Considerations Before Making a Complaint

• Safeguarding

Does your complaint involve any safeguarding or criminal matters that should be reported to the appropriate authorities?  If so, please refer to your local authority website for information on how to make a safeguarding referral.

• UK-SBA Registrant

Is the person you wish to complain about a registered member of the UK-SBA?  The UK-SBA only has jurisdiction over its registrants.  Search the UK-SBA register to find registrants and their membership number here.

• Self-Employed Registrants

Is it appropriate or possible to raise your concerns directly with the registrant in the first instance? 

• Employed Registrants

Is it appropriate or possible to raise your concerns directly with their employer in the first instance?

• Contractual Matters

Does the complaint relate to contractual issues regarding payment, holidays, and so on? Such matters are beyond the scope of the Complaints Procedure.  Please refer to the 'For the Public' section on our website.

• Organisational Complaints

The UK-SBA can only deal with complaints against individual registrants, not organisations.  If your complaint relates to an organisation, please refer to that organisation's complaints procedure.

• Supporting Evidence

All complaints must be submitted with relevant evidence otherwise the complaint cannot be accepted.  You will need to upload evidence for any alleged breach you detail in your complaint under the appropriate principle.  Please have all of your evidence saved and ready to upload for when you reach the appropriate principle(s) you consider having been breached.  If you do not have all of your evidence ready at that point please advise under the appropriate principle which evidence is missing and when you expect to submit this missing evidence.

• Completing the Complaint Form

Please complete the form in detail, referring to the UK-SBA Complaints Procedure.  Rest assured that your concerns will be thoroughly reviewed and addressed by our team.

Please detail with evidence which subsections from 1.1 to 1.4 relate to your complaint

1.1 Registrants do not engage in or condone harmful, degrading, painful or dehumanizing practices. They are aware of and committed to guarding against financial, social, organisational, political, emotional, personal or sexual factors that may lead to a misuse of their expertise or exploitation of those they work with or for.

1.2 Registrants consider both immediate and remote variables that may impact on a client’s experience of interventions and choose the least restrictive alternatives to accomplish habilitative goals.

1.3 Registrants do not provide services while they are unfit to do so or under such circumstances that professional judgement or practice may be impaired; such circumstances include, but are not limited to, physical or mental illness, adverse personal events, or addiction to substances.

1.4 Registrants do not support efforts to suppress self-regulatory behaviours except in rare cases when the behaviour poses harm or a significant risk to wellbeing. In such cases, the registrant must first ensure that the risk cannot be ameliorated by reasonable changes to the environment. The registrant acknowledges the function of the self-regulatory behaviour and always prioritises the well-being of the client by ensuring that functionally equivalent alternative behaviours are supported and encouraged. 

Please detail with evidence which subsections from 2.1 to 2.13 relate to your complaint

2.1 At all times, Registrants protect clients, colleagues and organisations from risk of harm presented by another person’s conduct, performance or health.

2.2 Registrants do not engage in behaviours that would delay effective intervention for clients or potential clients (e.g., maintaining waiting lists without providing referrals for other behaviour analytic providers).

2.3 Registrants ensure their practices pose no physical or emotional threat to the safety of clients, colleagues or staff. Environments presenting risk of harm are evaluated and relevant persons informed of measures necessary to reduce such risks.

2.4 Registrants report any concerns about the safety or wellbeing of clients promptly to appropriate personnel. They support and encourage others to report concerns and do not impede anyone raising concerns about safety, malpractice or risk of harm.

2.5 Registrants ensure that the safety and wellbeing of clients takes precedence over professional or other loyalties.

2.6 Registrants obtain and maintain appropriate provision for professional indemnity insurance.

2.7 Registrants ensure they have the appropriate DBS checks applicable to the clients with whom they work, if relevant to their field of work and expertise.

2.8 Registrants undertake safeguarding training appropriate to the clients with whom they work, if relevant to their field of work and expertise

2.9 Registrants ensure stakeholders understand the importance of DBS checks and safeguarding training relevant to the client or client group.

2.10 Registrants ensure, to the extent practicable, that they enquire about or assess medical or physiological needs that may contribute to behaviour and make referrals to other professionals as is appropriate.

2.11 Registrants monitor client responses to treatment and remove intervention components that appear to cause emotional or physical distress.

2.12 Registrants are obliged to follow any relevant legislation in relation to their field of work and practice within the law as governed by any such legislation.

2.13 Registrants engage in self-care activities that reduce the likelihood of burnout or other conditions that could impair judgement or affect their ability to benefit clients.

