MySafeTherapy
Safeguarding Policy

My Safe Therapy Ltd

Status: Approved

Owner: Safeguarding Lead / Data Protection Officer

Review Cycle: Annual or incident-triggered

Applies From: Platform launch onward

1. Purpose

My Safe Therapy Ltd (“My Safe Therapy”, “we”, “us”) is committed to safeguarding the wellbeing, dignity, autonomy, and safety of all individuals who access or provide services via our platform.

We recognise that individuals seeking mental health support may experience periods of vulnerability and distress. Our safeguarding approach balances:

Duty of care

Respect for autonomy

Proportional intervention

Clear legal and ethical boundaries

This policy ensures safeguarding risks are:

Identified early

Responded to appropriately

Managed by qualified humans

Documented and reviewed

This policy is designed to protect users, therapists, and My Safe Therapy Ltd from harm, misuse, and regulatory exposure.

2. Legal & Ethical Framework

This policy aligns with:

UK safeguarding principles

UK GDPR & Data Protection Act 2018 (risk-based processing)

BACP Ethical Framework for the Counselling Professions

ICO guidance on online services and vulnerable users

International digital mental-health best practice

Platform-based duty of care standards

3. Scope

This policy applies to:

All users of the My Safe Therapy platform

All therapists, counsellors, coaches, and clinical contractors

All employees, administrators, moderators, and support staff

All AI-supported tools operating within the platform

Safeguarding obligations apply regardless of geography, recognising that emergency responses vary by jurisdiction.

4. Definition of Vulnerability

A vulnerable individual may include (but is not limited to) someone who:

Expresses suicidal ideation, intent, or planning

Discloses self-harm behaviours or urges

Demonstrates severe emotional distress or psychological instability

Appears unable to maintain personal safety

Expresses feelings of being unsafe, trapped, or overwhelmed

Is at risk due to isolation, trauma, abuse, or acute crisis

Vulnerability is contextual, temporary, and dynamic.

It does not imply incapacity or diagnosis.

5. Safeguarding Principles

My Safe Therapy operates under the following principles:

5.1 Prevention

Safeguarding risks are identified as early as possible through:

Intake responses

User disclosures

Therapist observations

AI-based risk flagging (non-diagnostic)

5.2 Proportionality

Responses are matched to the level of risk, avoiding unnecessary escalation.

5.3 Least Intrusion

We respect user autonomy and privacy, intervening only when risk justifies action.

5.4 Human Oversight

Safeguarding decisions are made by qualified humans, never AI alone.

5.5 Clear Boundaries

My Safe Therapy is not an emergency or crisis service.

6. Platform Safeguards

My Safe Therapy implements layered safeguards, including:

6.1 Clear Service Boundaries

Prominent “Not for crisis use” messaging across the platform

Explicit disclaimers during onboarding and consent

6.2 Emergency Signposting

Immediate display of emergency resources when risk indicators appear

UK and international crisis resources provided contextually

Encouragement to contact local emergency services or trusted contacts

6.3 Therapist Vetting

Verified qualifications

Professional registration checks

Identity verification

Insurance verification

Ethical code acceptance

Manual approval prior to platform visibility

6.4 AI Safeguards

AI tools are supportive, not therapeutic

High-risk content triggers:

Output restrictions

Human review

Escalation pathways

AI does not provide crisis advice or clinical judgments

6.5 Access Controls

Role-based access to safeguarding data

Restricted visibility of sensitive records

Full audit logging

7. Safeguarding Escalation & Action

Where a safeguarding concern arises, My Safe Therapy may:

Conduct an immediate internal risk assessment

Provide clear, compassionate guidance to the user

Encourage external or emergency support

Suspend or restrict AI-only features

Pause or limit platform access if required

Notify assigned therapist (where applicable)

Log actions securely

⚠️ My Safe Therapy does not contact emergency services on behalf of users.

Responsibility for contacting emergency services remains with the individual, unless legally compelled otherwise.

8. Therapist Responsibilities

Therapists using the platform must:

Adhere to their professional ethical frameworks

Maintain appropriate clinical boundaries

Escalate safeguarding concerns promptly

Avoid providing crisis services beyond scope

Document safeguarding actions within their professional obligations

Therapists remain independent practitioners and are responsible for their clinical decisions.

9. Data Handling & Confidentiality

Safeguarding data is:

Treated as highly sensitive

Accessed only by authorised personnel

Logged and auditable

Retained only as long as necessary

Processed under GDPR lawful bases (vital interests / legal obligation)

10. Review & Accountability

This policy is reviewed:

Annually

After any safeguarding incident

Following platform feature changes

Upon legal or regulatory updates

Accountability rests with:

Safeguarding Lead

Senior Management

Data Protection Officer

EMERGENCY RESPONSE WORKFLOW

Internal Workflow

Risk identified

Immediate harm-prevention messaging displayed

Emergency resources provided

Human escalation triggered

Incident logged

Post-incident review conducted

Public Summary  

If you are in immediate danger or at risk of harm, please contact your local emergency services or a crisis helpline.

My Safe Therapy is not an emergency service and cannot contact emergency services on your behalf.

Explicit Limitation of Responsibility

My Safe Therapy:

Does not provide crisis intervention

Does not replace emergency services

Does not assume responsibility for real-time emergency response

This limitation is communicated clearly to all users.

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