Ms Denise Clarke-Campbell

Preliminary Matters

Hearing in private

1. The Panel Chair raised the issue of whether part of the hearing should be heard in private. This related to health details of the Referrer, a witness in the case, and to health details of the Registrant. Both parties were content that this evidence should be heard in private.

2. The Panel decided that it was appropriate that part of the case should be heard in private to protect the private life of the Referrer and the Registrant. The remainder of the case should be heard in public in accordance with the principle of open justice.

Amendment of the Allegation

3. At the conclusion of the HCPC evidence, the Panel considered its responsibility to ensure that there is no under-charging. It invited the parties to consider whether particular 2 adequately reflected the evidence.

4. Having taken instructions, Ms Bernard-Stevenson made an application to amend particular 2 of the allegation, add a new particular 3, and make consequential amendments. She submitted that the proposed amendments reflected the evidence and that in regulatory proceedings late amendments were permitted. She submitted that the proposed amendments would be in accordance with the overriding objective of protecting the public.

5. Further minor textual amendments were proposed, and Ms Renou, on behalf of the Registrant, informed the Committee that the proposed amendment was not opposed.

6. The Panel therefore decided that it was fair and appropriate to amend the allegation, to ensure that it reflected the evidence and adequately captured the concerns.

Background

7. The Registrant is a registered Practitioner Psychologist.

8. On 13 October 2021, the HCPC received a referral from the Referrer. In the referral, the Referrer alleged that the Registrant was assigned to investigate an ongoing complaint regarding treatment she had received under the administration of the Camden and Islington NHS Foundation Trust, ‘the Trust’. The Referrer described the steps she had taken to search for the Registrant on the HCPC register, her failure to find the Registrant on the register, and her steps to follow this up this with the Registrant and other individuals.

9. The background is that on 17 May 2021, the HCPC sent the Registrant an email stating that if she did not renew her registration in time, her name would be removed from the register. In this email, the HCPC advised that if the Registrant’s name was removed from the register, she should cease practising and cease using her protected title until she had completed the registration process.

10. On 1 June 2021, the HCPC sent the Registrant a further email stating that as the Registrant had not renewed her registration, she had been removed from the Register and that as a result of this the Registrant was no longer able to use her protected title.

11. On 8 June 2021, the Registrant submitted an application for readmission to the HCPC register. In section 1 of this form, the Registrant stated that the last date that she used her protected title ‘Practising Psychologist’ was 31 May 2021.

12. During the course of the HCPC investigation, the HCPC obtained a copy of the Health Roster in operation during the material time at the Trust. An extract from this roster indicates that the Registrant attended work on 1 June 2021, 3 June 2021, 4 June 2021, 8 June 2021, 10 June 2021 and 11 June 2021, notwithstanding the fact that her registration had lapsed.

13. In section 6 of her application for readmittance, the Registrant did not enter her signature. As a result of this, the Registrant’s registration was not renewed.

14. On 6 July 2021, the HCPC attempted to inform the Registrant of this but unfortunately a typographical error was made in the Registrant’s e-mail address and consequently the e-mail was returned to the HCPC inbox with an undelivered notification.

15. The Registrant submitted a further application form, with the declaration section 6 signed, on 18 October 2021.

16. On 9 September 2021, the Referrer was notified that the Registrant had been assigned to investigate her complaint. When the Referrer was unable to find the Registrant on the HCPC online Register she contacted the Registrant on 16 September 2021. She asked the Registrant to provide her HCPC registration number.

17. On 29 September 2021, the Registrant emailed the Referrer advising her that she would send a response to her initial complaint shortly. It is alleged that in this email, the Registrant used the title ‘Counselling Psychologist.’ On the same date, the Referrer contacted the Registrant a further time and asked for her registration number, however, she received no response.

18. On 7 October 2021, the Referrer sent an email to Lewis Brown at Icope in order to request the Registrant’s registration number. On 20 October 2021, the Referrer received a response from Dr Alexa Edgley (a consultant Clinical Psychologist).

19. On 17 February 2022, the Referrer received a formal response from JK, Chief Executive of the Trust. In this response, JK stated that on 2 June 2021, the Trust realised that the Registrant’s registration had lapsed and that this occurred following the Registrant’s failure to re-register by the end of May 2021. In this communication, JK went on to explain that this situation was not addressed until 22 October 2021. JK also confirmed that the Trust had been aware of the situation and that the Registrant had made many attempts to contact the HCPC by phone and email in order to resolve the delay.

Agreed Facts

20. The parties agreed the following facts:

1. The Registrant’s registration elapsed on 31 May 2021.
2. The Registrant submitted her application to renew on 8 June 2021.
3. The Registrant failed to sign the section 6 declaration contained in her application to renew her application.
4. On 6 July 2021, the HCPC attempted to send an email to the Registrant indicating that the Registrant’s application has been unsuccessful as she had failed to sign the section 6 declaration. The HCPC made a typographical error and misspelt the Registrant’s name in her email address. The HCPC sent the email to [redacted].
5. The email which the HCPC sent to the Registrant was undelivered.
6. The Registrant re-submitted her application form with the section 6 declaration signed on 18 October 2021.
7. The Registrant was informed that she had successfully renewed her application on 22 October 2021.

Decision on Facts

21. The HCPC called three witnesses to give evidence before the Panel:

• the Referrer;
• JL, Head of Psychology for the Camden Borough Division and Head of the Talking Therapies Services for Camden and Islington NHS Foundation Trust;
• Mr A Mawson, a Registrations Manager employed by the HCPC.

22. The documents presented by the HCPC extended to 101 pages. They included copies of the Registrant’s application forms, the Health Roster, HCPC records drawn from its administrative system described as “CRM” and e-mail correspondence.

23. The Registrant gave evidence to the Panel and provided a chronology of her contact with the HCPC.

24. In relation to the decision on the facts, the Panel accepted that it was for the HCPC to prove the facts and that the standard of proof is the balance of probabilities.

Particular 1

25. The Panel noted that the Registrant admitted particular 1. It found particular 1 proved by the agreed facts, the documentary evidence, and the evidence of The Referrer, JL, Mr Mawson and the Registrant.

26. The documents before the Panel confirmed the evidence of Mr Mawson and the Registrant that she did not complete the process for renewing her registration before the deadline for renewal which was 31 May 2021. A letter sent to the Registrant’s registered e-mail address dated 1 June 2021 stated that she had been removed from the Register on that date.

