17th February 2022
We write as a group of registered counsellors, psychotherapists and psychologists in clinical practice in the United Kingdom.
We are contacting you to express our grave concerns around Vaccines as a Condition of Deployment (VCOD) mandates for health and social care professionals, and the implications that these could have for our profession.
Whilst we welcome the recent suspension of the NHS vaccine mandate to allow space for further public consultation, we are also aware that Sajid Javid, the Secretary of State for Health and Social Care, has made it clear that the debate on mandatory vaccination is far from over. He was quoted in The Times on 7th February as demanding that medical regulators send the “clear message” that healthcare workers must be vaccinated against coronavirus.
The implication here is that the onus of enforcing and policing the vaccination status of healthcare workers could be shifted from employers to professional/regulatory bodies. We are concerned about the silence of our professional bodies on this matter and now seek urgent clarification on their positions.
We call upon our professional bodies to publicly reject any policy of mandating COVID-19 vaccines as a condition of registration and/or deployment amongst their membership – either now or at a future point. Furthermore, we urge them to commit to protecting the right to informed consent and bodily autonomy, both for their professional membership and the clients we serve.
In particular, we would like the professional bodies to consider and respond to our professional concerns on the following points:
1. Mandatory vaccination policies conflict with our professional ethics as counsellors and psychological therapists.
One of the core principles common to the Ethical Frameworks of all our professional bodies is that of upholding client autonomy and their right to informed consent to treatment.
As health practitioners, we rightly understand that no medical or clinical intervention can be considered universally safe. We know from our own practice that even authorised, regulated and ethically sound medical treatments can still pose significant risks and have the potential to cause harm at an individual level.
As such, suitability for any medical treatment needs to be assessed on a case-by-case basis and can only be authorised with informed consent from the client (so long as they have the capacity to do so), after they have been given full and accurate information around any potential risks.
This principle of informed consent is not only vital to our ethical practice, it is upheld as a central principle within wider medical ethics and international human rights law. For example, in the UK all medical interventions in the NHS must be fully voluntary and in line with this principle of informed consent:
The decision to either consent or not to consent to treatment must be made by the person, and must not be influenced by pressure from medical staff, friends or family… If an adult has the capacity to make a voluntary and informed decision to consent to or refuse a particular treatment, their decision must be respected.
In March 2015, a significant judgement about the nature of informed medical consent was made in the UK Supreme Court. The court clarified that doctors must: “take reasonable care to ensure that the patient is aware of any material risks involved in any treatment,” in which, “a reasonable person in the patient’s position would be likely to attach significance to the risk, or the doctor is aware that the particular patient would be likely to attach significance to it”.
The court ruled that UK doctors can no longer rely on simply sharing the consensus of a body of medical opinion (‘the Bolam test’) as a basis for a patient’s informed consent, but a personalised risk assessment must be given. In the case of COVID-19 mandates, this means that generic claims that ‘the science is settled’ or ‘vaccines are safe and effective’ – cannot be used to justify their safety for an individual.
The public and professional discourse on COVID-19 vaccination mandates are an example of how social pressure can be exerted on individuals to have a particular health intervention, even without a full individual risk assessment or any long-term safety data. As such, mandates can be considered medically coercive and in direct violation of the legal principle of informed consent.
We call on our professional bodies to recognise that coercion does not equal informed consent.
2. COVID-19 vaccines are far from universally ‘safe and effective’.
COVID-19 vaccinations use novel technologies which have been in widespread use for little more than a year, are still in clinical trials and for which by definition no long-term safety data is available.
Since the start of the vaccine rollout, we have already seen a significant shift from the COVID-19 jabs being promoted as being ‘safe and 100% effective’ – to a recognition that there can be serious, even fatal side effects for a small minority of people. Their overall efficacy, especially in reducing transmission and preventing the spread of Coronavirus, is also far from what was originally hoped for.
