Dr Evangelia Bonda

Preliminary Matters
Service
1. The Panel had information before it that the Notice of Hearing was sent to the Registrant’s email address on the HCPC Register on 30 October 2025.
2. The Panel took into account the HCPTS Practice Note entitled “Service of Documents” and accepted the advice of Legal Assessor. 
3. The Panel concluded that service of the Notice of Hearing had been served in accordance with Rules 3 and 6 of the Conduct and Competence Rules 2003 (the Rules).

Proceeding in Absence

4. Ms Shehadeh, on behalf of the HCPC, applied for the hearing to proceed in the Registrant’s absence. 
5. Ms Shehadeh submitted that it was clear from the correspondence from the Registrant in the substantive hearing bundle that the Registrant is aware of these proceedings and the allegations she faces and to some extent she has given her answer regarding those allegations, as such, the Panel could be satisfied that she is aware of this hearing. Ms Shehadeh submitted that the Registrant was entitled to waive her right to attend, that there was a public interest in resolving proceedings in a timely manner, highlighting that the complaints date from 2023, and to proceed promptly. It was also in the interests of the Registrant and the witnesses, as well as providing certainty as to the Registrant’s position. If the Panel did not proceed, there would be significant inconvenience to the live witnesses who have been scheduled to attend. Further, any adjournment would further blunt the memories of witnesses. In any event, Ms Shehadeh, submitted, the Registrant has not asked for an adjournment, and there is no indication that an adjournment would secure her attendance, rather it would prejudice the HCPC case due to the number of witnesses relied on by the HCPC. 
6. Ms Shehadeh told the Panel that on the basis of the Registrant’s written responses in the bundle, a fair hearing could be achieved in that the Panel can ask witnesses questions to ensure that the HCPC case is tested. 
7. The Panel took into account the HCPTS Practice Note entitled “Proceeding in the Absence of the Registrant” and accepted the advice of the Legal Assessor. 
8. The Panel took into account fairness as well as the considerations of public protection and the need for the expeditious progression of the hearing. The Panel also took into account that witnesses have been scheduled to attend this hearing to give live evidence, and that the date of the allegations primarily reach back to 2023 – 2024. 
9. The Registrant has not replied to the Notice of Hearing, nor to further chaser emails dated 26 January and 5 February 2026 from the HCPTS including the link for joining this hearing. The Panel considered that it was reasonable to infer that the Registrant has impliedly consented to the hearing proceeding in her absence, bearing in mind the extensive correspondence between her and the HCPC in earlier stages of the regulatory proceedings, which demonstrate that she is aware of the allegations. The Registrant has not applied for an adjournment, and there is no indication that any adjournment would change her position and secure her attendance. Thus, the Panel concluded that she had voluntarily waived her right to attend. 
10. In all the circumstances, the Panel was satisfied that it was fair and in the interests of justice to proceed, taking into account the absence of communication from the Registrant about whether or not she would be attending this hearing, as well as the public interest in the expeditious progression of the case. While there will be a degree of potential prejudice to the Registrant in that she will be unable to questions witnesses and present her case to the Panel, she has submitted numerous written submissions in earlier stages of the regulatory proceedings which have been included in the HCPC bundle. The Panel itself will be able to question witnesses and test the HCPC case, bearing in mind the Registrant’s written responses. If the hearing did not proceed, there would be significant inconvenience to the witnesses, and there was a risk their memories would fade. 
11. The panel therefore decided to proceed in the Registrant’s absence. 
Background
12. The Registrant has been registered with the HCPC since October 2015 under the title of Practitioner Psychologist. 
13. The allegations against the Registrant are that she engaged in a course of conduct which breached the confidentiality of Service User A, in respect of the disclosure of details relating to counselling sessions between the Registrant and Service User A, and a purported mental health diagnosis, to third parties. 
14. In addition, it is alleged that the Registrant demonstrated threatening and/ or harassing and / or coercive behaviour in demands for monetary compensation from Person B, the mother of Service User A’ s boyfriend. Further, such threatening and/ or harassing and / or coercive behaviour is also alleged in respect of repeated emails and telephone calls to Service User A’s university and the organisation at which she was undertaking a study placement, including persons associated with those organisations. 

Preliminary Issues 

15. At the outset of the hearing, Ms Shehadeh told the Panel that the HCPC was not calling Person F (who is one of the individuals referred to in the Allegation) as a witness. Mr Shehadeh made clear that the HCPC was not relying on any witness evidence of Person F or advancing the case in respect of Person F.
16. The Legal Assessor informed the Panel that if they had read the witness statement of Person F, which had been in a previous version of the HCPC bundle, they should put it entirely out of their minds, and it should play no part in any of their decision-making. The Panel accepted the advice of the Legal Assessor and agreed with that course of action. 
17. The Legal Assessor also raised the issue of the reference, by the Registrant in many of her emails and submissions, which were included in the HCPC bundle, to interim order proceedings to which she had been subject, and also the results of such proceedings in the months leading up to this substantive hearing. The Legal Assessor advised the Panel that ordinarily they would not have any information about any interim order proceedings before them in a substantive case, until the last stage of the hearing, and certainly not at the facts stage. The correspondence and submissions of the Registrant, referring to such matters, had been included in the bundle because they formed part of the Registrant’s more general submissions. The Registrant herself had volunteered information about the interim order process because she had submissions to make about it, and wider issues regarding the regulatory process. The Legal Assessor made clear it was appropriate for the Panel to see all the Registrant’s submissions. However, the Panel’s resulting knowledge of the interim order process, and specifically of the interim order which had been imposed, should be put out of their minds, and not be allowed to influence their decision making at this stage. The Panel accepted the advice of the Legal Assessor in this regard. 