27. The Registrant made an application for registration which she sent to the HCPC on 8 June 2021, followed by further supporting documents sent on 9 June 2021. This application was registered as received on CRM in Mr Mawson’s department on 21 June 2021.

28. On or around 6 July the application was reviewed and it was recorded on the CRM system that the Registrant had failed to sign the section 6 declaration. As a result, the Registrant’s application could not be processed. An e-mail was sent by the registration team to the Registrant’s registered e-mail address to advise her of the missing section 6 declaration, but this e-mail address was incorrect and the e-mail was not delivered.

29. When the Registrant did not receive any confirmation from the HCPC that her application for re-registration had been progressed she followed this up on 15 July 2021 and 16 August 2021. When the issue became pressing, following The Referrer’s request for her registration number, the Registrant was more active in her contact with the HCPC. She made three telephone calls which were unsuccessful, remaining on the line for up to fifty minutes before she was cut off. She also sent an e-mail on 5 October 2021. This prompted a response from a Registrations Adviser on 6 October 2021, informing the Registrant that her registration form could not be processed because she had not completed the section 6 declaration.

30. The Registrant re-submitted her application form with the section 6 declaration signed on 18 October 2021. This application was processed on 22 October 2021 and the Registrant was re-admitted to the register.

31. Therefore, between 1 June 2021 and 22 October 2021 the Registrant was not registered with the HCPC.

32. The Panel was provided with an extract from the Health Roster which indicates the dates the Registrant was at work in the early part of June 2021. These dates were 1, 3, 4, 8, 9, and 11 June 2021. The Registrant in her evidence confirmed that she was at work on these dates and that she acted in the capacity of a Counselling Psychologist.

33. The Registrant confirmed in her evidence that during the period of her lapsed registration, she used an e-mail signature by which she described herself as ‘a Highly Specialist Counselling Psychologist’, thereby using the title of counselling psychologist. An example is the e-mail she sent to the Referrer dated 29 September 2021.

34. The Panel also noted the evidence of JL, in which she confirmed the conclusion of her investigation into the Referrer’s complaint relating to the Registrant’s registration. The conclusion of JL’s investigation is contained in JK’s letter dated 17 October 2021. This letter includes the following: “the fact is that Ms Clarke-Campbell’s post is an HCPC registered psychology post and she was continuing to work in her post” and “in view of exceptional circumstances arising from the backlog of registrations at HCPC, it was felt appropriate to allow Ms Clarke-Campbell to continue with her work while the registration was being processed.”

35. Therefore, the Registrant had practised as a Counselling Psychologist and used the title Counselling Psychologist while she was unregistered between 1 June and 22 October 2021.
Particular 2

36. The Panel noted that the Registrant admitted particular 2. The Panel found particular 2 proved by the documentary evidence, and the evidence of the witnesses, including the Registrant.

37. The Panel was provided with the Health Roster which recorded that the Registrant attended work on 1, 3, 4, and 8 June 2021. The Registrant confirmed that she attended work on these days in her role as Counselling Psychologist.

38. The Panel was also provided with a copy of the Registrant’s application for readmission dated 8 June 2021. It is an agreed fact that the Registrant submitted this application.

39. In her oral evidence the Registrant told the Panel that she had printed the application form, but that she completed it on her computer by typing in the information. She typed “31 May 2021” in response to the question “When did you last use your protected title”. She confirmed that this was not correct.

Particular 3

40. The Panel noted that the Registrant admitted particular 3. The Panel found particular 3 proved by the documentary evidence and the evidence of the witnesses, including the Registrant.

41. The Panel was provided with a copy of the application form submitted by the Registrant on 18 October 2021. This application form included a signed section 6 declaration in which the Registrant confirmed that the information she had provided in the form was correct. It is an agreed fact that the Registrant submitted this application form.

42. The Panel reviewed the application form submitted on 18 October 2021 and noted that it included no change other than the Registrant’s signature. It included the information the Registrant had provided on 8 June 2021 that she had last used her protected title on 31 May 2021.

43. The Registrant had continued to practise as a Counselling Psychologist and to use the title of Counselling Psychologist between 1 June 2021 and 18 October 2021, as set out in the Panel’s reasons for its conclusion in particular 1.

Particular 4

44. The Panel accepted the advice of the Legal Assessor on the test for dishonesty and applied the guidance in the HCPTS Practice Note “Making decisions on a Registrant’s state of mind”.

45. There are two stages to the test. The Panel should first consider what the Registrant knew or believed as to the circumstances at the time of the alleged dishonesty. The Panel can take into account surrounding circumstances if they are linked to what the Registrant knew or believed at the relevant time, and examples of such circumstances are set out in the Practice Note.

46. The second stage of the test is for the Panel to decide, given the Registrant’s knowledge and beliefs, was her conduct dishonest by the standards of an ordinary decent person. The Registrant’s own standards of honesty are not relevant, and there is no requirement that she must have appreciated that what she did was dishonest by the standards of ordinary decent people. The objective standards of ordinary and decent people involve the expectation that registered professionals will have at least some regard to the professional standards under which they operate, pursuant to a system of regulation that is designed to protect the public.

47. The Panel considered the Registrant’s conduct in particulars 1, 2 and 3 separately.

Dishonesty in relation to particular 1

48. In her submissions Ms Renou invited the Panel to conclude that the events could be entirely explained by a series of errors and misunderstanding by various parties, including the Registrant. Broadly, the Panel accepted that errors had been made and that initially the Registrant had not fully understood the position, but it also decided that the Registrant’s knowledge and beliefs changed over time. The correspondence from the Referrer alerted the Registrant to the fact that she was not permitted to use her protected title while she was unregistered and that it was wrong to do so. The Panel also concluded that the Registrant had not discharged her duty of candour towards The Referrer, and inferred that she did not do so because she knew that she should not be practising as a Counselling Psychologist.

49. In its assessment of the Registrant’s credibility the Panel noted and gave some weight to the Registrant’s good character as confirmed by the positive testimonials she provided.

50. The Registrant told the Panel that she had not seen or read the automatically generated e-mails from the HCPC sent to her registered email address on 17 May 2021 and 1 June 2021. The email dated 17 May 2021 was the fourteen-day reminder e-mail, advising that the Registrant had not renewed her registration and informing her that if she did not renew by 31 May 2021 her name would be removed from the register. If her name had been removed from the register, she must then cease practising. The email of 1 June 2021 advised that the Registrant had been removed from the Register and that she must stop practising and using a protected title.

