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eIpnosis is edited, maintained and © Denis Postle 1999, 2000, 2001, 2002, 2003, 2004, 2005, 2006, 2007
This open letter is currently signed by five UKCP Member Organisations (listed at the end of the letter), and is being circulated now to organisations working in different modalities with an invitation to add their signatures (contact details at the end of the letter).

After careful consideration of the question of the ICO, we have decided that it is not compatible with the ethical position or orientation of our group to subscribe to the complaints procedures as currently formulated by ICO. This is for a number of reasons, which we set out below:

1. We have been increasingly concerned with the trend in the UKCP over the last five or so years to move away from a democratic representation of the different organisations involved. Instead, there have been more and more instances of a process, requirement or ideal imposed on Sections without proper consultation, followed by discussion over minor points as if to find some kind of compromise agreement, rather than a real representation of what is particular to the different Sections, and, of course, to the work of psychotherapy. Methods and practices from the business world are imported almost wholesale rather than the effort to formulate them from the starting point of what is particular to psychotherapy. The ICO is one example of this.

2. There has been correspondence to the UKCP and to the Department of Health to express disquiet at the way in which the ICO was formed. We do not believe that financial gain for its own sake is an acceptable ethical position for a psychotherapist. This concern is reflected not only in our code of ethics but also in that of most other organisations.

3. ICO procedures do not show a proper understanding of the psychological dynamics that may be at play in the formation of a complaint. The majority of those on any complaints panel need to be familiar with these in order to avoid potentially serious miscarriages of justice. All therapists are familiar with situations in which third parties have complaints about treatments even if these do not become formalised (the furious husband who blames the therapist for the fact that his wife leaves him after starting therapy etc).

4. The ICO code leaves unacceptably vague the question of what would constitute incompetent or unacceptable professional conduct. Current codes of ethics specify exactly what these are taken to be, yet the ICO relies on a ‘principle of charity’, according to which those making decisions will be eminently reasonable and knowledgeable about the facts of a given case. However, this principle would be absurd in any legal context and would be clearly open not only to abuse but also to misunderstanding. Current codes of ethics of most organisations do specify what actions therapists must avoid, and so any breach can be, at least in principle, assessed. It is worth remembering here that what constitutes a breach for one kind of therapy might not constitute a breach for another kind of therapy. Again, particularity matters here, and hence the importance of spelling things out clearly in the context of each organisation and orientation.

5. The suspension rules and criteria of ICO do not reflect principles of justice. If someone is suspended before proceedings have even started, this may have very damaging effects on ongoing treatments, not to speak of the economic question of the therapist's livelihood. If a complaint makes serious allegations, then the imperative is clearly to begin proceedings immediately and, if convicted, a suspension would no doubt begin. However, it is both unjust and fundamentally mistaken to give the ICO the power to suspend a therapist on the basis of unproven complaints.

6. The ICO rules seem to include little if any analysis of the current culture of complaint and the complaints industry which this has created. It must be recognised that the main motor of the complaints industry is financial gain and there is no shortage of lawyers who wish to exploit it. When we speak about the dangers of patients being exploited by therapists we need also to recognise the danger of patients being exploited by unscrupulous lawyers, possibly spurred on by the kind of framework that the ICO constitutes. A proper framework for complaints would need to give due consideration to this, as well as to the psychological dynamics at play in third party complaints, which seem to be encouraged by the ICO system.

7. The current framework of the ICO gives them an unacceptable power to issue procedural rules and regulations without proper consultation with those who are supposed to be bound by its rules. Again, there is an implicit appeal to a principle of charity which cannot really be taken seriously in the drafting of such important documentation. We simply do not know what procedural rules and regulations might be introduced in the future and although there have been promises of proper consultation, we must look to the formation of the ICO itself as an example of whether this will take place: and the fact is, this has not happened. Decisions are made, then people protest, then some small changes are introduced along with some wider consultation. Wider consultation does not happen at the beginning as it should in a democratic context. And of equal importance, there is currently no proper accountability of the ICO to those whom it supposedly serves.

Our conclusion is that we are unable to place our trust in the current ICO framework and we have serious concerns with the competence of those whose work it is. For these reasons we will not be signing up to ICO.

Arbours Association, 6 Church Lane, London N8 7BU

Centre for Freudian Analysis and Research, Suite 56, 571 Finchley Road, London NW3 7BN

The Guild of Psychotherapists, 47 Nelson Square, Blackfriars Road, London SE1 0QA

Philadelphia Association, 4 Marty’s Yard, London NW3 1QW

The Site for Contemporary Psychoanalysis, 35 Manor Road, Potters Bar, Herts EN6 1DQ

To add further organisational signatures this open letter, please email Ian Parker (

It will come as no surprise to eIpnosis regulars that we welcome, and are pleased to host, the Open Letter To The UKCP below.

We concluded in an earlier rumour about this take on the Independent Complaints Organisation [ICO] that it was well past its sellby date and the letter makes clear that its listed ingredients also make it an unacceptable threat to digestion.

That being said, a close look at the reasons for this NO to the ICO, shows that they closely mirror eIpnosis objections to the hegemony of UKCP and its mainstream partners that we have raised repeatedly for a decade and a half. It is tempting to rehearse them again here, but to cut to the chase, these ICO objections point to two consequences. One, that they also apply to the arranged marriage with the state that is now in sight for the mainstream therapies, and second, they apply with overwhelming certainty to any forseeable relationship between these five organisations and the HPC. If you think this is too strong, read the HPC documentation, take a look at the ENTO1 Counselling National Occupational Standards that the DoH has paid for, and keep in mind, Regulators don't negotiate.

Last word. Paragraph 5 of the Open Letter does not match eIpnosis recent, prolonged experience of researching failed complaints against the HPC (see Ipnosis HPC Special # 3). The professional abuse lawyers we consulted were even-handed and psychologically very sophisticated about the issues involved in the search for redress for abuses of civic accountability.

1 ENTO (formerly The Employment NTO) was formed by a merger in September 1997 of the Employment Occupational Standards Council and the Occupational Health and Safety Lead Board. It was in the first group of National Training Organisations to be recognised, and was the first all-sector NTO.

The organisation has wide experience in working with government agendas...
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