Policies and Procedures

Here at BAC, we believe creating a great platform requires a foundation of trust
grounded on consistent expectations of all staff and service users behaviour. At BAC
Online we follow these Community Standards to help guide behaviour and codify the
values that underpin our community.
This is a living document, as we’re constantly refining our approach to meet the
needs of our community. However, these standards – safety, security, fairness and
authenticity – remain central in our efforts to help ensure safety and foster belonging.
We’re always working to make sure they’re upheld and enforced.

A good BAC online experience begins the moment you join our platform. That’s only
possible when you trust this platform and feel safe. As a result, we require that you
refrain from endangering or threatening anyone.

You should not commit physical or sexual assault, sexual abuse, sexual harassment,
domestic violence, robbery, human trafficking, other acts of violence. Members of
dangerous organisations, including terrorist, organised criminal and violent racist
groups, are not welcome on this platform. BAC is committed to working with law
enforcement as appropriate and responding to valid law enforcement requests.
We take suicide; self-injury, eating disorders and hard drug abuse extremely
seriously and work to help people in crisis.

You should not convey intent to harm anyone by your words or physical actions. We
also take threats of self-harm as seriously as we do actions and may intervene if we
become aware of a threat.

You should not make transactions outside of BAC’s payments system; commit
booking fraud or credit card fraud or launder money; attempt to drive traffic to other
sites or market unrelated products.

Fairness is what holds us together, what makes it possible for us to trust one
another, integrate seamlessly within communities and feel as if we can truly belong.

You should treat everyone with respect in every interaction. So, you should follow all
applicable laws and not treat others differently because of their race, ethnicity,
national origin, religious affiliation, sexual orientation, sex, gender, gender identity,
disability or serious diseases. Similarly, insulting others on these bases is not
allowed.

You should not share personal information to shame or blackmail others, target
others with unwanted behaviour, defame others, or violate our review and content
standards.

Your BAC online experiences should be full of delightful moments. Since our platform
is built on trust, authenticity is essential – it requires a balance of shared
expectations, honest interactions and accurate details.

You should not provide a false name or date of birth, use the platform for commercial
purposes without BAC’s permission, maintain duplicate profiles, or create a profile if
you’re under 18.

You should not provide inaccurate information, have incorrect availability, mislead
people about your experience, nature or details of your profile, set up fake or
fraudulent profiles, leave fraudulent reviews, engage in deceptive pricing, or fail to
disclose any details that may fall foul of safeguarding policies.

This policy is designed to inform on what constitutes a complaint and a compliment. Further, this document outlines the responsibilities of BAC in relation to dealing with and recording the latter, detailing the relevant procedures. The procedures ensure the correct identification, receipt, recording, investigation and resolution of complaints in order to comply with legislation and ensure a fair and transparent process. The aim of Beecholme Adult Care (BAC) is to provide high quality, transparent and accessible service and as such, we need to know when we get things wrong. BAC listens to complaints and treats them seriously and with sensitivity in order to continuously improve the service provided.

For the purpose of this document, a complaint is a statement that something is deemed to be unsatisfactory or unacceptable by someone, whether justified or not and needs a response. Compliment for the purpose of this policy is a written expression of praise, gratitude or congratulation.

This policy applies to all staff, customers and counsellors. Therefore, the policy considers internal complaints, independent complaints and complaints handled by external agencies. The policy covers complaints and compliments about:

• The standard of service expected from BAC.
• The behaviour of the staff in delivering the service.
• Any action or lack of action by staff affecting an individual or group.

This policy does not cover:

• Matters that have been already fully investigated by this complaints procedure.
• Complaints that we deem do not warrant detailed investigation such as suggestions for improvements or repeated malicious submissions of complaints.

BAC will not reply to rude or abusive emails, phone calls or letters.

BAC offers an online coaching and therapy service to clients who are currently seeking some kind of support in their lives. Some of our clients might be vulnerable at present and may express mental health issues which can result in unexpected behaviour contributing to difficult communication and problems may arise, sometimes resulting in complaints. Further, complaints can also be received from professionals (coaches and therapists) who are working or aim to work with BAC.

• We treat all our complaints seriously, whether they are received by email, letter or verbally in person.
• We will treat your complaint promptly – we will acknowledge the receipt of a written complaint within 5 working days and we will send you a full reply within 20 working days of receipt.
• If we cannot send a full reply within 20 working days of receiving your complaint, we will tell you the reasons why and let you know when we will be able to reply in full.
• All complaints received will be dealt with confidentiality and in accordance with the requirements of the Data Protection Act 2018.

You can make a complaint by email, post, by speaking to our staff on the phone. 

Please forward your complaint to: online@beecholmeadultcare.co.uk or in writing to: 2-4 Beecholme Avenue, Mitcham, Surrey, CR4 2HT.

We have a 2-stage complaint procedure. At each stage, it will help us to resolve your complaint quickly if you provide us with clear and detailed information including any relevant documentation. 

Stage 1

The majority of complaints are resolved on the first contact. Once received the complaint is dealt with by dedicated staff within the specified timescales. 

Stage 2

If you are dissatisfied with the way your complaint has been handled, please consider the following contacts for taking your complaint further:

The Local Government Ombudsman
PO Box 4771
Coventry
CV4 0EH
Tel: 0845 602 1983 or 024 7682 1960
Fax: 024 7682 0001
advice@lgo.org.uk

You can also contact Citizens Advice on 03444 111 444 for general advice and guidance.

