Mickel Therapy Professional Framework
A personal covering note from Dr David Mickel:

Dear coaches,
APPROVED PROFESSIONAL FRAMEWORK | These first two pages are the plain-language introduction. The full Professional Standards Agreement follows for careful review and independent legal checking before signature.
Over the past year, our understanding and expression of Mickel Therapy have become much clearer. I do not feel we have changed the heart of the work. We have found simpler, more precise ways to describe what has always mattered: understanding body signals, helping people respond honestly to life, and returning authority to the client.

This Professional Framework brings that clarity into the way we train, practise and represent Mickel Therapy. It is not about making the work corporate or asking everyone to coach identically. It creates a shared foundation that supports coaches, protects clients and safeguards the integrity of the work.

Historical training remains recognised and respected. Current Approved status means something additional: completing the relevant current or refresher training, using the Core Course as an essential part of the client pathway, working faithfully within the current model, and taking part in a simple annual approval process.

These first two pages explain the changes in everyday language. The fuller document then sets out the professional and governance detail. This is the approved framework for circulation; its legal wording and bracketed items should still be checked by an appropriately qualified solicitor and data-protection adviser before it is executed or signed.

Please read it in that spirit and bring your questions. My hope is that it gives us a supportive and proportionate framework within which Mickel Therapy can grow well.
Warmest wishes,
David
Dr David Mickel
 
What has changed?
The principles at the heart of Mickel Therapy remain. The change is that the client pathway, coach status and shared standards are now stated more clearly.
THE SHORT VERSION | Historical training remains part of each coach's professional history. Current Approved status is a separate, time-limited assurance that the coach is working within today's Mickel Therapy framework.

The updated framework at a glance
1. A Professional Framework, not simply an agreement. The full document brings the training pathway, professional standards, code of conduct, approval process and fair governance arrangements into one place.
2. Historical training and current approval are different. Earlier training is acknowledged and may be described accurately, but it does not by itself confer Current Approved Mickel Therapy Coach status.
3. The Core Course is now essential. Every Mickel Therapy client must have legitimate access to the approved Core Course, which provides the shared foundation for coaching. It is no longer optional or replaceable by coach-led teaching.
4. Refresher training brings existing coaches up to date. The proposed pathway is four focused training days followed by a fifth review day using observed, recorded or simulated practice, with proportionate follow-up where needed.
5. Coaches work faithfully within the Current Model. This includes PAS, the sensory body, body emotions, the hypothalamus, the understanding that symptoms are not instructions, and the central importance of client autonomy. Coaches keep their own natural style while avoiding misleading hybrids or unsupported claims.
6. Current approval is renewed annually. Renewal is intended to be light-touch, confirming required learning, insurance, directory information, declarations and continuing eligibility, with deeper review only where reasonably needed.
7. Governance is fair and proportionate. Concerns are handled transparently, with reasons, a chance to respond, proportionate outcomes and a review route. Learning and correction are preferred where safe; prompt protective action remains possible where necessary.
 