Application for Judicial Review made by the Registrant

18. Following the commencement of hearing live witness evidence, the Panel was informed by Ms Shehadeh that the Registrant had made an application for Judicial Review (JR). A copy of the application was put before the Panel with the agreement of the Legal Assessor. 
19. Ms Shehadeh pointed out that the application was not sealed, meaning that proceedings had not been formally started, but if that situation changed, the Panel would be informed. Ms Shehadeh submitted that it was not clear from the contents of the application if JR was sought in respect of the Interim Order, or the HCPC decision to proceed with these allegations and to hold this hearing. Ms Shehadeh submitted that it was made clear in the application that the Registrant would not be attending this hearing, which she was aware of.
20. Ms Shehadeh highlighted that the submissions of in the JR application include that the HCPC and this panel are biased, there is a conflict of interest, that the Registrant has been discriminated against, that she questions the capacity of the Panel to make decisions, and that her qualifications have not been properly acknowledged in the regulatory proceedings. However, the Registrant did not refer to the specific allegations before the panel today. Ms Shehadeh submitted that it was fair for the Panel to be aware of the application and the Registrant’s objections to the regulatory process, which are similar to the objections she has expressed in other previous correspondence before the Panel. Ms Shehadeh submitted that there was nothing to suggest that there should be an adjournment of this hearing, and there was no suggestion that an adjournment would secure the Registrant’s attendance. Ms Shehadeh made clear the Panel would be informed if there were any further developments in respect of the JR application. 
21. The Panel accepted the advice of the Legal Assessor, who noted that there was no application for an adjournment of this hearing accompanying the JR application, and there did not seem to be any reference to the specific allegations before this Panel, but left the matter to the Panel to consider.
22. The Panel retired to consider the JR application and whether this should have any impact on the next steps of this hearing. 
23. The Panel noted that this was an urgent application for JR. The Panel considered whether or not to treat the JR application as an application to adjourn this hearing pending the resolution of any JR hearing. The Panel decided not to do so for the following reasons. It was clear from the JR application that it was only made on 9 February 2026, the first day of this substantive hearing, but that there was no mention in it of any request for this hearing to be adjourned. The general tenor of the submissions was that the HCPC is a fundamentally flawed and improper organisation and that the HCPC regulatory process should cease. The Registrant also expressed her clear intention not to attend this substantive hearing. The Panel noted that there is no information of any JR hearing that has been listed. 
24. Having examined these circumstances surrounding the application, the Panel did not consider that there was anything in it to be read as an application for an adjournment of this hearing, and it decided to continue with the hearing, nor was there any direction from the High Court to pause the hearing. 
25. On 11 February 2026, Ms Shehadeh gave the Panel a verbal update that the Registrant had sent copies of email correspondence form the Administrative Court Office informing her that she because she did not reside in the UK, she would be unable to lodge her claim for JR, and that this would be required. 
26. On 12 February 2026, Ms Shehadeh further updated the Panel that the HCPC had received information from the Registrant that she was in the process of taking steps to continue with the JR application. 
27. Ms Shehadeh submitted that the Panel should continue with this hearing.
28. The Panel accepted the advice of the Legal Assessor which was that there was no bar to continuation of this hearing at present. 
29. The Panel continued with the hearing, in the knowledge that the HCPC would bring to its attention any possible future order by the High Court to pause this hearing, which it would comply with. 

Application to admit hearsay evidence
30. Ms Shehadeh applied for three written witness statements to be admitted as hearsay. These were the witness statements of:
i. SY, Registration Manager at the HCPC;
ii. MR, Associate at Blake Morgan LLP;
iii. RM, Operational Manager at the HCPC. 

31. Ms Shehadeh referred to Thorneycroft v NMC [2014] EWHC 1565 and El Karout v NMC [2019] EWHC 28 (Admin), and Rule 10(1)(b) of the Rules, and referred to the principle of admissibility of evidence in the Rules on the basis that it is necessary to protect members of the public. 
32. Ms Shehadeh submitted the witnesses were professionals who had participated in the investigation of issues surrounding the case, and were not witnesses of fact. They had undertaken correspondence with the Registrant, checked records and computer systems and, the case of RM, arranged for translation of messages from French to English. The evidence was provided for context and continuity and the exhibits spoke for themselves, including correspondence between the Registrant and the solicitors acting for the HCPC. The Registrant’s messages contained her narrative and were important to be before the Panel, even if they did not appear to address the specific allegations before the Panel. It would be fair to admit them for the Panel to understand the Registrant’s stance on the HCPC as a regulator and the behaviour of Service User A and Person B.
33. Ms Shehadeh told the Panel that the Registrant had not raised any issue against the credibility of the witnesses in question or contended that their witness statements are inaccurate or fabricated, and had not challenged them. They provided a paper trail, and were not the sole and decisive evidence of the charges. 
34. Ms Shehadeh further told the Panel that the reason for their non-attendance was that the HCPC had not called them on the basis that it was not considered proportionate given that they are working professionals exhibiting documents, and there has been no challenge about their veracity from the Registrant. Ms Shehadeh asked the Panel to accept that this was a good and cogent reason for their absence.
35. Following a Panel question, Ms Shehadeh addressed one exhibit to the witness statement of MR, namely MR’s note of a telephone conversation between MR and the Registrant in which is set out, according to MR, what the Registrant said in that conversation on 3 April 2024. While MR would not be available to be questioned about what she wrote in this note, Ms Shehadeh clarified that the HCPC is not relying on the contents of that note to prove the allegations, rather it gives a fuller picture of the Registrant’s submissions about the Regulator. The HCPC was not exploring the tone of call, or its contents, rather the note was put before the Panel to be aware of the Registrant’s stance. Further, that stance was in the same vein as the Registrant’s JR application which was before the Panel. On Panel questioning, Ms Shehadeh clarified that the HCPC had not made the Registrant aware of the hearsay application for these three witnesses.
36. The Panel accepted the advice of the Legal Assessor who referred to the case of NMC v Ogbonna [2010] EWCA Civ 1216, R (Bonheoffer) v GMC (2012) IRLR 37, and Thorneycroft v NMC [2014] EWHC 1565.
37. The Panel took into account that none of the three witnesses were witnesses as to fact, and therefore were neither the sole nor decisive witnesses in respect of the factual charges. Their evidence was contextual, exhibiting documents held in records, exhibiting the Registrant’s written responses and submissions, and dealing with the translation of exhibits of other witnesses. In such circumstances, the Panel considered that the HCPC’s rationale for not calling these witnesses to give live evidence was justifiable. 
38. The Panel also took into account that the Registrant had not been informed about this hearsay application. However, the Panel also took into account there was no challenge from the Registrant specifically to the content of the witness statements or the exhibits, other than of course the Registrant’s general submissions, including with regard to the evidence of Service User A and B, and her challenges about unfairness in the HCPC regulatory proceedings more generally. There was no indication in the evidence before the Panel that there was any suggestion or reason to think that these witnesses had fabricated their evidence. While the allegations are serious, and any application to admit hearsay must be considered against that background. The Panel noted that the Registrant’s written submissions which these witnesses exhibit are important for the Panel to take into account for the hearing to be a fair one, and indeed the content of those submissions are similar to some others of the Registrant’s correspondence which is also in the bundle and before the Panel. 
39. The Panel therefore agreed to the hearsay application. 

Evidence before the Panel 

40. The Panel had before it:
i. Updated HCPC bundle
ii. Updated Service bundle
iii. HCPC Updated Final Case Summary
iv. The Registrant’s email dated 10 February 2026 including attachments and website links submitted to the HCPC on the second day of the hearing which the Registrant stated should be seen by this Panel.
v. The Registrant’s application for JR made on 9 February 2026 at 9am

41. The Panel heard live evidence from:
i. Service User A
ii. Person E, Director of Organisation D
iii. Person G, Academic Director at the Business School at Organisation C
iv. Person B
v. Professor Tim Dalgleish (TD), Consultant Clinical Psychologist, called as an expert witness, and relying on his expert report dated 26 November 2024. 