All Coaches and Counsellors agree to:

• Always conduct themselves to the highest levels of ethics, integrity, accountability, and
  responsibility.
• Treat all clients and potential clients with absolute dignity, confidentiality and respect as free
  and equal individuals.
• Maintain the good reputation of the coaching profession in general and The BAC online
  platform in particular.
• Comply with both the spirit and the letter of any commercial agreements made with clients,
  potential clients, The BAC online platform.
• Enter into any arrangement or agreement that may impair the coaching relationship.
• Not knowingly take any personal, professional or monetary advantage or benefit of the
  coach-client relationship, except by a form of compensation as agreed in the pre-session
  agreement.
• Keep appropriate and accurate records of your work with clients and ensure they will remain
  confidential, are stored securely and comply with GDPR requirements.
• Maintain professional boundaries with all current clients and/or sponsors.
• Have professional indemnity insurance adequate to cover your coaching and/or coaching
  supervision practice.
• Represent true levels of status, title, competence and experience in order not to mislead,
  misrepresent or defraud.
• Clearly state to clients and potential clients the terms of any commercial agreement including
  the expectations of both parties.
• Be aware of and actively manage any power or status difference between the client and
  coach that may be caused by cultural, relational, psychological or contextual issues.
• Assure consistent quality of coaching regardless of the amount or form of agreed sessions.
• Make no claims or implications of outcomes that cannot be demonstrated or guaranteed.
• Agree to the monitoring of the quality of your work through feedback from clients and other
  appropriate professionals.
• Have qualifications, skills and experience appropriate to the needs of your client. If not refer
  your client to those who do, such as more experienced coaches or counsellors.
• Respect the absolute rights of the client's confidentiality except as expressly permitted by the client or potential client in writing or as required by law.
• Avoid all conflicts of interest and give notice of such potential conflicts.
• Refrain from offering professional information or advice that you know to be confidential, misleading or where the accuracy is beyond your competence to assess.
• Endeavour to enhance public understanding and acceptance of professional coaching.
• Hold responsibility for being aware of and setting clear, appropriate and culturally sensitive boundaries that govern interactions, physical or otherwise.
• Do not participate in any sexual or romantic engagement with client(s) or sponsor(s). Be ever mindful of the level of intimacy appropriate for the relationship. Take any appropriate action to address the issue or cancel the engagement.
• Be fit and healthy enough to practice. If not, you should stop until you are and, if necessary, your clients should be offered alternative support.
• Continually develop professionally in both the theory and practice of coaching.
• Respect all copyrights, agreements, work, intellectual property and trademarks and comply with all laws covering such areas.
• Avoid coaching minors (people who have not yet had their 18th birthday) without the express written consent of parent, guardian or teacher as appropriate.
• Respect the clients right to terminate the coaching relationship at any point during the process, subject to the provisions of the agreement or contract.
• Contact BAC Online immediately if you find yourself in a situation, which may create conflict, litigation or bad publicity.
• Comply with all laws and by-laws of the UK and, if coaching clients based abroad, with the laws of the clients’ country.
• Respect the commercial confidentiality of BAC online by not divulging business information to any third parties.
• Make a copy of this Code freely available to clients if they request it.

The challenge with working ethically means that coaches will inevitably encounter situations that require responses to unexpected issues, resolution of dilemmas and solutions to problems. This Code of Conduct is intended to assist those persons subject to the Code by directing them to the variety of ethical factors that may need to be taken into consideration and helping to identify alternative ways of approaching ethical behaviour

***The Serious Incident Policy should be used in conjunction with this policy***

This policy is designed to ensure compliance with the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014:Regulation 20, to ensure that as a care provider Beecholme Adult Care (BAC) is open and transparent with its customers and other relevant persons in general and in relation to care and treatment. Further, the policy sets out the procedures BAC’s staff and counsellors must follow when things go wrong including informing people about any incident, providing reasonable support, truthful information and an apology when things go wrong.  

Candour: The state or quality of being open, honest, frank and sincere.

Moderate harm: Harm that requires a moderate increase in treatment, or significant harm which is not permanent.

Notifiable patient safety incident: Any unintended or unexpected incident that occurred during the provision of a regulated activity that did or could result in death or harm.

Severe harm: A permanent lessening of bodily, sensory, motor, physiologic or intellectual functions, including removal of the wrong limb, organ or brain damage.

Claim: Any demand, however, made, but usually by the service user’s legal adviser, for monetary compensation in respect of an adverse clinical incident leading to a personal injury. 

This policy and the relevant procedures apply to all staff working for BAC (including Counsellors). All staff and counsellors should comply with the requirements of this policy and report all incidents promptly to ensure that the most appropriate actions are taken. 

BAC is committed to fulfilling its obligation around ‘Duty of Candour’ by communicating with the customers any failure in the services provided whether they be the result of a safety incident, complaint or claim. This policy deals with the information and methods of sharing that information with customers. The extent to which it is enacted will be determined on the grading of the severity of the event. Further information on the grading of harm is contained in the table found at the end of this policy. 

‘Duty of Candour’ is triggered when there is: 

• Death or severe harm 
• Moderate harm- when there is a moderate increase in treatment and/or significant, but no permanent harm.

Under this policy and the relevant legislation BAC staff and counsellors must ensure that the following is conducted: 

As soon as practicable after becoming aware that a notifiable incident has occurred staff must :

• Notify the relevant person that the incident has occurred and:
• Provide reasonable support to the relevant person in relation to the incident, including when giving such notification.

The  notification to be given must:

• Provide an account, which to the best of the service’s knowledge is true, includes all the facts known to BAC about the incident as at the date of the notification.
• Advise the relevant person what further enquiries into the incident are appropriate
• Include an apology.
• Be recorded in a written record which is kept securely.

As a starting point, staff should notify the client or the relevant person. This initial notification will include an apology and must be provided as soon as is practicable. In addition to this staff  involved should always inform their manager and were requested:

• Provide all information directly relevant to the incident which will be a step by step factual explanation of what has happened.  
• Advise and, if possible, agree with the customer what further enquiries are appropriate.  
• Provide reasonable support to the customer. 

Following an incident, the client should receive a sincere expression of sorrow or regret for any harm from the incident as early as possible. This is not an admission of liability, but an acknowledgement of the person’s distress at that time which may mitigate the trauma suffered and potentially avoid any complaint or claim being made. The apology can be made by the member of staff or counsellors involved in the incident but may be made by any member of staff if it is decided this is more beneficial.

Should the incident result in an investigation, then the designated manager should take the lead.

The level and depth of the investigation will be in line with the seriousness of the incident.

In many cases, the investigation will be immediate and short with the apology, explanation and results of the investigation being delivered all at the same time.

In other cases, there may be three distinct stages, the apology, the explanation and the results of the investigation. The process for investigating the incident should be explained to the service user and/or their carer informing them that as any new information emerges as a result of any investigation they will be kept up to date. The Investigator for the incident is responsible for liaising with and providing information in a timely, truthful and open manner to the service user and/or carer in line with the agreed investigation process. Managers must consider BAC’s Serious Incident Policy and procedures when conducting an investigation. 

