Communication from UKCP

UKCP have asked us to amend two of our statements.

UKCP argue that they have never said that they are seeking to replace the existing MoU and that TACTT is misrepresenting this. Our statement was based on the following comments by Jen Ayling, vice chair of UKCP, in the meeting on Monday 17th June:

“I think it’s not about thinking that there’s anything in the current MoU that’s harmful. It’s about the fact that it doesn’t go far enough”

“As a board we’ve long been sitting not just us as a board but previous incarnations of the board with concerns about the brevity of the MoU as a document and its lack of nuance […] and we think this call for a better regulatory guidance and best practice guidance is most urgently needed”.

If we have misunderstood these statements, we apologise, but we would also request clarification of them as a matter of urgency – do UKCP seek to develop “better regulatory guidance and best practice guidance” in place of the MoU, or do these words have another meaning?

UKCP would also like us to communicate that NCPS “has not distanced themselves from the project, as your piece implies”. For full transparency, we share the information that NCPS has given us:

“As was stated in April, we [NCPS] have been in discussions with UKCP and other talking therapy membership bodies regarding potential practice guidelines. However, nothing has been agreed regarding ‘regulatory guidelines’ or indeed the establishment of a working group; there have simply been some discussions. I have raised this with UKCP and asked them to refrain for sending out these statements”.

We hope this clarifies the matter.

Responses to the UKCP meeting

UKCP – The Board Removal Vote.

As many of you know, The UKCP Board held an online meeting Monday to put its case to members on how to vote in its forthcoming removal election. Over 300 UKCP members are reported to have joined this meeting.

We are listing here the headlines, as we understood them, and below this (in the longer version), quotations from the meeting and links to relevant documents.

As the vote begins we remain extremely concerned about the actions of the UKCP Board and we do not believe that their actions in withdrawing from the MoU have been adequately explained. We believe that some very serious questions remain, and in the absence of receiving answers, despite trying for months, our UKCP cohort continues to call for the removal of the Board and their subsequent replacement with a new team which will restore the UKCP to the MoU (as the current Board restated that it would not do), unless a full and transparent consultative process involving members of all kinds indicates a different course of action.

The headlines from the meeting are:

1.    The UKCP Board states that their figure for triggering the vote is 2% and that that’s low by comparison with other organisations. They stated that the petition achieved this level, just, and inferred that if a higher number had been required, it wouldn’t have been reached. We’d like to respond that TACTT’s open letter stopped being promoted at the point we reached the number of signatures required and a decision was made to submit to UKCP. TACTT is confident that it could have added more signatures, perhaps significantly more, had it continued to seek them.

2.     The UKCP Board states that NCPS supports them in the aim of creating a new, alternative version of the MoU. NCPS has categorically denied this and has now asked UKCP to stop saying it’s true. (Please note that communication from the UKCP to TACTT after the publication of this blog asks us to update. The UKCP is not planning to create a new version of the MoU. We are not sure what they are planning to create, except a regulatory document of some kind that involves conversion therapy. In the meeting they discussed the MoU ‘not going far enough’ and wanting to strengthen this, but it seems that what they are planning to create is not something like the MoU).

3.     The UKCP Board states they had no choice but to withdraw at speed from the MoU and although they knew that this may be seen as a transphobic action, they a) didn’t have time to mitigate the process around this, and b) although they knew it could be perceived as transphobic, they didn’t consider how their action would impact members. They also feel that they are “ethically sensitive” and the right people to remain on the board. However, the Board has also said it discussed this in advance of making the decision with colleagues and some of the member colleges. Which is it? That there was time to engage with several colleges and colleagues, or that this had to be done so fast that there wasn’t time to consider the impact the decision would have?

WHY did the decision have to be so fast?  Can the UKCP categorically state that they have signed no legal settlement that has compelled them to withdraw from the MoU?

4.     The UKCP Board’s original stated reason for withdrawal was about ‘children’. At the meeting the main message seemed to be about ‘insurance premiums’. The Board now states that it had to withdraw the UKCP because of insurance policy premiums (and that their responsibility is to UKCP, with no mention of clients or their members). With respect to stated concerns about the care of children, the UKCP board has claimed that the MoU Secretariat refused to engage on this. There is nothing in the minutes of any UKCP trustee meeting from the last 18 months that suggests this and it has been stated in the meeting on June 17th by an attendee (presumably on the secretariat) via the Q&A panel that the minutes of the MoU meetings do not support this. Whichever way, the MoU was a guideline, rather than a legal document.

5.    The UKCP Board has repeatedly said that they want to hear from LGBTQ+ (and other) voices. TACTT has been trying to engage with UKCP on this matter since November 2023, with no results whatsoever. The UKCP Board also states that it supports the Cass review, which has been widely criticised since its publication, not least by trans people whose voices were systematically excluded from it.

6.    The   UKCP Board stated that the removal of the trustees would destabilise the organisation and that many new developments would have to be ‘put on ice’, yet also claiming that the current Board is new. Irrespective of this seemingly contradictory rhetoric, it must be pointed out that the Board wouldn’t be replaced until new members of a trustee board (also potentially members with experience of being trustees) were in place.

In short: the narrative we have heard seems to be as follows.

They couldn’t tell members the truth, but they’ve also been transparent from the start.

They are against conversion therapy, but they support the Cass Review. This has been widely discredited by leading academics, and was created and managed by a government that explicitly and energetically attempted to destroy the rights of trans people in the UK. This government has refused to bring forward a ban of Conversion Therapy (the Minister who commissioned it celebrated the release of the final Cass report with excited claims of the defeat of the “militant gender lobby”) and the Cass report has been weaponised extensively within the political and media discourse since its release.

They believe in ‘healthy exploratory therapy’ but will not commit to a starting point of stating that trans identities are valid and are as legitimate as cisgender identities. Without this, so-called ‘exploratory therapy’ effectively becomes conversion therapy.

