appropriate.

A child’s objection to information sharing must be heard and considered. It may be overridden where sharing is necessary to protect the child or another person, but the reasons must be explained where it is safe to do so.

Where the concern involves a teacher, school employee, volunteer or another person working with children, the Practice must consider consultation or referral through the relevant Local Authority Designated Officer or other applicable allegations-management pathway.

4.10 Adults at risk

Adult safeguarding decisions must respect the adult’s autonomy, wishes and desired outcomes as far as possible.

The Practice must not assume that an adult requires a safeguarding intervention solely because they are distressed, disabled, marginalised or describing serious institutional harm.

Where an adult appears to have care and support needs, is experiencing or at risk of abuse or neglect and may be unable to protect themselves, the Practice must consider whether adult-safeguarding advice or referral is required.

Information should normally be shared with the adult’s agreement. Sharing without agreement may be justified where, for example:

another person, including a child, may be at risk;
the adult may be subject to coercion or unable to make the relevant decision;
there is a risk of death or serious harm;
a legal obligation requires disclosure.

The decision and its justification must be recorded.

4.11 Group participation

Where an activity involves more than one participant, the Practice must explain that it cannot guarantee that other participants will preserve confidentiality.

Appropriate group agreements must be established, but those agreements must not be presented as providing the same protection as the Practice’s own confidentiality obligations.

Participants must be told not to disclose another participant’s identity or account outside the activity. The Practice must consider whether the sensitivity of the subject makes a group method inappropriate.

4.12 Support and role boundaries

The Practice must not represent participation as counselling, therapy, legal representation, formal advocacy or a safeguarding investigation.

Where participation causes distress or identifies a need for support, the Practice may:

pause or end the activity;
discuss what the participant needs at that point;
provide appropriate information or signposting;
support the participant to contact an appropriate service where this falls within the Practice’s role and competence.

The Practice must not promise that another service will accept a referral, take a particular action or reach a particular conclusion.

4.13 Safeguarding records

Safeguarding concerns and decisions must be recorded promptly and factually.

The record must distinguish between:

what the participant said or submitted;
what the Practice directly observed;
what information was obtained from another source;
The Practice’s assessment;
advice received;
the decision taken and its reasons;
what information was shared, with whom and when;
any agreed follow-up.

Safeguarding records must be access-restricted and stored separately from analytical working material wherever practicable. Their retention and disposal must comply with the applicable safeguarding, data-protection and information-security requirements.

Retention periods for safeguarding records are set under Section 5.9.

4.14 Concerns involving the Practice’s personnel

Any safeguarding allegation or concern involving the Practice Lead, a volunteer, associate, contractor or partner representative must not be handled solely by the person concerned.

The applicable external safeguarding, allegations-management or professional route must be identified without delay. This may include the Local Authority Designated Officer, children’s social care, adult safeguarding, police, DBS or a relevant professional body.

Access to participants and participant material may be suspended while the concern is assessed. Suspension is a protective measure and does not determine that an allegation has been substantiated.

Section 5: Privacy, Recording, Anonymisation, Data Use and Retention

5.1 Data-protection responsibility

The Practice will process personal information lawfully, fairly, transparently and in a manner that protects participants’ rights and safety.

For each project, the Practice must identify and document whether it acts as a controller, joint controller or processor. A commissioner or partner must not be described as determining the purposes or means of processing unless its actual role and responsibilities have been agreed in writing.

Ethical consent to participate does not by itself provide a lawful basis for processing personal data. Before processing begins, the Practice must identify:

an applicable UK GDPR Article 6 lawful basis;
an applicable Article 9 condition where special-category data is processed;
an applicable condition and policy basis where criminal-offence data is processed;
the purpose for which each category of information is required;
the rights available to the participant;
any relevant research provisions or restrictions.

The Practice must not select consent as its data-protection lawful basis where it cannot provide the genuine ability to withdraw that consent and stop the relevant processing.

5.2 Data-protection assessment before participation

Before a strand of work begins, the Practice must document a data-protection assessment, in a data protection impact assessment where one is required, covering:

the categories of personal and special-category data involved;
the proposed sources and recipients;
the intended data flow from collection to deletion or anonymisation;
the lawful basis and special-category condition;
privacy information for participants;
access controls and approved systems;
recording and transcription arrangements;
retention periods and disposal;
processors, partners and international transfers, if any;
the risk of identification or reidentification;
whether a Data Protection Impact Assessment is required.

A Data Protection Impact Assessment must be completed before processing begins where the proposed activity is likely to create a high risk to individuals’ rights and freedoms. Uncertainty about the need for an assessment must be resolved before the activity proceeds.

5.3 Data minimisation

The Practice will collect only information that is reasonably necessary for the defined purpose.