Should the client disagrees with the information they have been provided with, the following strategies may assist:

• Write a comprehensive list of the points that the client disagrees with and reassure them you will follow up these issues.  
• Offer the client another contact person with whom they may feel more comfortable. 
• Use a mutually acceptable mediator to help identify the issues and to look for a mutually agreeable solution.
• Ensure the client is fully aware of the formal complaints procedures.

The general procedures under this policy may be modified in particular circumstances that include, but are not limited to: 

• When a client dies
• When there is a corresponding criminal enquiry 
• Client lack capacity

All communication should be recorded, including the initial apology and explanation. A detailed note of this must be also placed on the service user’s personal file. 

Once the person(s) concerned have been told in person about the incident, this should be followed by a written note of the discussion. With serious incidents and complaints, the relevant procedure within the policies must be followed. 

Staff should make every reasonable effort to contact the relevant people through various communication means. All attempts to contact the relevant people should be documented. If the relevant person declines to contact BAC, their wishes should be respected and a record of this kept.

Discussions around the time of an incident should be recorded in the service user record. Any subsequent meetings should be minuted and followed up by letter.

The outcomes or results of any enquiries and investigations should also be provided in writing to the relevant people, should they wish to receive them. Any correspondence from relevant person(s) relating to the incident should be responded to in an appropriate and timely manner and a record of communications kept.

The relevant person should be advised on what further enquiries are appropriate and they should be given all reasonable opportunity to be involved as much as they wish to be in the progress of any enquiries. New information may emerge during the course of any inquiry into the incident, and the relevant people must be informed of new information as it arises.

• Speak to the client when they are best able to understand and retain the information and have someone with them who can support them.
• Give the client the information they want or need to know in a way that they can understand and avoid jargon.  
• Take into account that the client may find receiving the information distressing and to carry this out in a considerate way, respecting their right to privacy and dignity.  
• Say “ I am sorry” rather than a general expression of regret about the incident on the organisation’s behalf. 
• Give information about Independent Advocacy, counselling and or details for other mechanisms of support. 

Clients are entitled to expect they will continue to receive all usual support and continue to be treated with respect and compassion. If a client expresses a preference that their support needs be taken over by others, the appropriate arrangements should be made for them to receive the support with other professionals. Clients should be reassured that they will continue to be supported according to their needs even in circumstances where there is a dispute between them and the team. They should also be informed that they have the right to continue their support elsewhere if they have lost confidence in the team involved in the incident, complaint or claim.

• Act in an open and transparent way with relevant persons in relation to care and treatment provided to people who use our services in carrying on a regulated activity.
• Tell the relevant person as soon as reasonably practicable after becoming aware that an incident has occurred, and provide support to them in relation to the incident, including when giving the notification.
• Provide an account of the incident, which to the best of its knowledge is true, of all the facts that it knows about the incident as at the date of notification.
• Advise the relevant person what further enquiries it believes are appropriate.
• Offer an apology.
• Follow this up by giving the same information in writing, and providing an update on the enquiries. 
• Keep a written record of all communication with the relevant person.

The purpose of this Policy is to outline the principles that must be observed by all who work for Beecholme Adult Care (BAC) and who have access to personally identifiable information and/or confidential information. This policy, in addition to our Data Protection Policy, aims to secure full compliance with the requirements of the Data Protection Act 2018.

It is important that BAC protects and safeguards person-identifiable and confidential information that it gathers, creates, processes and discloses, in order to comply with the law and to provide assurance to service users, their families and the public where applicable. This policy sets out the requirements placed on all staff when sharing information within BAC and between BAC and other organisations/persons.

Person-identifiable information is anything that contains the means to identify a person (e.g. name, address, postcode, date of birth, NHS number).

Confidential information is commonly thought of as health information, but it can also include information that is private and not public knowledge or information that an individual would not expect to be shared. Such information can include, but it is not limited to: patient’s health information, employee records, occupational health recordset. In the context of BAC, it also includes BAC’s confidential business information, information relating to patients and staff,  however, stored. 

When referring to information, we consider such that may be held on paper, CD/DVD, USB sticks, computer file or print out, laptops, mobile phones, digital cameras and that distributed by word of mouth.

This policy applies to all staff that works for BAC, including contractors and other visiting professionals.

BAC is responsible for protecting all the information it holds and must always be able to justify any decision to share information. Wherever appropriate, we anonymised any person-identifiable information by removing as many identifiers as possible. 

Data Protection Officer (DPO) – DPO of BAC is the Director – Myron Agyiri. The latter, when needed, provides advice to the organisation and its employees on data protection issues and ensures the organisation’s compliance with data protection law.

The Director of BAC is responsible for ensuring that the contracts of all staff and Counsellors are compliant with the requirements of the policy and that confidentiality is included in corporate inductions for all staff.

Staff and Counsellors – Confidentiality is an obligation for all staff and Counsellors. There is a confidentiality clause in their contract and it is mandatory to participate in induction training and awareness sessions carried out to inform and update staff on confidentiality issues. Any breach of confidentiality or inappropriate use of business/work-related data is a disciplinary offence, which may result in dismissal or termination of employment contract, and must be reported to an appropriate line manager as soon as it occurs. 

Information whether person-identifiable and/or confidential should be generally disclosed when:

• The information is required by law or under a court order.
• It is required for a specific purpose, with the individual’s written consent.
• The disclosure is necessary for the protection of the public and is likely to be in relation to the prevention and detection of serious crime. 

*****Breaches of confidentiality could be regarded as gross misconduct and may result in serious disciplinary action up to and including dismissal.*****

All BAC staff and Counsellors must adhere to the following:

• Person-identifiable or confidential information must be effectively protected against improper disclosure when it is received, stored, transmitted or disposed of
• Access to person-identifiable or confidential information must be on a need-to-know basis.
• Disclosure of personally identifiable or confidential information must be limited to that purpose for which it is required.
• Recipients of disclosed information must respect that it is given to them in confidence. 
• If the decision is taken to disclose information, that decision must be justified and documented.
• Any concerns about disclosure of information must be discussed with the Director.
• All data stored online should not be shared with any external persons or bodies at any time. 
• Unwanted printouts containing person-identifiable or confidential information must be shredded and be put into a confidential waste bin. 
• If staff have any concerns about disclosing information they must seek advice from their manager 
• When sharing person-identifiable and/or confidential information on-line via email, ensure the file that is sent with it is password protected.
• Staff must NOT forward any person-identifiable or confidential information via email to their personal email accounts.
• Staff must not use or store person-identifiable or confidential information on a privately-owned computer or device.
• Passwords must be kept secure and must not be disclosed to unauthorised persons. 
• Staff must not use someone else’s password to gain access to information.
• If staff need to take person-identifiable or confidential information home they have a personal responsibility to ensure the information is kept secure and confidential. This means that other members of their family and/or their friends/colleagues must not be able to see the content or have any access to the information.