51. In his oral evidence, Mr Mawson told the Panel that the Registrant’s registered email address prior to 8 June 2021 was a private email address, and not an NHS address and that the automatically generated emails would be sent to that address.

52. The Panel accepted the Registrant’s evidence that at the relevant time period, May to October 2021 she used two NHS email addresses. She also had a private Yahoo email address which at that time she used infrequently for shopping. She was alerted to the fact that she had not renewed her registration within time by Mr Coombes, a member of the HR team and not by the HCPC. She had not opened or read either of the emails sent to her Yahoo email address.

53. When the Registrant completed her application for registration on or around 8 June 2021, she had the opportunity to read the guidance contained in the form. If the Registrant had read the guidance in detail, it would have alerted her to the importance of her registration status and that she would be breaking the law if she used a protected title when she was not registered.

54. In her evidence, the Registrant told the Panel that although she printed the application form, she did not read the guidance in detail. [redacted] The Panel accepted the Registrant’s evidence that she had not read the detail in the guidance [redacted]. The Registrant was therefore not alerted to the fact that she was not permitted to practise through the guidance notes.

55. In early June the Registrant knew that she had not renewed her registration within time and that she had to address this with the HCPC, but she did not think about the consequences or enquire whether her name had been removed from the register.

56. The Registrant believed that she had adequately addressed the issue with regard to her registration by submitting an application for registration on 8 June 2021, and submitting supporting documents on 9 June 2021.

57. The Registrant’s evidence was that she was advised on 21 June 2021 that her application had been sent to the re-admission inbox on 21 June 2021. Her evidence was supported by her e-mail dated 21 October 2021 to her line manager in which she reported this event as part of the chronology. It was also consistent with Mr Mawson’s evidence that the Registrant’s application was received by his team on 21 June 2021. Although the Panel was not provided with a copy of an e-mail or evidence of any communication from the HCPC to the Registrant on 21 June 2021, it inferred that, on an unknown date, the Registrant was advised by the HCPC that her application for re-admission to the Register had been sent to the re-admission inbox on 21 June 2021.

58. The Registrant’s line manager was aware that her registration had lapsed and that the Registrant had made an application for re-registration. The Registrant sent an e-mail to Mr Coombes on 10 June 2021 advising him that she had submitted her documentation to the HCPC for re-registration.

59. The Registrant’s managers within the Trust and Mr Coombes were aware that the Registrant’s registration had lapsed and were content for her continue to practise as a Counselling Psychologist. This position adopted by the Registrant’s managers is described in the letter from JK dated 17 February 2022. It was confirmed in JL’s evidence to the Panel. Her view was that it was appropriate for the Registrant to continue to practise while her application for re-registration was being processed.

60. The Registrant knew that her managers were aware of the position and that they were content for her to continue practising as a Counselling Psychologist and using the protected title.

61. The Registrant believed that her application was being processed and did not know, until 6 October 2021, that it could not be processed because it was incomplete.

62. The Panel found that in June, July, August and early September 2021, the Registrant was complacent in relation to her registration status, but it was not in her mind that she was not permitted to practise or use her protected title.

63. The Registrant contacted the HCPC on 8 June 2021 because she was unable to use an NHS email address to log onto the HCPC system. The CRM records that on 8 June 2021 the Registrant advised the HCPC of an nhs.net address. Unfortunately, a typographical mistake was made when this email address was recorded. CRM also records that on 6 July 2021 an email was sent to the Registrant informing her that her application was incomplete because the Section 6 declaration was missing. This email was not delivered because the email address was incorrect. The HCPC received a notification that the email was not delivered, but did not follow this up.

64. In her oral evidence, the Registrant confirmed that she became aware that her application was not complete when she received an e-mail from an HCPC registration advisor dated 7 October 2021. This e-mail was in response to an e-mail sent by the Registrant enquiring about her “renewal”. The Registrant was advised to send the signed Section 6 declaration to the HCPC “priorityreg” inbox. The Registrant was also informed by her manager in a telephone call that her application had not been processed because it was incomplete. The Registrant was unable to recollect whether this telephone call was before or after she had received the e-mail from the registration adviser, but the Panel noted that the Registrant’s manager had become involved in this issue in October 2021.

65. The Panel concluded that the Registrant knew, from 7 October 2021, that her application was not being processed by the HCPC.

66. Although the Registrant was not alerted to any issue relating to her registration status by her employer, by correspondence from the HCPC, or by reading the guidance in the application form, she was alerted to this matter by The Referrer.

67. The Referrer requested the Registrant’s registration number in an e-mail dated 16 September 2021 and repeated that request in e-mails dated 29 September and 30 September 2021. She made further requests to the Trust’s complaints team, copied to the Registrant on 1 October 2021 and 4 October 2021. In an email dated 4 October 2021, the Referrer advised that if the Registrant’s registration number was not provided, she would forward her concerns about the lack of registration to the HCPC.

68. On 7 October 2021, the Referrer sent a further e-mail to the complaints team, again copied to the Registrant. This email included the following:
“I checked the HCPC online register to see if Ms Clarke-Campbell was registered, as is the law. She is not. I contacted both ICOPE, Lewis Brown who is in your complaints/feedback team and Denise herself to try and get a registration number or an explanation, and have not received a reply from anyone.
I find it astonishing that nobody bothered to check she was registered/renewed her registration as a counselling psychologist, and also at the lack of candour from Denise. I feel she is ignoring my emails to avoid admitting she is not appropriately registered, or putting of [sic] replying until she is registered.”

69. The Referrer sent a further email to the complaints team on 19 October 2021, which was again copied to the Registrant. This e-mail included the following:
“I want a response from the chief executive as to why Denise has been allowed to practice using the protected title against the law, and why nobody checked if she was registered….
I want to know why Denise has ignored all my efforts to communicate with her since I asked for her registration number. I want to know if she stopped using the protected title of counselling psychologist since I asked for her registration number and she presumably realised she was not registered, and I want to know for how long she used the protected title whilst unregistered. Due to the lack of response from anyone at the trust, I have also forward a complaint against Denise to the HCPC fitness to practice team.”

70. These emails were sent to the Registrant’s email address that she was using to communicate with The Referrer. The Registrant received them and read them. They prompted her and her manager to take further action to contact the HCPC with respect to the application she had submitted on 10 June 2022. The e-mails from the Referrer alerted the Registrant to the fact that she was not registered and therefore could not use her protected title. They also highlighted the serious nature of the issue, that it would be illegal to practice if she was not registered.