42. The Panel read the witness statements of:
i. SY, Registration Manager at the HCPC;
ii. MR, Associate at Blake Morgan LLP;
iii. RM, Operational Manager at the HCPC. 
Decision on Facts
43. In coming to its decision, the Panel bore in mind that the burden of proof rests entirely on the HCPC. The standard of proof is the balance of probabilities. 
44. The Panel drew no adverse inference from the Registrant’s absence. In addition, the Panel took into account that the Registrant is a person of good character, and took this into account in relation to the issues of her credibility and her propensity to act as alleged. 
45. The Panel took into account all the documentation before it, Ms Shehadeh’s closing submissions, and the written submissions of the Registrant. 
46. The Panel noted the contextual nature of the hearsay witnesses, and their function in exhibiting documents, as well as the lack of challenge to their evidence by the Registrant. The Panel gave them a significant degree of weight. 
Preliminary issues raised by the Registrant throughout her submissions
47. The Registrant contested the jurisdiction of the HCPC to bring these regulatory proceedings against her at all, on the basis essentially that she does not live or work in the UK, and the Panel took into account that the sessions with Service User A took place while the Registrant was in working France, and Service User A was in the UK. 
48. The Registrant also submitted that the HCPC has failed to recognise her qualifications and her competence to diagnose. 
49. The Registrant also submitted that the proceedings are unfair. There is bias and a conflict of interest in that the daughter of Person C, the Chair of the Council of the HCPC, was a student of Organisation C and that Person C has a connection to a company, named by the Registrant, which has a business interest in Madagascar, and further, there is a suggestion of a connection between that company and Person B. These points were expanded in more detail in the Registrant’s submissions dated 10 February 2026.
50. Ms Shehadeh addressed these submissions in her closing, submitting that the HCPC has jurisdiction, the HCPC accepts her qualifications and makes no issues about her competence, and that having asked Person B questions during her evidence Ms Shehadeh established that Person B does not know Person C or the company in question.
51. The Panel accepted the advice of the Legal Assessor. The Legal Assessor expressed the view that the HCPC did have jurisdiction to conduct these proceedings. The Legal Assessor advised the Panel to consider all the submissions on these preliminary issues. 
52. The Panel considered these arguments in turn. Firstly, the Panel found no evidence to suggest that the HCPC does not have jurisdiction. By virtue of the registrant’s registration with the HCPC, it has jurisdiction over the Registrant. Secondly, the allegations do not touch on any criticism of the Registrant’s qualifications or competence. In this regard, the Panel took into account the witness statement of SY which made clear the HCPC’s recognition of the Registrant’s qualifications and experience. Thirdly, with regard to the conflict of interest point, having considered the Registrant’s submissions, as well as the evidence of Person B, there was no suggestion that any conflict of interest was made out. In addition, this fitness to practise Panel, which is independent of the HCPC, is the decision-maker in respect of the Allegation and no other party or person. 
Particular 1
 Between 16 September 2023 and 6 October 2023, you disclosed confidential information about Service User A to Person B and/or Organisation C and/or Organisation D by disclosing details relating to Service User A’s counselling sessions with you and/or details of an alleged mental health diagnosis. 

53. The Panel took into account the expert evidence of TD. He firstly referred to the duty set out in the HCPC Standards of Conduct, Performance and Ethics 2016-2024 which states that Registrants must respect confidentiality. 
54. TD highlighted section 5 of the guidance entitled “HCPC Confidentiality – Guidance for Registrants” (the Guidance) which set out what personal information includes and this is specifically listed as:
“− personal details, such as names and addresses;
− information about a service user’s health, treatment or care that could
identify them;
− photos, videos or other images; and
− other information that a service user, family member or carer shares with you that is not strictly related to the care, treatment or other services you provide.”

55. TD referred to section 7 of the Guidance which states:
“You must only disclose confidential information if:

− you have permission;
− the law allows this;
− it is in the service user’s best interests; or
− it is in the public interest, such as if it is necessary to protect public safety or prevent harm to other people.”. 

56. TD considered the meaning of “consent” in the Guidance which states that it:
“means that the service user understands and does not object to:

− the information being disclosed or shared;
− the reason for the disclosure;
− the people or organisations the information will
be shared with; and
− how the information will be used.”

57. TD referred to section 8 of the guidance which sets out when it might be reasonable to share confidential information with other health care providers:
“One of the most common reasons for disclosing confidential information will be when you contact other health and care practitioners. This might include discussing a case with a colleague or referring a service user to another health and care professional.

Sharing information is part of good practice. Care is rarely provided by just one health and care professional, and sharing information within the multidisciplinary team or with other organisations or agencies is often an important way of making sure care can be provided effectively.

Most service users will understand the importance of sharing information with others who are involved in their care or treatment and will expect you to do so, so you will normally have implied consent to do this.”

58. TD also referred to section 9 of the Guidance which sets out when it might be acceptable to disclose personal information in the absence of consent on the basis that it is in the public interest to do so:
“You can also disclose confidential information without consent from the service user if it is in the ‘public interest’ to do so.
This might be in circumstances where disclosing the information is
necessary to prevent a serious crime or serious harm to other people. You can find out whether it is in the public interest to disclose information by considering the possible risk of harm to other people if you do not pass it on, compared with the possible consequences if you do. This includes taking account of how disclosing the information could affect the care, treatment or other services you provide to the service user.”

Person B

59. According to the evidence of Person B, Person B arranged to pay the fees for Service User A’s two therapy sessions and agreed this directly with the Registrant. The Registrant sent Person B messages on LinkedIn on 16 September 2023, which were exhibited to Person B’s witness statement. In those messages the Registrant gave some details of how Service User A presented in the counselling sessions, namely that she conveyed a strong dislike towards the Registrant and that she exhibited anxiety and a need to challenge others. In one message, the Registrant suggested a particular diagnosis namely “Oppositional Defiant Disorder (ODD).” 
Organisation C

60. The evidence of Person G was that on 6 October 2023, the Registrant sent a letter by email to the Business School of Organisation C, and that the Registrant forwarded this email to AF on 11 October 2023. That letter was before the Panel. It is entitled “An Expression of Concern” and names Service User A by name. It disclosed details of counselling sessions which took place on 8 and 16 September 2023, the Registrant described the behaviour of Service User towards the Registrant, and matters which Service User A said to the Registrant during the counselling sessions. That letter states as follows:
 “I consider her behaviour socially dangerous, inappropriate and defamatory with harmful intention and maladaptive vindictiveness.

 I further diagnose [Service User A] may suffer from Oppositional Conduct Disorder, a pattern of uncooperative, defiant and angry behaviour toward people in authority.”

61. On 12 March 2024, the Registrant sent an email to Person G which was exhibited to his witness statement and stated as follows, giving an explanation of her rationale for making the disclosure:
“The condition of consent of the student is not mandatory where it is necessary to share information with other professionals, where the student is considered to be at risk to herself and to others or when the actions of the student crosses serious boundaries of respect to others, involving legal pursuits.” Thus, in this case, the information should be shared legally without consent.”