Furthermore, since their general release, some COVID-19 injections have now been discontinued for use within certain demographics due to safety concerns. For example, the AZ and Moderna vaccines have been discontinued for young people in several countries after safety concerns arose around the risks of blood clots, following several high-profile deaths. In more recent months there have been emerging scientific studies showing the risks, particularly to younger males, of serious side effects such as myocarditis and pericarditis following vaccination, as well as ongoing concerns about the impact of vaccines on the female menstrual cycle. Both concerns have led to the commissioning of major safety investigations through additional clinical trials.
Whatever the outcome of these investigations, the fact remains that our understanding of these novel COVID-19 vaccines and the risks they pose to human health is far from comprehensive or complete.
Whenever there is risk of significant harm from a medical intervention, especially when the treatment is newly developed and those harms could be life-threatening, it is imperative that there is free choice for the individual to refuse that treatment without fear of negative consequences.
For professional bodies to require mandatory vaccination as a condition of professional registration, for acceptance on professional training courses, or as a condition of employment, would amount to unethical coercion of its professional members. To do so would place the professional bodies in direct violation of the principle of informed consent.
We ask that the professional bodies join us in speaking out against the unethical nature of mandatory vaccination policies, and publicly affirm their commitment to the ethical principle of informed medical consent.
3. Informed consent goes beyond issues of safety and risk.
As counsellors and therapists, we recognise that assessing the safety profile of a specific intervention is only one aspect of the complex decision-making process that informs our consent to medical treatment.
An individual’s moral, spiritual and political beliefs, as well as their cultural practices, life experiences and approach to managing their health, will also have an impact on their willingness to give, or withhold, informed medical consent.
Many of us take a holistic, person-centred approach to working with our clients. As such, we believe in the validity, authority and importance of these broader factors that can be drawn upon to inform medical consent. We see these wider factors as valuable, essential and equal; individuals have a right to refuse a medical treatment on wider grounds than its official safety profile or potential side effects. We are particularly concerned about the impact of mandates on those who have complex health conditions, those who have prior experiences of being harmed by medical treatments, those who favour their natural immunity, and those with religious or ethical concerns about the development process of the vaccines.
Current government guidelines for vaccine mandates only grant ‘medical exemption’ to staff with a tiny number of officially permitted medical conditions , with no allowance for many broader concerns that could be central to someone deciding not to consent to a COVID-19 injection. We believe that the government has no lawful right or moral authority to draw up a set of very limited medical criteria and then insist that these are the only permitted circumstances in which someone can be officially ‘exempted’ from vaccine mandates without facing redeployment or job loss.
As counsellors and psychological therapists, we uphold the right of every individual to make an informed choice about whether to take a COVID-19 vaccination, or indeed any other medical intervention, based on their own personal circumstances and medical history. We call on our professional bodies to uphold that right for practitioners and the clients we serve.
4. Professional bodies are failing in their duty of care to members who are affected by NHS vaccination mandates.
It would be incongruent for professional bodies to enshrine the principle of informed consent within their ethical codes of conduct for working with clients, whilst their professional members are not permitted to make autonomous decisions about their own medical treatment.
Mandatory vaccination policies, and the loss of the right to informed medical consent, is causing significant psychological distress to many UK counsellors and therapists, especially those working in the NHS. Many of these affected practitioners have been loyal, paying members of their respective professional bodies for decades. The silence and seeming lack of engagement from our professional bodies around this issue is both disturbing and disappointing given how severe the consequences are for members who face job loss.
The exact number of counsellors and psychological therapists who stand to be affected by NHS vaccine mandates is uncertain, as to our knowledge, there has been no formal consultation process around this issue by any of the professional bodies.
However, Therapists for Medical Freedom have now facilitated numerous free, volunteer-run support workshops for affected therapists, which have often been full to capacity. We have also had hundreds of communications from distressed members who are under significant stress from the vaccine mandate process. Many have complained to us about experiencing an utter lack of clarity, guidance or support from their professional body.
Professional bodies have a duty to represent the interests of their paying members, especially at times where their human and employment rights are under threat in a professional context.
Therapists affected by vaccine mandates deserve better treatment and representation than they are currently getting from professional bodies. This situation must change, and we appeal to professional bodies to address this with the utmost urgency.