71. The Registrant continued to practise as a Counselling Psychologist knowing that she was not registered, that she could not use her protected title, and that this was a serious matter that the Referrer intended to report to the HCPC.

72. The Registrant did not reply to The Referrer’s requests for her registration number. She told the Panel that this was because there was an expectation in the Trust that such queries would be dealt with by the complaints team rather than the individual appointed to investigate the complaint. She also had some concerns arising from the content of The Referrer’s complaint.

73. This reason did not explain why there was no response from the complaints team to the Referrer on the Registrant’s behalf. The Registrant was copied into the correspondence and was therefore aware that no response had been provided, despite the Referrer’s clear and repeated requests. The request from the Referrer was a simple one, and an open and frank answer could have been provided either by the Registrant directly, or through the complaints team. The Panel inferred that the Registrant did not want the Referrer to know that she had allowed her registration to lapse and that she was not currently registered. This reinforced the Panel’s conclusion that, by October 2021, the Registrant knew that it was impermissible for her to practise as a Counselling Psychologist or use her protected title when she was not registered.

74. The Panel next considered the objective test of whether the Registrant’s conduct was dishonest by the standards of ordinary decent people. It concluded that an ordinary decent person would not conclude that her conduct from 1 June to mid-September 2021 was dishonest. However, once the Registrant was alerted to her removal from the Register by the Referrer’s correspondence, her behaviour would be regarded as dishonest by ordinary decent people. At this time, she was aware that she was not registered and that consequently she was not entitled to use her protected title. She also knew from 6 October 2021 that her application for re-registration was not being processed by the HCPC because it was not complete. The objective standards of ordinary and decent people involve the expectation that registered professionals will have at least some regard to the requirement to be registered which is part of a system which is in place for the protection of the public. The Registrant continued to practise in October 2021, knowing that she was not permitted to do so.

Dishonesty in relation to particular 2

75. In her oral evidence the Registrant told the Panel that when she completed her application form, she made an error when entering the date of 31 May 2021 as the last day she used her protected title. She did not expand on how she might have made such an error and she did not suggest that she had misunderstood the question on the form.

76. The Registrant described that she found the process of completing the application form difficult and convoluted, [redacted]. The Panel accepted that there were difficulties, but, as described by the Registrant, these related to the process, and they did not impact on the content of the form. They did not explain the incorrect date which was typed by the Registrant onto the form.

77. The Registrant typed the information to the form on or around 8 June 2021. The Registrant knew that she had worked on 1, 3, and 4 June and had worked or was due to work on 8 June 2021 and she knew when she submitted the form that her registration had lapsed.

78. The Panel inferred that the Registrant had selected the date of 31 May 2021 because this was the last date she was registered. This was a choice rather than an error. As explained in its decision on dishonesty in relation to particular 1, the Registrant did not at this time have a full understanding of the consequences of the lapse of her registration, but she did know that the date she had entered into the form was incorrect.

79. The Panel next considered the objective test of whether the Registrant’s conduct was dishonest by the standards of ordinary decent people. It concluded that an ordinary decent person would conclude that her conduct was dishonest. The Registrant had made a statement which she knew to be untrue in a document which was to enable her to obtain admission to the register. The objective standards of ordinary and decent people involve the expectation that registered professionals will complete such forms accurately. They also involve the expectation that Registrants would not provide misleading information which would potentially undermine the system of regulation.

Dishonesty in relation to particular 3

80. The Panel accepted the Registrant’s evidence that when she signed the declaration and re-submitted her application on 18 October 2021 she had not read or checked the information in the form. Her evidence was supported by the content of the form. The only change she made was to sign the declaration. She did not change the date on the form of 8 June 2021.

81. Although the Registrant did not consider or check the content of the form, her knowledge and beliefs had not changed since she originally entered the information on the form on 8 June 2021.

82. The Panel next considered the objective test of whether the Registrant’s conduct was dishonest by the standards of ordinary decent people. Ordinary and decent people would note that the Registrant, unlike 8 June 2021, she took no active steps. She had simply re-submitted her original dishonest form and had given no thought at the time to its content. Nevertheless, she was dishonest when she had originally prepared that statement, and her state of mind had not changed. The Panel concluded that an ordinary decent person would conclude that her conduct was dishonest. This was a passive form of dishonesty. The Registrant had not corrected a dishonest statement in a form which was to enable her to obtain admission to the register. The objective standards of ordinary and decent people involve the expectation that registered professionals will complete such forms accurately and will correct any misleading information.

83. The Panel therefore found particular 4 proved.

 

Decision on misconduct

84. The Panel heard submissions from Ms Bernard-Stevenson who also provided the panel with her oral submissions in written form. She submitted that the proven factual particulars marked a serious departure from the standards expected of a registered Psychologist and amounted to misconduct.

85. The Panel heard submissions from Mr Lloyd. He acknowledged that dishonesty is treated seriously and that the integrity of the Register is important, but he also invited the panel to take into account the surrounding circumstances when considering the gravity of conduct. He submitted that the Registrant was open and honest with her employer and that her employer was aware of the registration position. He also submitted that the HCPC delays in the registration system were not irrelevant. While acknowledging that personal mitigating circumstances should not be the deciding factor, he also invited the panel to consider the Registrant’s personal circumstances.

86. The Panel accepted the advice of the Legal Assessor who reminded the Panel of the guidance in Roylance v General Medical Council [2000] 1 AC 311 that “misconduct is a word of general effect involving some act or omission which falls short of what would be proper in the circumstances. The standard of propriety may often be found by reference to the rules and standards ordinarily required to be followed by a …practitioner in the particular circumstances”. The Legal Assessor also referred to Nandi v GMC [2004] EWHC 2317 where it was stated that the falling short of standards must be “serious”.

87. The Panel reviewed the HCPC Standards of Conduct, Performance and Ethics (2020) and the Standards of Proficiency for Practitioner Psychologists. It considered that the following standards were engaged:

HCPC Standards of Conduct, Performance and Ethics 2020

Standard 3.4
You must keep up to date with and follow the law, our guidance and other requirements relevant to your practice.

Standard 9.1
You must make sure that your conduct justifies the public’s trust and confidence in you and your profession.

Standards of Proficiency for Practitioner Psychologists
Standard 2.1
maintain high standards of personal and professional conduct.

