Poppy Sprague

Preliminary Matters
Admissibility of videos
1. The Registrant invited the Panel to privately view the videos which could be accessed by the dynamic links provided by her in the addendum bundle or using the YouTube URLs in the second addendum bundle.

2. The Registrant explained that she did not intend to provide any narrative, explanation, or commentary in respect of the videos beyond that which was in the bundles. Three of the videos contained information from Dr Kary Mullis and Mark Zuckerberg, relating to Covid-19 matters raised at the Substantive Hearing. Four of the videos contained examples of the Registrant’s professional practice as a coach, with one posted 10 days ago. One video was a collection of testimonials reflecting her current practice. The Registrant explained that the Panel would therefore be able to form its own independent impression of her good practice.

3. The Panel accepted the Legal Assessor’s advice regarding the admissibility of the intended evidence under rule 10 of the Health and Care Professions Council (Conduct and Competence Committee) (Procedure) Rules 2003 (the rules).

4. The Panel decided not to admit the videos as evidence, because:
• It would require the Panel to conduct an independent review of the evidence outside of the hearing and without the parties being present to explaining the importance or purpose of the content. It was irregular for the Panel to, in effect, take into account evidence and come to its own conclusions in a way that was not open to the scrutiny, comment and submissions of the parties.
• The videos were not authenticated or exhibited in a statement of truth.
• The Panel was not tasked with evaluating the Registrant’s fitness to practise outside of the profession of Practitioner Psychologist.
• There was no expert testimony available to assist the Panel with any questions that it might have.
• The parties had no practical safeguards in this procedure to find and correct any errors of fact or conclusions that might have been formed, without, in effect, calling the Panel members as witnesses.
• The Registrant acknowledged that three of her videos preceded the events in which she made the social media posts that were the subject of the misconduct; in one case by more than ten years.
• In relation to the videos relating to Covid-19 matters, the task of this Panel is not to make decisions on conflicting opinions on public health measures.

5. In these circumstances, the Panel concluded that the videos were not relevant as they did not assist the Panel in deciding whether the Registrant had discharged her burden of satisfying the Panel regarding her current impairment or otherwise.

Background
6. The Registrant is registered with the HCPC as a Practitioner Psychologist and at all material times practised in that capacity on a self-employed basis.

7. Between August 2020 and March 2021, the Registrant engaged in inappropriate and/or unprofessional conduct via social media by sharing and/or posting content via a public personal Facebook Profile which identified her as a Practitioner Psychologist registered with the HCPC.

8. The relevant posts expressed the Registrant’s views about the Covid-19 pandemic and the government’s response to it.

9. Concerns about the content of the Registrant’s posts on social media were reported by a member of the public to the HCPC, resulting in an investigation culminating in these proceedings.

The Substantive Panel’s findings on 19 July 2023
Misconduct
10. The Substantive panel made the following finding with regard to the Registrant’s misconduct;
• the Registrant acknowledged that she was not a qualified expert on public health matters, or the transmission or prevention of diseases. She nevertheless purported to give advice in her Facebook messages in her capacity as a Practitioner Psychologist on public health matters in which she had no expertise;
• the Registrant’s posts on social media were “inappropriate and unprofessional” as alleged in the stem to Particular 1 of the Allegation and were in breach of the following standards of the HCPC Standards of Conduct, Performance and Ethics (2016), namely:
2.7 You must use all forms of communication appropriately and responsibly, including social media and networking websites.
9.1 You must make sure that your conduct justifies the public’s trust and confidence in you and your profession.

Impairment

11. The substantive panel made the following findings with regard to the impairment for the Registrant’s fitness to practise. The substantive panel dealt first with the personal component:
• the Registrant’s fitness to practise was and remains impaired having regard to the “personal” component;
• the Registrant maintained that she saw it as her duty to provide members of the public with the fruits of her research. She demonstrated no insight into the possibility that the content of her postings on social media might have been wrong or that her opinions and advice, if adopted by others, had the potential to cause them significant harm;
• she had little, if any, awareness that her postings could cause damage to the reputation of her profession;
• she did not provide any evidence of changes that she had made;
• it did not appear to occur to her that it was inappropriate for her to make pronouncements on medical issues in which she had no relevant expertise;
• she said that she would continue to post material on her Facebook account, under the banner of the HCPC, which identified her as a Practitioner Psychologist and on matters relevant to “informed consent.” She asserted that it would be unprofessional not to express her views in matters where she could assist others in achieving informed consent; and
• she stated her “inalienable right of freedom of speech” and that she followed, in effect, her own guidelines.