They want to create a new regulatory version of the MoU, but again, will not commit to the standpoint of the original MoU. They didn’t know that the MoU covered children (we ask, why would it not, and why did it take 8 years and having signed the document twice to bring this question – which could have been answered easily and quickly at any stage?) and state that children have age-specific needs. Our response to this? Of course they do, but why does this mean that a well-practised approach of supporting a child to explore their identity – trans, cisgender or anything else – is invalid?. And we point out again that the MoU does not state any particular way of working for either adults or children and young people.

Long version

1: In the interests of expediency, TACTT sent the list of signatures when we knew we had reached the number required. If the number had been higher, we would have continued to share the letter until the higher number was reached.

2: UKCP have withdrawn from the MoU2 and intend to create a regulatory document around conversion therapy. UKCP (Jon Levett, CEO) said in the meeting “We’ve got together a working group which is going to start to meet on a monthly basis to really start to get some momentum on this. So NCPS are very definitely involved, very definitely signed up to this.” Another trustee states “ [we have] form[ed] a working group led by our CEO John Levitt already we’re collaborating with a number of organisations including the British Psychoanalytic Council, the National Counselling and Psychotherapy Society and a number of others”

NCPS’s response is “Just to reassure you, the NCPS has re-joined, and is fully supportive of, the MOU as the right mechanism to ban conversion therapy, a ban which has been our consistent policy. We are not looking to create an alternative MOU […] I have raised this with UKCP and asked them to refrain from sending out these statements”

3: UKCP say that they didn’t have time to consider the potential fallout. We respect that the open letter went up the same day as the announcement. However, what this tells us is that the board just did not consider this, in advance of releasing such a huge statement. They also say in the same meeting that they DID consider that it might be seen as transphobic, but that none of them (it seems) considered the impact that might have. One cannot have it both ways.

“We didn’t have time to address the potential fallout before the petition came against us. So we have been and we are always against conversion therapy and the petition was based on incorrect information”

“To be totally transparent we considered that the withdrawal taken out of context could be experienced as transphobic and homophobic, but what we didn’t consider was the potential impact.” “We believe that as the existing board that we have the skills, the vision and the ethical sensitivity to take the forward and deliver on the charity’s strategic aims”

“We did discuss it with colleagues. We did discuss with some of the colleges, although we acknowledged we didn’t discuss with all of them”

4: From the MoU2: “conversion therapy’ is an umbrella term for a therapeutic approach, or any model or individual viewpoint that demonstrates an assumption that any sexual orientation or gender identity is inherently preferable to any other, and which attempts to bring about a change of sexual orientation or gender identity, or seeks to suppress an individual’s expression of sexual orientation or gender identity on that basis.” and “signatory organisations agree that the practice of conversion therapy, whether in relation to sexual orientation or gender identity, is unethical and potentially harmful.”

UKCP state concerns about children and not knowing that children were covered under ‘people’. What exactly *are* children, to UKCP, if not people? Jen Ayling stated:  “you know, a child’s need is very different to an adult’s needs and I think that’s where there’s the need for additional guidance.” The MoU does not give guidance on HOW to work with people exploring their gender. It simply allows room for children to fully explore their identities from within a framework that believes “that neither sexual orientation nor gender identity in themselves are indicators of a mental disorder” (MoU2)

From the UKCP meeting: “Now we did an attempt to engage in dialogue but came to the point when faced with a significant increase in our insurance premium”

They suggest that “over the last few weeks we have endeavoured as a board to transparently communicate the reasoning and risk assessment process which underpinned our decision”, yet they have changed their story to being about insurance and explicitly state they couldn’t state this originally. What has legally changed that they now can?

5: From the meeting: “Any clinical guidance will be backed by robust research evidence. We’re supportive of the Cass review and it will form part of our ongoing considerations when creating new regulation and clinical guidance”. Cass has been discredited in many areas and by many voices since its publication. See Transactual the OSF Preprint paper, and Dr Ruth Pearce’s ongoing updates for just three of them.

They also state “You see what we urgently need to do is create new regulatory guidance for conversion practices that has good governance, transparency, consultation, the voice of psychotherapy and most importantly the voices of the LGBTQIA+ community”.

UKCP would not answer a question as to whether they were prepared to start any new version of an MoU from the point of view that a trans identity was as valid as a cisgender identity. They did talk about “healthy exploratory therapy”. Florence Ashley has a very useful paper on why ‘exploratory therapy’ within a framework that doesn’t accept trans (whether in adults or children) as a valid identity is conversion therapy. UKCP declined to answer to this question as well.

6: From the meeting: “The upheaval and cost implications to the charity of appointing an entirely new board would essentially make the organization non-functioning in terms of major future developments for a significant period of time. Conference planning, strategic development work and many of the other projects we’ve successfully launched would have to be put on ice.”

However they go on to list all the things they have achieved as a new board. Which seems to directly contradict their claims of destabilisation.

“There’s a lot done but not all of it will be directly visible to you. So we started to work preparing the relationship with colleges, which was a factor within the EGM core. We are managing legal claims. We relocated the offices.  17th June, I think was the D date. And estimated to save 150 K annually. We’re improving office performance. We’re guiding the NHS pathways, talking therapies pilots. We’ve reinstated the annual conference. We reinstated the ethics committee. And as many of you again will be aware, we’ve consulted on and a developing the new 3 year strategy. And I just want to say a little bit about that is that the three-year strategy and we’ve run 3 4 seminars on that already through 4 webinars on that already. And put up various polls just to gain attraction and interest. The Strategy Working Group is comprised of 2 chairs at the colleges and one vice chair of the colleges working with the board nominated board of trustees.”

UKCP is presenting a bundle of contradictions and obfuscations to its members. There is no real clarity and in removing themselves from the MoU they place their members in a very difficult position.

Ahead of UKCP’s meeting this evening

Ahead of tonight’s UKCP meeting members about the Board election with we wanted to give a loose timeline and comments on UKCP’s withdrawal from the MoU.