Organisation D

62. The evidence of Person E was that his first contact with the Registrant was on 29 September 2023 when she called the reception desk of Organisation D. His evidence was that the Registrant had sent an email to Organisation D prior to this call, but he did not have a copy of it. The administrative team had informed him of it and he had told the team not to take any action on it. Person E’s evidence was that the email “was very similar” to an email received by Organisation D on 6 October 2023, which was exhibited to Person G’s witness statement. This was essentially the same letter, dated 6 October 2023, which had been sent to Organisation C, and which is referred to above. 
63. The evidence of Service User A was that this information had been shared by the Registrant to those third parties without her consent. 
64. In her written submissions to the HCPC, the Registrant accepted that she shared information with Person B, although she denied that she had breached confidentiality, and specifically stated that she provided no confidential information to Person B. 
65. The Registrant did not deny that she sent the letter dated 6 October 2023 to Organisation C and D. The Registrant stated in her email to Person G dated 12 March 2024 that she had a legal duty to share the information without Service User A’s consent where service user A was to be considered a risk to herself or others, or “when the actions of the student crosses serious boundaries of respect to others..”
66. TD is an experienced Clinical Psychologist. The Panel considered his evidence was clear, and methodically reasoned, taking the Panel through the HCPC guidance and applying it specifically and clearly to the evidence and also the Registrant’s expressed position. Further, in writing his report, TD had seen the communications from the Registrant to Person B, Organisations C and D and also had read the Registrant’s submissions to the HCPC.
67. TD’s opinion was that the Registrant had disclosed confidential information, as described in the HCPC guidance, because it included ‘personal details” and “information about a service user’s health, treatment or care”. 
68. It was clear to the Panel that Service User A had not given the Registrant her consent to share information, according to the evidence of Service User A. This was made clear in her evidence, as well as having made clear by her as early as in her referral to the HCPC dated 16 September 2023. 
69. TD’s opinion was that the situations in which the Registrant could share confidential information without Service User A’s consent were not applicable here. Firstly, it was not shared with other health care providers who had responsibility for her care. Secondly, it was not in the public interest to do so, by reference to the risk of harm to others, nor by reference to the risk of danger to herself. There was, in TD’s opinion, no evidence that the Service User A was going to act in a manner which was a danger to herself or others. TD was clear in that there was no evidence that disclosures were justified, even if the Registrant was of the professional view, as expressed by her, about Service user A in her communications as set out above. He also stated that the demand to Organisation D to have Service User A dismissed was “completely inappropriate”.
70. The Panel also noted more generally that Person E and Person G had no concerns about Service User A, nor had any concerns been reported to either Organisation C or D.
71. Considering all of the evidence before it, the Panel was satisfied that the Registrant had disclosed confidential information by disclosing details relating to Service User A’s counselling sessions, and also details of an alleged mental health diagnosis with Person B, and Organisations C and D, Person E and Person G. The Panel found on the balance of probabilities that this was in the absence of Service User A’s consent. The panel did not accept that the Registrant had any professional or legal justification in doing so, when taking into account the HCPC Guidance and TD’s expert evidence. 
72. The Panel therefore found this Particular proved. 

Particular 2a

2. You demonstrated threatening and/or harassing and/or coercive behaviour by: 
a. asking Person B to pay you damages/reparations on 5 October 2023 otherwise you would report Service User A to Organisation C and Organisation D; and 

73. An email exchange took place on 5 October 2023 between Person B and the Registrant. 
74. An email from the Registrant to Person B dated 5 October 2025 at 21:55 stated:
 “Please find attached my letter dated 5th October, 2023 to be
honoured within ten days and before the 15th October 2023 in the absence of a complaint for Defamation”. 

75. The Panel had before it in evidence what appeared to be the attached letter in which the Registrant demanded a letter of apology and damages in the sum of 3000 euros as damages for the “defamatory behaviour” of Service User A in making her referral to the HCPC in respect of the Registrant. The Registrant went on to write in the letter:
“Otherwise, I must report her inappropriate behavior and mental illness to the schools where she studies, which include Oppositional Conduct Disorder, an uncooperative behaviour disorder, where she can be provocative and angry behavior towards people in positions of
authority.”

76. Another email from the Registrant to Person B dated 5 October 2023 at 23.01 stated:
“I will not compromise regarding my letter of 5th October 2023 and it is
your duty to take necessary action, since these consultations were at your request, or to send the letter to the family of [Service User A]…”

77. Another email from the Registrant to Person B was before the panel, also dated 5 October 2023, timed at 23.26 and which stated:
“If I do not receive a letter of apology and damages for defamation before the 15th of OCTOBER 2023, I will reach out to the educational establishments to take charge of the situation of [Service User A], who is a very sick girl.

This is not a threat, but my legitimate rights against damaged authority and reputation.”

78. An email from the Registrant to Person on 5 October 2023 at 23.49 stated:
“If I do not receive a letter of apology, damages, or interest for defamation before OCTOBER 15th 2023, I will follow my lawyers’ advice and teach you a lesson in ethics and intellectual
merit. Cf. Letter attached”

79. Person B wrote an email in response to the Registrant on 5 October 2023 at 21.31 stating, amongst other matters, that she would not pay her any money, and reiterated this in two more emails that evening.
80. In four separate communications from the Registrant to Person B she demanded damages from Person B for “defamation”, stating that if she did not receive this, she would report to Service User A’s educational institutions that she had a mental illness, namely ODD. In a reply on 5 October 2023, Person B asked the Registrant not to threaten or extort money from her. Person B in her evidence confirmed that this was her response and that she was very distressed as a direct result of the Registrant’s emails.
81. Taking into account the tone, the contents and the number of the emails, the Panel concluded that these communications constituted threatening and coercive behaviour because the Registrant was not only trying to compel the Person B to pay the damages, she was threatening to report to the Service User A’s educational institutions if Person B did not comply. Thus, she was threatening to carry out an action if Person B did not comply with her demands. In terms of the number of the emails, their proximity in time and their insisting and repetitive nature, the Panel also concluded that they were harassing in nature. 

82. The Panel therefore found Particular 2a proved. 

Particular 2b

2. You demonstrated threatening and/or harassing and/or coercive behaviour by: 
b) sending repeated emails and/or phone calls to Organisation C and/or Organisation D and/or Person E and/or Person F and/or Person G between 29 September 2023 and 19 June 2024 as set out in Schedule 1. 

Schedule 1 
29 September 2023 
6 October 2023 
14 October 2023 
20 October 2023 
7 March 2024 
9 March 2024 
11 March 2024 
12 March 2024 
14 March 2024 
11 April 2024 
3 June 2024 
16 June 2024 
19 June 2024

Organisation D and Person E

83. The evidence of Person E was that the Registrant called him on 29 September 2023. His evidence was that she was very aggressive. She was demanding that Organisation D take action on an email she had sent to Organisation D some days before the phone call. While Person E stated that he no longer had a copy of that initial email, his evidence as that it was very similar to the letter sent email sent by the Registrant on 6 October 2023, which was referred to in the Panel’s reasoning in respect of Particular 1.
84. Person E’s evidence was that in the phone call, the Registrant kept mentioning that she was a professional who had informed Organisation D of a concern and action had to be taken; specifically, that the action which Organisation D should take should be to dismiss Service User A from Organisation D. 
85. Person E’s evidence was that he told the Registrant that this concern was a matter of “doctor-patient confidentiality’ and he questioned her intention. Person E’s evidence was that the Registrant kept repeating that there was a concern, she wanted Organisation D to be aware of it, and she “remained very demanding and aggressive on the phone, insisting that we dismiss [Service User A] and that we respond to the Registrant’s email”. 
86. Person E’s evidence was that he told the Registrant that Organisation D would not be taking any action at that stage and that it would not be responding to her emails. The conversation became “heated”, and Person E terminated the call. 
87. Person E ‘s evidence was that Organisation D next received the email dated 6 October 2023 attaching the letter of the same date, referred to above, and in respect of Particular 1. 
88. The Registrant sent two further emails to Organisation D as set out below.
89. On 14 October 2023, the Registrant’s email referred to the email of 6 October 2023 and stated:
 “Please acknowledge reception of my message below and action considered from your part”. 