BAC Staff and Counsellors may be held personally liable for a breach of confidence and must not:

• Leave any person-identifiable or confidential information lying around unattended, this includes telephone messages, computer printouts, faxes and other documents.
• Talk about person-identifiable or confidential information in public places or where they can be overheard.
• Leave a computer terminal logged on to a system where person-identifiable or confidential information can be accessed, unattended.
• Disclose any information to the press, unless authorised by your manager and subject to statute.

All staff and Counsellors are expected to have read and fully familiarised with this policy and procedures. In addition, staff are given confidentiality training as part of their induction.

Additional reading 

In order to build a platform of trust, we need to ensure that reviews on BAC Online
are useful, informative, and do not expose our community to harm. Therefore, BAC
expects that all reviews adhere to the following:

Reviews should not violate our content policy.

Some content is never allowed on BAC Online please read our content policy.
Reviews will be posted immediately after being published, and they cannot be edited
once posted.
Clients will have the opportunity to leave a review for up to 14 Days after a booked
session has been completed.

Reviews should be unbiased.

Reviews are most helpful when they provide unbiased information.
You are not allowed to incentivise positive reviews, to use the threat of a negative
review to manipulate the desired outcome, or to influence another’s review with the
promise of compensation.
You are also not allowed to accept any type of compensation in exchange for a
positive review, use a second alias to leave yourself a review, or coordinate with
entities’ to get positive reviews.

Reviews should be relevant.

Keep your reviews relevant to BAC Online and the service or session you have had.
Other potential service users are reading your reviews to learn about the counsellor
or therapist. Reviews that are off-topic are distracting and don’t help our service
users make informed booking decisions. For this reason, reviews should focus on
your interactions with BAC Online and your sessions with counsellors or therapist.

To keep reviews relevant, we recommend avoiding the following:

• Commentary about a person’s social, political or religious views
• Profanity, name-calling, and assumptions about a person’s character or personality
• Content that refers to circumstances entirely outside of another’s control
• Content about services not related to BAC Online
• Commentary about past BAC Online sessions, hosts, counsellors or therapist, or about the BAC Online product where it does not relate to the session or BAC Online service you are rating.

When we receive a report of a review that violates this policy, we may remove the
review from our platform. Repeated violations may lead to suspension or permanent
deactivation of responsible account(s).

To report a review for violating BAC Online review policy please contact us at
online@beecholmeadultcare.co.uk

If you feel a review is untrue

While we encourage and expect all clients to post reviews that contain objective and
accurate information, BAC Online does not mediate disputes concerning truth or
fairness. We expect the author of the review to stand behind the content of their
review. Reviews can only be removed if they violate BAC Online review policy.

The purpose of this policy is to ensure that relevant procedures are put in place to enable employees and Counsellors working for Beecholme Adult Care (BAC) to challenge poor or dangerous practice. This policy has been written to take account of the Public Interest Disclosure Act 1998 which protects workers making disclosures about certain matters of concern when those disclosures are made in accordance with the Act’s provisions and in the public interest.

We recognise that everyone providing health and care services has a duty to follow professional codes of conduct, and put clients and people they care and support for first, whilst protecting their safety.  We see whistleblowing as a positive act that can make a  valuable contribution to Beecholme Adult Care’s efficiency and long term success. 

Definition 

Government definition states that “ you are a whistleblower if you’re a worker and you report certain types of wrongdoing.” wrongdoing should be something the employee has seen at work, but not strictly necessary. In addition, the wrongdoing disclosed must be in the public interest, therefore affecting others such as the general public. 

Scope 

The Policy applies to all employees of BAC, contractors and other professionals working on or for  BAC. This policy intends to enable all those who become aware of possible wrongdoing on the premisses of BAC, and if this affects any person or the service, to report their concerns at the earliest opportunity so that they can be properly investigated.

General Procedures and Guidance for staff and Counsellors

Any person wishing to raise concerns should report the matter to the manager (BAC staff) or to BAC staff (Counsellors). In the event that the concerns relate to the manager, they should be reported to the director of BAC. If you feel that both have failed to appropriately handle your concerns, report your complaint directly to the contacts provided at the end of this policy document. We will always listen to your concerns and decide if any action is needed. We may ask you for additional information and designate someone to keep you informed about the actions taken. All staff should raise a concern should they genuinely, honestly and reasonably believe that the safety of our service users is breached and/or the level of care we provide is inadequate and dangerous. However, staff and Counsellors should always consider the following before resorting to whistleblowing externally:

• Can you tackle the issue, concern, wrongdoing there and then, by politely yet firmly challenging it.
• Raise the issue to the manager, including the Director of BAC.
• If you do not feel able to raise your concern with the above stated, then consult this policy and contact the external numbers provided.

Making your claim

• You must tell us straight away if you don’t want anyone else to know it was you who raised the concern.
• You can tell us anonymously about a concern, but in this, we may not be able to take the claim further if you haven’t provided all the information we need.
• You can give your name but request confidentiality, any other person or body you tell should make every effort to protect your identity.
• If you report your concern to the media, in most cases you’ll lose your whistleblowing law rights.

You may raise your concern by telephone, in person or in writing.  The earlier you express your concern, the easier it is to take action.  You will need to provide the following information:

• The nature of your concern and why you believe it to be true.
• The background and history of the concern.

In addition, you will need to demonstrate that you have a genuine concern relating to suspected wrongdoing or malpractice within BAC and there are reasonable grounds for your concern. You may wish to consider discussing your concerns with a colleague first and you may find it easier to raise the matter if there are two (or more) of you who have had the same experience or concerns. You may invite a  representative or a friend to be present for support during any meetings or interviews in connection with the concerns you have raised.