Project design must consider whether the purpose can be achieved by:

avoiding the collection of names and direct identifiers;
allowing participants to redact material;
using participant references;
separating contact details from substantive accounts;
collecting less detailed contextual information;
using anonymised rather than identifiable data;
declining documents or information that are not required.

Information must not be retained merely because it may be useful at an unspecified future point.

5.4 Recording and transcription

Audio or video recording may take place only where:

recording is necessary for the approved method;
the participant has provided specific informed consent;
the recording method and storage location have been approved;
the participant has been told who will have access;
transcription and deletion arrangements have been explained;
the participant can request that recording stop.

Recordings must be transferred to approved secure storage as soon as practicable and removed from the recording device when secure transfer has been confirmed.

Transcription must be undertaken by an authorised person or approved service subject to appropriate confidentiality, security and data-processing terms.

Identifiable participant material is recorded and transcribed only through the approved service named in the Privacy Notice. AI-assisted analysis receives only material from which identifying details have been removed and checked. Recordings and unredacted transcripts are never used for AI-assisted analysis.

5.5 Separation and pseudonymisation

Direct identifiers, contact details, consent records, raw accounts, safeguarding records and analytical material must be separated wherever practicable.

Codes and replacement identifiers must not be treated as anonymisation where the Practice or another person can reasonably reconnect the material to an individual or organisation. In those circumstances, the material remains personal data and must be protected accordingly.

The key or information capable of reconnecting a code to an identity must be:

stored separately;
access-restricted;
used only for an authorised purpose;
deleted when it is no longer required.

5.6 Anonymisation and reidentification risk

The Practice will not describe information as anonymous unless individuals are no longer identifiable by means reasonably likely to be used.

Removing a name is not sufficient where identity may be inferred from:

a rare incident or distinctive sequence of events;
a small school, team, cohort or geographical area;
a person’s role, age, year group or protected characteristics;
dates, locations or quoted language;
the combination of several indirect identifiers;
knowledge held by the institution or local community;
linkage with public or privately held information.

Reidentification risk must be assessed at collection, analysis and release. It must be reconsidered whenever accounts are connected, a new dataset is introduced or an output is prepared for a new audience.

Anonymisation decisions must not erase characteristics necessary to identify racialised or institutional patterns without first considering whether the same protection can be achieved by another method.

Protections applied when an output is released are set out in Section 7.4.

5.7 Access and security

Access to participant material must be limited to people who require it for an authorised role.

The Practice must apply:

role-based and least-privilege access;
approved storage and communication systems;
appropriate encryption in storage and transit;
multi-factor authentication where available;
secure device and password practices;
restricted sharing permissions;
access removal when a role or project ends;
secure deletion or return of material.

Participant material must not be stored in personal email accounts, unapproved messaging services or unapproved local or cloud storage.

Funders, commissioners and partner organisations do not receive access to raw participant accounts merely because they support or host the work.

5.8 Processors, partners and sharing arrangements

Before another organisation or service processes participant information for the Practice, the project record must establish:

why the processing is necessary;
the organisation’s data-protection role;
the information it will receive;
the instructions and restrictions governing its use;
security, breach and deletion requirements;
whether information will leave the United Kingdom;
how compliance will be monitored.

Required contracts, data-processing terms or data-sharing agreements must be in place before access is granted.

No recipient may reuse participant information for its own research, service development, training, publicity or commercial purpose unless that use has been separately approved, is lawful and falls within what participants were told.

5.9 Retention and disposal

Every project must have a retention schedule specifying how long each category of material will be kept and why.

Different periods may apply to:

contact and administrative information;
consent and assent records;
raw forms and submissions;
audio or video recordings;
transcripts;
coded analytical material;
safeguarding records;
final reports and publication records;
complaints, incidents and governance records.

Retention must be based on a defined legal, ethical, methodological or accountability need. Material must not be retained indefinitely by default.

The current periods are those set out in section 4 of the Privacy Notice.

When the approved retention period ends, information must be securely deleted, destroyed or irreversibly anonymised. The Practice must take reasonable steps to address copies and backups in accordance with its technical arrangements.

Where longer retention is justified for research or archiving purposes, the purpose and safeguards must be documented and the material must not be repurposed to make decisions affecting an identifiable person unless a separate lawful and ethical basis exists.

5.10 Participant rights and requests

Participants must receive privacy information explaining how to exercise their data-protection rights and whom to contact.

Requests for access, correction, restriction, objection, erasure or another applicable right must be handled promptly and in accordance with the law.

The Practice must not promise that every right applies in every circumstance. The available rights may depend on the lawful basis, the nature of the information, whether it remains identifiable and whether a lawful research-related limitation applies.