90. On 20 October 2023, the Registrant sent another email again stating:
 “Please acknowledge reception of my message below and action considered from your part”. 

91. The Registrant did not deny that she entered into these communications. 

Organisation C and Person G

92. The evidence of Person G was that the Registrant had sent to Organisation C the email dated 6 October 2023 attaching the letter of the same date, which was considered in Particular 1. The Registrant forwarded this email to Person G directly on 11 October 2023. Person G’s evidence was that he responded to the email on 12 October 2023 acknowledging her email and reassuring her that action would be taken if appropriate and in line with University processes. 
93. The following emails were sent to Person G. While it is not clear from the emails whether they were sent to other staff members in Organisation C, it was clear to the Panel that Person G had consulted other members of the Organisation and the contents were directed more widely to Organisation C as a whole as well as Person G. 
94. The Registrant sent another email on 7 March 2024. That email stated as follows:
“I have addressed a letter to your Department after an action of this student with defamatory intention against me. You should please forward my letter to your University Office as well as your specialised Mental Health team.

From my point of view as a professional in Clinical and Cognitive Neuroscience, it is appropriate that this student be tested thoroughly and and [sic] independently by Neuropsychological tests to establish her cognitive and affective neuropsychological profile and her Ethics compliance behaviour.

Please update me on your results.”

95. Person G replied on 7 March 2024 stating that Organisation C could not comment or provide information on this matter and suggesting she contact the Organisation C’s Office for Student Conduct, Complaints and Appeals. 
96. The Registrant replied to Person G on 7 March 2024 stating:
“I please ask you to confirm if [Service User A] has been tested by your University’s Mental Health neuropsychologists' team or assessed for ethics compliance and with which results.”

97. The Registrant next sent an email to Person G two days later, on 9 March 2024. Person G’s evidence was that this email referred to a report dated 7 March 2024, however Person G was unable to locate this report. The Registrant’s email of 9 March 2024 states as follows:
“I have addressed a letter to your Department after an action of your student with defamatory intention against me. You should please forward my letter to your University Office as well as your
specialised Mental Health team.

From my point of view as a professional in Clinical and Cognitive Neuroscience, it is appropriate that this student be tested thoroughly and independently by Neuropsychological tests to
establish her cognitive and affective neuropsychological profile and her Ethics compliance behaviour.

In my Report of 7th of March 2024 concerning this patient I wrote that ‘there is an urgent need for the patient’s security and well-being to be neuropsychologically assessed independently and
objectively by the competent team of [Organisation C], if this University follows the Ethics Regulations in Mental Health Prevention and not the financial interest.’

98. Two days later, on 11 March 2024 the Registrant sent Person G two emails. 
99. The first email, timed at 10.24 state that access to mental health services at Organisation C is by staff referral only, and she enclosed a link to Organisation C’s website. The Registrant went on to state that there was a “need for full Personality and Neuropsychological Assessment by Services” and she included a link to another website associated with the NHS. The Registrant ended the email by stating:
“I please request your due reply given upcoming deadlines for a follow-up concerning this student.”

100. The second email, timed at 13.18 and stated:
“I resend my email of this morning, and I do not wish direct communication with other offices”. 

101. The Registrant went on to refer the matters she had referred to in her earlier email that day, and went on to state: 
“The student has assessed by me only with two online sessions as an Oppositional Conduct Disorder or Anti-Social Personality Disorder or similar with clear proved behaviours of pathological lying and propensity for harming intentionally and deliberately others. However, several tests should be done to establish the diagnosis.

I suspect also this student had some interest in Cognitive Science for which I provide online teachings showing thus a highly maladaptive vindictiveness, another reason for which she tried to defame me, although she has referred to me by her potential mother in law for extremely aggressive behaviour towards her family.

My CV is attached.

I please request your due reply given upcoming deadlines for a follow-up concerning this student.”

102. The Panel had the Registrant’s 20-page CV attachment in evidence before it. 
103. On the following day, 12 March 2024, the Registrant sent person G another email, stating in bold font:
“The condition of consent of the student is not mandatory where it is necessary to share information with other professionals, where the student is considered to be at risk to herself and to others or when the actions of the student crosses serious boundaries of respect to others, involving legal pursuits.
Thus, in this case, the information should be shared legally without consent.

I expect your answer the soonest.”

104. The Registrant attached her CV again, and that CV attachment was also before the Panel in evidence. 
105. Person G responded to the Registrant on 14 March 2024 as follows:
“I cannot enter into any further correspondence about this matter and any further emails will be filed without a response.”

106. The Registrant replied on the same day as follows, once again in bold font:
“You should give a follow up through the specialised services or I will contact the Presidency.”

107. On 11 April 2024, Person G received two emails from the Registrant which were the same. He had been copied into an email which the Registrant had addressed to the HCPC’s solicitor. It stated, amongst other matters, as follows:
“[Person G] Head of The Department, copied here, had agreed on 12th October 2023, as you can read below and in my Report of 19th of Feb 2024, to take action in line with the University processes.

The condition of consent of the student is not mandatory where it is necessary to share information with other professionals, where the student is considered to be at risk to herself and to others or when the actions of the student crosses serious boundaries of respect to others, involving legal pursuits. Thus, in this case, the information should be shared legally without consent.

In this case, you have the opportunity to intervene.”
108. On 3 June 2024 the Registrant emailed Person G as follows:
“For reasons of academic and professional deontology you have the obligation to reply on this matter.

I thus ask you to follow the University Procedures and proceed to the Personality and Neuropsychological Assessment as well as Ethics Compliance assessment of [Service User A], whom I denounce for mental health disorder and intentional defamation by pathological lying behaviours of my person and qualifications.

I reminded you that you have committed to do so on the 12th of October 2023 below.

You could also report the case to the Legal services of your University in order to make this process feasible without consent which is not mandatory as I explain below.

This is a task that you are obliged to do, again for Ethics and Code of Conduct reasons, as Staff of the University and Head of the Department.”

109. The Registrant emailed the Registrant again on 16 June, forwarding the email of 3 June 2024. 
110. On 19 June, the Registrant emailed the Registrant as follows:
“I reiterate my message below, and I ask to be in my position and seek justice if defamed.

For reasons of academic and professional deontology you have the obligation to reply on this matter.

I thus ask you to follow the University Procedures and proceed to the Personality and Neuropsychological Assessment as well as Ethics Compliance assessment of [Service User A], whom I denounce for mental health disorder and intentional defamation by pathological lying behaviours of my person and qualifications.

I reminded you that you have committed to do so on the 12th of October 2023 below.
You could also report the case to the Legal services of your University in order to make this process feasible without consent which is not mandatory as I explain below.

This is a task that you are obliged to do, again for Ethics and Code of Conduct reasons, as Staff of the University and Head of the Department.”

