ipnosis has given bold emphasis to passages that seem relevant to psychopractitioners outside the psychoanalytic tradition.

Dear Colleague,

I am writing this letter to you and to all registrants in the PP and AP Sections of UKCP, in relation to certain developments in the profession which may have important repercussions for practitioners whose clinical work is founded on the discipline of psychoanalysis.

You may have heard that the British Confederation of Psychotherapists (BCP) intends to commence negotiations unilaterally with the Health Professions Council (HPC) with the intention of setting up a statutory register for three protected professional titles: psychoanalytic psychotherapist; Jungian analyst; and psychoanalyst. Obviously, this is a matter of concern for those who are not BCP registrants, since only those on the proposed statutory registers would, under these proposals, be entitled to use the above professional titles.

UKCP, while not specifically taking up the issue of the three psychoanalytic professional titles, has obtained an assurance from the Department of Health that BCP will not be allowed to proceed unilaterally with their negotiations but will be required to pursue any aspirations for state regulation via UKCP. The College, however, has taken up with HPC, and will now do so with the Department of Health and UKCP, the specific issues related to these three professional titles; so that no single group is able to monopolise them. Later in this letter, I will draw your attention to important reasons why, if you have not already done so, you might now wish to apply for membership of The College to safeguard your interests in connection with these serious matters.

I have also written to the Chairs of all organisations in the PP Section and AP Section of UKCP, strongly urging them to take a keen interest in what is going on between BCP and HPC. Clearly, HPC should be made aware that psychoanalytic training is not the sole preserve of BCP organisations and that many more organisations exist under the umbrella of UKCP which have been conducting such training for many years. The regulation of professional titles is not in itself a bad thing, so long as all interested parties are properly consulted on the question of who is qualified to be entered on the proposed registers.

Coupled with the above development is the news that UKCP has decided that it intends soon to publish two registers: one for psychotherapists and one for therapeutic counsellors. Apparently, it is their intention that none of the professional labels used hitherto, such as psychoanalytic psychotherapist, shall appear on their register of psychotherapists.

These developments may mean that it would no longer be possible for UKCP registrants in the PP Section and AP Section to indicate, on the UKCP register, the connection that their clinical work has with the discipline of psychoanalysis, whether as psychoanalytic psychotherapists, analytical psychologists or otherwise.

The primary preoccupation of The College is not with regulation of the profession and we have no wish, at the present time, to take any part in the regulatory process itself. We are a professional body and learned society whose aims are to further the discipline of psychoanalysis and the interests of its practitioners. Nevertheless, because we publish a Register of Practitioners, we are unable to ignore entirely the regulatory process and we acknowledge the duty which we have to the public in respect of our Register.

The College is also closely associated with the newly-formed separate, though closely-affiliated, College of Psychoanalysis (CPA) which hopes in the near future to run a clinical professional-doctorate programme in psychoanalysis, validated by a leading university.

Returning to the question of state-regulation of the profession by HPC, you might like to visit their website: www.hpc-uk.org. You might, in particular, be interested to see how three modalities of psychotherapy are already regulated by HPC and where the following professional titles are protected by statutory registers: art psychotherapist; art therapist; dramatherapist; and music therapist. If you have the opportunity of speaking to an art therapist, as I have done, it is quite a salutary glimpse of how things might develop in our own profession. All training courses in art therapy are now validated by HPC and there is almost limitless scope for complaints from members of the public against those on the register, based on a vague and undefined notion of "fitness to practise". Very little, if any, control of the profession now remains vested in what was formerly the professional body for art therapists: the British Association of Art Therapists (BAAT). That organisation retains a presence (clearly specified on the relevant HPC website page) which now appears to be little more than nominal. The effect of all of this is that a modality of psychotherapy, which was once governed by a vibrant professional organisation, is now effectively controlled by civil servants who have little understanding for psychotherapy of any kind. Any person or organisation can now apply to HPC to validate a course for training art therapists and completely bypass BAAT. Those who complete an HPC-approved course are entitled to be on the HPC register and to use the relevant professional title. Nobody who is not on the register is entitled to use that professional title. Practitioners who are on the HPC register cannot, however, be required to become members of BAAT.