12. With regard to the “public” component of impairment, the panel considered that:
• There is a real risk that the Registrant will continue to post potentially harmful material on her Facebook account which identifies her as a Practitioner Psychologist registered with the HCPC. It follows that a finding of current impairment is necessary to protect the public.

13. In addition, the panel was mindful of the need to maintain public confidence in the profession and to declare and uphold proper standards of conduct and behaviour. The panel considered that the Registrant’s misconduct represented a serious departure from the standards to be expected of a member of her profession. In the panel’s judgement, public confidence in the profession and in the HCPC as its Regulator would be undermined if there were no finding of impairment.

14. Accordingly, the panel found the Registrant’s fitness to practise to be impaired having regard to both the personal and public components.

Sanction
15. With regard to sanction, the Substantive panel decided to impose a Suspension Order for a period of 12 months. This was to allow the Registrant sufficient time and opportunity to reflect on the panel’s findings and address any outstanding concerns.
16. The panel considered whether to impose a striking off order but decided that to do so would be disproportionate at that time.

First substantive review on 31 July 2024
17. At the first substantive review the panel made the following findings in relation to impairment and sanction.

The panel’s decision on Impairment

18. The panel had regard first to the Registrant’s level of insight and asked whether that had improved to a point that reassured the panel. The panel noted that she understood in general terms that her language had been unprofessional and inappropriate and brought the profession into disrepute.

19. Nevertheless, the panel noted that, even a year after the Substantive Panel’s decision and more than three years after the Registrant’s misconduct, she did not demonstrate any detailed understanding of why she had behaved as she did (apart from a general reference to trauma) and her understanding of the effect on the profession and those who read her posts remained superficial.

20. The panel concluded that, probably because of her superficial insight, the Registrant had not undertaken remediation and training focused on the issues in this case. The panel had read the Registrant’s reflection on the webinar she attended and the reference from Associate Professor Sarah Federman and was satisfied that the webinar was focused on assisting those who had suffered trauma, not on how to use social media in a professional manner that does not bring the profession into disrepute.

21. The panel found this particularly troubling because the Substantive panel had given the Registrant clear guidance and also noted that the HCPC had issued registrants with guidance on “using social media wisely,” which should have informed the Registrant’s approach.

22. The panel examined the testimonials provided by the Registrant and acknowledged that these demonstrated that there were many who held her in high esteem. However, the Registrant accepted that these were not from people who knew the details of the misconduct proved against her and who could assist the panel with the likelihood or otherwise of repetition.

23. The panel read the Registrant’s reflections but did not find in these any reassurance that she had yet developed sufficient insight to direct her remediation and reduce the risk of repetition if there were to be a crisis in future. The panel accepted that the Registrant had not repeated her misconduct but, in light of the views she expressed, the extent to which her posts were inevitably associated with the HCPC and the language she used in her posts, that reassurance was not sufficient.

24. The panel also found that it would be failing to uphold proper standards for the profession and maintain public confidence in the profession if it allowed the Registrant to return to unrestricted practice before the risk of repetition had been resolved.

25. The panel concluded that, with the personal and public interest components in mind, the Registrant's fitness to practise remained impaired; that is to say that the panel found that there was still a significant risk of harm to the public and the wider public interest if the panel did not make a finding of impairment.

Sanction
26. The panel then considered each of the available sanctions in turn. The panel was satisfied, for the same reasons as the substantive panel that:
• The case is too serious for the panel to take no further action.
• A Caution Order would not reflect the seriousness of the Registrant’s misconduct or provide any protection to members of the public. There remained a risk of repetition, and the Registrant had shown insufficient insight or remediation.
• A Conditions of Practice Order would not be appropriate because the misconduct did not relate to the Registrant’s practice as a clinician and the panel could not formulate any conditions which would address the underlying concerns regarding the Registrant’s use of social media.