Standard 2.10
Understand and apply legislation, policies and guidance relevant to their profession and scope of practice.

88. The Panel first considered particular 1 of the Allegation, together with the related finding of dishonesty in particular 4. In considering this particular the Panel bore in mind that it was the personal responsibility of the Registrant to ensure that she complied with the legal requirement to be registered if she was practising as a Practitioner Psychologist. Professional registration is not simply a box ticking exercise, but an essential requirement and it relates to public protection and public confidence in the profession.

89. The Panel was referred by Ms Bernard-Stevenson to the evidence of Mr Mawson who explained that the Register was an important part of the regulatory process and it was the only way of letting people know who is allowed to practise. Mr Mawson added that the Register enables members of the public to be reassured that a practitioner is fit to practise and meets HCPC standards.

90. The Register gives members of the public confidence that professionals treating them are appropriately skilled and qualified and that they can be trusted. An example of a member of the public losing that confidence is The Referrer who was unable to find the Registrant on the HCPC register. Her complaint to the Trust and her evidence to the Panel clearly illustrated the negative impact of the Registrant’s behaviour on herself and on public confidence in the profession. The Panel was able to understand the Referrer’s frustration and disappointment when she received little or no response to her legitimate enquiries. The Referrer was not a patient seeking treatment, but there was the potential for patients under the Registrant’s care to similarly lose confidence in both the Registrant and the integrity of the register.

91. Although acknowledging that the Registrant was at all times suitably skilled and qualified to be registered as a Practitioner Psychologist, the Panel nevertheless considered that Ms Clarke-Campbell’s behaviour involved the potential for serious harm to the reputation of the profession.

92. The Panel also considered the degree of the Registrant’s culpability. As explained in its decision on dishonesty, the Panel was of the view that in the initial period of June, July, August and early September 2021, the Registrant was complacent in relation to her registration status, but it was not in her mind that she was not permitted to practise or use her protected title. In respect of this period of time, the Registrant’s responsibility, her degree of culpability is reduced. In reaching this conclusion the Panel took into account the explanations for the Registrant’s state of mind as explained in the Panel’s decision including the Registrant’s unsuccessful attempts to contact the HCPC, and the errors and misunderstandings by the Registrant as described in the Panel’s decision on the facts.

93. The position changed over the period of time from mid-September 2021 to 7 October 2021. Due to the information provided to her by the Referrer and the HCPC, the Registrant knew at that time that her application for registration was not being processed, that she was not registered, and that she was not permitted to use her protected title without being registered. In respect of this later period of time, during which the Panel concluded that the Registrant acted dishonestly, she bears a high degree of culpability.

94. The Panel considered whether the gravity of the Registrant’s conduct was reduced by the fact that her employer was aware that she was continuing to practise as a Psychologist in a position that required registration notwithstanding the fact that she was not registered. The Panel took a nuanced view. On the one hand the Panel accepted that the ongoing support of her employer may have given the Registrant an inappropriate reassurance which was unhelpful to her. The Panel would have expected the Registrant’s employer to be fully aware that it was not permissible for the Registrant to practise as a Psychologist if she was not registered and that there are no exceptions. On the other hand, the Panel did not agree that the Registrant had been fully frank with her employer about all the circumstances. Her employer remained under the impression that the problems with the Registrant’s registration were due to a backlog at the HCPC, when this was not the case. The Registrant knew in October 2021 that the reason she was not registered was that her readmission form had not been fully completed. Her managers appear to have been unaware of this information at the time the responses to The Referrer’s complaint were prepared.

95. The Registrant’s employer was not aware of the Registrant’s dishonest behaviour and therefore the Panel concluded that the gravity of that behaviour was not reduced by her employer’s knowledge that she was continuing to practise as Psychologist when she was not registered.

96. Having carefully considered particular 1, together with the related finding of dishonesty in particular 4, the Panel concluded that the Registrant’s behaviour fell well below the expected standards of a Practitioner Psychologist and was sufficiently serious to amount to misconduct.

97. The Panel next considered particular 2, together with the related finding of dishonesty in particular 4. In its decision on the facts the Panel concluded that the Registrant had chosen the date of 31 May because this was the last date she was registered and that she knew this date was incorrect.

98. The incorrect information on the form had the potential to undermine the system of regulation which is based on trust. The HCPC places its trust in Registrants who submit and application for re-admission to the Register to provide accurate and truthful information. The Registrant’s action had the potential to undermine the integrity of the Register and public confidence in the Register and the Regulator.

99. In its decision on facts the Panel rejected the Registrant’s explanation that she made an error on the form and concluded that she acted dishonestly. Dishonesty is serious and it can have a significant impact on public confidence in the profession.

100. The Panel decided that the Registrant’s behaviour fell well below the expected standards for a Practitioner Psychologist and was sufficiently serious to amount to misconduct.

101. Having reflected on particular 3 of the Allegation together with the related finding in particular 4, the Panel was of the view, in the context of its finding of misconduct on particular 2, it would not be appropriate to treat particular 3 as a further finding of misconduct. The Registrant did not correct the dishonest statement, but she gave no separate thought to it when she resubmitted the form. The degree of her culpability was low. She took no active dishonest step. In the Panel’s judgment particular 3 did not add to or elevate the seriousness of the Registrant’s conduct and, considered by itself, was not sufficiently serious to amount to misconduct.

102. The Panel therefore concluded that particulars 1, 2 and 4 amounted to misconduct and that particular 3 did not amount to misconduct.

 

Decision on impairment

103. The Panel went on to decide whether, as a result of her misconduct, the Registrant’s fitness to practise is impaired.

104. The Panel heard submissions from Ms Bernard-Stevenson. She submitted that the Registrant’s fitness to practise is impaired on the basis of the personal component and the public component.

105. The Panel heard submissions from Mr Lloyd. He invited the Panel to conclude that the risk of repetition was low and he referred to the evidence of the Registrant’s good character, that the conduct was an isolated period in the context of a long and distinguished career and the nature of the Registrant’s dishonesty. He also submitted that a finding of current impairment was not required to maintain public confidence in the profession and to uphold standards. He submitted that not every act of dishonesty results in a finding of current impairment and he referred to examples of the cases of PSA v GMC and Uppal [2015] EWHC 1304 and PSA v Nursing and Midwifery Council and SM [2017] CSIH 29. He submitted that the regulatory process and the Panel’s finding of misconduct was sufficient to mark the Panel’s opprobrium of the Registrant’s behaviour and to maintain public confidence in the profession.