Under these circumstances, it is vital to understand that, while BCP may hope to monopolise certain professional titles associated with psychoanalysis, the reality is that, if they were allowed to proceed with their plans, it would become HPC which controls all aspects of access to and use of these professional titles; as well as all complaints procedures. Provided courses for training comply with the criteria published by HPC (not BCP) there would be no power to exclude anybody who qualifies for registration. The end result of all this would be that those who wish to continue to use any of the usual psychoanalytic professional titles would be obliged to submit to governance exclusively by a body of civil servants; while their former professional body would have little if any influence or real relevance.

I might add that a comparable situation would arise if UKCP were to seek any form of state regulation by HPC. At the moment, it looks as if UKCP might consider alternative ways of dealing with state-regulation of psychotherapists and I hope that, in view of what I have said above, you will agree that they should be encouraged to do so.

Under the above circumstances and assuming that BCP is not allowed to pursue its plans unilaterally, the following serious issues remain:

UKCP is, under the terms of its constitution, obliged, to pursue regulation of the profession, only in the interests of members of the public. It is, by law, prevented from pursuing the interests of practitioners generally or, in particular, the interests of any one particular modality of psychotherapy, including psychoanalysis. BCP, on the other hand, exists solely for the purpose of furthering the interests of psychoanalysis, though only within the limited understanding they have of that modality. BCP is not prevented by law from furthering the interests of either their practitioners or the limited understanding of the discipline of psychoanalysis which they espouse. In fact, it is worth noting that BCP, unlike UKCP, failed in its attempt to obtain registration as a charity; when the Charity Commission found that its activities amount, not to regulation but to the promotion of a "trade list". All of this means that the discipline of psychoanalysis, as understood in its widest and most pluralistic sense, is represented by neither UKCP nor BCP. The PP and AP Sections of UKCP struggle to represent psychoanalysis as best they can between them. However, ultimately, each is a constituent part of UKCP and, as a result, suffers under the limited regulatory objectives which UKCP is obliged by law to pursue and the constitutionally-determined inability of the Governing Board of UKCP to give any real support to these two Sections on these vitally important issues.

If, as now seems likely, our profession does become subject to state-regulation, whether by HPC or some other statutory body, the most serious question for practitioners in the long term is likely to be the question of how the manner in which they become subject to complaints from members of the public is dealt with. I have already outlined the wide, indeed almost limitless, scope there would be for complaints under HPC. This is an area which should be of serious concern to all practitioners.

In the light of the above you might, as I suggested earlier, like to consider the benefits, if you are not already a member, of joining The College. We are the only professional organisation currently able to look after and further the interests of practitioners from every area of the psychoanalytic spectrum in relation to the issues which now face us. Joining The College does not necessarily mean that you would be calling yourself a psychoanalyst and I know that some practitioners would not wish to do so. However, if you look at both our flag statement on What is a Psychoanalyst as well as the preamble to our Register of Practitioners, both on our website, you will see various other professional titles there which we acknowledge that our members might use, rather than the title psychoanalyst. In particular, we acknowledge that some may use the professional title psychoanalytic psychotherapist or Jungian analyst.

If you are not already a member of The College and would like to join, please email: enquiries@psychoanalysts.org.uk (please ensure that you enter psychoanalysts and not psychoanalysis in the address or your email will end up elsewhere!) and an application form for membership will be sent to

you. If you do not have an email address, you may send an SAE to the address at the head of this letter, to register your request for an application form. We are unable to respond to such requests made by telephone, so please use every effort to make your request by email, if at all possible.

A very significant reason for being on the Register of Practitioners of The College is that, for UKCP registrants at least, it may soon be the only public register on which they can make clear that their clinical practice is connected with the discipline of psychoanalysis.

You are also invited to enquire about the clinical professional-doctorate programme which will be run by the College of Psychoanalysis (CPA). Although closely associated with the professional organisation of The College of Psychoanalysts, CPA is a separate organisation in its own right. It is concerned with academic programmes and post-graduate development generally, as well as research.

Please do not hesitate to contact me if you would like to discuss further any aspect of what I have written above.

I would like to conclude by drawing your attention to our forthcoming conference on 10th May which will feature Chris Oakley in conversation with Adam Phillips. You will find all the details on a flyer on the reverse of this page. You might like to circulate copies to colleagues who will not receive this letter.

Yours sincerely,

Jacques China President The College of Psychoanalysts - UK

Email: jacqueschina@psychoanalysts.org.uk

The College of Psychoanalysts (United Kingdom) is a company limited by guarantee No 4684476 (England & Wales) Registered Office 54 Compton Road London NI 2PB