Any reliance on an exemption or restriction must be considered individually, documented and applied only to the extent necessary. It must not be used merely because fulfilling a request would be inconvenient.

5.11 Data incidents and breaches

Any actual or suspected loss, unauthorised access, disclosure, alteration or destruction of participant information must be reported immediately through the Practice’s information-security incident process.

The Practice must:

contain and assess the incident;
consider the risks to affected people;
preserve an accurate incident record;
take corrective action;
notify the Information Commissioner’s Office and affected individuals where legally required;
consider whether the project or relevant processing must pause;
review whether the incident changes the ethical basis for continuing the work.

An information-security incident may also constitute an ethical or safeguarding incident and must be considered under the relevant sections of this policy.

5.12 People described in accounts who are not participants

Accounts often describe children, staff and other people who have not taken part. The Practice must protect their information with the same care as a participant’s.

Being described or named in an account does not make a person a participant. The Practice does not contact them to seek consent or to check an account, because doing so would reveal that the account exists and could identify the contributor.
The Practice keeps only the information about them that is needed to understand the account and its pattern. Their names and direct identifiers are removed at coding, at the same point as the contributor’s.
Reidentification risk under Section 5.6 is assessed for them as well as for participants, including what people inside the institution could piece together.
A child or adult at risk described in an account is considered under Section 4, whether or not they take part.
Where several accounts concern the same incident, person, child or institution, the Practice may connect them for analysis. Connecting accounts must never reveal one contributor or account to another contributor, to the institution or to anyone described.
Where accounts conflict, including about a person described in them, the conflict is handled under Section 6.7. The Practice does not decide which account is true about an individual.
The Practice’s findings concern patterns and institutional responses, not judgements about individuals. Research outputs never name an organisation or an individual (Section 7.6).
A person described in an account has the data-protection rights set out in the Privacy Notice, including the right to object. Requests are handled under Section 5.10 without revealing who contributed the account.

Section 6: Analysis, Pattern Evidence and Evidential Integrity

6.1 Purpose of analysis

The Practice’s analysis is intended to identify and explain relational and institutional mechanisms connecting experiences that are commonly treated as isolated events.

Analysis must preserve the distinction between a participant’s account, supporting material, analytical coding, identified repetition and the Practice’s conclusions.

The purpose of pattern analysis is not to convert every account into proof of a wider claim. It is to determine, transparently and consistently, what the material does and does not support.

6.2 Integrity of the source account

The participant’s account is kept as the source record. Once identifying details have been deleted under the retention periods, the redacted account or transcript becomes the source record.

The Practice must not:

alter the source account to fit an existing pattern category;
remove contradiction or uncertainty merely to strengthen a finding;
present an inference as though it were the participant’s own statement;
combine the words of several people into a quotation without clearly identifying it as a composite;
treat institutional language as inherently more authoritative than a participant’s account.

Editing for clarity, accessibility, anonymity or length must not change the substance or meaning of an account.

Where a participant opts to review their interview transcript, the purpose of that review must be explained. Their corrected version stands. Anything they add, rather than correct, is noted as added afterwards. Participant review does not require the Practice to remove a properly evidenced analytical conclusion or alter another person’s account.

6.3 Analytical separation

The Practice’s records must distinguish between:

reported experience: what a participant says happened or was experienced;
supporting material: records or other sources relevant to the account;
coding: the analytical labels applied under the Practice’s pattern framework;
repetition or connection: features recurring across time, interactions, decisions or accounts;
documented divergence: a difference between lived experience and a relevant policy, record, procedure, duty or stated position;
analytical inference: the Practice’s reasoned interpretation of the available material;
unresolved matter: a contradiction, gap or question that the available material does not determine.

These categories must not be collapsed in reporting.

6.4 Use of the pattern framework

Accounts are analysed against the current version of the Practice’s pattern framework (EP-01 to EP-11) and its definitions. Accounts may also be coded in the back office against a separately attributed instrument. Back-office coding, provisional pattern candidates and automated suggestions never appear in anything a participant or client receives.

The project record must identify:

the framework version used;
any project-specific coding decisions;
any new or provisional pattern category;
any material departure from the standard method;
who conducted and reviewed the analysis.

A new pattern must not be added to the framework merely because it appears useful to a particular argument. Its definition, relationship to existing patterns and evidential basis must be documented and reviewed.

6.5 Establishing pattern evidence

Pattern evidence may arise:

across time within one person’s longitudinal account;
across several interactions or institutional responses;
across independent participants connected to the same organisation or system;
through repeated divergence between lived experience and policy or stated practice;
through the recurrence of a relational or institutional mechanism in different settings.