In short: UKCP withdrew citing concerns that the MoU applied to children. The MoU does not prescribe how we work, except that we must start from the premise that no one identity (cis or trans) is better than the other. The UKCP’s clarification letter then says more about this, but draws on irrelevant things to support its point (which is a concern about working with children). Then a letter from the UKCP’s board cites legal actions as a reason. We were aware of one legal action involving UKCP, which they settled early this year. We are aware of one other legal action which also does not specify children. However, the clarification letter now states legal actions (and resultant increase in insurance) as a significant reason. Whether children are covered under the MoU2 is irrelevant to the claims, as this disctinction would not have stopped either legal action (which began in 2022 BEFORE the re-signing of the MoU2). The long UKCP letter claims “we couldn’t directly engage with you all due to the content of some of the organisational risks”. NCPS also failed to engage with its members on this. However, when approached, NCPS were open about their reasons (financial). If UKCP was also struggling with the financial aspect, they too could have been transparent from the start. Pink Therapy, who were forced to withdraw from the MoU (for insurance reasons) were transparent about this aspect.

We argue that the insurance premiums, whilst perhaps a  genuine concern, are a red herring for the real issue here, which is that the MoU SHOULD cover all people. We also argue that if it was explicit that children were not covered, UKCP would be facing the same issue of finances.

Conversion therapy kills. The view put forward by people describing themselves as “gender critical” is that trans people are at best deluded about their experiences and at worst, predatory. Gender critical therapists apply the term “exploratory therapy” to their work with trans clients and trans clients only, which in the context of gender critical views and the limited application of “exploratory therapy” means that this can only be conversion therapy by another, more palatable name. The legal cases mentioned by UKCP have BOTH been in place since before the UKCP re-signed the MoU in 2022. This would also mean that the insurance company would have been aware of these cases for over a year.

At length:

UKCP initially withdrew citing the following reasons:

“The UKCP Board of Trustees reached this decision following concerns it held regarding whether the MoU applies exclusively to adults, or if children and young people are included in its scope. UKCP has received clarification that the MoU does indeed relate to all ages. Upon investigation, it became evident that there are historical concerns held by a number of UKCP colleges that regulate psychotherapeutic work with children and young people relating to this subject, and which have yet to be addressed – hence our decision to withdraw at this time.” (UKCP update on conversion therapy (psychotherapy.org.uk))

It seems clear from this statement that the issue for the UKCP here is about conversion therapy and children.

 Their clarification states:

“Children and young people require and deserve careful support, that is often different from what is required for adults.

UKCP has been concerned for some time that this is not reflected in the current MoU. The current MoU was drafted to apply to adults and was retrospectively applied to children and young people without consultation with the relevant bodies and child therapists with the specialist and regulatory knowledge of working with children and young people.” (UKCP withdrawal from MoU on conversion therapy (psychotherapy.org.uk))

UKCP has not raised concerns suggesting this is the case in the past. The current MoU has consistently been accepted as a document that would protect LGBTQ+ youth as well as adults from conversion therapy since its inception. In particular, UKCP as a signatory agreed to the BPS Document ‘Guidelines and Literature Review for Psychologists Working Therapeutically with Sexual and Gender Minority Clients’ as the basis for their work in relation to the MoU as early as 2012. The document incorporates adults, young people and children.

In 2015 the UKCP agreed to the following as part of the  publication of MoUv1 under the section: ‘Roles and Responsibilities’ that:

“Training Organisations will refer to the BPS guidelines on working with                              gender and sexual minority clients when reviewing their curriculum on equality and diversity issues”.

Within this document Children and young people are mentioned in Part II.

At several points along the way and between 2012 to date there have been ample opportunities for UKCP to move from the inclusion of children and young people and they have not. Trustees of UKCP have attended and been a party to discussions within the MoU about inclusion of young people as ‘members of the public’ who might be impacted by conversion therapy. UKCP Trustees have always been party to the knowledge and decision making surrounding MoU1 and 2, and the spirit, aims, and wording of these documents were unanimously aimed at safeguarding LBGTQ+ youth from conversion therapy. This is well documented and witnessed by those in attendance as signatory members. UKCP Trustees have attended meetings and been part of the decision making process.

As late as 2019 the MoU2 released a position statement to the press, agreed by all members including UKCP, which states clearly that:

“… a legal ban should not divert our attention from the fact that education and professional training remain essential in order for practitioners to be able to work competently with LGBT people of all ages and to provide them with a safe and respectful environment in which they can explore who they are without judgement or fear”. 

UKCP has always been part of the decision making process surrounding the MoU2, and have always been aware that conversion therapy involving LGBT members of the public of all ages is harmful. As a signatory to the MoU2 UKCP have previously agreed that an adequate description of the MoU Coalition submitted to Parliamentary members is that the Coalition ‘acts on behalf of’  children and young people as well as LGBT people of all ages’ as part of its brief to government consultations.

It is not clear what the concern actually is. UKCP says it is against conversion therapy and the MoU states that:

“’conversion therapy’ is an umbrella term for a therapeutic approach, or any model or individual viewpoint that demonstrates an assumption that any sexual orientation or gender identity is inherently preferable to any other, and which attempts to bring about a change of sexual orientation or gender identity, or seeks to suppress an individual’s expression of sexual orientation or gender identity on that basis.”

It also states:

“this position is not intended to deny, discourage or exclude those with uncertain feelings around sexuality or gender identity from seeking qualified and appropriate help.” And “Nor is it intended to stop psychological and medical professionals who work with trans and gender questioning clients from performing a clinical assessment of suitability prior to medical intervention. Nor is it intended to stop medical professionals from prescribing hormone treatments and other medications to trans patients and people experiencing gender dysphoria.

For people who are unhappy about their sexual orientation or their gender identity, there may be grounds for exploring therapeutic options to help them live more comfortably with it, reduce their distress and reach a greater degree of self-acceptance. Some people may benefit from the support of psychotherapy and counselling to help them manage unhappiness and to clarify their sense of themselves.

Clients make healthy choices when they understand themselves better. Ethical practice in these cases requires the practitioner to have adequate knowledge and understanding of gender and sexual diversity and to be free from any agenda that favours one gender identity or sexual orientation as preferable over other gender and sexual diversities. For this reason, it is essential for clinicians to acknowledge the broad spectrum of sexual orientations and gender identities and gender expressions.”