106. The Panel accepted the advice of the Legal Assessor. Her advice included reference to the HCPTS Practice Note on “Fitness to Practise ‘Impairment’” and to cases including Professional Standards Authority v Health Care Professions Council and Ghaffer [2014] EWHC 2723 and General Medical Council v Armstrong [2021] EWHC 1658.

107. In its deliberations the Panel considered that there were two strands relevant in the assessment of the Registrant’s current fitness to practise. The first strand was the behaviour the Registrant admitted in paragraphs 2 and 3 of the Allegation. The second strand was the Registrant’s dishonest behaviour.

108. The first strand is the Registrant’s failure to comply with the legal requirements for registration and her submission of an application for re-registration which contained information which was incorrect. The Registrant admitted particulars 1 and 2. In her statement and evidence to the Panel she took personal responsibility for her actions and was self-critical. She also was able to explain the importance of registration and professional accountability.

109. The Panel noted that the Registrant reflected on the events at a management review with Dr E and that learning points were agreed. The Registrant actioned the learning points by attending two webinars entitled “Helping you manage your emotional health and wellbeing whilst looking after others” and “coping with burnout and stress”. The Registrant also renewed her registration on time as part of the cycle of renewals of registration in the summer of 2023.

110. The Registrant has continued to work as a Clinical Coordinator and her practice has not been subject to conditions. There is no evidence of any complaint or concern about the Registrant’s practice.

111. The Panel was of the view that the Registrant demonstrated a sufficient level of insight in relation those parts of the Allegation that she admitted. The Panel was also of the view that the Registrant now has systems in place to ensure that her registration does not lapse in the future and that she manages her time to ensure that such routine matters are dealt with appropriately. The Panel acknowledged that the events occurred during a period of time the Registrant was subject to work and personal stress during the pandemic. While similar stressors may arise again, the Panel was satisfied from the Registrant’s reflections and the changes that she has made, that the risk of repetition is low.

112. The Panel next considered the second strand which is the Registrant’s dishonest behaviour. The dishonesty involved the two separate elements of the incorrect information on the application for re-registration in June 2021 and the dishonesty over a period of approximately two to three weeks in early October 2021. The Panel noted that the Registrant’s dishonesty in October 2021 did not cause patient harm, but it had a negative impact on the service user The Referrer.

113. The Panel was reminded by the Legal Assessor to consider the guidance in the case of Sawati v General Medical Council [2022] EWHC 283. The Panel acknowledged that the right to a fair hearing includes the Registrant’s entitlement to deny the Allegation. It also reminded itself that a Registrant can demonstrate insight, notwithstanding that they deny either all or part of an Allegation. The Panel therefore did not consider that the Registrant’s denial of dishonesty, of itself, was a factor that aggravated the Registrant’s behaviour or that it automatically led to the conclusion that she has not demonstrated insight.

114. Dishonesty is an attitudinal issue, and it is therefore more difficult to demonstrate remediation. The Panel considered the nature of the dishonesty in this case and was of the view that it is capable of remediation. The Registrant potentially might demonstrate remediation through reflection, insight, and evidence of her understanding of and commitment to the fundamental principles of integrity and candour.

115. The Registrant chose not to give evidence or to present any new evidence to the Panel at the impairment stage. The Panel was not presented with evidence that the Registrant has an understanding of the seriousness of the Panel’s finding of dishonesty, the impact of her dishonest behaviour on The Referrer, or the impact of the finding on public confidence in the profession. The Panel was not reassured that the Registrant completely understands her obligation to be fully open and transparent, in circumstances where the information she is providing may be detrimental to herself. The Panel was not provided with any examples of occasions when the Registrant has been faced with a conflict between her own interests and the requirement to be candid and has acted professionally.

116. The Panel concluded that there was insufficient evidence that the Registrant has insight into the Panel’s finding that she acted dishonestly and insufficient evidence that she has taken remedial action in relation to the finding of dishonesty.

117. In assessing the risk of repetition, the Panel carefully balanced the evidence of the Registrant’s good character and the absence of any evidence of repetition of similar behaviour, and the absence of evidence of insight or remediation. The Panel would not describe the risk of repetition as high, but it considered it to be substantial. The Panel therefore conclude that the Registrant’s fitness to practise is impaired on the basis of the personal component.

118. The Panel next considered the need to maintain public confidence in the profession and to uphold standards of conduct. It bore in mind that while there are cases where Panels may conclude that a finding of dishonesty did not lead to a finding of impairment the Panel would need to identify weighty factors in favour of the Registrant if it were to reach that conclusion. The Panel gave weight to the importance of honesty which is a fundamental tenet for members of the profession.

119. The Panel considered that the Registrant’s dishonesty was not at the top end of the scale of dishonest behaviour. The good character evidence indicates that the dishonesty was out of character for the Registrant, and it was limited in its duration. The dishonesty did not involve planning, fraud, or direct patient harm. The Panel had in mind that the Registrant’s employer appeared to be aware of some of the facts and to condone the Registrant’s behaviour. For example, the employer appeared to be content for the Registrant to describe herself as a ‘Counselling Psychologist’ and to continue using that protected title, even when she and the employer were aware that she was not registered. This mitigated the seriousness of the Registrant’s behaviour to some extent, but the Registrant remains personally responsible for her professional behaviour and the Panel also noted that the Registrant’s employer was not fully aware of all the facts.

120. On the other hand, the dishonesty was not at the lowest end of the scale. The Registrant acted in her own self-interest. In her application for re-registration she did not want to provide information that she had worked as a ‘Counselling Psychologist’ after her registration had lapsed. She maintained the use of her e-mail signature when she did not wish to provide the information that she was not currently registered.

121. The Panel was of the view that although there were some mitigating factors, they were not of sufficient weight when considered in the context of the Panel’s responsibility under the overarching objective to maintain public confidence in the profession and to uphold standards for members of the profession. The Registrant acted in breach of the trust placed in her to comply with the registration system. The Panel concluded that the Registrant’s dishonest behaviour should be marked by a finding of current impairment in order to maintain public confidence in the profession and to uphold standards for members of the profession.

122. The Panel therefore concluded that the Registrant’s fitness to practise is impaired on the basis of the public component.