A member of staff or Counsellor will never be disciplined for raising a concern so long as they follow the procedures in this policy. We promise that you will be given full support by management, your concern will be taken seriously and we will do anything we can to support you throughout the investigation. However, disciplinary action could be taken if someone used the whistleblowing procedures to raise false concerns intentionally and or in bad faith. BAC will take any steps necessary to ensure that those who raise concerns are protected from bullying or victimisation by fellow workers. 

Within 10 days of you raising a concern, whoever is investigating your concern internally will notify you that the concern has been received, indicating how we propose to deal with the matter, supply you with information on staff support mechanisms and tell you whether further investigations will take place and if not, why not.

Raising your concern externally (exceptional cases)

The main purpose of this policy is to give you the opportunity and protection you need to raise your concerns internally. The Company would expect that in almost all cases raising concerns internally would be the most appropriate action for you to take. 

However, if you feel you cannot raise your concerns internally and you honestly and reasonably believe the information and any allegations are true, you should consider raising the matter with an appropriate ‘prescribed person’. The identity of the appropriate prescribed person will depend on the nature of your concern. However, they must be one of those prescribed by an order made by the Secretary of State for the purposes of the Employment Rights Act 1996 Section 43F. The Public Interest Disclosure (Prescribed Persons) Order 2014 (as amended) lists the prescribed persons. 

If you have good reasons for not using the internal disclosure procedures or the disclosure procedure described above, you may consider making wider disclosure by reporting the matter to the police or to the media, for example. However, whistleblowers who make wider disclosures of this type will only be protected in certain circumstances. The Company recommends that you take legal advice before following this course of action since we believe it will be in your own interests to do so.

Protection for whistleblowers

You may be worried that by reporting your concerns you will be opening yourself up to victimisation or detriment, or risking your job security. However, all staff benefit from statutory protection if they raise concerns in the right way and do so with the reasonable belief that raising the concern is in the public interest. This protection means that employees must not be dismissed or suffer any detrimental treatment as a result of raising a concern. As it will be in your own interests to do so we would encourage you, in particular, to ensure you have a reasonable belief that the disclosure you wish to make is in the public interest as this is one of the requirements that must be met in order to obtain the statutory protection mentioned earlier.

Staff must not threaten or retaliate against whistleblowers in any way. This will be regarded as gross misconduct and may result in those involved being dismissed without notice or payment in lieu of notice.

If you believe that you have suffered any detrimental treatment, you should inform a Director immediately. If the matter is not remedied you should raise it formally using our Grievance Procedure.

Suspected malpractice

BAC encourages you to report suspected malpractice in relation to our activities. We construe malpractice widely and this includes:

• Any illegal activity at the Company.
• Any activity that causes the Company to breach its legal obligations.
• Any activity that causes the Company to endanger the health and safety of any person.
• Any activity that damages the environment.
• Any attempt to willfully conceal any information that tends to show malpractice.

You are not required to obtain evidence of malpractice before raising your concern. As such you must not commit an act or acts of misconduct, breach company rules or damage the Company in any way in order to obtain information. The Company is committed to ensuring that you work in an environment in which you can raise concerns and there is no question of you having to prove anything. The Company will support employees, who with the reasonable belief that it is in the public interest to do so raise concerns under this policy, even if they turn out to be mistaken.

The following is an example list of what you can report under this policy:

• Conduct which is an offence or a breach of the law (a criminal offence has been committed or failing to comply with any other legal obligation) disclosures related to miscarriages of justice.
• Racial, sexual, disability or other discrimination.
• Health and safety of the public and/or other employees.
• Unauthorised use of funds. 
• Possible fraud and corruption.
• Neglect or abuse of service users, or
• Other unethical conduct.

Personal grievances (eg bullying, harassment, discrimination) are not covered by whistleblowing law unless your particular case is in the public interest.

Contacts

• Whistleblowing Helpline – 08000 724725
• Public Concern at Work-  020 7404 6609

Additional reading 

https://www.gov.uk/whistleblowing Whistleblowing for employees  

This document is produced to ensure Beecholme Adult Care (BAC) compliance with statutory regulations under the Health & Safety at Work etc. Act 1974 and other related legislation/guidance. Further, this policy is written with the aim of achieving a positive attitude and approach towards our staff and counsellors, preventing incidents of abuse.

Definition 

The Health and Safety Executive (HSE) defines violence at work as “any incident in which an employee is abused, threatened or assaulted in circumstances relating to their work.”

When referring to the abuse we consider the following:

• Non-physical abuse- the use of inappropriate words or behaviour causing distress and/or constituting harassment. 
• Physical abuse– the intentional application of force against the person of another without lawful justification resulting in physical injury or personal discomfort.
• Anti-social behaviour– the following are examples of anti-social behaviour that are not acceptable at or in connection with work:  excessive noise (such as shouting); threatening or abusive language including excess swearing or offensive remarks or gestures; derogatory racial, religious or sexual remarks or behaviour;  malicious allegations relating to members of staff; inappropriate behaviour as a result of alcohol or misuse of illicit drugs, including non-prescribed medication or drugs  Intimidation; threats or threatening behaviour; harassment or stalking; violence, perceived acts of violence or threats of violence; any explicit or implicit challenge to the safety, well-being or health of any member of staff; brandishing weapons or objects which could be used as weapons.

Scope

This Policy applies to violence and aggression towards all BAC employees as well as to employees of external contractors, including agency staff and other visiting professionals. This policy applies to situations arising during the course of professional duties or due to employment. It also applies to those undertaking work on behalf of BAC, whether from service users, other staff or members of the public.

Context

BAC offers an online coaching and therapy service to clients who are currently seeking some kind of support in their lives. Some of our clients might be vulnerable at present and may express mental health issues which can result in unexpected behaviour contributing to difficult communication and can become agitated, aggressive and violent towards staff and counsellors. complaints can also be received from professionals (coaches and therapists) who are working or aim to work with BAC.  

As a general rule, we encourage our staff and counsellors to use effective communication to defuse situations from escalating. We do however acknowledge that this is not always possible and that staff and counsellors may at times find themselves involved in violent situations. All staff have a vital role to play in protecting themselves, including participation in appropriate training, reporting of incidents and to take appropriate action against perpetrators of abuse or violence. BAC has a responsibility to ensure that appropriate support is given to staff in such instances.