27. The panel then considered whether the Suspension Order remained sufficient to protect the public and the wider public interest. The panel considered with care whether the time had arrived when it would be necessary to impose a striking off order. The panel concluded that the time had not yet arrived because:
• the Registrant had engaged with the HCPC and attended the hearing;
• the Registrant had developed some insight and undertaken some, although unfocused remediation; and
• there was just sufficient material before the Panel to persuade it that a further period of suspension may be capable of serving the wider public interest in returning a practitioner to unrestricted practice, if the Registrant takes the opportunity given to her to demonstrate sufficient insight and remediation.

28. The panel then considered how long a period of suspension should be and concluded that 12 months was the appropriate period because the Registrant had demonstrated that she needed a significant time to develop insight and undertake properly focused remediation.

The second substantive review 16 July 2025
29. This second substantive review Panel received the following documents:
i. A substantive review bundle of 41 pages
ii. An addendum review bundle of 274 pages
iii. A second addendum bundle of 4 pages, and,
iv. An audio recording entitled ‘Dr Buttar Mask Dangers’ (21:59).

30. The Registrant provided testimony under affirmation.

31. The Registrant said that she had dedicated more than 30 years to the profession. The posts that she made on her personal social media page were reckless, inappropriate, and unprofessional. She said however that that the context of her posts was important in understanding her departures from the high standards that she otherwise kept to. The exceptional conditions created by the unprecedented public health crisis caused her to become overwhelmed with fear and distress by what the public were being told from mainstream media. The Registrant emphasised that this was not an excuse. The situation caused her to research in depth regarding the public health measures and their effects. Initially, she was motivated to buy masks to distribute for free locally and she adhered closely to government guidelines on social distancing and wearing protective face masks.

32. However, she came to doubt and then to challenge the official government position regarding the necessary protective measures. She became sceptical about advice regarding vaccination although she never became an anti-vaxer. She learned that Dr Kary Mullis, the designer of the PCR test, was concerned that his test was being misused to diagnose for Covid, which it was not intended for. Privately her own family had losses in the Covid epidemic which affected her.

33. The Registrant’s concerns grew to the level that she felt it necessary to take action to alert people to another approach which suggested that masks were unhygienic and dangerous and that the social isolation impact on individuals was an unnecessary and unproven burden on the population. The Registrant then posted social media memes on her personal Facebook page. The memes were seen by a professional colleague who complained to the HCPC. The memes were posted on a page that linked the Registrant with the HCPC.

34. The Registrant assured the Panel that there was ‘…no way…’ that she would do that again. At the time she had been overwhelmed by fear and distress for public safety. She has now done work on herself which had the effect that she would never enter that state again. She had been reactive and was not proud of what she had done.

35. The present situation is different, the Registrant explained. She had been engaged in work which mirrored her role as a Practitioner Psychologist although not using a protected title. It involved life coaching and work with high achieving elite athletes. She had received uninvited testimonials which supported both her professionalism and her contribution to people’s lives, including being instrumental in deflecting clients from suicidal intentions. The Registrant said that she had done everything possible to restore her fitness to practise and was not now impaired. In the circumstances, the Panel should return her to unrestricted practice.

36. In answer to Panel questions the Registrant explained that she had undertaken two courses which involved the use of social media. The Panel was taken to paragraph 6.3.2 of her most recent reflective piece dated 10 July 2025 and the Registrant highlighted the courses involved. The Panel did not have sight of any training certificates or information detailing course content.

37. The Registrant also explained in answer to questions, that she would not want to be registered with the HCPC unless they look at how they will rectify their breach of their own guidelines. In her perception, the HCPC had departed from its own standards and had been responsible for distributing highly damaging inaccurate advice and guidance based on an uncritical repetition of government advice. The results had been to discourage and divert patients and service users from accessing valuable alternative therapies and strategies and risked their lives by enforcing a mask mandate for all members of the HCPC when in contact with patients. She had been consistent, trying to provide public access to information that has been censored and suppressed.

38. The outcome, in the Registrant’s view, merited a criminal investigation of the HCPC. The HCPC owed her an apology for its actions and in particular for the way that it had responded to her. It had not been reflective and had taken no responsibility or accountability for the part it played in harming the public. She would not wish to be associated with the HCPC until she had received an acceptable public apology.