111. The Registrant did not deny that she entered into these communications. 
112. In his oral evidence, Person E stated that during the telephone call on 29 September 2023, while the Registrant was not loud, she was very demanding and aggressive. She was demanding that Organisation D act by dismissing Service User A because she was a danger to the community of Organisation D.
113. The Panel took into account that following that telephone call, the Registrant emailed Organisation D three times within 14 days asking it to act, such action having been articulated to Person E verbally as taking the form of dismissing Service User A as a student. The Panel also took into account that these emails were despite Person E, the Director of Organisation D, having stated in the telephone call that he had concerns about the Registrant’s breach of confidentiality and that he would not be taking any action. Person E, as the Director of Organisation D, was required to be aware of and assess these emails on behalf of the Organisation.
114. Person G stated that the correspondence received by the Registrant caused him to feel stress, and it also caused other colleagues in Organisation C concern, whom he had to consult, in having to deal with the correspondence. 
115. The Panel took into account that the Registrant sent Organisation C initially, on 6 October 2023, and then Person G (and Organisation C) some 13 emails on the dates from 7 March 2024 onwards as set out in the Schedule 1. 
116. They were in the same vein, namely demanding that Person G and Organisation C have Service User A’s mental health assessed, and claiming that Person G had “committed” to doing so, when his email simply stated that Organisation C would act if appropriate, and in line with its processes. 
117. The Registrant also suggested a number of times that Person G and Organisation C would be breaching their ethical duties if they did not do so. 
118. The Panel considered the word “threatening” in its ordinary and natural meaning. The Panel considered that it does not necessarily require behaviour that stated an intention to take action in revenge or retribution for something. It could simply mean having a hostile manner. 
119. The Registrant continued to email Organisation D even after Person E told her on the telephone that he would not be taking the action which she was demanding, and she continued to email Person G and Organisation C even after Person G’s email dated 14 March 2024 which stated he would no longer reply to her.
120. Demands were made of Person E and G, and Organisations D and C, and in a repeated, insistent manner in a way that was expressed as designed to compel them to comply. The tone of the communications, was demanding, coercive, hostile and also threatening. In respect of Person G, the Registrant clearly suggested that if neither he nor Organisation C acted, they would be in breach of their ethical duties. The Panel also concluded that there was a threat to inform Organisation C’s “Presidency” if Person G did not comply with her demand. 
121. The number of insistent and repetitive communications demanding compliance was also a course of harassing behaviour by the Registrant, taking into account their tone, and their number, often close proximity in time. 
122. The Panel therefore found the Registrant’s communications to Person E, Organisation D, Person G and Organisation C, as set out in Schedule 1, to be threatening, harassing and coercive in nature. 
123. The Panel therefore found Particular 2b proved. 
Decision on Grounds

124. The Panel next considered whether or not the facts found proved constituted misconduct. 
125. Ms Shehadeh referred to the cases of Roylance v GMC [2000] 1AC 311 and Nandi v GMC EWHC 2317, as well as the expert witness TD’s reference to the HCPC Standards and Guidelines on Confidentiality. Ms Shehadeh submitted that the Registrant had departed significantly from those standards in her lack of respect for confidentiality and lack of appropriate communication, which included communication linked to demands for compensation. Ms Shehadeh submitted that there was an attitudinal issue displayed by the Registrant with a lack of insight and/or remediation, and that all of the facts found proved clearly amounted to misconduct. Ms Shehadeh highlighted the standards she considered that the Registrant had breached.
126. The Panel took into account the advice of the Legal Assessor who referred to the case of Roylance and Nandi. The Panel bore in mind that the issue of misconduct is a matter for its judgment, that there was no burden of proof at this stage, and that the conduct in question must be serious enough to constitute misconduct. A breach of the relevant standards was not necessarily in itself determinative of whether there was misconduct. 
127. The Panel determined that the Registrant had breached the following standards:

HCPC Standards of conduct, performance and ethics (2016)

1 Promote and protect the interests of
service users and carers

Treat service users and carers with respect

1.1 You must treat service users and carers as individuals, respecting their privacy and dignity.
…
2 Communicate appropriately and effectively

Communicate with service users and carers

2.1 You must be polite and considerate.

2.2 You must listen to service users and carers and take account of
their needs and wishes.

…

9. 

Personal and professional behaviour

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

128. The Panel has already decided in its decision on Facts that the Registrant breached the following provisions:

HCPC Confidentiality – Guidance for Registrants

Section 7
“You must only disclose confidential information if:

− you have permission;
− the law allows this;
− it is in the service user’s best interests; or
− it is in the public interest, such as if it is necessary to protect public safety or prevent harm to other people.”. 

Section 8
“One of the most common reasons for disclosing confidential information will be when you contact other health and care practitioners. This might include discussing a case with a colleague or referring a service user to another health and care professional.

Sharing information is part of good practice. Care is rarely provided by just one health and care professional, and sharing information within the multidisciplinary team or with other organisations or agencies is often an important way of making sure care can be provided effectively.

Most service users will understand the importance of sharing information with others who are involved in their care or treatment and will expect you to do so, so you will normally have implied consent to do this.”

Section 9
“You can also disclose confidential information without consent from the service user if it is in the ‘public interest’ to do so.
This might be in circumstances where disclosing the information is
necessary to prevent a serious crime or serious harm to other people. You can find out whether it is in the public interest to disclose information by considering the possible risk of harm to other people if you do not pass it on, compared with the possible consequences if you do. This includes taking account of how disclosing the information could affect the care, treatment or other services you provide to the service user.”