The Practice must state the basis on which a pattern has been identified. It must not use the existence of repetition to make unsupported claims about prevalence, intention, causation or every member of an institution.

The absence of multiple accounts does not invalidate an individual account. Equally, one account must not be described as establishing prevalence across a population.

6.6 Context and corroboration

Where relevant and lawfully available, the Practice may examine accounts alongside:

policies and procedures;
correspondence and complaint records;
sanctions, exclusions, attendance or safeguarding information;
statutory duties and professional standards;
published data or inspection findings;
other participant accounts;
the institution’s stated position or response.

Corroborating material may strengthen, qualify or contradict an analytical conclusion. Its absence must not automatically be treated as disproving lived experience, particularly where the institution controls or has failed to create the formal record.

The Practice must consider the source, completeness, purpose and limitations of institutional records rather than treating them as neutral by default.

6.7 Contradiction and counter-evidence

Material that does not fit an emerging pattern must be considered rather than discarded.

The analytical record must show how the Practice addressed:

conflicting accounts;
missing information;
alternative explanations;
evidence of different institutional practice;
differences in context or severity;
uncertainty about sequence, responsibility or causation.

Where the evidence supports more than one reasonable interpretation, the report must say so.

6.8 Consistency and review

The level of analytical review must be proportionate to the seriousness and intended use of the findings.

Independent or second-person review must be considered where findings:

may identify or materially affect an individual or institution;
concern children or adults at risk;
may be used in legal, regulatory or formal accountability processes;
depend on a new or disputed pattern category;
are based on complex or contradictory material;
may create a significant risk to participants or communities.

Reviewers must declare relevant interests, protect confidentiality and apply the same evidential standards as the primary analyst.

Where the Practice Lead is also the primary analyst, Section 8.3 applies to any direct work with children.

6.9 Use of artificial intelligence and automated tools

Artificial-intelligence or automated tools may assist with authorised administrative, transcription or analytical tasks only where their use complies with the Practice’s information-security, privacy and project-specific ethical requirements.

The Practice will not delegate analytical authority to an automated system. In particular:

identifiable participant material must not be entered into any AI tool (Section 5.4);
an automated output must not determine whether an account is credible;
pattern naming and evidential conclusions require human judgement;
generated text must be checked against the source material;
errors, omissions and bias introduced by a tool remain the Practice’s responsibility;
material use of automated assistance must be recorded where it affects the analytical process or output.

6.10 Analytical audit trail

The Practice must retain an auditable record sufficient to show:

which material entered the analysis;
which framework and definitions were used;
how accounts were coded;
how patterns or divergences were identified;
what contradictory material was considered;
what review took place;
why the final claims were judged proportionate to the evidence.

The audit trail must protect participant confidentiality and must not be disclosed to a commissioner or institution merely to enable it to identify contributors or reconstruct protected accounts.

6.11 Ethical interpretation

Participants must not be reduced to data points detached from the context and consequences of the harm described.

Analysis must consider how institutional power, racialisation, age, dependency and credibility are operating within the evidence. It must also avoid assuming that every difference in experience has the same cause or meaning.

The Practice must remain alert to the possibility that its own framework, professional position or prior experience may influence interpretation. Material analytical judgements and uncertainties must therefore be documented and open to appropriate review.

Section 7: Reporting, Publication, Secondary Use and Participant Protection

7.1 Release planning

The intended audiences, outputs and publication routes must be considered during project design rather than only after analysis is complete.

Before releasing an output, the Practice must complete a documented release review addressing:

the purpose and intended audience;
whether the proposed use falls within what participants were told;
confidentiality and reidentification risk;
safeguarding implications;
legal and reputational risk;
evidential accuracy and proportionality;
the inclusion of quotations or distinctive details;
institutional naming and any right-of-response process;
funder, commissioner or partner interests;
accessibility for participants and affected communities.

An output must not be released while a material protection or evidential issue remains unresolved.

Individual Pattern Reflections and interview reflections are checked under Section 7.12 instead of a full release review.

7.2 Types of output

The Practice’s outputs may include:

Individual Pattern Reflections and interview reflections (Section 7.12);
anonymised pattern-evidence reports;
thematic or organisational reports;
research papers or briefings;
submissions to scrutiny, regulatory or policy processes;
presentations, training or public education material;
accessible participant or community summaries.

Each output must state its purpose, evidential basis and relevant limitations. A report must not be presented as representative of a population where the method does not support that claim.

7.3 Participant choices and analytical independence

The Practice must use a participant’s contribution only within the choices and permissions that apply to that contribution.

Where separate permission is required for quotation, attribution, publication or secondary use, the absence of that permission must be respected.