It is completely unclear as to why this wording would provide a problem when working with children and young people. As therapists we should be seeking to help all clients understand themselves better. We should be able to help clients clarify their sense of themselves. 

When challenged, UKCP have not been able to answer this question. Their concerns are listed as:

  • “No safeguarding distinctions between adults and children and young people”.

Trying to work out if you’re trans is not a safeguarding issue, if you work from the basis that being trans is not a ‘worse’ position than being cis. It simply means that you work ethically with children to allow them to explore their identities, INCLUDING the possibility that they are trans.

  • Applying adult-focused legislation and guidelines to children and young people which overlooks their unique developmental requirements.

There is no adult-focused legislation in the MoU. The MoU is not a legislatory document and the guidance is to remain open

  • Children and young people need a unique therapeutic approach that acknowledges their developmental stage and capacity for informed consent.

Agreed. However, the MoU leaves explicit space for professionals to work in the ways in which they work ethically with children. The MoU does not prescribe an approach; it says we have to work ethically.

  • The family and social context of children and young people, which is a vital source of information to understand the child/young person, is not taken into account.

Again – this is not what the MoU is trying to achieve here. It does not say that professionals cannot do this.

  • Due to the lack of child-specific guidance, child therapists face legal risks, including the possibility of lawsuits if a child detransitions in the future.

Any therapist who works with anyone  is at risk of a lawsuit. We are not infallible and will make mistakes. The MoU does not say “YOU MUST TELL A CLIENT THEY ARE TRANS” it says “accept that trans is a valid identity”. It explicitly asks us to allow clients to clarify their sense of themselves.

  • Policy changes in the Department for Education (DfE) and the National Health Service England (NHSE) and safeguarding implications from emerging evidence and research relating to gender incongruence has not been taken into account.

We would argue again that this is irrelevant. Whatever NHS and DfEE policy say, this does not mean that counsellors/psychotherapists cannot allow clients the space they need. To suggest this is to suggest that we are in some dystopian future where thoughts should be policed. Stopping a person from having space to fully explore their identity will not stop people from coming out as trans. It *will* potentially lead to poorer mental health outcomes when children are being pushed into one particular outcome (“not trans”)

In a lengthy email to UKCP Members on 11th June, the focus shifts from instead of leaving because of safeguarding concerns (although this is still mentioned) to UKCP being named in legal action and this being expensive. UKCP suggests they could not consult with members in advance.

This may be true. However, there is nothing in any of the minutes available online for trustee meetings in 18 months that even mentions the MoU, leaving us to wonder just how important this was, when the UKCP has been named and implicated in legal action across that entire timeframe.

However we feel about whether or not UKCP should remain in the MoU (and of course, it is TACTT’s position that they should), the UKCP has not engaged in its stated objectives – the organisation should be consulting with members. It should have a clear narrative on why it has done what it has done. It seems clear that when faced with the backlash, the focus of the UKCP’s story has slowly changed to reflect a more palatable version of the reasons why. This is unacceptable and not how a board of trustees should be acting.

Statement by TACTT on UKCP Board ‘no confidence’ vote (full version)

Context

The UKCP has announced a removal election of the Board of Trustees in response to a call from some of its membership through an open letter petition initiated by UKCP members who are also members of Therapists Against Conversion Therapy and Transphobia (TACTT). The petition was signed by the required threshold of at least 2% of the UKCP membership, and also garnered support from over 1500 professionals and trainees from across the sector. 

The open letter and petition came after the UKCP Board decided to withdraw the UKCP as a signatory of the Memorandum of Understanding on Conversion Therapy (MoU2) (and as a member of the Coalition) earlier this year, without consultation with the UKCP membership.

In this statement,TACTT want to take the opportunity to clarify the origins of the petition, and its rationale for calling a vote of no confidence.

Who Are TACTT?

TACTT is a collective of therapists, counsellors, psychotherapists, psychologists and other therapeutic practitioners, including trainees in these fields, who oppose conversion therapy and transphobia in the therapy profession. TACTT members belong to a number of professions, and those who are counsellors, psychotherapists, or psychotherapeutic counsellors are members of a number of different professional bodies, including the UKCP. TACTT holds members of all genders.

What is the Memorandum of Understanding (MoU2) on Conversion Therapy?

The MoU2’s main aim “is the protection of the public through a commitment to ending the practice of ‘conversion therapy’ in the UK” (MoU2, point 1), viewing conversion therapies as unethical and harmful. By signing they are committing to ending the practice and ensuring their members are working ethically, based on training, within that principle. 

Anyone seeking therapeutic support deserves a safe, trained professional who is truly acting in their best interests. This assurance has now been removed for LGBT+ people approaching UKCP members for such support.

What led to the petition? 

(i) No consultation of membership for major policy shift

While much of the TACTT membership was alarmed by the Board’s decision to withdraw from the MoU2, we were further shocked that this was done without any consultation with the membership or Articles-mandated Member’s Forum which “should be consulted on the future direction and strategy of the Charity and advise and collaborate with the Board of Trustees.”

(ii) Contravening UKCP’s Code of Ethics point 32

Furthermore, we are appalled by the contradictions and lack of clarity found in the UKCP’s Board statements:

The stated reason for the withdrawal given by the Board included concerns about how it specifically applied to children and young people. This contradicts the facts of the MoU2 (which states in point 10 that it does not provide these specifics to signatories and leaves each organisation within their own purview to determine the specifics of how that training, and working practice is managed to achieve the commitment of ending the practice of conversion therapy). The Board also stated the UKCP had not known, when signing, that this statement applied to children. This cannot be squared against their years of membership supporting the MoU and its re-signing of the Memorandum in its second version.

Unfortunately the statement put out by the UKCP Board thus contradicts itself as well as the facts of the MoU2. Especially when their withdrawal statement still speaks to the same end purpose of the MoU2 that they are now disavowing. 