39. The Registrant explained that her online followers had grown from 6,000 to 100,000 in response to her sharing online her own research and analysis amounting to 1,000 research hours, unpaid. Her evidence was that she had performed a very valuable service for people who sought clear and thoroughly validated alternative narratives to the damaging propaganda advanced by the government and in turn, the HCPC.

40. The Registrant explained that she is pro informed consent, which was the opposite of the approach adopted by the HCPC. That is the basis of her work. She spoke to very many people at the time who had been denied access to loved ones unnecessarily. These were people like her.

41. The Registrant said that she had already explained this to the substantive hearing panel and to the first review panel, but her explanation ‘…had not landed’ because of the way in which she had expressed herself, being very passionate about her work.

42. The Registrant said that she intended to explore other closely related areas of counselling and coaching and to take up other registration possibilities once this process had concluded. She had no present intention of returning to work as a registered Practitioner Psychologist because of her views regarding the HCPC. She intended to pursue her career outside of the HCPC but wished to have her restrictions on practice removed, to help with that. She had tried to register with another body but had not been successful because of her current Suspension Order.

43. The Registrant said that she had gone above and beyond what was required. She said that in no way is her fitness to practise impaired today.

The HCPC
44. Ms Khorassani, on behalf of the HCPC, invited the Panel to find that the Registrant’s fitness to practise remained impaired. The Registrant had not discharged her duty to persuade the Panel otherwise. The Registrant had also disavowed the possibility of returning to practise and that conditions of practice were an unworkable option. The Registrant had stated that she did not wish to return to what she said was a ‘…corrupt system,’ referring to the HCPC. The only appropriate and proportionate outcome at this stage was a striking off order.

Decision
45. The Panel accepted the Legal Assessor’s advice. It recognised that the Registrant had a practical burden to persuade the Panel that she had identified and solved all of the failings in her practice so that she was no longer a danger to the public and that there was no real possibility of a repeat of her failings in any context.

46. The Panel acknowledged that its purpose today was to conduct a comprehensive review to determine if the Registrant is fit to return to unrestricted practice. The Panel must not conduct a rehearing of the Allegation, nor is it to go behind the previous findings. It must exercise its own independent judgement. If the evidence before the Panel is enough to show that there has been full remediation and full insight gained, such that there is little or no likelihood of a repetition of misconduct, the Panel may come to the conclusion that there is no continuing impairment and, in this situation, the Panel may allow the current order to lapse on 16 August 2025.

47. The Panel held in mind what the Supreme Court had said in Khan v GPhC [2017] 1 WLR 169 SC (Sc) said that:
26. The Committee will also need to satisfy itself that the Registrant has fully appreciated the seriousness of the relevant breach(es), has not committed any further breaches of the Council’s standards of conduct, ethics and performance, and has maintained their skills and knowledge to date, and that the public will not be placed at risk by resumption of practice or by the imposition of conditional registration. Lord Wilson said:
27. The focus of a review is upon the current fitness of the Registrant to resume practice, judged in the light of what he has, or has not, achieved since the date of the suspension. The review committee will note the particular concerns articulated by the original committee and seek to discern what steps, if any, the Registrant has taken to allay them during the period of his suspension. The original committee will have found that his fitness to practise was impaired. The review committee asks: “Does his fitness to practise remain impaired”?
29. It is also noteworthy that, in the fifth report of the Shipman Inquiry, 9 December 2004 (Cm 6394), Dame Janet Smith, Chairman, when referring to reviews under section 35D(5) of the Medical Act 1983, stated at paragraph 27.267: “Review hearings are extremely important. They are the “teeth” behind the sanctions other than erasure and should focus the doctor’s mind on the need to undertake any necessary remediation.”

48. The Panel therefore should be alive to any material change in position since the last hearing.

49. The Panel considered carefully the basis on which the Registrant had approached her presentation. She wished the Panel to accept that her failings were closely linked in time and circumstances to a closed chapter of the Covid-19 national emergency provisions. In that context, the focus should exclusively be on the regrettable content of the posts, which were made when the Registrant was in a reactive fear state. In the Registrant’s presentation, this chapter was now closed and the matter was fully remedied.

50. However, it became increasingly clear to the Panel that this superficial approach to the issue was at best misguided and may indeed reflect the degree of lack of insight held by the Registrant. It was a troubling misperception.