Please detail with evidence which subsections from 3.1 to 3.8 relate to your complaint

3.1 Registrants prioritise the values of the client to inform treatment goals and behaviour change procedures.

3.2 Registrants identify all relevant stakeholders when working with clients and invite input from those stakeholders. However, registrants advocate for the best interests of clients regardless of other stakeholder priorities.

3.3 Registrants promote the inclusion and participation of clients across all aspects of the behaviour analytic process, prioritising client choice and promotion of self-advocacy.

3.4 Registrants are committed to understanding and embracing culture as central to effective practice, and demonstrate self-awareness, cultural responsiveness, humility, and sensitivity.

3.5 Registrants do not engage in or condone discrimination against individuals or groups based on age, gender, race, culture, ethnicity, national origin, religion, disability, language, LGBT+ identity or socioeconomic status. They do not engage in behaviour that is harassing or demeaning to colleagues, supervisees, students, clients or representatives of organisations or other persons with whom they work based on age, gender, LGBT+ identity, race, culture, ethnicity, national origin, religion, disability, language or socioeconomic status of those persons.

3.6 Registrants translate behaviour analytic terminology in a way that is appropriate to the audience with whom they are communicating.

3.7 Registrants respect and value neurodivergent identities. Registrants advocate for acceptance and understanding of neurodiversity.

3.8 Registrants only support individuals in their pursuit of changes to their behaviour that are meaningful to them; registrants never select goals independently but do so only in collaboration with the individuals whom they serve and when appropriate, with those who advocate for those individuals.

Please detail with evidence which subsections from 4.1 to 4.10 relate to your complaint

4.1 Registrants conduct assessments prior to making recommendations or developing behaviour change programmes. They explain assessment results to clients using plain language and graphic displays of data.

4.2 Registrants are guided by the empirical literature and rely on scientific knowledge, conceptual analysis, and technical practices derived from the field of Behaviour Analysis. They maintain knowledge of current scientific and professional information in their areas of practice and continue to update their knowledge and skills by keeping abreast of relevant scientific literature, attending professional and scientific meetings and conferences, and accruing continuing professional development credentials as required.

4.3 Registrants continue data collection throughout behaviour-change programmes. They use graphical displays of data to inform judgements about the progress of behaviour change, the suitability of procedures for individual clients and environments, the efficacy of behaviour-change procedures, and the necessity of adjustments or revisions based on outcomes. Recommendations for new procedures or adjustment of procedures already in place are at all times based on an analysis of ongoing data collection

4.4 Registrants advocate for the clients’ right to effective treatment based on current scientific knowledge and their unique requirements.

4.5 Registrants advocate for scientifically supported, effective and ethical procedures, and inform clients and the public about such procedures.

4.6 Registrants ensure that behaviour-change procedures are conceptually consistent with Behaviour Analytic principles and scientific knowledge.

4.7 Registrants do not promise specific outcomes but share data to show progress toward achieving specific, operationalised goals.

4.8 Where Registrants oversee the provision of services by others, they ensure those they oversee are skilled in reliable and valid data collection.

4.9 In seeking to provide the most effective procedures available, Registrants do not succumb to undue pressure from, for example, clients, relatives, school personnel or other service providers to abandon or compromise the scientific, analytic or technical procedures that characterise the field of Behaviour Analysis. In such circumstances, Registrants make clear their adherence to the UK-SBA Code of Ethical and Professional Conduct and seek to educate those concerned of the practical importance of maintaining the high standards set by the UK-SBA and the wider profession of Behaviour Analysis.

4.10 Registrants do not use testimonials, either solicited or unsolicited, to advertise services.

Please detail with evidence which subsections from 5.1 to 5.7 relate to your complaint

5.1 When designing behaviour change strategies, Registrants consider and plan for long-term outcomes that improve quality of life.

5.2 Registrants support clients to develop functionally equivalent alternatives to behaviours targeted for change (e.g., developing functional communication) that promote autonomy and success across a range of environments.

5.3 Registrants prioritise pro-active and preventative strategies that promote safety and reduce risk, and may preclude the need for further intervention.

5.4 Registrants actively plan for the maintenance and generalisation of skills to produce long-term, meaningful outcomes.

5.5 When Registrants use consequence-based interventions, they prioritise reinforcement strategies.

5.6 Registrants ensure that those tasked with implementing interventions have sufficient training and support to implement those interventions with integrity.

5.7 Registrants actively identify obstacles in the environment that may negatively impact intervention outcomes and take reasonable measures to remove those obstacles.