 

Decision on Sanction

123. Ms Bernard-Stevenson’s submissions on sanction included reference to aggravating features and the HCPC Sanctions Policy. She did not make submissions on a particular sanction, but drew the Panel’s attention to paragraphs of the Sanctions Policy including those which address dishonesty.

124. Mr Lloyd referred the Panel to the case of Atkinson v General Medical Council [2017] and the guidance that erasure is not inevitable and necessary in every case involving dishonesty. Mr Lloyd submitted that the Registrant’s dishonesty was not at the top end of the scale and he made references to mitigating features, including the Registrant’s otherwise unblemished career and the positive references. He referred the Panel to case law including Giele v General Medical Council [2005] EWHC 2143 and invited the Panel to take into account the public interest in not ending the career of a competent professional. He invited the Panel to consider imposing a Conditions of Practice order, or alternatively imposing a short period of suspension, which is a serious sanction.

125. Mr Lloyd made further submissions on the issue of insight which was raised by the Panel chair. His submissions included reference to the case of GMC v Awan [2020] EWHC 1553.

126. The Panel accepted the advice of the Legal Assessor. She reminded the Panel that the purpose of a sanction is not to punish the Registrant, but to protect the public and the wider public interest. She advised that the Panel should take into account the Sanctions Policy. She advised the Panel to consider each available sanction in ascending order of severity and to apply the principle of proportionality, carefully balancing the Registrant’s interests and the public interest.

127. On the issue of insight, and the Registrant’s denial of dishonesty the Legal Assessor reminded the Panel of her earlier advice with reference to the summary of the case of Sawati as set out in the “Fitness to Practise Impairment” Practice Note. This approach is relevant when deciding which sanction, if any, should be imposed.

128. As set out in its decision on current impairment the Panel’s decision in relation to insight was nuanced. The Panel concluded that the Registrant demonstrated sufficient understanding and insight in relation to her administrative failings, the underlying causes of those administrative failings, and the HCPC registration system and the consequences of practising when she was not registered. As set out in its decision on current impairment the Panel did not conclude that the Registrant’s denial of dishonesty is an aggravating factor, but it found a lack of evidence that the Registrant understood the importance of honesty, integrity, and candour for a registered Counselling Psychologist, or that she had reflected on the impact of her behaviour that the Panel has found to be dishonest on the Referrer or the reputation of the profession.

129. The evidence presented to the Panel in the form of character references, the Registrant’s otherwise unblemished career before and since the period June to October 2021, together with the Registrant’s full engagement with these proceedings indicated that she should be capable of developing insight into the issue of dishonesty and reflecting on the finding the Panel has made.

130. The Panel identified the following mitigating features.

• no impact on public safety;
• the Registrant’s personal circumstances and the pressures arising from the time of the COVID response;
• the HCPC sent an e-mail to the Registrant at an incorrect address and took no further action when the e-mail bounced back;
• The Registrant and her managers tried without success to contact the HCPC to resolve the situation relating to her registration;
• The Registrant’s managers and senior representatives at the Trust condoned the Registrant working when she was not registered suggesting that it was not in breach of the law;
• The Registrant’s otherwise unblemished career both before and after June-October 2021, including the period after October 2021 when the Registrant has practised without restriction;
• Excellent testimonials;
• The conduct is confined to the period June – October 2021 and there has been no repetition;
• The Registrant’s admissions of the primary facts (particulars 1 -3).

131. The Panel identified the following aggravating features:

• Two instances of dishonesty (particulars 1 and 2);
• The absence of evidence of insight or remediation in relation to dishonesty;
• The Registrant’s lack of candour in answering questions from the Referrer and lack of full candour to her employer as to the reasons her application for re-registration had not progressed;
• The Registrant’s treatment of the Referrer and absence of an apology (for conduct the Registrant admits)

132. The Panel noted the guidance in the Sanctions Policy on dishonesty at paragraphs 56-58. Dishonesty is regarded as serious for the reasons explained in the Sanctions Policy. As set out in paragraph 56 dishonesty undermines public confidence in the profession and can, in some cases, impact the public’s safety. This is not a case that impacts public safety, but the Registrant’s conduct did undermine public confidence in the profession. The Panel does not condone the Registrant’s dishonest behaviour.

133. Paragraph 58 of the policy sets out factors which are relevant to the consideration of the form and degree of dishonesty.
“Given the seriousness of dishonesty, cases are likely to result in more serious sanctions. However, Panels should bear in mind that there are different forms, and different degrees of dishonesty, that ned to be considered in an appropriately nuanced way. Factors that Panels should take into account in this regard include:

• whether the relevant behaviour took the form of a single act or occurred on multiple occasions;
• the duration of the dishonesty;
• whether the registrant took a passive or active role in it;
• any early admission of dishonesty on the registrant’s behalf; and
• any other relevant mitigating factors.

134. In its decisions on misconduct and impairment, the Panel has taken the view that the dishonesty in this case is not at the top end of the scale of seriousness, but is also not at the lowest end of the scale. The dishonesty involved more than a single occasion, the Registrant took some active steps, and there has been no admission of dishonesty. On the other hand, the Panel gave weight to the mitigating features as outlined above.

135. The Panel considered each sanction in ascending order. The Panel did not consider that it would be appropriate to take no action or to impose a Caution Order. These options do not restrict practice and are not appropriate when there is an ongoing risk of repetition. They would also be insufficient to mark the seriousness of the Registrant’s departure from professional standards and to maintain public confidence in the profession.

136. The Panel next considered a Conditions of Practice Order. The guidance in the Sanctions Policy is that conditions of practice are less likely to be appropriate in more serious cases such as dishonesty and that in such cases the Panel should only impose this sanction where it was satisfied that the Registrant’s conduct was minor, out of character, capable of remediation and unlikely to be repeated.

137. Although the Panel was of the view that the Registrant’s conduct is out of character and capable of remediation, the Registrant’s conduct cannot be described as minor and the Panel has not been able to conclude that it is unlikely to be repeated. The Panel did not consider that the risk that the Registrant might repeat dishonest behaviour could be adequately addressed by a Conditions of Practice Order. The Panel reviewed the conditions bank and gave consideration to the proposals put forward by Mr Lloyd that the Registrant be subject to restrictions that might include peer review and supervision. Having considered potential conditions of practice, the Panel concluded that they would not adequately address the risk of repetition, in circumstances where the Registrant has not demonstrated any level of insight in relation to the Panel’s findings of dishonesty.