Reporting, Investigating and Monitoring 

All incidents of abuse or violence to counsellors must be formally reported to BAC staff using the online@beecholmeadultcare.co.uk 

All incidents should be investigated and reviewed by the manager to ensure that control measures are appropriate and proportionate. 

Additional Reading 

http://www.hse.gov.uk/ 

This policy sets out Beecholme Adult Care’s (BAC) approach to equality and diversity, in compliance with the Equality Act 2010. BAC is committed to promoting equality and diversity and a culture that actively values difference and recognises that people from different backgrounds and experiences can bring value to the workplace and enhance the way we work. Further, BAC aims to be inclusive and is committed to providing equal opportunities throughout employment including in the recruitment, training and development of employees, pro-actively identifying and eliminating discrimination. The same applies to all counsellors using the online platform. 

Definitions 

Equality is ensuring individuals or groups of individuals are not treated differently or less favourably, on the basis of their specific protected characteristics, including race, gender, disability, religion or belief, sexual orientation and age.

Diversity aims to recognise, respect and value people’s differences to contribute and realise their full potential by promoting an inclusive culture for all.

Scope

The rights and obligations set out in this policy apply equally to all employees, whether part-time or full time on a substantive or fixed-term contract, and also to associated persons such as agency staff and contractors.

This policy applies to all conduct in the workplace and also to conduct outside of the workplace that is related to your work (meetings, social events and social interactions with colleagues) or which may impact on BAC’s reputation (e.g. the expression of views on social media, contrary to the commitments expressed in this policy, that could be linked to BAC). 

BAC’s commitment

Every employee and counsellor is entitled to a working environment that promotes dignity, equality and respect for all. BAC will not tolerate any acts of unlawful or unfair discrimination (including harassment) committed against an employee, contractor or visitor because of the following protected characteristic: 

• Sex, sexual orientation and gender reassignment
• Marriage and civil partnership
• Pregnancy and maternity
• Race, including ethnic origin, colour, nationality and national origin
• Disability
• Religion and or belief
• Age

In addition, BAC will provide fair treatment to all its employees and take positive action where this is permitted by legislation. This policy applies to all employment decisions, including those in connection with:

• Recruitment, selection, promotion and advertisement of jobs.
• Terms and conditions of employment.
• Training, career development and progression.
• Grievance and disciplinary procedures.
• Performance.
• Relationships between members of staff and counsellors
• Treatment of employees when their contract ends.

Enquiries about disability and health during recruitment

As an equal opportunity employer Beecholme Adult Care will not ask about the health of an applicant (including whether they are disabled) prior to either offering work to the applicant or prior to including the applicant in a pool of applicants from which we intend to select a person to whom to offer work unless an exemption applies. 

The only circumstances in which the Company may make pre-employment health enquiries are:

• To establish whether the Company has a duty to make a reasonable adjustment in respect of an interview/assessment process.
• To establish whether the applicant will be able to carry out a function that is intrinsic to the work concerned.
• To monitor the diversity of applicants.
• To implement positive action in employment for disabled people.
• To recruit appropriately where having a particular disability is a requirement of the role.
• To comply with national security vetting requirements.

Discrimination on the basis of work pattern (part-time working, fixed-term contract, flexible working) which is unjustifiable will also not be tolerated. Selection for employment, promotion, training, or any other benefit will be on the basis of aptitude and ability. No form of intimidation, bullying or harassment will be tolerated.

BAC will ensure that individuals who make allegations in good faith will not be victimised or treated less favourably by the organisation as a result. However, false allegations or a breach of this policy, found to have been made in bad faith will be dealt with accordingly. 

Types of discrimination

There are various types of discrimination prohibited by this policy. The main types are:

Direct discrimination 

Direct discrimination occurs where one person is treated less favourably than another because of a protected characteristic set out in this policy. Other types of direct discrimination are: 

• Perceptive discrimination – this is direct discrimination against an individual because others think they possess a particular protected characteristic. For example, where co-workers believe the individual is gay. It applies even if the person does not actually possess that characteristic.
• Associative discrimination – this is direct discrimination against someone because they associate with another person who possesses a protected characteristic. For example, an employee is discriminated against because his/her son is disabled. 

Indirect discrimination

Indirect discrimination occurs when an unjustifiable requirement or condition is applied, which appears to be the same for all, but which has a disproportionate, adverse effect on one group of people. This is discrimination even though there was no intention to discriminate.

Victimisation 

Victimisation is where an employee is treated less favourably than others because they have asserted legal rights against BAC or assisted a colleague in doing so. For example, victimisation may occur where an employee has raised a genuine grievance against BAC and is demoted as a result.

Harassment

Harassment is “unwanted conduct related to a relevant protected characteristic, which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual.” It is important to remember that it is not the intention of the harasser but how the recipient perceives their behaviour, which determines whether harassment has occurred.

Staff’s Procedure and Responsibilities 

Please be aware that this policy is for guidance only and does not form part of your contract of employment. If you believe that you may have suffered discrimination because of any of the above protected characteristics, first of all, consider, where appropriate, attempting informal resolution by discussing the issue with your line manager or another colleague in a relevant position of seniority. Alternatively, you may decide to raise the matter through BAC’s Grievance Policy. 

All staff and Counsellors are personally responsible for the practical application of this policy and must support BAC in creating and maintaining an environment that promotes equality of opportunity and diversity in practice. It is, therefore, the duty of all staff to:

• Be familiar with and understand this policy, acting in ways that are in accordance with this policy and the organisation’s values. 
• Use communication methods that other people understand when carrying out duties and take account of their own behaviour and its effects on others.
• Ensure that each customer is provided with equity in service, which takes into consideration the diverse needs of the population we serve.
• Not discriminate unlawfully 
• Not discriminate unlawfully in relation to any of the services we provide and purchase. 
• Not induce or attempt to induce other employees or management to practice unlawful discrimination.
• Not victimise or attempt to victimise other employees or customers on the grounds that they have made complaints, or provided information on discrimination.
• Be aware that malicious or unfounded allegations of discrimination may result in taking positive action under another company policy. 
• Not harass, abuse or intimidate other employees or customers for any reason
• Report incidents of discrimination, abuse, victimisation or pressure to discriminate to their line manager or BAC staff (for counsellors). 