5. Vaccine mandates will have negative consequences for clients accessing therapeutic services.
NHS England estimated that had the vaccine mandate policy been implemented in April as planned, this would have left the NHS down by at least 80,000 staff, as many planned to leave the profession rather than comply with the policy. . This number would increase exponentially if vaccines were mandated as part of the professional registration process, thereby affecting health professionals working outside of NHS services, which applies to most therapists and counsellors in the UK.
To lose a significant number of counsellors and therapists at a time of national crisis could pose significant harm to clients. COVID-19 and the wide-ranging impact of restrictions on the population has left a legacy of new and worsening existing mental health problems. The Centre for Mental Health estimates that 8 million adults and 1.5 million children will need mental health support in the years following the pandemic.
Those of us who have worked to provide psychological therapies throughout this challenging time are now seeing an unprecedented rise in demand for NHS and voluntary sector counselling and therapy services, to the point where people in need now face dangerously long waiting times. Across the UK, even private therapy services and individual practitioners are in short supply, with many having to make difficult decisions to turn away people in need because they simply do not have the resources to treat them. At a time of increased mental health need, vaccine mandates would therefore be detrimental for current and future clients.
We call upon the professional bodies to provide reassurance that clients’ access to therapeutic support will not be restricted based on vaccination status, either now or in the future. We also call on them to reject policies that will risk the loss of experienced practitioners, put further strain on existing services and staff, and potentially dissuade others from training to enter the field.
6. It is essential to consider the wider context to mandatory vaccination policies and to remember the lessons of history.
As counsellors and psychological therapists, when faced with an ethical dilemma, we are encouraged to look beyond the issue itself and consider the wider field and context – including any relevant historical, sociological and political factors. Therefore, when considering the ethics of vaccine mandates, we must consider more than just the risk posed by COVID-19 vs the benefits and risks of vaccination.
When we step back and consider the wider socio-political context, we can clearly see that:
- Governments do not always act in the best interests of the public they are appointed to serve, whatever their political rhetoric might be. We are seeing numerous examples of this emerging now, for example the conflicts of interests in the awarding of PPE contracts and the flouting of COVID-19 rules by senior government figures.
- There have been numerous instances in human history, especially at times of ‘national emergency’, where government bodies have actively lied to the population, exploited the situation to further their own aims, or have sought to conceal important information, especially when it could harm their wider political agenda.
- The health care system has a long history of being vulnerable to exploitation by political lobbyists, corporate donors or becoming compromised by internal pressures from within government or from regulatory bodies. Consider examples from our recent history – public health advice given to reassure the public of the safety of tobacco, pesticides, GMOs – which have later been proven to be manifestly unsafe, despite the proclamations of the government-sanctioned public health experts of the time.
- Many authorised medical treatments have later been discovered to be causing significant harm to human health and have been withdrawn from public use, despite having passed required safety checks and being widely embraced by the medical orthodoxy of the time.
- We are being exhorted to “trust the science” when there is no such thing as ‘the’ science. Rather, science has always comprised a breadth of opinions, conclusions, methods and ethical standpoints. History has shown us that public trust has not always been as safe as we would hope for in the hands of scientists and medical professionals, especially when there are financial interests at stake.
- Politicians, pharmaceutical companies, peer-reviewed medical research, clinical trials, regulatory bodies and individual expert opinion – all of these are vulnerable to human error, corruption and conflicts of interest which are not always declared or formalised.
In the context of our collective history, as ethical health practitioners, we have a responsibility to ask difficult questions if we see draconian policies such as vaccination mandates being introduced in our society. We must continue to think critically about who would profit and benefit most from such policies. Might there also be vested interests, whether in government, science and medicine or the pharmaceutical industry, that could stand in the way of open and transparent discussion?
It is not the terrain of ‘conspiracy theory’ for therapists and other health professionals to demand that government and medical experts are scrutinised and held to account for the policies they impose upon the public. As a profession, we must make room for alternative perspectives and difficult questions without these legitimate concerns being dismissed or slandered as ‘anti vax’, ‘dangerous disinformation’ or even more alarmingly, as ‘far-right extremism’.