A participant may correct the inaccurate presentation of their own account. They may not require the Practice to:

alter another participant’s account;
suppress a properly supported pattern;
make a conclusion the evidence does not support;
remove relevant counter-evidence;
transfer control of the independent analysis to them.

The same limits apply to a commissioner, funder, school, partner or institution.

7.4 Anonymisation and small-number protection

Every proposed output must be assessed for direct and indirect identification risk.

Protective measures may include:

removing or generalising dates, locations, roles or demographic details;
withholding the name of an organisation;
combining or suppressing small categories;
paraphrasing distinctive wording with the participant’s agreement;
withholding a quotation;
delaying publication;
limiting circulation;
producing separate public and restricted versions;
deciding that the material cannot safely be released.

Small-number suppression must not be applied mechanically. The Practice must consider whether several details, harmless in isolation, could identify a person when combined.

In a commissioned engagement, no finding is reported from fewer than 5 accounts. This is a minimum, not a substitute for the check above.

Where adequate protection would require removing so much context that the finding becomes misleading, the Practice must reconsider the form or timing of publication rather than publish a distorted account.

7.5 Quotations and representation

Quotations must be used accurately, proportionately and within the permission given.

The Practice must not:

select quotations solely for emotional impact;
remove context in a way that changes meaning;
present a paraphrase as a direct quotation;
create a composite quotation without labelling it clearly;
use distinctive wording where the identification risk outweighs its evidential value;
translate or simplify a quotation without checking that its meaning has been preserved.

Where a participant’s words are edited for length, accessibility or anonymity, the change must not misrepresent their position.

7.6 Naming institutions and individuals

Research outputs never name an organisation or an individual. The most specific level they report is sector. The rest of this clause, and Section 7.7, apply only to reports prepared for a commissioning organisation about that organisation.

The decision to name an organisation or individual must be made through the release review and must consider:

the public-interest and accountability purpose;
the strength and nature of the supporting evidence;
identification and retaliation risks for participants;
safeguarding and legal implications;
whether naming is necessary to understand or act on the findings;
whether a less identifying alternative would achieve the purpose.

An institution does not gain a right to know who participated merely because it is named or invited to respond.

The Practice will not name an individual alleged to have caused harm unless there is a clear, lawful and ethically justified reason to do so and the evidential and legal implications have been appropriately reviewed.

7.7 Institutional response

Where an identifiable institution is materially criticised, the Practice must consider whether fairness requires an opportunity to respond before publication.

Any response process must:

protect participant identities and the firewall;
provide only the information necessary to understand the proposed finding;
specify a reasonable response period;
avoid transferring editorial or analytical control;
record the response or absence of response accurately;
distinguish the institution’s position from the Practice’s findings.

An invitation to respond does not create a veto or permit indefinite delay. The Practice may correct an error or reconsider a conclusion where new evidence warrants it, but will not suppress a finding merely because the institution disputes it.

Where contacting the institution could create a safeguarding risk, expose participants or compromise another process, the Practice may delay, modify or omit the response stage. The reason must be documented.

7.8 Independence from funding and commissioning

Funding or commissioning agreements must state that the Practice retains authority over methodology, analysis and findings.

A funder or commissioner may comment on factual accuracy, accessibility or whether the agreed scope has been addressed. It may not:

require a predetermined conclusion;
remove a finding because it is uncomfortable or reputationally damaging;
obtain raw accounts or identifying information without a separate ethical and lawful basis;
prevent publication contrary to the agreed independence terms;
present itself as owning participant testimony.

Any funder or commissioner review must be declared in the output where it materially affected the publication process.

7.9 Secondary use

Participant material must not be used for a new project, dataset, publication, training product or other materially different purpose merely because the Practice already holds it.

Before secondary use, the Practice must determine:

whether the use falls within the original participant information and choices;
whether renewed consent is required;
whether the lawful basis and privacy information cover the use;
whether the new context changes safeguarding or identification risk;
whether the use is compatible with the original ethical purpose;
whether a new assessment under Section 8.2 is required.

Where the proposed use would undermine the informed nature of the participant’s original choice, it must not proceed without a new ethical and lawful basis.

7.10 Return of findings and accessibility

Where practicable and safe, participants must be told how they can access the resulting output or an appropriate summary.

The Practice should consider:

child-accessible and plain-language summaries;
formats suitable for disabled participants;
whether participants need advance notice of publication;
the emotional or practical impact of receiving the findings;
whether public release could expose participants despite anonymisation;
how communities whose accounts created the evidence can access its benefit.

Returning findings does not require the Practice to disclose another participant’s account or confidential analytical material.

In a commissioned engagement, a plain-language participant summary is required. The commissioning organisation shares it, unaltered, with everyone invited to take part, within 8 weeks of the final report. It gives no count below 5 and no quotations.