This all stands to confuse the wider MoU2 membership, the UKCP membership, and the wider public about the expectations of therapy they can receive from counsellors and psychotherapists. 

Furthermore, the nature of the comments the Board makes in its withdrawal statement imply that the MoU2, and by extension every other signatory organisation, is failing to sufficiently safeguarding the interests of young people. In doing so the UKCP Board is calling the practice of the wider psychotherapeutic community into disrepute and contravenes the UKCP’s Code of Ethics point 32, which states that members must “act in a way which upholds the profession’s reputation and promotes public confidence in the profession and its members.”

In addition to this, the Chair of the Board of Trustees has in TACTT’s view, publicly contributed to this misrepresentation in the national press and on social media accusing the signatories of the petition and TACTT of “bullying” the Board, comparing UKCP’s members’ legitimate and constitutional call for a removal election with a ‘coup’, and further suggesting that those who support the petition are somehow not interested in the “safety of children”. 

We point out once more that in calling for a removal election, the UKCP’s Articles of Association have been adhered to and members are entitled to exercise their democratic right to vote on the continuation or removal of the Board of Trustees, without being defamed by the Chair of their Board. In TACTT’s response statement, TACTT reminds readers that being held accountable through a democratic election is not bullying.

(iii) Lack of response and dialogue

Following the UKCP’s withdrawal from the MoU2 and their statement, UKCP members of TACTT individually and TACTT as an organisation, have tried on numerous occasions to contact the UKCP to discuss their decision and try to talk to them about reconsidering. All attempted contact has been ignored. The open letter/petition is a response to this lack of engagement by the UKCP.

Concerning views about gender and invalidation of trans identities

The open letter/petition was not TACTT’s first attempt to raise questions about the UKCP’s seeming policy direction and its lack of consultation around this. In late 2023, a previous open letter, raised major concerns about how the UKCP’s position was moving towards one that re-pathologised trans identities- in ways that seemed resonant of outdated, homophobic positions-, and how it seemed to promote so-called ‘exploratory therapy’ (a practice which typically ‘explores’ all possible meanings of a trans client’s gender identity experience other than that they are actually trans) for ‘gender-critical’ therapists (i.e. those who typically do not believe being trans is a valid state of being). Here again, the UKCP repeatedly refused to respond to invitations for dialogue about serious concerns raised by multiple UKCP members, Members’ Forum Representatives as well as over a thousand signatories of Therapists Against Conversion Therapy and Transphobia (TACTT)’s open letter (last updated in January 2024). 

From this lack of dialogue, engagement and reassurance, we do not have the confidence that the UKCP Board is supportive of trans voices, trans clients, trans students, trans therapists, as now embodied in its unconstitutional withdrawal from the MoU. Again, many other UKCP members outside of TACTT, along with professionals who are members of other therapeutic bodies, agree.

Conclusion

The public discourse around transgender people in the UK is currently toxic, with relentless political and media attempts to smear and misrepresent them. This has left the small UK trans community in deep distress. TACTT sees this in the lives of some of its members and in the anxiety it encounters from many trans and gender expansive clients. This said, TACTT wants to make clear that the grounds for this vote of no confidence lie in the UKCP’s own Code of Ethics, as the authors and signatories of the letter believed that the UKCP Board’s decision did not meet point 32 and they have not been “acting in a way which upholds the profession’s reputation and promotes public confidence in the profession and its members.”

We point out that the Board has made a major policy decision without consultation with individual, college or educational members and note that its communication of its decision to psychotherapy professionals, the wider public, LGBTQIA+ people as potential clients is at best confusing, at worst incoherent. In this confusion they are damaging the reputations of other MoU2 signatory bodies and their professional members by implication. 

Further, whilst the UKCP’s statements still claim its opposition to conversion therapy, this confusion stands to harm and reduce the safety of LGBTQIA+ clients and potential clients.

We cannot believe that these actions are in the interest of the fee-paying members or of our clients. Numerous LGBTQIA+ students and trainees from within and outside TACTT have shared their concerns, including students on UKCP accredited courses who are required to be members of the UKCP or to remain members after completing their courses for qualification until they can be able to even consider transfer to a different professional body. That they may be required to remain members of a professional body that leaves them feeling this unprotected and unvalued is unconscionable. 

The Board’s Chair has chosen to stand by his comments and the Board’s decision, even after TACTT raised its concerns, and how, in TACTT’s view, they risked casting many UKCP members, and/or members of the wider professional community, into disrepute. We remain puzzled about the Board’s claim to be in discussion with other organisations about the creation of alternatives to the MoU2, when the largest of these organisations, the NCPS, have just announced their intention to rejoin the MoU2, having confirmed that their previous withdrawal was solely on the grounds of being subject to potential legal action by hostile actors which would have been prohibitively expensive to defend. 

We ask all the UKCP members with voting rights to consider what, in TACCT’s view, has been done in your name and how, by the Board :

  • Ignoring the concerns of professionals
  • Making large policy changes without consultation of educational, college, or individual members
  • Implying that large swathes of our profession, including UKCP members are failing in safeguarding responsibilities for continuing to support a document, which continues to have the support of 23 other major mental health and related organisations (soon to be 24 once more), whilst claiming confusion over a core aspect of the agreement, eight years after having first signed and then later resigned it. 
  • Breaching the UKCP Code of Ethics 
  • Claiming to be in discussion with other organisations about a successor agreement to the MoU without providing evidence of this, and offering no response to recent NCPS actions which seem to clearly contradict this.
  • Betraying and abandoning LGBTQIA+ members, many of whom now feel unsafe within the UKCP, and LGBTQIA+ clients.

As a UKCP member, we believe that you deserve better than this. If you agree, then you have the right to vote to remove the members of the Board who enacted this in your name. If you are happy with these actions then you too must vote with your conscience.