Please detail with evidence which subsections from 6.1 to 6.7 relate to your complaint

6.1 Registrants gain informed consent from clients in writing prior to assessment, implementation of behaviour change procedures, and change of programme components.

6.2 Registrants prioritise client assent, even in situations in which a client is unable to provide consent due to age or capacity and best interest decisions are made by legal guardians and stakeholders.

6.3 Registrants continuously monitor client consent (or assent) for procedures, and make changes when clients communicate, verbally or otherwise, that they do not consent or assent to a procedure.

6.4 Registrants obtain consent for electronic recording from all concerned parties and separately for specific uses. In situations where electronic recording is required, Registrants ensure clients understand the purpose of such recording and secure permission from clients and from relevant staff in service settings. The use and storage of any electronic recordings for the purposes of training others should be agreed prior to sharing and reviewed periodically.

6.5 Registrants obtain written consent from relevant parties before sharing any details about the client with other professionals.

6.6 In situations where anonymised client data might be used for the purposes of training others (e.g., scientific publications, conference presentations, training workshops), Registrants ensure written consent for use of client data.

6.7 Registrants only support individuals in their pursuit of changes to their behaviour that are meaningful to them; registrants never select goals independently but do so only in collaboration with the individuals whom they serve and when appropriate, with those who advocate for those individuals.

Please detail with evidence which subsections from 7.1 to 7.5 relate to your complaint

7.1 Registrants are honest, open and clear in relation to any and all financial matters concerning clients, service delivery, training and provision of supervision.

7.2 Before providing services, Registrants provide full and clear explanations of fee levels and structure, terms and methods of payment, and any charges that might be imposed non-attendance or cancelled appointments. Registrants clarify the terms on which they offer services in advance of clients incurring any financial cost or obligation, or other costs or liabilities, reasonably foreseen by the Registrant.

7.3 After consultation with potential service recipients, Registrants prepare a contract outlining responsibilities of all parties, the scope and nature of the services to be provided, fees, conditions of contract termination and notice period, the Registrant’s commitment to the UK-SBA Code of Ethical and Professional Conduct, and the right to complain about the Registrant’s ethical or professional behaviour. The contract must be agreed and signed by all relevant parties before service provision begins.

7.4 Registrants thoroughly document their professional work for purposes of review with clients and other relevant parties, to accurately inform the provision of services by the Registrant, supervisees and trainees, and to facilitate handover should the need arise. Records should include assessments and outcomes, intervention plans and revisions to those plans, case notes, and any data pertinent to the case.

7.5 Registrants maintain, transport, store and destroy client data in compliance with General Data Protect Regulation (GDPR).

Please detail with evidence which subsections from 8.1 to 8.8 relate to your complaint

8.1 Registrants ensure information pertaining to present and past clients, professional colleagues and/or organisations they have worked with or for remains strictly confidential. They protect all such information from unauthorised disclosure.

8.2 Registrants take necessary and appropriate steps to ensure personal information, practice reports, data sets and other records pertaining to Behaviour Analytic services are stored securely with access restricted to relevant concerned parties with appropriate consent only.

8.3 Registrants take precautions to protect confidentiality, ensuring client notes and records are kept secure and use of records remain within the terms of GDPR. Records held on computers should be password protected and manual records locked away when not in use. When transferring data to GDPR compliant parties, a VPN (virtual private network) should be used to ensure data transfers are encrypted. When client records need to be kept in a car, they should be in a secure locked container and stored in the car boot.

8.4 Registrants only discuss confidential information with clients and relevant professionals and only for appropriate professional purposes.

8.5 Registrants discuss issues relating to client confidentiality with clients, fellow professionals with whom they work and supervisees or trainees at the outset and remind all concerned parties of the importance of maintaining confidentiality and adhere to the same principles throughout.

8.6 Registrants do not share information about clients or supervisees on social media. This includes sharing photographs or social media handles, or any information or detail that might potentially identify past or present clients.

8.7 Communications or sharing of information on the basis of client consent or as required for safeguarding purposes do not constitute a breach of confidentiality.

8.8 In situations where Registrants wish to share data and/or any identifying details of their practice for the purpose of training others or dissemination (e.g. scientific publication, conference presentations, training workshops), data must be anonymised and written consent from clients must be obtained.

Please detail with evidence which subsections from 9.1 to 9.33 relate to your complaint

9.1 Registrants uphold the highest standards of professional integrity in their work with clients, colleagues and other professionals.