7.11 Corrections, withdrawal and post-publication action

The Practice must provide a route for reporting factual errors, identification concerns or unintended harm arising from an output.

Where a material problem is established, the Practice may:

correct the output;
remove or replace a quotation;
restrict access;
publish a clarification;
pause further dissemination;
withdraw or retract the output;
notify relevant recipients.

Post-publication action must be proportionate to the issue and preserve an appropriate record of what changed and why.

A disagreement with a properly supported finding does not, by itself, require correction or withdrawal.

7.12 Individual Pattern Reflections and interview reflections

An Individual Pattern Reflection or interview reflection is prepared only when the participant asks for one and gives explicit consent. It is sent within 20 working days of a research form, or 30 working days of a research interview.

It names at most two patterns from the Practice’s pattern framework, and only where the account supports them.
Back-office coding and pattern candidates are never included.
A reflection about a child is prepared only for a contributor who confirms parental responsibility for that child.
A reflection is not an investigation, a finding about any person, school or organisation, or evidence for a complaint.

Before sending, the Practice checks the reflection against the account for accuracy, for identifying details of anyone else, and for safety, and records the date it was sent. This check replaces the release review in Section 7.1.

Reflections are offered only through the Practice’s research route. They are not part of commissioned engagements. People who take part in a commissioned engagement receive the participant summary instead (Section 7.10), and are told how to use the research route if they want a reflection of their own.

Section 8: Governance, Independence, Conflicts and Complaints

8.1 Overall accountability

The Practice Lead is accountable for ensuring that the Practice’s work complies with this policy.

That accountability includes:

maintaining the policy and supporting procedures;
ensuring that each strand of work is assessed before it begins (Section 8.2);
confirming that required safeguards are in place;
ensuring that people undertaking the Practice’s work are competent and appropriately supported;
maintaining ethical, safeguarding, incident and complaints records;
securing independent or specialist advice when required;
pausing or ending work that cannot be conducted ethically;
reporting accurately on the Practice’s governance and approval status.

The Practice Lead may delegate tasks but cannot delegate overall accountability for the Practice’s ethical conduct.

The operational roles below apply to every strand of work. One person may hold more than one role in a small practice, except where this policy requires independence, recusal or external review. The project records show who holds each role. Where one person holds several roles, the outside checks are the external routes that apply: the Information Commissioner’s Office for data protection, the local authority and the Local Authority Designated Officer for safeguarding allegations (Section 4.14), and the Independent Ethical Reviewer for any direct work with children (Section 8.3).

Role	Responsibilities	Decision authority	Escalation route
Practice Lead	Overall accountability under 8.1. Maintains the policy, records and governance.	May decide that a strand of work proceeds, proceeds with conditions, is paused or is declined (2.4). Cannot override a decision reserved to an independent role.	External specialist advice; the Independent Ethical Reviewer for any direct work with children.
Project Lead	Runs a strand of work day to day within its agreed scope and conditions.	May pause an activity. May not change scope, method or intended use without a further assessment (8.4).	Practice Lead.
Safeguarding Lead	Safeguarding decisions under Section 4. Keeps safeguarding records (4.13).	May pause or stop any activity immediately on safeguarding grounds. Decides whether to share information (4.7).	The external safeguarding advice source in the project records (4.2).
Data-Protection Lead	Lawful basis, privacy information, DPIA decisions, rights requests, retention and breaches (Section 5).	May pause or stop processing. Decides whether a breach is reported to the ICO (5.11).	Specialist data-protection advice; the ICO where required.
Independent Ethical Reviewer	Independent review of any direct work with children (8.3). Must meet the 8.3 criteria.	Approve, approve with conditions or decline. That work may not proceed without a favourable decision.	Records its reasoning. Disagreements are recorded and are not overridden by the Practice Lead.
Analyst or second reviewer	Analysis under Section 6. Second-person review where 6.8 calls for it.	May hold back a finding pending review. May not change a participant’s account.	Practice Lead.
Complaints	The Practice Lead receives and answers every complaint, including complaints about the Practice Lead.	The Practice Lead. There is no internal review above this.	The external routes in 8.7, where they apply.

Any person acting for the Practice may stop an activity at once where continuing would put someone at immediate risk, and must then tell the Safeguarding Lead.

8.2 Assessment before work begins

Before a strand of work involving participant accounts begins, the Practice Lead assesses it against Section 2.3 and records the outcome in the project records.

The assessment must confirm that the requirements of Sections 3 to 7 have been considered.