It is not acceptable for our Professional Bodies to simply dismiss or silence any dissenting voices within their membership, or to ignore these difficult questions. Nor is it acceptable for heavy-handed policies such as COVID-19 vaccine mandates to be supported and justified by our professional bodies on the sole basis that they are acting in line with ‘official legislation or government guidance’ without any independent analysis of the actual effectiveness, ethics, or impact of the guidelines – or any acknowledgement that governments do not always act solely in the public interest.
Our professional bodies have a duty to carefully scrutinise any mandated public health measures that compromise our medical autonomy. They must not be accepted on face value as being in the public interest simply based on the assurances of government and its approved health advisors, or pharmaceutical companies with vested interests.
It is time for the professional bodies who represent counsellors and psychological therapists in the UK to show courage and break their collective silence on the issue of mandatory vaccination in our profession.
In light of all the above, we call on our professional bodies to:
- Uphold the values that are written and protected within their own ethical codes by publicly affirming their commitment to protecting the right of therapists and clients to freely give or withhold their consent to medical treatment without fear of coercion or punishment.
- Affirm that their commitment to upholding the right to informed consent will stand regardless of the emergence of new future variants, waves of disease or novel medical treatments.
- Engage with Therapists for Medical Freedom and other groups of concerned professionals in a process of dialogue around the ethics and legality of vaccine mandates in our profession.
- Pledge to protect the rights of therapists and clients who have exercised their lawful right to informed consent to refuse COVID-19 vaccinations.
- Use their authority as professional membership bodies to prohibit the implementation of discriminatory policies around COVID-19 vaccinations within their organisational membership and associated training institutes – and to publicly speak out against such discriminatory practices in the wider field.
- Remind their members that we each have an ethical responsibility to think critically for ourselves when assessing any government health advice, especially when it is mandated. Professional bodies should help facilitate this broader risk assessment process within their membership, especially the potentially negative impact that any existing or future public health advice might have on practitioners and clients.
- Take into account the broader historical, social and political context when assessing the ethics of mandatory health interventions. We cannot forget the harm that has been caused to human health and civil liberties when the right to refuse medical treatment has been denied to populations at other times in history.
We await to hear your considered responses on these important matters of professional ethics, legislation and human rights, and look forward to beginning a process of dialogue with you.
Therapists for Medical Freedom
Jennifer Ayling, Psychotherapeutic Counsellor, UKCP
Clare Beatson, Counsellor, BACP
Elizabeth Bentley, Psychotherapist, BACP
Paula Charnley, Counsellor, BACP
Ben Harris, Psychotherapist, MBACP
Julie Horsley, Counsellor, NCS