Additional reading 

http://www.acas.org.uk/index.aspx?articleid=1461 ACAS

https://www.gov.uk/guidance/equality-act-2010-guidance Equality Act 2010

By posting content on BAC Online you agree to abide by this policy. We reserve the right to remove any content, in whole or part, that violates this policy, our Data Protection Policy our Duty of Candour our Confidentiality Policy or for any other reason at our sole discretion.

In the event of repeated or severe violations, we may suspend or permanently
deactivate the profile in question.
You can report the content directly or contact us to report content that appears to violate this policy.

The following content is never allowed on BAC’s online platform:

• Content created solely for the purpose of advertising or other commercial content, including company logos, links, or company names;
• Spam, unwanted contact, or content that is shared repeatedly in a disruptive manner
• Content that endorses or promotes illegal or harmful activity or that is sexually explicit, violent, graphic, threatening, or harassing;
• Content that is discriminatory;
• Attempts to impersonate another person, profile, or entity, including a representative of BAC
• Content that is illegal or that violates another person’s or entity’s rights, including intellectual property rights and privacy rights;
• Content that includes another person’s private or confidential information.

The following are policy violations specific to a type of content:

Profile titles

• Profile titles that include information irrelevant to the profile, style, or experience
• Profile titles that include symbols or emojis

Profile pages

• Profiles that provide fraudulent, false, misleading, or deceptive information
• Content that is off-topic.
• Advertising of any medium that is not authorised by BAC Reviews.
• Reviews that are biased and exhibit indications of extortion/incentivisation, conflicts of interest, or direct competition.
• Reviews that contain no relevant information about a counsellor, therapist or will be removed.
• Reviews that contain mostly irrelevant information are also subject to removal, but only where the otherwise relevant information would not be expected to meaningfully inform the booking session.

This policy is designed to ensure that all counsellors using BAC online platform are aware of their responsibilities in regards to the acceptance and allocation of gifts and donations.

Definitions 

Client – is any person(s) for whom BAC provides services either directly or indirectly including a person with a disability, a person with disabilities family member(s), or other organisations.

Donations – Means a voluntary contribution by a donor of money, property, goods or services to BAC for the purpose of furthering the work of BAC. 

Donor – Means an individual or other entity that makes a contribution of value to BAC.

Gifts – A non-monetary voluntary contribution made to a person engaged to provide services, as a token of appreciation for their work and/or assistance.

Scope

This policy is to be complied with by all counsellors using BAC online services. 

Counsellors’ guidelines and responsibilities

Counsellors engaged in online services are only permitted to accept small gifts or gratuities from clients. Under no circumstances are counsellors to accept or seek any financial payment or borrow money from clients. 

Counsellors should not accept any gift where there is or may be,  a perception of a conflict of interest with past, present or future duties, or where the object of the gift is to maintain or return of a favour.

All Counsellors must declare all offers of gifts and hospitality, made to themselves or by themselves, regardless of their value. All such offers must be declared whether accepted or declined. The declaration must be recorded on BAC’s declaration register (form attached at the end of this policy). 

A gift may be accepted if the staff  believes that:

• Would cause offence, disrespect or distress to the donor to refuse the gift.
• Would jeopardise a positive working relationship with a donor.

When the above circumstances apply then staff may :

• Accept and retain token gifts, such as flowers (from someone’s garden as opposed to purchased), homemade cakes or other homemade items.
• Accept and retain all gifts valued at £20.00 or under. For gifts exceeding a value of £20.00 the following options are suggested:  share the gift with all staff;  raffle the gift for charity;  donate the gift to charity, or make a donation to charity and keep the gift. 
• A gift with a monetary value, whether this is a box of chocolates, a book or anything else must be reported to the manager.

Counsellors must not accept money as a gift.

Hospitality offered should only be accepted where there is a direct link to working arrangements and a genuine business reason can be demonstrated, for example:  

• attending a free training course.
• attending a drinks reception to network.

BAC does not make contributions of any kind to political parties, causes or politicians. Nor do we make charitable donations of any kind. You are prohibited from offering, promising or giving political or charitable donations for the purpose of obtaining business or a business advantage for this Company.

Declaration form

This policy document is designed to ensure compliance with legal requirements contained within the Data Protection Act 2018 (DPA 2018) and the General Data Protection Regulation EU 2016/679(GDPR). Beecholme Adult Care (BAC) strives to build trusting relationships between itself as an organisation and its people- both clients and staff, recognising people’s right to have control over their own identity. This document also provides detailed guidance on procedures staff must follow to ensure compliance with DPA 2018 and GDPR. 

Definition 

Data Protection, in general, is about ensuring that people can trust you to use their data fairly and responsibly. Further, data protection is concerned with the private as well as the personal data of an individual and with the processing of it: collection, recording, storing, using, analysing, combining, disclosing or deleting. 

Scope

In this capacity, it is BAC that handles personal and special category data belonging to staff, counsellors and customers. BAC understands the need to comply with the above law. As such, BAC operates within the general processing regime of the DPA 2018 in its capacity of a data collector and to some extent data processor.

Data protection principles in accordance with responsibilities under the GDPR( Article 5)

Article 5(1)of the GDPR requires that personal data shall be:

• Processed lawfully, fairly and in a transparent manner in relation to individuals 
• Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.
• Adequate, relevant and limited to what is necessary for the purpose for which they are processed.
• Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that any personal data that is inaccurate; having regard to the purposes for which they are processed, are erased or rectified without delay. 
• Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes subject to the implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of the individuals.
• Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.

General Provisions

• This policy applies to all personal data processed by BAC.
• BAC will appoint an individual who will ensure ongoing compliance with this policy and conduct a regular review.
• BAC will register with the ICO as an organisation that holds personal data, including special category data.

Lawful basis for processing 

1. Staff and Counsellors

Article 6 of the GDPR sets the lawful grounds in relation to data processing. In relation to staff working for BAC and Counsellors, those legal grounds are contained within point (a),(b) and (c) of the article:

• (a) “the data subject has given consent to the processing of his or her personal data for one or more specific purposes”
• (b) “processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract”
• (c) “processing is necessary for compliance with legal obligations to which the controller is subject”

Article 7 of the GDPR sets the lawful grounds in relation to consensual data processing. BAC staff and counsellors are subject to point 1 of the article: “ Where the processing is based on consent, the controller shall be able to demonstrate that the data subject has consented to the processing of his or her personal data” and are further informed in accordance with point 3 of the article: “ the data subject shall have the right to withdraw his or her consent at any time..”