Particular care is needed where a strand involves one or more of the following:

children or young people;
adults who may be at risk;
highly sensitive or special-category data;
allegations of abuse, serious misconduct or criminal behaviour;
a substantial safeguarding or retaliation risk;
an institution controlling access to prospective participants;
identifiable or potentially identifiable publication;
linkage of several accounts or datasets;
a new or untested method;
a proposed method that would prevent a participant from making an informed choice;
a material conflict of interest;
intended legal, regulatory or formal accountability use;
a significant risk that the researcher’s interests could conflict with participants’ interests.

The Practice will not use covert or deceptive methods with participants. This does not prevent the ethical and lawful analysis of public records, published institutional material or other sources that do not involve participation under this policy.

8.3 Independent review

Independent review is required only before any direct participation by children or young people, unless a formal external ethics process has already provided adequate independent review.

An independent reviewer must:

have competence relevant to the ethical issues under consideration;
have no material financial, personal or institutional interest in the outcome;
understand and agree to the applicable confidentiality requirements;
receive sufficient information to assess the proposal;
record their decision, reasoning, conditions and limitations.

Independent review under this policy does not become formal institutional research-ethics approval merely because an external person has reviewed the project. The status of the review must be described accurately.

8.4 Ongoing review and project changes

Assessment is not a one-off event.

The project must be reviewed where:

the purpose, method, participant group or partner changes;
new risks or safeguarding concerns emerge;
an incident, complaint or data breach occurs;
a proposed output creates a new identification or legal risk;
the original assumptions prove inaccurate;
participants report an unintended burden or consequence;
a funder, commissioner or institution seeks additional control or access;
relevant law, guidance or professional standards change.

A material amendment must be approved before it is implemented, unless immediate action is required to protect a person from harm. Emergency action and the reasons for it must be recorded and reviewed as soon as practicable.

8.5 Partnerships, funding and commissioning

Before entering a partnership, funding or commissioning arrangement, the Practice must assess:

the partner’s purpose and interests;
its role in participant access, data processing and publication;
any power imbalance affecting participation;
whether it is implicated in the harm being examined;
whether it seeks access to identities, raw accounts or analytical decisions;
any conditions affecting independence or publication;
how complaints, safeguarding and data incidents will be handled;
whether responsibilities are clearly recorded in writing.

The Practice will decline or withdraw from an arrangement where adequate participant protection or analytical independence cannot be maintained.

8.6 Conflicts of interest

Anyone undertaking or reviewing the Practice’s work must disclose any actual, potential or perceived conflict of interest.

Relevant conflicts may include:

employment, funding or governance relationships;
personal or family relationships with participants or institutional personnel;
previous involvement in a complaint, grievance, investigation or legal process;
a live personal complaint or dispute with the institution concerned;
financial or professional interests in the outcome;
public advocacy or prior statements that could reasonably call independence into question;
access to confidential information obtained through another role.

A disclosed interest must be assessed and result in one of the following:

no further action, with reasons recorded;
additional transparency;
restricted access to specified information or decisions;
independent analytical or ethical review;
reassignment or recusal;
appointment of an independent project lead;
refusal or termination of the work.

Where the Practice Lead is personally involved in an active complaint concerning an institution, or where their own child or close family member is directly involved, the Practice must not undertake independent work concerning that institution unless the conflict can be removed through genuinely independent leadership and governance. Disclosure alone is not sufficient where objectivity or participant confidence cannot reasonably be protected.

Where the Practice Lead holds, or could hold, both a counselling relationship and a research or analytical relationship with the same person, this constitutes a dual-role conflict requiring disclosure and assessment under this section. The default position is that these roles should be held by different people wherever practicable. Where separation is not practicable, the conflict must be recorded, the reasons for proceeding without separation documented, and independent review under Section 8.3 obtained before the research relationship begins or continues.

8.7 Concerns and complaints

Participants and other affected people must have an accessible route to raise a concern or make a complaint about:

how participation was invited or conducted;
consent, assent or withdrawal;
safeguarding or confidentiality;
privacy and data use;
the representation of an account;
discrimination, disrespect or accessibility;
a conflict of interest;
an ethical or methodological failure;
the conduct of the Practice Lead or another person acting for the Practice.

Making a complaint does not result in retaliation, loss of an earned payment or avoidable disadvantage.

The complaints process must:

acknowledge the complaint and explain the process;
identify who will consider it;
provide, where possible, an indicative timescale and updates where necessary;
protect confidential information;
distinguish disagreement with a finding from a complaint about process or conduct;
record the evidence considered, outcome and reasons;
explain any available review or external route.

The Practice is a sole-practitioner practice. There is no internal review above the Practice Lead, who considers every complaint, including complaints about the Practice Lead’s own conduct. Each complaint is acknowledged, answered in writing with reasons, and recorded. Where something went wrong, the response says so plainly.