Frances Kandler-Singer, Psychotherapist, BACP
Naintara Land, Psychotherapist, UKCP
Rachel Maisey, Counsellor, BACP
Kate Morrissey, Psychotherapist, BACP
Melanie Pickles, Counsellor, BACP
Dr. Bruce Scott, Psychoanalyst, UKCP & CP-UK
Dr. Gary Sidley, Clinical Psychologist (Retired)
Deborah Short, Psychotherapist, UKCP
Elizabeth Smith, Psychotherapist, Pre-Accred
Leanne Ward, Clinical Psychologist, HCPC
Sarah Waters, Psychotherapist, MBACP
Dr. Elena Alexandrou, Clinical Psychologist, HCPC
Marc Allen, Trainee Therapist, Pre-Accred
Emily Barber, Psychotherapist, BACP
Dr. Alison Bates, Clinical Psychologist, HCPC
John Bates, Psychotherapist, UKCP
Tonya Bathe, Psychotherapist, BABCP & BACP
Dr. Faye Bellanca, Clinical Psychologist, HCPC
Stephen Biggs, Clinical Psychologist, HCPC
Paul Birch, Psychotherapist, UKCP
Vanessa Blackmore, Psychotherapist, BACP
Dr. Claire Bone, Clinical Psychologist, HCPC
Rosemary Boon, Psychotherapist, APS
Anne Booth, Counsellor, BACP
Antoine Bowes, Counsellor, BACP
Matthew Bowes, Psychotherapist, UKCP
Jacqueline O’Brien, Psychotherapist, (retired)
Jeremy Brooks, Psychotherapist, BACP & UKCP
Jo Bull, Psychotherapist, BABCP
Sheila Burchell, Clinical Psychologist, HCPC
Johann Burton, Counsellor, NCS
Charles Campbell-Jones, Psychotherapist, BPC & BACP
Ruby Chance, Psychotherapist, UKCP
Liz Cobb, Psychotherapist, BACP
Dr. Theresa Comer, HCPC, Clinical Psychologist
Jo Conrad, Counsellor, BACP
Dr. Jo Coombs, Clinical Psychologist, HCPC
Kim Cooper, Counsellor, BACP
Helen Cowan, Counsellor, BACP
Danielle Crawshaw, Psychotherapist, UKCP
Kate Dalton, Psychotherapist, BACP
Gemma Davies, Psychotherapist, BACP
Emma Davis, Psychotherapist, UKCP & HCPC
Kadi Debbah, Counsellor, BACP
Vagelis Dimitriou, Counsellor, BACP
Miriam Donaghy, Psychotherapist, UKCP
Laura Driesen, Clinical Psychologist, HCPC
Dr. Timothy Dunne, Clinical Psychologist, Associate Fellow of BPS
Davina Elsen, Counsellor, BACP
Gillian England, Psychotherapist, BACP & BABCP
Audrey Elliot, Counsellor, BACP
Dr. Erika Filova, Clinical Psychologist, HCPC
Zac Fine, Psychotherapist, BACP
Katherine Franklin-Adams, Psychotherapist, BACP
Angela Gilchrist, Clinical Psychologist, BPS & HCPC & ACP-UK
Gemma Gilham, Trainee Therapist, CPCAB
Sara Godoli, Psychotherapist, UKCP
Dr. June Golding, Psychotherapist, UKCP
Mr. John Gordon, Psychotherapist, BCP
Heather Graham, Counsellor, BACP
James Graham Corscadden, Clinical Psychologist, BPS
Dr. Nicola Graham-Kevan, Counsellor, BPS
Dr. Tracey Grant Lee, Clinical Psychologist, HCPC
Dr. Federica Graziano, Clinical Psychologist, HCPC
Dr. Diane Griffiths, Clinical Psychologist, HCPC
Jan Haghverdi, Counsellor, BACP
Sarah Harber, Psychotherapist, Pre-Accred
Renata Harris, Clinical Psychologist, HCPC
Andy Halewood, Psychotherapist, BACP & BPS
Andrew Harry, Counsellor, UKPTA
Mark Hartshorn, Psychotherapist, BACP
Andrea Hazlett, Trainee Therapist, FHT
Susan Hayes, Psychotherapist
Laurie Hole, Counsellor, NCS
Michael Horgan, Trainee Therapist, Pre-accred
Jessica Horton, Counsellor, BACP & BPS
Ruth Hoskins, Psychotherapist, UKCP
Isla Hunter, Psychotherapist, BABCP
Leiah Ikafa, Retired Therapist
Miranda Jenkins, Counsellor, BACP
Rebecca Jesty, Counsellor, BACP
Andrea Jordan, Counsellor, RCM
Natasha King, Psychotherapist, HCPC
Lena Kornyeyeva, Clinical Psychologist, EATA
Cabby Laffy, Psychotherapist, UKCP & CORST & NCP
Gabrielle Lake Mitchell, Trainee Therapist, BACP
Rosey Lawrence, Trainee Therapist, Pre-Accred