Statement by TACTT on UKCP Board ‘no confidence’ vote (Summary Version)

Context

Last month, the UKCP announced a removal election of the Board of Trustees in response to a call from some of its membership through an open letter petition initiated by UKCP members who are also members of Therapists Against Conversion Therapy and Transphobia (TACTT). The petition was signed by the required threshold of at least 2% of the UKCP membership, and also garnered support from over 1500 professionals and trainees from across the sector. The petition followed UKCP’s decision to withdraw from the Memorandum of Understanding on conversion therapy.

UKCP’s decision to withdraw from the MoU2 on conversion therapy

On 5th April 2024 the United Kingdom Council for Psychotherapy (UKCP) advised its members and the public that it had withdrawn its signature from the Memorandum of Understanding on Conversion Therapy in the UK v2 (MoU2). The major decision to withdraw from the MoU2 was made by the UKCP Board of Trustees, without consultation nor notice with its wider membership.

In the statement, UKCP asserts itself as “fully committed in its belief that conversion therapy is harmful and must not be practised” and later confirmed that to do so would also breach of the organisation’s Code of Ethics, while at the same time advising its members to “discount the MoU as a published policy of UKCP”. In effect, UKCP asks its membership to discount as policy a document of which its entire purpose is ensuring conversion therapy is understood as harmful, unethical, and should not be practised.

These actions and statements are contradictory and potentially confusing, especially for a Board who is informing their membership and the public about major changes they have enacted without consultation. 

Who are TACTT?

TACTT is a grassroots collective of therapists, counsellors, psychotherapists, psychologists and other therapeutic practitioners, including trainees in these fields, who oppose conversion therapy and transphobia in the therapy profession. TACTT members belong to a number of professions, and those who are counsellors, psychotherapists, or psychotherapeutic counsellors are members of a number of different professional bodies, including the UKCP.

Why is the MoU2 important for LGBT+ people?

The MoU2’s main aim “is the protection of the public through a commitment to ending the practice of ‘conversion therapy’ in the UK” (MoU2, point 1), viewing conversion therapies as unethical and harmful. By signing they are committing to ending the practice and ensuring their members are working ethically, based on training, within that principle.

Anyone seeking therapeutic support deserves a safe, trained professional who is truly acting in their best interests. This assurance has now been removed for LGBT+ people approaching UKCP members for such support.

Responses to UKCP’s decision to withdraw

While much of our membership was alarmed by the Board’s decision to withdraw from the MoU2, we were further shocked that this was done without consultation with its members. 

Following the UKCP’s withdrawal from the MoU2 and their statement, UKCP members of TACTT individually and TACTT as a collective tried on numerous occasions to contact the UKCP to discuss their decision and try to talk to them about reconsidering. All attempted contact was ignored.

UKCP members from TACTT then decided to try and bring our concerns to the Board’s awareness, as well as other UKCP members, through public conversation via an open letter: Open letter to UKCP on their recent withdrawal from the MoU2 on conversion therapy

Why has a ‘vote of no confidence’ in the Board been called within UKCP?

UKCP members of TACTT created the above letter, and were joined by UKCP members within and outside of our group as signatories, to trigger the call for a removal election. Together we reached the 2% of the UKCP membership who are eligible to vote on matters within the professional body, that is sufficient to trigger an election for a vote of no confidence in the Board.

These authors and signatories believe that the current Board’s actions around the MoU2 membership have not been in keeping with UKCP policies that seek to “[act] in a way which upholds the profession’s reputation and promotes public confidence in the profession and its members.” (point 32 of the Code of Ethics).

The way UKCP’s Board have made this decision and communicated about it will be confusing to psychotherapy professionals, the wider public, LGBTQIA+ people as current and potential clients.

In that confusion they are damaging the reputations of other MoU2 signatory bodies and their professional members by implication. They are misleading the public and the professional community about the MoU2 either on purpose or by misunderstanding.

In addition to this, the Chair of the Board of Trustees has in TACTT’s view, publicly contributed to this misrepresentation in the national press and on social media comparing the UKCP’s members’ legitimate and constitutional call for a removal election with “a coup” and “bullying” of the Board.

Whilst TACTT’s opinions on conversion therapy are clear from our name as well as our work, any breach of UKCP’s Code of Ethics and its policies (regardless of the subject matter and related opinions) must be taken seriously. 

Next steps

We ask all UKCP members with voting rights to consider what has been done in your name and in making use of your membership fees. Is this what you expect from a Board who represents you?

·      Vote for what you believe is correct conduct for your membership group’s Board members: https://www.psychotherapy.org.uk/about-ukcp/elections/

17th June, 6:30pm (online): Hear from the Board.

20th June – 3rd July (5pm): Voting opens.

All eligible UKCP members will receive an e-mail to vote.

NCPS’ letter to TACTT

NCPS have also now responded to TACTT. Their email is given below for completeness:

Thank you for your letter of 23rd April.

While there is an historic blog by Dominic Davies on our website, we did remove reference to membership of MOU when we were forced to step back. We don’t remove historic blogs from the site where they are accurate at the time they were written. We apologise if this may have caused any confusion.

Our not being a member of the MOU has never meant we have changed our policy on conversion therapy, and it hasn’t changed our Code of Ethics. We are members of many different organisations and groupings, but leaving or joining any of these is a separate issue from our ethical stance. You can rest assured therefore that there hasn’t been any effect on your practice or with any of your clients. As a valued member, you have been working under the same ethical guidance and policy framework irrespective of what organisations or groupings your professional body belongs to.

We felt it was in the MOU’s best interests not to publicise our withdrawal as this risked media headlines of division and could have imparted the sense that the legal activists were gaining traction. We didn’t want this to happen.

Opposing conversion therapy can take many forms – for example, we pioneered and suggested making sure insurance companies would not cover therapists practising in this way. After our meetings with the GEO we were assured that, in the absence of a ban coming in to force, there is a multitude of actions than can still be taken.

We have been working behind the scenes for many months to find a route back to the MOU and have now been able to ringfence funds to protect us from future legal action. We’re happy to inform you that we have applied to rejoin MOU.

We appreciate your concerns over this matter. Do rest assured that we are engaged appropriately in this issue on behalf of our members.