138. The Panel also reflected on the seriousness of its finding on misconduct, impairment and the aggravating features, and took the view that a Conditions of Practice Order was not a sufficiently serious sanction. The honesty of Registrants is fundamental to the integrity of the register, which is part of the system of regulation which is in place for the protection of the public. The Registrant made a false representation about her registration status to the Referrer and other members of the public, and that is entirely unacceptable for registered Psychologists. The Panel concluded that a Conditions of Practice Order would be insufficient to maintain public confidence in the profession and to uphold standards for members of the profession.

139. The Panel next considered the option of a Suspension Order. The Panel considered the guidance in the Sanctions Policy at paragraph 121. It considered that most of the factors were present. The concerns represented a serious breach of the HCPC Standards of conduct, performance and ethics, the Registrant demonstrated some insight (in relation to the particulars 1 and 2), and there was evidence to suggest that she was likely to be able to remedy the matters. The Panel has not concluded that the dishonesty is unlikely to be repeated, but the reason for this conclusion is that the Registrant has not provided evidence of insight. The Registrant did not have advance notice of the Panel’s decision on the facts, and has not yet had a full opportunity to reflect on it.

140. For the reasons set out above, the Panel considered that there was a realistic prospect that the Registrant will understand the need for her to reflect on the Panel’s decision and provide evidence of her insight and appropriate remediation.

141. The Panel considered that a Suspension Order is a serious sanction, which prevents the Registrant practising as a Psychologist. It sends a clear message to the Registrant and to other members of the profession that it is entirely unacceptable for a Counselling Psychologist to continue to practise when they are not registered, to falsely indicate that they are registered, and to give incorrect information to the regulator in an application for re-registration.

142. In the Panel’s judgment, a Suspension Order was a sufficiently serious sanction to mark the seriousness of the Registrant’s departure from professional standards and to uphold confidence in the profession.

143. A Suspension Order also protects the public against any risk of repetition during the period of suspension and provides for a review of the order for another Panel to assess whether the Registrant has demonstrated sufficient insight and whether or not the risk of repetition has been sufficiently reduced.

144. The Panel had regard to the Sanctions Policy and considered the more restrictive option of a Striking Off Order which can be appropriate in dishonesty cases. The Panel was of the view that a Striking Off Order would be disproportionate. In reaching this view the Panel gave weight to the mitigating features. It also had in mind its assessment of the seriousness of the Registrant’s dishonesty as explained in its decisions on misconduct and current impairment. At this stage of its determination the Panel also had in mind the public interest in the retention of the services of a skilled and experienced practitioner where there is a realistic prospect of rehabilitation. There was evidence before the Panel that the Registrant is an experienced and skilled practitioner who is valued by her employer.

145. In the circumstances, the Panel concluded that a Suspension Order is the appropriate and proportionate sanction.

146. The Panel next considered the length of the Suspension Order. It considered the guidance in the Sanctions Policy at paragraphs 122-124. The Panel was of the view that a period of suspension of four months struck the appropriate balance between the public protection and the public interest and the interests of the Registrant. The Panel was of the view that this would be sufficient time for the Registrant to reflect on the Panel’s decision and prepare evidence for a reviewing Panel.

147. The four-month Suspension Order will have a negative impact on the Registrant, but the Panel decided that her interests were outweighed by the need to protect the public and the wider public interest.

148. This Panel cannot bind a future reviewing Panel, but that Panel may be assisted by the following:

• A reflective statement from the Registrant with reference to her understanding of the importance of honesty, integrity and candour, the impact of her behaviour on The Referrer, and the impact of her behaviour on public confidence in the profession;
• Appropriate remediation through relevant and credible training concerning integrity;
• A clear indication as to how the Registrant will inform her practice through her developed insight and training derived learning;
• Attendance at and full engagement in the substantive review hearing.

ORDER: The Registrar is directed to suspend the name of Denise Clarke-Campbell from the Register for a period of four months from the date this order takes effect.

This Suspension Order will take effect on 8 November 2024, if no appeal is made.

Interim Order
Application
1. Ms Bernard-Stevenson made an application for an Interim Suspension Order for a period of 18 months on the grounds that it is necessary for the protection of the public and is otherwise in the public interest.

2. In his submissions, Mr Lloyd accepted that the Panel might conclude that an interim order was required, given the findings it has made. He made submissions on the length of the Interim Suspension Order, referring to two HCPC cases in which the appeal was concluded in 7 months and 8 months. He submitted that in these circumstances the Panel should consider the imposition of an interim order for a shorter period than 18 months.

3. The Panel accepted the advice of the Legal Assessor. She confirmed that the Panel has the power to make an interim order under Article 31(2) of the Health Professions Order 2001, but this is not an automatic outcome. The Panel should carefully consider if an interim order is necessary and if so on which of the statutory grounds. If an interim order is required, thePanel should apply the principle of proportionality and impose the least restrictive order which is sufficient to protect the public and the wider public interest. The principle of proportionality also applies to the Panel’s decision on the appropriate length of any interim order.

Decision

4. In its decision on current impairment, the Panel concluded that there was a risk that the Registrant might repeat dishonest behaviour. The Panel was concerned that during the appeal period and if the Registrant were to appeal the decision, there would be no protection for the public in respect of this risk. The Panel therefore decided that an interim order is necessary for the protection of the public. The Panel was also of the view that the gravity and seriousness of the Registrant’s misconduct was such that an interim order was otherwise in the public interest.

5. The Panel considered the option of an Interim Conditions of Practice Order but decided that for the reasons outlined in its decision on sanction there are currently no workable conditions of practice that would sufficiently address the risk of repetition of dishonest behaviour. The Panel therefore decided to impose an Interim Suspension Order with immediate effect, under Article 31(2) of the Health Professions Order 2001, the same being necessary to protect members of the public and being otherwise in the public interest.

6. The Panel considered the length of the order and decided that it was appropriate and proportionate to impose the order for a period of 12 months. In reaching this decision the Panel took into account the submissions of the parties and concluded that 12 months was a sufficient length of time for the final determination of any appeal.

This order will expire: (if no appeal is made against the Panel’s decision and Order) upon the expiry of the period during which such an appeal could be made; (if an appeal is made against the Panel’s decision and Order) the final determination of that appeal, subject to a maximum period of 12 months.

History of Hearings for Ms Denise Clarke-Campbell

Date	Panel	Hearing type	Outcomes / Status
05/02/2024	Conduct and Competence Committee	Final Hearing	Suspended