9.2 Registrants are objective, honest and accurate in their verbal and written account of a client’s needs and recommendations. In their representation of Behaviour Analysis they declare any self-interests and are open to other’s viewpoints whilst maintaining their position based on the data and evidence they have.]

9.3 All research must be approved by an ethics committee and conducted in compliance with the UK-SBA Code of Ethical and Professional Conduct.

Maintaining professional boundaries

9.4 Registrants recognise the importance of maintaining appropriate professional boundaries and take steps to ensure relationships between themselves and those to whom they provide services are and remain professional.

9.5 Registrants are sensitive to the potential harmful effects of multiple relationships and avoid social or other non-professional contacts with persons to whom they provide services.

9.6 Registrants declare any conflicts of interest in professional relationships or roles they undertake. They recuse themselves from decision-making in which those conflicts might result in bias or be reasonably perceived as bias.

9.7 Registrants do not provide professional services to members of their immediate or extended family. Registrants are aware of the consequences of practicing with people with whom they have a multiple relationship and mitigate for this as far as possible.

9.8 Registrants do not exploit persons to whom they have supervisory, evaluative or other authoritative responsibility (e.g., supervisees, students, employees, clients).

9.9 Registrants do not engage in sexual relationships with persons for whom they have supervisory or other authoritative responsibility (e.g. supervisees, students, employees, clients). Registrants recognise that such relationships impair judgment and have the potential to be exploitative.

Ensuring continuity of services

9.10 Registrants take care to avoid interruption or disruption to the services they have agreed to provide. In the event of unplanned disruption (e.g. through illness or other impairment, relocation, change of employment status), Registrants make reasonable and timely efforts to facilitate the continuation of services to affected clients.

9.11 Registrants ensure suitable arrangements are in place to cover roles and responsibilities in case of absence. This includes handover of relevant case notes, reports and assessment/support plans at sufficient level of detail to competent colleagues.

9.12 Handover of client information must include discussions with affected clients where relevant, including their consent to sharing and maintaining confidentiality of such information.

9.13 Registrants do not discontinue services with clients, trainees, or supervisees without sufficient notice and transition planning. If discontinuation of services is necessary, Registrants discuss service needs with the relevant parties, provide appropriate pre-termination services and advice, suggest alternative relevant service providers and, where appropriate, facilitate timely transfer of reports, documentation, and service plans to another provider with full consent of all parties involved.

Working with behaviour analytic colleagues and other professionals

9.14 Professional relationships should be conducted on the basis of mutual respect both within the profession of Behaviour Analysis and across other relevant professions.

9.15 Registrants actively foster positive, trusting and non-judgemental professional relationships with clients, stakeholders and other professionals they may work with.

9.16 Registrants do not publicly criticise, malign or professionally obstruct another member of the profession or any other professional. This excludes situations relating to issues of safety or concern for the wellbeing of clients or others with whom they work. This includes both in-person and online behaviour.

9.17 Registrants avoid the use of professional jargon when communicating with clients or professionals who may be unfamiliar with the science and practice of Behaviour Analysis.

Supervising and training others

9.18 Registrants responsible for managing, supervising and training practitioners identify the professional development needs of those for whom they have responsibilities.

9.19 Registrants managing, supervising or training practitioners rely on principles of Behaviour Analysis. They draw on relevant scientific literature to bring about and improve the skills required for the safe and reliable practice of Behaviour Analysis by those they oversee. Where possible and appropriate, managers, trainers and supervisors use principles of Behaviour Skills Training.

9.20 Registrants are fair, honest and accurate in their assessment of those they manage, supervise and train.

9.21 All management or training in Behaviour Analysis should model practices and standards of conduct expected of practitioners in the roles for which training is provided.

9.22 Registrants adhere to UK-SBA supervisory standards when supervising individuals pursuing the UK-SBA certification pathways.

Challenging bad practice and the right to complain

9.23 Registrants have a responsibility to Behaviour Analysis and to the individuals and organisations with whom they work to challenge the incompetence, malpractice, or misconduct of others and to contribute to investigations or adjudications of such allegations. UKBA(cert) Registrants manage their supervision caseload carefully, ensuring they have enough time to check in with their supervisees about their caseload regularly, providing effective support and coaching. Where a Registrant witnesses what they believe to be incompetence, malpractice, or misconduct, they will attempt, if possible, to raise the issue with relevant person and seek clarification, or where appropriate, seek to make corrections and improvements with those involved. If the issue is not resolved, the Registrant will refer the circumstances to appropriate individuals or organisational representatives for further action. If the practices in question are those of a Registrant, the Registrant who identified potential incompetence, malpractice, or misconduct will raise a complaint to the UK-SBA Complaints Secretary.