129. With regard to Particular 1, as already found by the Panel in its decision on Facts, the Registrant’s disclosure of confidential information, in the absence of Service User A’s consent, breached these sections of the HCPC Guidance on Confidentiality, without any legal or professional justification.  
130. The Panel noted that TD had expressed the opinion in his report that the Registrant’s behaviour in breaching confidentiality fell far below the applicable HCPC standards. However, this matter was for the Panel’s own judgment, taking into account its findings and the evidence. 
131. The Panel took into account that the disclosures of confidential information were made to a number of recipients, both Person B as well as Organisations C and D (including Person E and Person G) at which Service User A was undertaking further levels of study.
132. The duty upon the Registrant to maintain Service User A’s confidentiality was a cornerstone of her professional obligations. It is a duty which is designed to protect service users and their interests, their privacy and dignity. The Registrant is an experienced Practitioner Psychologist. This was not a lapse in judgment, but a repeated and deliberate breach of confidentiality to a number of recipients. 
133. In all the circumstances, the Panel concluded that the Registrant’s behaviour fell so far below the standards expected of her that her actions constituted misconduct. 
134. With regard to Particular 2a, the Panel took into account that the numerous messages sent to Person B postdated Service User A’s referral of the Registrant to the HCPC, and by the content of the messages to Person B, the Registrant’s objection to that referral was clear. The Registrant sought damages from Person B for Service User A’s “defamatory behaviour”, “otherwise, the Registrant wrote, she would report “her inappropriate behavior and mental illness to the schools where she studies….”.
135. As has already been found, the Registrant’s messages constituted threatening, harassing and coercive behaviour. This was in a series of messages on the same day, within a short space of time, directed at Person B, motivated by the Registrant’s self-interest. The Registrant was seeking to threaten and coerce Person B into paying her 3000 euros “otherwise” she would disclose Service User A’s “mental illness” to her educational institutions. Rather than any genuine desire to properly make justifiable disclosures as a professional, the Registrant was using her position of authority to apply financial pressure to Person B, who was the person who had arranged and paid for the two counselling sessions. The Registrant made repeated threats to Person B that if she did not pay her damages, she would make disclosures about Service User A to her educational institutions which were potentially damaging. The Registrant caused Person B distress, as the Panel heard from Person B’s evidence, and Person B became distressed during her oral evidence while recollecting the Registrant’s behaviour in this regard. 
136. Such behaviour was far from appropriate and effective communication. Rather it was motivated by self-interest, and was in response to the referral to the HCPC about her by Service User A which she took objection to as “defamatory”. The Panel had no doubt it was also designed to cast doubt on the credibility of Service User A’s referral and effectively interfere with her right to complain to the HCPC about her. The Panel considered this conduct to be totally unprofessional and deplorable.
137. The Panel therefore found that the Registrant’s conduct fell so far below what was expected of her as to constitute misconduct. 
138. In relation to Particular 2b, the Registrant effectively carried out a campaign of threatening, harassing and coercive behaviour in respect of two individuals and their two organisations of further education. Once again, the Registrant’s behaviour post-dated Service User A ‘s referral of her to the HCPC. The Registrant’s demands of Person E and Organisation D for Service User A to be dismissed from Organisation D, and her demands to Person G and Organisation C to have her psychologically assessed, was likely to be motivated by the Registrant’s wish for retribution against Service User A for the referral to the HCPC , and was likely to be aimed also at discrediting Service User A as the referrer in the HCPC regulatory proceedings. 
139. Once more, the Registrant’s behaviour, which was a course of repeated and insistent conduct, was motivated by self -interest and not by any promotion of Service User A’s interests which she had a duty to uphold. Again, far from appropriate communication this was a utilisation of her position of authority as a Registrant to threaten, coerce and harass. The Registrant constantly referred to her qualifications, sent her CV twice to Person G and Organisation C, relying on her professional position to seek to enforce her demands. The Panel considered this conduct to be deplorable.
140. Both Person G and Person E made Service User A aware of the disclosures they had received from the Registrant. Service User A found this upsetting, and she told the Panel that she has sought therapy following her experience, and her experience of the Registrant’s behaviour has affected the trust she has been able to place in those from whom she has sought therapeutic assistance. 
141. In all the circumstances, the Registrant’s behaviour fell so far below what was expected of the Registrant as to clearly constitute misconduct. 

Decision on Impairment

142. Ms Shehadeh referred to CHRE v (1) NMC (2) Grant [2011] EWHC 927 and submitted that the Registrant’s fitness to practise was impaired on the basis of both the personal and public components. She referred to the HCPTS Practice Note entitled “Fitness to Practise Impairment” and reminded the Panel of the HCPC’s overarching objective to protect the public, declare and uphold proper standards, and maintain public confidence in the profession. 
143. The Panel accepted the advice of the Legal Assessor who referred to Grant and R (on the Application of Cohen) v. GMC [2008] EWHC 581 (Admin). The Panel took into account the HCPTS Practice Note entitled “Fitness to Practise Impairment”. The Panel was aware that current impairment is a matter for its own independent judgment and that public protection and the wider public interest should be considered. 
144. The Panel took into account the questions formulated by Dame Janet Smith in the Fifth Shipman report, as set out in the case of Grant, which are presented in Grant as a test of impairment and ask whether a practitioner:
“a. has in the past acted and/or is liable in the future to act so as to put a patient or patients at unwarranted risk of harm; and/or
b. has in the past brought and/or is liable in the future to bring the medical profession into disrepute; and/or
c. has in the past breached and/or is liable in the future to breach one of the fundamental tenets of the medical profession;…”

145. The Panel decided that the Registrant had acted in all the ways as set out in these questions by her past actions, taking into account its finding on Misconduct. Harm was caused to Service User A in the upset caused to her by the Registrant’s disclosures, for example her evidence was that she was “mortified” when made aware by Organisation C of the Registrant’s letter to it dated 6 October 2023. She told the Panel that she has sought therapy following her experience and has been caused to become cautious about seeking therapeutic help in the future as a result of the Registrant’s behaviour.
146. The Panel concluded that the Registrant has brought the profession into disrepute by her actions, and breached fundamental tenets of the profession, including breach of confidentiality and the breach of the duty to protect service users’ interests. 
147. The Registrant has not produced any written reflections, or any indication of insight. She has not engaged with this hearing, rather has expressed her position in her JR application that she decided some time ago not to attend. Nor has she taken any steps to address the concerns. There was no demonstration of any understanding of the impact of her behaviour on Service User A; nor of the impact on Person B or the other recipients of her harassing threatening and coercive behaviour. On the contrary much of her written responses and submissions have been focussed on justifying her behaviour and seeking to undermine the HCPC regulatory process. Nor has there been any indication of the impact of her behaviour on public confidence in her or the profession as a whole. The Panel could not identify any acceptance of the need to change her thinking and behaviours nor any reflection on how she would act differently should a similar situation arise in the future. In light of the persistent and deliberate nature of her behaviour in as a whole, the Panel concluded that there was a deep-seated attitudinal aspect to her behaviour, lacking in insight, and unable to step away from her perceived slights to her professional standing, and view her behaviour objectively. 
148. Consequently, the Panel decided that there was a real risk that the Registrant would repeat her actions and thus behave in the ways set out in Grant in the future in the same or similar circumstances. 
149. The Panel was therefore of the view that the Registrant’s fitness to practise is currently impaired on the basis of the personal component. 
150. The Panel next considered the wider public interest. 
151. With regard to the misconduct, the Panel was of the view that it was serious. The registrant was a senior professional and had a duty to adhere to fundamental professional duties. She should not have breached confidentiality in a wilful and persistent manner. 
152. Further, she embarked on a course of threatening, harassing and coercive behaviour motivated by her sense of self-interest. Looking at the totality of her behaviour, this continued over a period of some nine months. Her repeated and insistent behaviour flew in the face of her fundamental duty to protect and promote Service User A’s interests and there was a deep-seated attitudinal aspect to it, placing her own interests over Service User A and the recipients of her threatening, harassing and coercive behaviour. 
153. The Registrant’s behaviour brought the profession into disrepute. In these circumstances, the Panel decided that the need to uphold proper standards of conduct and performance, and the need to maintain confidence in the profession would be undermined if no finding of impairment were made. 
154. The Panel therefore found the Registrant to be impaired on the basis of both the personal component and the public components.