51. The Registrant had discussed in strong and undisguised terms, her deep antipathy for the HCPC and its standards. She had said emphatically that her regulator was criminally responsible for substantial harm to patients and the public. It was, she said, in material breach of its own standards. This was due to its inability to recognise the correctness of the Registrant’s deeply researched position which laid bare the mismanagement of the emergency and obfuscation of better alternatives available from scientifically driven humanitarian distributors of the truth like her.

52. The Registrant’s embedded self-certainty and uncritical conceit revealed itself as the most probable driver for her social media activity. The element of the misconduct that she acknowledged was that the memes that she had posted were divisive. The Panel accepted that the Registrant now regretted the posts and would not repeat that kind of misconduct again. In the Panel’s view this attitude had not been inspired by a full realisation of the potential harm that the posts had created for the public and the damage occasioned to the reputation of the profession and to her regulator.

53. The Registrant had asked the Panel to accept that, in practical terms, she had remedied her failings by no longer posting such harmful content. However, there was no assertion by the Registrant that she had posted publicly available social media posts repudiating the harmful content previously made by her. The Registrant seemed to have limited her understanding of insight and reflection to her silence on the topic in social media. The circumstances had changed and some time had passed (more than half a decade ago she repeated) so that the incident could be regarded as closed. That hypothesis however did not align with the Registrant’s deeply held antipathy for her regulator. The Panel was satisfied that the Registrant’s disregard came from a current and very active state of mind which subsisted little changed by the 5 years since the last social media post complained about.

54. The Registrant was not silent in the hearing. Her mission had matured. She now tried to branch out into seeking alternative registrations as a vehicle for her work. She had, it appeared, a loyal following. The current suspension by her regulator is an impediment to her progress.

55. In all of these circumstances, the Panel was satisfied that the Registrant had not remedied her past failings but had only abandoned one means of showing her failings. She had not offered sufficient apology for the potential harm of her actions. There had been no real recognition of the potential harm to which individuals had been exposed and the standing of her profession reduced in the eyes of the public. Her insight did not extend to a realisation that her disregard of her regulator was incompatible with a wish to remediate and to restore her previous good standing.

56. The Registrant appeared to be baffled that earlier panels had come to similar conclusions, despite the earnestness of her submissions. She seemed to regard that as a failure in communication – her case on the point had ‘…not landed.’ That was also troubling for the Panel. There remained a high and unquantifiable risk of other failings in different circumstances, coming from the same un-remedied root cause.

57. The Panel considered that the public would remain concerned that the Registrant’s failures included a hostile opposition to her own regulator. She was plainly disinclined, at present, to accept the restraints that came with professional registration as a Practitioner Psychologist. That led the Panel to have a real concern for the safety of patients.

58. The Panel was satisfied that public confidence in the profession would be undermined if a finding of current impairment were not made. The Panel decided that the Registrant’s fitness to practise is impaired on the basis of the personal component and the public component.

Sanction
59. The Panel applied the guidance in the Sanctions Policy.

60. The Panel is aware that the primary function of any sanction is to address public safety. The Panel should also give appropriate weight to the wider public interest, which includes maintaining confidence in the profession and setting the proper professional standards.

61. The Panel applied the principle of proportionality and balanced the Registrant’s interests against the public interest. The Panel noted that the sanction should be the least restrictive which is enough to provide the necessary degree of public protection.

62. The Panel considered the sanctions in ascending order of severity.

63. The Panel decided that the Registrant’s misconduct and sustained impairment is of a nature and gravity that the option of taking no action would not be enough to protect the public and to maintain public confidence in the profession.

64. The Panel considered imposing a Caution Order but decided that it would not provide enough protection to the public. The Registrant has not shown the required measure of insight into her conduct and its potential to cause harm. The Panel has found that in these circumstances there is a real risk of repetition of conduct which would bring the reputation of the profession and the regulator into disrepute. A Caution Order would not restrict the Registrant’s practice and would not therefore provide enough protection for the public.