Where relevant, a complainant must also be informed of an appropriate external route, which may include the Information Commissioner’s Office, a safeguarding body, a funder, a formal ethics body or a professional regulator. The Practice must not imply that an external body has jurisdiction where it does not.

8.8 Ethical breaches, adverse events and incidents

An ethical breach or adverse event includes an action, omission or unintended consequence that materially compromises participant rights, welfare, confidentiality, agency, evidential integrity or the Practice’s independence.

When a breach or adverse event is identified, the Practice must:

take immediate action to reduce continuing harm;
consider whether participation, processing, analysis or publication must pause;
protect relevant records;
assess safeguarding, data-protection and legal implications;
obtain independent or specialist advice where required;
inform affected participants where appropriate and safe;
record the incident, decision and remedial action;
review whether findings, outputs or the decision under Section 2.4 remain valid;
update policy, training or procedure where necessary.

Serious or repeated breaches may result in removal of access, termination of a role or partnership, withdrawal of an output or referral to an appropriate external body.

8.9 Competence and support

No person may undertake an activity of the Practice for which they lack the necessary competence, training or support.

Competence requirements must consider:

the participant group;
the method being used;
safeguarding and disclosure responsibilities;
racialised and institutional power dynamics;
trauma-aware participation without converting the work into therapy;
data protection and confidentiality;
analytical and evidential judgement;
accessibility and communication needs.

The Practice must also consider the effect of repeated exposure to accounts of harm on the people undertaking the work. Appropriate supervision, consultation, workload limits or reflective support must be available without disclosing participant information unnecessarily.

Until the Practice has income, this support comes through the external safeguarding advice routes. Independent supervision will be arranged once the Practice has income.

8.10 Transparency and record keeping

The Practice must maintain sufficient records to demonstrate:

which version of this policy applied;
how each strand of work was assessed before it began;
who made the decision under Section 2.4;
what conditions were imposed;
how conflicts were managed;
what amendments, incidents or complaints occurred;
how final release decisions were reached.

Governance records must be accurate, access-restricted and retained according to the applicable schedule.

The Practice must be transparent about the difference between internal approval, independent review, partner review and formal institutional research-ethics approval.

8.11 Policy review and approval

This policy must be reviewed:

at least annually;
before a materially new strand of participant work begins;
following a serious incident, complaint or breach;
following a relevant change in law, statutory guidance or professional standards;
where experience shows that a provision is unclear or does not provide adequate protection.

Changes must be version-controlled and approved by the Practice Lead. Material changes affecting current participants or agreed uses must be communicated where required and may require renewed consent or project review.

Superseded versions must be retained in accordance with the Practice’s document-control arrangements so that the standards applying to earlier work can be established.

Required Supporting Instruments

This policy establishes the governing standard. The following operational instruments must exist, or be completed before the relevant activity begins:

project records (Section 1.5);
participant information materials;
adult consent record;
child and young-person information and assent materials;
parent or person-with-parental-responsibility permission record;
Safeguarding Response Protocol, with the interim safeguarding contact sheet and safeguarding tracker;
Research and Counselling Interface Protocol (the operational detail of routes, referral practice, support information and dual-role management between research participation and counselling support);
Support information (national support services, how to find local services, and Christ-centred resources where the Practice holds them), kept current.
safeguarding contact sheet and safeguarding tracker;
Privacy Notice and any project-specific privacy information;
Data Protection Impact Assessment, where required;
Data Retention Schedule;
research interview consent form;
IT and Information Security Policy;
confidentiality agreements for authorised personnel;
Declaration of Interest;
complaints record (Section 8.7);
Publication and Release Review Record;
incident and breach records.

The existence of a template does not establish that a requirement has been met. Each instrument must be completed and applied to the specific activity.

Reference Framework

This policy has been drafted with reference to:

the BACP Ethical Framework for the Counselling Professions and BACP Ethical Guidelines for Research in the Counselling Professions;
the Economic and Social Research Council’s research ethics guidance, including its guidance on consent and research with children and young people;
the Medical Research Council and ESRC joint guidance on involving children in research;
the Information Commissioner’s Office guidance on research provisions, valid consent, anonymisation and data protection by design;
Working Together to Safeguard Children 2026;
Department for Education information-sharing advice for safeguarding practitioners;
the Care and Support Statutory Guidance issued under the Care Act 2014;
applicable safeguarding-partnership and Local Authority Designated Officer procedures in the area where a project operates.

These sources inform the policy but do not by themselves confer formal ethical approval on the Practice or any particular project.

Document Approval

Approved by: Dionne Wilson-Brown

Role: Practice Lead

Approval date: 1 November 2026

Effective date: 1 November 2026

Next review date: 1 November 2027