Decision on Sanction
155. Ms Shehadeh submitted that the matter of what sanction, if any, to impose was for the Panel’s independent judgment. Ms Shehadeh referred to provisions of the HCPC Sanctions Policy (SP), and referred to mitigating and aggravating factors. Ms Shehadeh submitted that there was a lack of insight or remediation demonstrated by the Registrant, and that the facts found proved were towards the serious end of the scale of misconduct. Ms Shehadeh also submitted that the Registrant had not demonstrated respect or regard for the regulatory process which may be relevant to her likelihood to engage in any sanction which required her active and ongoing involvement. 
156. The Panel took into account the SP and accepted the advice of the Legal Assessor. The Panel bore in mind that what, if any, sanction to impose is a matter for its own independent judgment, and that the purpose of a sanction is not to punish the Registrant but to protect the public and uphold the wider public interest. Further, any sanction must be proportionate, so that any order that the Panel makes is the least restrictive order that would protect the public and address the public interest. Any impact on the Registrant must not be disproportionate when considering the need to protect the public and uphold the public interest.
157. The Panel was unable to identify any mitigating factors in this case. 
158. The Panel was of the view the following were aggravating factors: 

i. No remorse or apology for the misconduct;
ii. no insight or remediation demonstrated;
iii. persistent and repeated pattern of behaviour in her threatening, harassing and coercive communications;
iv. actions motivated by self-interest;
v. harm to Service User A, Person B and stress caused to Person G;
vi. abuse of professional position and trust.

159. The Panel took into account that previously, the Registrant was of good character. 
160. The Panel took the view that the misconduct in this case was at the higher end of the spectrum of seriousness, based on all the circumstances. The Registrant abused her position of authority to seek to compel the recipients of her hostile communications to comply with her demands, as well as to discredit Service User A in her referral of the Registrant to the HCPC, and to interfere with Service User A’s right to complain. The Registrant also breached the trust which Service User A was entitled to place in her. The Registrant was motivated by self-interest rather than the interests of Service User A to whom she had provided two counselling sessions. These aspects amplified the seriousness of the misconduct. 
161. The Registrant has not engaged in the hearing. She has been unable to address her behaviour before the Panel, demonstrate insight or reflection into the misconduct, into why it happened and how to prevent it from recurring in the future. Nor has she demonstrated that she understands the impact of her behaviour on Service User A, or the wider impact on the profession and public confidence int the profession as a whole. On the contrary, she has rejected the jurisdiction of the HCPC and also challenged the validity and credibility of the regulatory process. Moreover, the Panel has already decided that there is a real risk of repetition resulting from the absence of insight and any remedial steps to address the misconduct.
162. The Panel first considered taking no action. The Panel concluded that, in view of the nature and seriousness of the Registrant’s misconduct and the ongoing risk to public protection, it would be inappropriate to take no action. It would be insufficient to protect the public, maintain public confidence and uphold the reputation of the profession.
163. The Panel then considered a Caution Order. The Registrant’s misconduct was not minor in nature, it was not an isolated event, and there is a real risk of repetition. Furthermore, the Registrant has not demonstrated that she has taken any of the steps required to address that misconduct. Therefore, the Panel concluded that a Caution Order would be inappropriate and insufficient to protect the public and meet the public interest.
164. The Panel next considered a Conditions of Practice Order. The Panel took into account that the Registrant has not attended these proceedings, has challenged the jurisdiction of the HCPC to hold the regulatory proceedings, and criticised them. Further, the misconduct demonstrated a deep-seated attitudinal issue in her behaviour. As such, there was no suggestion that the Registrant would comply with any conditions. In addition, the Panel took into account that the misconduct included a matter of attitude on the part of the Registrant and it would be impossible to formulate conditions to deal with the attitudinal issues in this case. The Panel therefore decided that conditions would be unworkable and neither sufficient to protect the public, nor in the public interest. 
165. The Panel next considered a Suspension Order, the Panel took the view that, in light of the Registrant’s absence from the regulatory proceedings, and her lack of insight and lack of remediation, she is either unable to or unwilling to resolve her failings. There was a pattern of behaviour and there have been no remedial steps taken. These matters together with the ongoing real risk of repetition, led the Panel to conclude that Suspension would not be appropriate or sufficient to protect the public or uphold the wider public interest. 
166. The misconduct demonstrated that the Registrant deliberately disregarded her obligations which gave rise to a risk to service users and others of threatening, harassing and coercive conduct. Such behaviour seriously undermined public confidence in her and the wider profession.
167. Taken together, all of these factors led the Panel to decide that, in light of the nature and gravity of the concerns, coupled with the real risk of repetition, and the breach of trust which the Registrant wilfully and deliberately demonstrated, Striking Off was the only way in which the public could be protected, and the only way in which the wider public interest could be upheld in terms of maintaining proper standards of professional conduct and behaviour, and upholding confidence in the profession. The Panel was also of the view that any lesser sanction would lack a deterrent effect.
168. In coming to its decision, the Panel took into account the principle of proportionality, and the potential impact that such a sanction will have on the Registrant’s right to practise her profession, as well as potential reputational and financial impact. However, the Panel decided that the need to protect the public and uphold the public interest outweighed the Registrant’s interests in this regard.
169. The Panel therefore decided to impose a Striking Off Order. 

ORDER: That the Registrar is directed to strike the name of Evangelia Bonda from the Register on the date this order comes into effect

Interim Order

Application for an interim order to cover the appeal period

170.    The Panel heard an application from Ms Shehadeh for an Interim Suspension Order to cover the appeal period and any possible appeal made by the Registrant. She submitted that such an order is necessary for the protection of the public and is in the public interest. 
171.    The Panel took into account the HCPTS Practice Note entitled “Interim Orders” as well as the SP. The Panel accepted the advice of the Legal Assessor. 
172.    The Panel decided whether or not hear the application for an interim order in the absence of the Registrant. In deciding this issue, the Panel took into account that the Registrant had been informed, in the Notice of Hearing dated 30 October 2025, that this Panel may impose an interim order at any stage of the hearing. In addition, the Panel took into account the reasons set out in its earlier decision to commence the hearing in the absence of the Registrant. The Panel also took into account the indication by the Registrant in the JR application, which the Panel received after its initial decision to proceed in absence, which made it clear that the Registrant had decided previously that she would not be attending this hearing. In the circumstances, and for the same reasons, the Panel determined that it would also be fair, proportionate and in the interests of justice to proceed.
173.    The Panel took into account its previous findings in respect of impairment and sanction, and the need to protect the public and uphold the public interest. 
174.    The Panel came to the conclusion that an interim order is necessary to protect the public and that an interim order is also in the wider public interest in order to maintain public confidence in the profession and to uphold proper standards, relying on the reasons set out in its previous decisions. The Panel also already decided that there is a real risk of repetition of the misconduct. In addition, in the circumstances and relying on the reasons as set out in its previous decisions, public confidence in the profession and the regulatory process would be seriously harmed if the Registrant were not made subject to an interim order during the appeal period. 
175.    The Panel was mindful of its decision at the sanction stage that Conditions were not appropriate. The Panel considered that not to impose an Interim Suspension Order would be inconsistent with its finding that a Striking Off Order is required, and decided that an Interim Suspension Order was necessary.
176.    The Panel recognised that the Panel must take into consideration the potential impact of such an interim order on the Registrant as part of the principle of proportionality, and must balance such impact on the Registrant with the need to protect the public and uphold the public interest. The Panel was satisfied that the need to protect the public and the public interest outweighed the Registrant’s interests in this regard.
177.    The Panel decided to impose an Interim Suspension Order for a period of 18 months, a duration which is necessary and proportionate to allow any appeal which the Registrant brings, to be concluded.

Decision
The Panel makes an Interim Suspension Order 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. 
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 18 months.

History of Hearings for Dr Evangelia Bonda