Sophie Leader, Psychotherapist, BACP
Maggie Leathley, Psychotherapist, BACP
Jane Lewis, Psychotherapist, UKCP
Dr. Samantha Lewis, Clinical Psychologist, HCPC
Jane Lindsay, Psychotherapist, UKCP
Maya Mamish, Clinical Psychologist, BPS
Jane Margerison, Psychotherapist, BACP
Jonathan Martin, Psychotherapist, UKCP
Rufus May, Clinical Psychologist, HCPC
Fiona McAlister, Psychotherapist, BACP
Conor McCafferty, Psychotherapist, BACP
Gary McKeever, Counsellor, BACP
Fiona McNally, Psychotherapist, BACP
Aysem Mehmet, Psychotherapist, BABCP
Maria Michalakopoulou, Counsellor, MBACP
Jason Middleton, Psychotherapist, BACP
Caroline Montanaro, Psychotherapist, UKCP
Suzanne Moore, Psychotherapist, BABCP
Christopher Morris, Psychotherapist, BACP
Anne Murphy, Counsellor, BACP
Dr. Naomi Murphy, Clinical Psychologist, HCPC & A-CP
Mark Murray, Counsellor, NCS
Anna Murray Preece, Psychotherapist, UKCP
Dr. Rachel Newton, Clinical Psychologist, HCPC & BPS
Katie Neylan, Psychotherapist, BACP & BABCP
Malgorzata Paliszewska, Clinical Psychologist, HCPC
Lauren Parker, Trainee Therapist, Pre-Accred
Sue Parker Hall, Psychotherapist, UKCP
Kay Parkinson, Psychotherapist, UKCP
Darshna Patel, Psychotherapist, BABCP
Dr. Helen Payne, Psychotherapist, UKCP & ADMP UK
Dr. Nicholas Peckham, Clinical Psychologist, HCPC
Dr. Kirsten Perkins, Clinical Psychologist, BPS & HCPC
Carolyn Polunin, Psychotherapist, UKCP
Livia Pontes, Clinical Psychologist, BPS, HCPC & BABCP
Dr. Kate Porter, Clinical Psychologist, HCPC
Rob Preece, Psychotherapist, UKCP (retired)
Rebecca Quick, Clinical Psychologist, PBS
Dr. Andrew Rayner, Clinical Psychologist, HCPC
Sasha Reay, Counsellor
Tracy Rees, Trainee Therapist, Pre-Accred
Becky Ridgewell, Psychotherapist, MBACP
Marijke Roberts, Counsellor, NCS
Dr. Helen Ross, Clinical Psychologist, HCPC
Antonella Russo-Ball, Psychotherapist, UKCP & MBACP
Jane Sanders, Psychotherapist, UKCP
David Scott, Clinical Psychologist, HCPC
Paige Sessions, Psychotherapist, BABCP
Jeremy Slaughter, Clinical Psychologist, HCPC
Leah O’Shaughnessy, Counsellor, BACP
Sara Simon, Psychotherapist, HCPC
Regina Sinkovicz, Psychotherapist, BACP
Dr. Helen Startup, Clinical Psychologist, HCPC & BABPC
Karen Sturch, Counsellor, BACP
Eileen Sullivan, Counsellor, BACP
Cath Sunderland, Psychotherapist, UKCP
Patricia Taddei, Psychotherapist, UKCP
Vicky Talbot, Psychotherapist, BABCP
Angela Taylor, Counsellor, BACP
Lori Thackham, Counsellor, BACP & NCS
Gem Thomson, Psychotherapist, BABCP
Marsha Towey, Clinical Psychologist, BPS & HCPC & BACP
Dr. Lucie Turner, Clinical Psychologist, HCPC
Philippa Vaizey, Psychotherapist, UKCP
Marc Venner, Counsellor, BACP
Dionne Ward, Counsellor, BACP
Dr. Alice Welham, Clinical Psychologist, HCPC
Anna Westwood, Counsellor, BACP
Georgia Whyte, Trainee Therapist, BABPC
Debbie Williams, Psychotherapist
Tracy Williams, Counsellor, BACP
Robert Wills, Counsellor, BACP
Lee Wilkes, Counsellor, BACP
Tracy Wood, Counsellor, BACP
Sarah Worth, Counsellor, ACC
Dominique Wynn, Psychotherapist, (Retired)
Dr. Clare Young, Clinical Psychologist, HCPC
Sign the Open Letter
Are you a Counsellor, Psychotherapist or Clinical Psychologist based in the UK who is concerned about the impact of vaccine mandates on the profession? (whether you are personally vaccinated or not).
If so, please sign the letter below along with your professional body and we will add you to our public list of signatories:
Professional Bodies Open Letter