BAC processes employees/future employees and counsellors data in order to enable compliance with legal obligations as an employer as well as for other personnel, legal and administrative purposes. At all times BAC ensures that the data processed is relevant and limited to just what is necessary. BAC only processes data for the purposes notified to the specific employee or other purposes specifically permitted by the DPA 2018. 

Every effort will be made to keep personal data accurate and up to date. It is the employee’s responsibility to ensure that they inform management on the change of address, next of kin, contact numbers or any other changes such as new bank account details in order to ensure that their personal file is kept up to date. Personal data will not be kept longer than necessary and will be disposed of according to law.

Personal data will be processed in accordance with the DPA 2018 and will not be transferred to a place outside the EEA (European Economic Area). Further, appropriate technical and organisational measures will be taken to ensure that data is kept secure. Should BAC need access to employees’ medical records, this will be obtained consensually under the Medical Reports Act 1988. 

Under Article 15, employees should have the right to know whether personal data regarding him/her are being processed and if so access the personal data and further information as stated in article 15. 

BAC preserves its right to NOT document its processing activities relating to staff personal data using the GDPR exemption for small and medium-sized organisations. However, we also consider and apply the principles of good governance and additional compliance. We are also aware that good documentation provides the basis for a good audit. 

2. Customers

In terms of processing special categories personal data in relation to its subject users BAC uses the exemption criteria specified in point (h), paragraph 2, Article 9 of the GDPR:

• (h)” processing is necessary for the purpose of preventive  or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care  or treatment or the management of health and social care systems and services on the basis or Union or Member state law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3”

Staff’s responsibilities 

BAC staff do not share any personal data from the counsellors using the platform with external people. Counsellors personal data is only shared internally with staff. 

Councellors’s responsibilities

Counsellors using BAC online platform should not share any personal data from their clients to any external people. All personal data should be stored safely with no access from external people. 

Documentation and Archiving

All documentation is stored in online folders with strict access and password protected. 

BAC will ensure that personal data is kept for no longer than required by putting in place an archival policy for each area in which personal data is processed and review this process regularly. The policy will consider what data must be retained and how long for, complying with legislation. BAC will periodically review the data held and erase or anonymise it when no longer needed. BAC clearly identifies personal data that is to be kept for statistical purposes and always strives to anonymise it. BAC is at all times considered of the “right to be forgotten” principle that enables data subjects to request their data to be erased. 

BAC is fully aware of the GDPR’s Article 5(1) principle for personal data storage and the fact that GDPR does not specify time limits for data storage, but rather applies the principle of “no longer than is necessary for the purposes for which the personal data are processed”. 

BAC will conduct an information audit every year in addition to its regular activities in order to find out what personal data is held and locate where it is. The audit will also look into why the personal data is used, who it is shared with and how long it is kept. The findings will be documented. The audit will be actioned by the Policy and Audit officer or in their absence by one of the acting managers of BAC. 

Information Security

• BAC will take the necessary steps to ensure that personal data of both staff and counsellors are stored securely using modern software that is kept in date.
• Access to personal data will be limited to personnel who need access and appropriate security will be in place to avoid unauthorised sharing of information. 
• When personal data is deleted this will be done safely in accordance with time regulations outlined in the DPA 2018, ensuring the data is irrecoverable .
• Appropriate back-up and recovery measures will be put in place. 

Staff  and Counsellors Procedures

Staff and Counsellors must read this policy, understand and correctly apply its content in their everyday working activities. In relation to this staff must:

• Ensure that when disclosing information about our customers you do so in line with legislation
• Seek consent to share information when possible.
• Always ensure that you know who you are providing the information to. Ascertain who you are speaking to and what is the service they represent. 
• When away from your desk, ensure that your computer screen is blacked out and any personal information regarding service users is removed from the screen.
• Regularly change your computer password.
• Do not share personal information relating to our customers or staff outside work and in your home.
• If in doubt whether you should or should not share information seek advice from management or BAC staff (for Counsellors).
• When faced with a “life or death”  situation SHARE information 
• Know your rights and responsibilities under the DPA 2018 and the related GDPR!

Additional Reading

Data security and protection requirements 

Guide to the general data protection regulations (GDPR)

CCTV code of practice 

By creating a Profile on BAC Online, you agree to abide by our terms and policies, which we reserve the right to enforce at our sole discretion. In the event of repeated or severe violations, we may suspend or permanently deactivate a person’s profile.

In order to protect our community and business, the following behaviour’s are
prohibited:

Asking clients for feedback off of BAC Online

Asking for clients to review you off of BAC Online takes valuable input about a clients experience, away from BAC Online community.

We want Clients to share their feedback directly on BAC Online so that other clients may benefit from their insights.

This includes:

• Asking clients to review a BAC Online session on a non-BAC Online website, or taking reviews from BAC Online and posting them on a non- BAC Online website.
• Asking clients to fill out a survey regarding a BAC Online session via a non-BAC Online website.

Asking clients for contact information prior to booking sessions 

All client communications prior to booking should be on BAC Online.

Asking clients for contact information prior to booking is prohibited.

This includes:

• Asking clients for their phone number or email address prior to booking a
  session.
• Asking clients to call or email in order to discuss a session prior to booking.
• Asking clients to go to a third-party website or fill out a form in order to make a booking.

Asking clients for contact information after booking or misusing contact information provided by BAC Online

This includes asking for or using contact information for any reasons unrelated to a
booked session, or in a way that compromises the quality of a clients session. Clients
should be able to communicate directly with counsellors or therapist about their
session through BAC Online. Soliciting additional contact information (email address,
residential address) should be avoided unless needed for legal or compliance
reasons.

This includes, but is not limited to:

• Asking guests for an email address for the purpose of their BAC Online session and then subscribing them to marketing materials.
• Asking clients to move the conversation to texts or emails in order to circumvent the BAC Online platform.
• Asking clients for contact information after booking in order to run background checks.
• Asking clients to send photos or identification prior to a booked session.
• Asking clients to create a separate account or register on another website besides BAC Online.
• Asking clients to install any third-party app to access a session.