TRB Complaints and Fitness to Practise Policy

PSA Standards Met: 1b, 2, 4, 5, 6, 11

Purpose

This policy outlines how the Trauma Regulation Board (TRB) receives, investigates, and adjudicates complaints and fitness to practise concerns related to trauma practitioners on its voluntary register. It affirms TRB’s commitment to public protection, procedural fairness, and trauma-informed regulation, in accordance with:

Professional Standards Authority (PSA) Standard 11
Human Rights Act 1998
Equality Act 2010
Data Protection Act 2018
Nolan Principles of Public Life

Scope

This policy applies to:

Members of the public, service users, professionals, or organisations raising a concern
All individuals on the TRB Register
Concerns regarding conduct, competence, ethics, safeguarding, or breach of TRB Code of Practice

Definitions

We do not sell or lease personal data. We may share information only when:

Complaint: A concern that a practitioner has breached TRB's Code of Ethics or caused harm
Fitness to Practise: Whether a registrant remains suitable to deliver safe, ethical trauma care
Sanction: Regulatory action (e.g. conditions, suspension, removal) in response to risk or breach
Triage: Risk-based classification: Minor, Moderate, or High-Risk
Panel: A 3-person independent panel with no conflicts of interest

Guiding Principles

Public protection is paramount
All investigations are trauma-informed, independent, and proportionate
Anonymous complaints accepted (subject to evidentiary review)
All complainants and registrants are treated with dignity, fairness, and equity
The process will uphold data security, confidentiality, and accessibility

Submitting a Complaint

Complaints can be submitted via:

Online form (preferred)
Email or written letter
Third-party referral (e.g. commissioners, employers, safeguarding leads)

Required information:

Name of practitioner (if known)
Description of concern
Approximate date(s)
Any supporting documentation

Adjustments for neurodivergent, disabled or trauma-impacted individuals are available upon request.

Initial Triage (within 5 working days)

Reviewed by Complaints Lead
Categorised as Minor, Moderate, or High-Risk
Low-risk issues may be resolved informally (with complainant and registrant consent)
Moderate- or High-risk cases proceed to formal investigation
Where immediate risk is identified, interim suspension powers may be applied

Timeframe for informal resolution: within 10 working days
Timeframe for escalation to Panel (if required): within 20 working days

Outcomes and Sanctions

The Panel may:

Dismiss the complaint (with rationale)
Issue guidance or reflection notice
Apply conditions to practice (time-limited or review-based)
Suspend the registrant
Remove registrant from the register

Sanctions are proportionate, transparent, and time-bound.
Where safeguarding risks are identified, TRB will refer to statutory authorities (e.g. LADO, DBS, police).

Your Rights

You have the right to:

Be informed about what data we hold
Request access to your data (Subject Access Request)
Rectify inaccurate or incomplete data
Withdraw consent for specific types of contact
Request deletion of data (subject to legal and ethical obligations)

To exercise these rights, contact us at [email protected]

Appeals

All registrants have the right to appeal any sanction or decision via the TRB Appeals & Restoration Policy, within 28 calendar days.
Appeals will be heard by an independent panel and must provide new evidence or grounds (e.g. procedural unfairness, disproportionality).

Risk and Public Protection Measures

TRB may suspend registration during investigation if urgent risk is present
Pattern-based concerns trigger systemic review of practitioner’s conduct or training
Public-facing register will display active sanctions (subject to safety/privacy assessment)
Safeguarding referrals are made to relevant statutory bodies where necessary

Trauma-Sensitive Procedure

Communications use accessible, respectful, and non-pathologising language
Complainants may nominate an advocate or trauma support person
Written timelines, process expectations, and informed consent will be provided
Re-traumatisation is actively mitigated through flexible evidence-taking methods

Learning and Improvement

All complaints are logged and reviewed quarterly by TRB’s Oversight Committee
Themes are extracted to improve training, policy, or regulatory focus
Annual Report includes anonymised complaint data, thematic risk trends, and response metrics
All registrants are offered targeted CPD in areas of complaint concern (e.g. ethics, consent)