Risk Management (Trainees) Policy

1. Purpose

The purpose of this policy is to set out how DLTC manages clinical, ethical, and operational risks associated with trainee counsellors and their clients. It ensures that all risks — particularly those involving client safety, safeguarding, or trainee competence — are addressed consistently and transparently.

2. Scope

This policy applies to:

  • All trainees on placement at DLTC;
  • DLTC Directors and Supervisors;
  • Clients allocated to trainees;
  • Training providers with whom DLTC collaborates.

It must be read in conjunction with:

  • Safeguarding Policy (v3)
  • Clinical Responsibility Policy
  • Placement Policy
  • Complaints Policy and Procedure
  • Indemnity and Complaints Policy
3. Definition of Risk

For the purposes of this policy, “risk” means any event or circumstance that could lead to harm, loss, or damage to clients, trainees, DLTC staff, or the organisation.

  • Clinical risk — e.g. client distress, suicide, or self-harm.
  • Operational risk — e.g. breach of confidentiality, data loss, absence of supervision.
  • Reputational risk — e.g. unprofessional conduct, poor communication, boundary violations.
  • Safeguarding risk — e.g. abuse, neglect, exploitation, or failure to report a concern.
4. Responsibilities

DLTC Directors

  • Hold ultimate accountability for identifying, recording, and reviewing risks.
  • Ensure risk registers and incident logs are maintained securely.
  • Act immediately in cases of serious harm, breach of confidentiality, or safeguarding concern.
  • Report notifiable incidents under RIDDOR or safeguarding law where required.

Supervisors

  • Monitor trainee fitness to practise during supervision sessions.
  • Address risks proactively and escalate serious matters to DLTC Directors.
  • Document discussions of risk and mitigation in supervision notes.
  • Support trainees to develop awareness and self-reflection around risk management.

Trainees

  • Identify, assess, and communicate any emerging risks to clients or themselves.
  • Follow agreed escalation routes: Trainee → Supervisor → DLTC Director → Emergency services (if immediate risk to life).
  • Maintain accurate records of client concerns, actions taken, and supervision outcomes.
  • Comply fully with the Safeguarding and Confidentiality policies.
5. Managing Clinical Risk
  1. Gather relevant information sensitively and without making assumptions.
  2. Discuss immediately with Supervisor or, if unavailable, contact a DLTC Director.
  3. Document the discussion, decision-making, and any agreed actions.
  4. If risk is urgent, contact emergency services (999) and then inform DLTC Directors.
  5. Follow up with written incident documentation within 24 hours.
6. Safeguarding and Escalation

All safeguarding concerns must be reported to the DLTC Safeguarding Leads (Directors) in line with the Safeguarding Policy. DLTC ensures all trainees receive safeguarding training as part of their professional training. Failure to report or escalate safeguarding concerns may result in suspension or termination of placement.

7. Incident Recording
  • All incidents, near misses, or complaints must be recorded in the DLTC Risk Register.
  • Each entry must include date, description, actions taken, and outcome.
  • The register is reviewed quarterly by DLTC Directors to identify patterns or training needs.
  • Records are stored securely under GDPR 2018 and retained for seven years.
8. Risk Mitigation and Prevention
  • Clear supervision contracts and boundaries for trainees.
  • Regular training and reflective practice.
  • Open communication channels between Directors, Supervisors, and trainees.
  • Annual review of placement risk assessments and procedures.
  • Continuous feedback loops with training providers to share learning outcomes.
9. Confidentiality and Data Protection

All information relating to risk management is confidential and shared only on a need-to-know basis. Documentation must follow GDPR and DLTC Privacy Notice requirements. Anonymised examples may be used for supervision or training purposes.

10. Review and Version Control

This policy will be reviewed annually or sooner if there are changes in law or practice requirements. Review Due: November 2026

v8.11.25 – Updated for alignment with DLTC Safeguarding, Placement, and Clinical Responsibility Policies; clarified escalation routes, roles, and documentation requirements.