Yours sincerely,

Jyles

The NCPS applies to rejoin the MoU!

Some of our members (certainly not all the members that have approached them about this) have had an email from NCPS saying that they are applying to rejoin the MoU. We know this to be factually accurate – this is not empty words.

There are still many questions to be answered – specifically around being a ‘member-led’ organisation and the naivety around the idea that one must withdraw from the MoU for fear of being sued but can create an alternative that doesn’t have that threat (which seems to have shifted position in the letter below), but please see below the full letter.

Dear [member]

Please find a message from the Society below regarding your communication with us.

Thank you for contacting us regarding the MOU and conversion therapy. Due to the number of communications from members we’ve received, we are sending out this response to everyone who kindly contacted us about the issue.

The Society opposes conversion therapy and wishes to see legislation that would ensure it was unequivocally banned. We have campaigned on this for a number of years, including engaging with Equalities Ministers, meeting their advisors, and meeting with the senior civil servant at the Government Equality Office (GEO) as far back as 2018.

The Society put forward and pioneered the approach, in the absence of legislation, to approach insurance companies in order that they invalidated insurance cover where a counsellor practised conversion therapy. Our Code of Ethics specifically prohibits conversion therapy and a member practising it would face de-registration.

Our policy has not changed on conversion therapy in any way. We signed up to the multi organisational Memorandum of Understanding (MOU) in order to come together with other organisations to push forward a plan to ban conversion therapy.

In 2022, we were targeted by legal campaigners who threatened us with legal action if we remained in MOU. Our insurance providers would not cover our defence of said legal action, and at the time we did not have sufficient funds to allocate to defending our position.

Alongside other signatories, such as our friends Pink Therapy, the noted LGBTQIA+ organisation, we were forced to leave MOU at the time and the threat of legal action was dropped. This was not a decision we wished to make. At no time did this decision change any of our policies or our Code of Ethics. We decided not to publicise this withdrawal to avoid misrepresentation or reputational harm to MOU.

Since then we have continued to campaign against conversion therapy, and have been looking for solutions that would enable us to rejoin MOU. We have managed to secure funds to protect the Society against future legal action and so we are pleased to announce that we have started the process to rejoin the MOU. We look forward to resuming joint campaigning on this issue.

We have no plans to change any of our policies in this area. Any substantive policy change would be a matter for our members, just as with ScoPEd. It’s worth emphasising again that leaving or indeed rejoining MOU is not related to our policies.

Thank you again for contacting us. Please rest assured that we continue to be a member-led organisation and all our members’ views are very welcome.

Kind regards,

The NCPS

Response and corrections to The Telegraph

We are aware of an article by Henry Bodkin for The Telegraph that has made several unfounded claims about Therapists Against Conversion Therapy and Transphobia (TACTT). The article focuses on the UK Council for Psychotherapy (UKCP)’s public withdrawal from the Memorandum of Understanding opposing Conversion Therapy (MOU2), citing concerns about the inclusion of children in that document.

The article features comments from the Chairman of UKCP, representatives of the Cass Review Committee, and the British Psychoanalytic Council. A variety of accusations were levelled at TACTT in the article and, in a failure of the most basic journalistic ethics set out in the IPSO Editors’ Code of Practice, the article does not accurately convey the facts of the situation and misrepresents both TACTT and members of UKCP who have sought a ballot for possible removal of the Board of Trustees. 

TACTT can confirm that no approaches have been made publicly or via direct message for us to comment on the piece or its accusations, even though we are easy for journalists to reach through email and social media and Mr Bodkin cited our website in the article. 

There are three patently false claims in the article that defame members of TACTT who have taken a stand on UKCP’s withdrawal from MOU2, and one further factual inaccuracy. All of these inaccuracies are liable to mislead the public: 

1. TACTT is trying to undertake a coup against the UKCP Board of Trustees
2. Members of TACCT are ‘bullying’ members of the UKCP Board of Trustees
3. TACTT is ‘[turning] a blind eye to the safety of children
4. UKCP is a “regulator of child psychotherapy and psychotherapeutic counselling”

We will address each of these points in turn. 

1. The calls for a vote of no confidence in UKCP’s Board of Trustees come from within the UKCP’s own membership. Signatories to the motion included members of TACTT and UKCP members who have no association with us. The motion was submitted in line with the regulation established in article 17.1 of UKCP’s own Articles of Association. 

The numbers of UKCP members who signed the motion exceeded the minimum required two percent of the number of members as of the first day of the month of the receipt of the first petition, as set out in the Articles of Association. Signatories believed that UKCP Trustees did not follow their own by the UKCP board when they made this decision to withdraw from the MOU2 without consultation with the membership or Articles-mandated Member’s Forum which “should be consulted on the future direction and strategy of the Charity and advise and collaborate with the Board of Trustees.” It is this failure in process that led to this call for a vote of no confidence. 

The motion will put the continuation or removal of the Board of Trustees to a democratic vote of the entire membership within 120 days of the motion, as set out in the Articles of Association. This is far from the definition of a coup. If the membership expresses through a free vote that it agrees with the organisation’s withdrawal from MOU2 and is satisfied with the conduct of the Board of Trustees on this matter, no individual or group of members will be in a position to take over the Board of Trustees nor does TACTT believe this would be in the best interest of members or psychotherapy clients of any age.

The Board of Trustees is accountable to its membership. The Articles of Association have been adhered to and members are entitled to exercise their democratic right to vote on the continuation or removal of the Board of Trustees. 

The characterisation of TACTT as making a power grab is disingenuous. TACTT would have been able to correct these inaccuracies had we been approached, but no attempts have been made to contact us for comment. 

2. It is false and misleading to characterise the membership of UKCP who have requested the removal election as “bullying” the Chair of the Board of Trustees or any other members of the Board. It is particularly misleading to say that TACTT as a collective is doing so. The Articles exist to ensure the proper running of the UKCP for the benefit of its membership and the psychotherapy and psychotherapeutic counselling clients with whom its membership works. Being held accountable through a democratic election is not bullying.