65. The Panel next considered the option of a Conditions of Practice Order. Although the Panel agreed with the substantive hearing panel that the concerns are remediable, the Panel concluded that conditions of practice would not be appropriate because the Registrant has shown an unwillingness to work with practical measures sponsored and controlled by a regulator that she seems to scorn. In any event, the Panel has identified that the Registrant’s failings are attitudinal in nature rather than based in clinical errors that could be solved by supervision and training. Further, the Panel did not consider that the Registrant has shown a sufficient level of insight for conditions of practice to be an effective means of addressing the risk of repetition. Given the current absence of any evidence of remedial steps or any true substantive insight, the Panel decided that any conditions of practice would need to be so restrictive that they would be tantamount to a suspension. The Panel decided that conditions of practice would not be enough to protect the public and would be inappropriate.

66. The Panel then considered the guidance on imposing a Suspension Order. It noted that the Registrant had still not developed and demonstrated enough insight to reassure the Panel regarding the risk of repetition. The risks for the safety of the public and for the reputation of the Practitioner Psychologist profession were high in these circumstances.

67. The Panel turned to paragraph 119 of the Sanctions Policy which informed that Panel that:
A suspension order is likely to be appropriate where there are serious concerns which cannot be reasonably addressed by a conditions of practice order, but which do not require the registrant to be struck off the Register. These types of cases will typically exhibit the following factors:
• the concerns represent a serious breach of the Standards of conduct, performance and ethics;
• the registrant has insight;
• the issues are unlikely to be repeated; and
• there is evidence to suggest the registrant is likely to be able to resolve or remedy their failings.

68. The Panel was satisfied that the Registrant’s misconduct was a serious breach of the Standards. The Registrant’s insight however remained undeveloped beyond the recognition of the need to restrain her use of social media posts to express her deeply held opinions. She still held to the position however, that the government and the HCPC had been responsible for mismanaging the response to a public health crisis, resulting in real harm to individuals. The Registrant remained of that view and had said to the Panel, in clear language, that the HCPC had to examine its own approach to the health crisis, reflect and accept that her views were not incorrect, and then offer her a public apology. The insight into the need to confine social media posts to acceptable limits was valuable, but had not connected to the underlying attitudinal concerns which resulted in her remaining impaired today.

69. The Panel had no basis to doubt the Registrant’s commitment to ensuring that her social media posts would be within acceptable limits in future. However, the risk of repetition of similar harmful behaviours in other contexts remained undiminished and high. Taking into account all of the Registrant’s evidence regarding her own importance as a source of public health information coupled with her unambiguous disregard for her regulator, there is no basis for the Panel to find that the Registrant is likely to be able to resolve or to remedy her failings. The opposite appeared to be true. The Registrant in her most recent reflective piece and confirmed in her live evidence insisted that she could not agree to comply with standard 2.10 of the HCPC Standards of Conduct, Performance and Ethics which states:
2.10 Understand and apply legislation, policies and guidance relevant to their profession and scope of practice.

70. The Panel considered that this evidence exemplified the Registrant’s fundamental incompatibility with her continued registration.

Striking Off Order

71. The Panel turned to the guidance provided by the Sanctions Policy in respect of striking off orders. It recognised that a Striking Off Order was a sanction of last resort.

72. Paragraph 119 of the Sanctions Policy guided the Panel in stating:
A striking off order is likely to be appropriate where the nature and gravity of the concerns are such that any lesser sanction would be insufficient to protect the public, public confidence in the profession, and public confidence in the regulatory process. In particular where the registrant:
• lacks insight;
• continues to repeat the misconduct or, where a registrant has been suspended for two years continuously, fails to address a lack of competence; or
• is unwilling to resolve matters.

73. The Panel was satisfied that for all of the reasons already given, the Registrant lacks insight and is unwilling to resolve matters.

74. There is no evidence that the Registrant has again used social media posts to repeat the particulars of her misconduct. However, for the reasons already set out above, the Registrant’s lack of insight creates a very real risk of a repetition of her misconduct in another context. The Registrant’s evidence regarding her attitude to her regulator persuaded the Panel that she has no intention of addressing or resolving her lack of insight into the harm that any repetition might cause to the public.

75. In all of these circumstances, the Panel came to the view that the only appropriate and proportionate order that would protect the public was a Striking Off Order.

ORDER: The Registrar is directed to strike the name of Miss Poppy Sprague from the Register on the date this Order comes into effect.

The Order imposed today will apply from 16 August 2025.

History of Hearings for Poppy Sprague