9.24 Registrants inform recipients of services of the UK-SBA Code of Ethical and Professional Conduct and complaints procedure in the event of dissatisfaction with services provided. This information should be provided at the onset of services and included within the written contract or service level agreement.

Use of intellectual property

9.25  Registrants do not use trademarked or copyrighted materials without specific permission from the rightful owners of such materials as required by law. Further, they do not use materials related to assessments, data collection, reports, etc. that have been developed by other professionals without their permission.

9.26 Registrants delivering teaching or training avoid plagiarism and only deliver services that are entirely their own intellectual property. They give appropriate credit to authors during teaching or training sessions.

9.27 Registrants refrain from using any and all of the UK-SBA’s intellectual property, including use of the UK-SBA logo on personal materials such as websites, business cards, assessment and data-collection documents, or other materials such as advertising flyers and other service adverts. 

9.28 Registrants use the “UK-SBA Registered” membership badge only if their membership is approved and up to date. Registrants understand that the membership badge is specific to the Registrant and not to any company that might employ them and use the badge accordingly.

9.29 Registrants inform the UK-SBA of unauthorised use of the Society’s intellectual property by others.

Maintaining accurate Registrant information

9.30 Registrants inform the Society in writing of any changes to their personal or practice name and contact information – including address, email, telephone number – as soon as practicable when such changes occur.

9.31 Registrants inform the Society of any complaint made against them of which they are aware.

9.32 Registrants inform the Society of any disciplinary action taken against them by employers or professional bodies.

9.33 Registrants inform the Society of any criminal offence for which they have been arrested or cautioned and ensure the Society is updated on the progress of any case or criminal conviction.

Please detail with evidence which subsections from 10.1 to 10.8 relate to your complaint

10.1 Registrants work only within the limits of their own competence, training, and experience.

10.2 In situations outside a Registrant’s professional competence but are within the remit of behaviour analytic assessment and intervention, the Registrant clearly states the limits of their skills or experience and declines to offer services or seeks relevant training and ongoing supervision from a professional with the necessary experience and knowledge, and is open with the individual or organisation concerned that they are receiving such training and support. If the client’s needs fall outside the scope of behaviour analytic evidence, Registrants refer clients to other professionals.

10.3 Registrants are open and honest about their professional credentials and their areas of expertise. Registrants provide clients, trainees and supervisees with evidence of their professional credentials when requested.

10.4 Registrants provide, with the consent of those persons, contact information for persons who can speak to their competence and expertise in professional references and recommendations, when requested.

10.5 Registrants ensure all advertising of services or display of credentials, in whatever form, represents their expertise and credentials truthfully, accurately and without deception or exaggeration.

10.6 Registrants claim as credentials for Behaviour Analytic practice only degrees and continuing professional development that were primarily or exclusively in Behaviour Analysis.

10.7 Registrants distinguish in practice and in public statements (including advertising, brochures, printed material, public speaking, media appearances etc.) between their role as a Behaviour Analyst and any non-Behaviour Analytic roles, personal or professional, that they may have.

10.8 All Registrants provide an accurate description of their qualification and their role and capabilities in their contract. aUKBAs provide written details of their supervisor in their contracts.

Please detail with evidence which subsections from 11.1 to 11.3 relate to your complaint

11.1 Registrants who are practitioners continually update scientific, practical and professional information by attending conferences and workshops on Behaviour Analysis, keeping abreast of advances reported in scientific literature relevant to their work, obtaining (where required by the UKSBA) formal credits in Continuing Professional Development (also known as Continuing Education Units).

11.2 Registrants ensure they are aware of the latest research in areas of application specific to Registrants’ expertise and, when appropriate, use this knowledge to inform their practice.

11.3 Registrants regularly seek supervision and/or peer review of their practice from one or more qualified behaviour analysts.

Complaint Submission

Thank you for completing this complaint form. 

Please now check through all pages and ensure you have uploaded all your supporting evidence for each of the subsection(s) of each Principle you have identified as potentially breached.

When you are satisfied that you have included all relevant information please click on the "submit" button below.  You will receive an acknowledgement email once your completed form is received.

We will now carefully consider your complaint and respond fully in due course, but no later than 28 days of receipt.  

We will contact you within 5 working days to acknowledge receipt of your complaint and to advise if we need any further information to progress.

Thank you for your time.