3. It is false and defamatory to characterise either TACTT as a group or members of UKCP who have signed the removal election motion as having disregard for the wellbeing and safeguarding of transgender children and young people. While we were not able to comment on The Telegraph’s article, we would like to thank Dr Moon for their comments included in the article. We concur that all therapeutic models are exploratory and this can only be ethically achieved in situations where gender or sexuality enter the therapeutic work by viewing no gender or sexuality as inherently better or preferable. This holds true for people of all ages seeking psychotherapy or psychotherapeutic counselling. Any other approach is conversion therapy.  

The comments from the Cass Review committee representative also imply that any membership organisation or regulatory body remaining signatories of the MOU2 are “[lowering] the bar on standards of clinical practice and safeguarding for… children and young people.” In the Cass Review’s own FAQs, they state that “no LGBTQ+ group should be subjected to conversion therapy,” and the MOU2 and TACTT are in agreement on this point. It is the guiding idea behind both the memorandum and our group. However by standing by that idea, we and the MOU2 signatories are painted as placing children and young people at risk.

Within the article, the Cass Review itself is presented as a “report on the dangers of gender ideology”, rather than the systematic review of trans healthcare provision by NHS England for children and adolescents. This is false and misleading. The article also misquotes and misrepresents the recommendation from the review that enhanced follow-on support for those aged 17-25 from GIDS, suggesting that people under 25 have been “rushed into changing gender”.

4. The story as presented in the article had a further inaccuracy and raised additional concerns amongst TACTT members. The UKCP chair presents the organisation as a “regulator of child psychotherapy and psychotherapeutic counselling.” The representative of the Cass Review committee similarly implies that the UKCP is a “regulator.” 

The UKCP is a membership organisation, not a regulatory body. It is factually incorrect to state that UKCP is a regulator, as membership organisations and regulatory bodies are very different things. A regulatory body mandates registration. Counsellors and Psychotherapists in the UK can voluntarily join a number of organisations, but it is not a requirement to be a member of any, nor specifically the UKCP. 

While TACTT members have our concerns about the Cass Review recommendations, and are working on a full response having given an interim response on our blog, we find the way the report is being used, misused, and weaponised in media conversations deeply worrying. This is especially evident when erroneous claims that misrepresent the UKCP members within and outside of the TACTT members who are making use of their democratic ability within their voluntary membership bodies to work how they see ethically fit when the Board of Trustees has not adhered to its own standards of behaviour.

Our petition for removal by election to UKCP

As many followers know, we have recently been described as bullying for asking that processes be invoked around voting for removal by election of the trustees of UKCP.

Our response to the newspaper article will follow later today but for completeness’ sake, here is the official letter to UKCP, sent on 11 April:

Dear UKCP Company Secretary, and who else this may concern,

I am writing to formally deliver a petition on behalf of alarmed UKCP members regarding UKCP’s board’s latest decision to withdraw as a signatory of the Memorandum of Understanding on Conversion Therapy in the UK v2 (MoU) and its membership of the Coalition Against Conversion Therapy. 

The petition lays out the reasons for our petition and calls for a vote of no confidence in the UKCP board, and for a removal election to be held for the current Trustees. Please find the link to the petition here: Petition

As per UKCP’s Articles of Association, Article 17, the petition has so far garnered the signatures of the required threshold of 2% of your membership as of the 10th April 2024 (9072) (this is not considering students, trainees and retired members). Please find attached the list of the signatures extracted from the letter for your reference. The letter has also garnered the additional support of more than 1000 of concerned professionals in the sector.

As per your Articles of Association, we are expecting a removal election to be held within 120 days of receipt of this petition, with members receiving at least 30 days of notice of it happening. 

Please kindly confirm reception of this petition and provide confirmation of the timeline by which we should get a response.

As a trainee UKCP member, I am personally delivering this petition as one of the many trainees and students who are refused a voice in UKCP elections, as a symbolic show that we do have a voice.

Sincerely,

Where do NCPS stand?

TACTT recently sent a group letter to The National Counselling and Psychotherapy Society (NCPS), signed by members, asking for clarification on their position regarding conversion therapy, and the Memorandum of Understanding. This followed NCPS being named in the statement in which UKCP announced their withdrawal from MoU; UKCP stated that they, with NCPS (and other bodies would seek to create new guidelines). The CEO of NCPS, Jyles Robillard-Day, has confirmed that he has received this letter and will respond within 28 days, but since then, new information has come to light, which have raised further questions for us.

Through further investigation, we have become aware that NCPS themselves does not appear to be listed as a signatory on the MoU. This was, for all of us NCPS members at TACTT, a big shock, especially given the fact that historically, they had been a signatory. From what we can see, they remained a signatory up until the end of 2022, but no longer appear on the document in January 2023. This seems to coincide with an update that was made to the MoU in November 2022.

The questions we are therefore asking are as follows:

*Why is it that NCPS appears to have disappeared as an MoU signatory between those dates?

Is this an error, or was it purposeful?

*If this is an error:

  • is it connected to the changing of the name of the society, from NCS to NCPS?
  • Can it be rectified asap so the membership can feel confident that they belong to a body who is part of the partnership against conversion therapy and supports the principles laid out in the MoU?

*If it was purposeful:

  • what was it about version two of MoU that they originally signed that made them make this decision, when their own written code of ethics supports it?
  • why have the membership not been informed, let alone consulted?

If the NCPS has not been a member of the MoU for nearly a year and a half, without its members being aware (and given there is still open reference to the MoU on the website), this would be an extremely serious matter.

Whether an intentional action or an error, we consider this action a grave mistake. What will be actioned in order that NCPS is fully transparent and accountable to its members to ensure such a grave error not be made again?

All these questions need answering and in our opinion, NCPS must (re)commit to the MoU at the earliest opportunity, and an apology and explanation should be submitted to its thousands of members, untold numbers of whom believed that they were part of an organisation signed up to the MoU, and who thus had a known and widely accepted framework to work within.

We await a full response from NCPS and will share any updates accordingly.