Part I — Professional Standards Agreement
This Agreement is made on [date] between:
8. [Full legal name of Mickel Therapy entity], incorporated/established in [jurisdiction] with registered/principal address at [address] (“Mickel Therapy”); and
9. [Coach full legal name] of [address / business address] (“Coach”).
Together, the “Parties” and each a “Party”.
1. Purpose and shared intention
1.1 This Agreement sets the conditions on which the Coach may be recognised publicly as a current approved Mickel Therapy Coach and may use the permissions described here. Its purposes are to protect clients, support good coaching, maintain the integrity of the current Mickel Therapy model, and create a fair framework for learning and accountability.
1.2 The Parties intend to work collaboratively and in good faith. Standards will be applied proportionately, with learning and correction preferred where this is safe and appropriate. Nothing in this clause prevents prompt protective action where client welfare, confidentiality, intellectual property or public trust may be at material risk.
2. Definitions and interpretation
In this Agreement:
10. “Approved Coach” means a person whose current approval has been confirmed in writing by Mickel Therapy and has not expired, been suspended, withdrawn or surrendered.
11. “Core Course” means the then-current Mickel Therapy Core Course approved by Mickel Therapy for the client pathway.
12. “Current Model” means the principles, language, boundaries and practice framework set out in the then-current approved manual, Core Course and required updates.
13. “Historical Training” means completion of a recognised Mickel Therapy training programme at an earlier time. It is a factual description of training and does not by itself confer current approval.
14. “Materials” means manuals, course content, slides, recordings, scripts, worksheets, training resources, assessments, graphics and other content supplied or made available by Mickel Therapy.
15. “Mickel Therapy Services” means services expressly represented to a client or the public as Mickel Therapy or as being delivered by an Approved Coach in that capacity.
16. “Required Update” means an update designated by Mickel Therapy as essential for continued approval, with a reasonable completion date.
17. “Standards” means this Agreement, its Schedules, the Current Model and any written policies expressly incorporated into it after reasonable notice.
2.2 “Including” means including without limitation. A written notice includes email to the last notified address. If a Schedule conflicts with the main body, the main body prevails.
3. Historical training and current approval
3.1 Historical Training remains part of the Coach’s professional history. The Coach may describe it accurately, including the year and version where helpful, but must not imply that Historical Training alone amounts to current approval.
3.2 The titles “approved Mickel Therapy Coach”, “current Mickel Therapy Coach” and any materially similar description may be used only while approval is current and only in accordance with this Agreement.
3.3 Initial approval begins only when Mickel Therapy confirms it in writing after the Coach has completed the applicable training, assessment, declarations and administrative requirements. Approval is personal, non-transferable and subject to renewal under clause 20.
3.4 This Agreement does not create employment, worker, partnership, agency, franchise or joint-venture status. Unless separately agreed in writing, the Coach operates an independent practice, controls their own business and is responsible for fees, taxes, contracts with clients and regulatory compliance. The Coach has no authority to bind Mickel Therapy.
4. Training, refresher and readiness to practise
4.1 A new coach must complete the then-current initial training and readiness assessment. A historically trained coach returning to or continuing current practice must complete the refresher and review requirements specified by Mickel Therapy, taking account of prior learning and current competence.
4.2 The proposed refresher pathway is four focused training days followed by a fifth review day. The review may include observed, recorded or simulated practice, subject to consent and data-protection safeguards. Mickel Therapy may reasonably require targeted follow-up learning or another review before approval.
4.3 Assessment will focus on safe and faithful application, not agreement with a fixed personal style. Mickel Therapy will explain any material gap, the evidence relied upon and, where appropriate, a reasonable route to meet the standard.
5. Continuing professional development and updates
5.1 The Coach must complete Required Updates by the stated deadline, keep sufficiently familiar with the current manual and Core Course, and maintain any knowledge or skills reasonably necessary for safe practice.
5.2 Where a change materially affects the client pathway, scope, safeguarding, claims or use of Materials, Mickel Therapy will identify it clearly as essential and allow reasonable time for implementation, unless urgent client protection requires an earlier date.
5.3 Broader learning outside Mickel Therapy is welcomed. The Coach should keep a simple learning record and reflect on relevance to practice. Recommended development is not a condition of approval unless later designated as a Required Update through a fair notice process.
6. Mandatory Core Course pathway
6.1 Before or at the start of Mickel Therapy coaching, the Coach must ensure that each client has legitimate access to the approved Core Course and clearly explain that the course is an essential part of the pathway.
6.2 The Coach must use the Core Course as the foundation and shared structure for Mickel Therapy Services. The Coach may help a client understand and apply it but must not replace it with a summary, an older version, personal handouts, another programme or coach-led teaching.
6.3 If access, language, disability or another genuine barrier affects participation, the Coach must seek an approved reasonable adjustment or alternative from Mickel Therapy before representing the adapted pathway as Mickel Therapy. The client must not be disadvantaged for raising an access need.
6.4 The Coach must not share logins, copy course content or obtain access for a client in an unauthorised way. [Legal review: confirm consumer contracting, pricing, refunds and accessibility responsibilities for the Core Course.]
7. Faithful representation of the Current Model
7.1 In Mickel Therapy Services, the Coach will accurately convey the Current Model, including:
18. Prolonged Activation State (PAS) as the present-day consequence of repeatedly unresponded body signals;
19. the sensory body as the part of us that responds to our interaction with life;
20. body emotions as meaningful signals rather than symptoms or problems to regulate;
21. the hypothalamus coordinating physical activation in response to ongoing signals;
22. that symptoms are not instructions; and
23. the importance of client autonomy, honest communication, boundaries and self-first fulfilment.
7.2 The Coach must not present Mickel Therapy as a fear-based, nervous-system-safety, trauma-processing, brain-retraining or predictive-processing approach, or merge those explanations into the Current Model in a way that changes its meaning.
7.3 The Coach may use their own natural language and examples if they remain accurate, do not add unsupported scientific or medical claims and do not obscure the distinctive principles of the Current Model.
8. Other approaches and professional roles
8.1 A Coach may hold other qualifications and offer other services. Any integration must be clinically or professionally appropriate, lawful, within competence and clearly explained to the client.
8.2 The Coach must clearly distinguish: (a) Mickel Therapy; (b) another named modality or regulated service; and (c) general coaching support. The client must be able to understand what is being offered, on what basis, by whom, and under which complaints and insurance arrangements.
8.3 The Coach must not re-label another approach as Mickel Therapy, imply that an unapproved hybrid is endorsed, or use Mickel Therapy Materials to market or deliver another programme. Where the boundary would be unclear, the Coach must seek written guidance before proceeding.
9. Role and scope of the Coach
9.1 The Coach provides a steady and perceptive framework around the client’s use of the Core Course. The Coach helps the client apply the principles to their own life, supports honest noticing and communication, and notices when either person may be drifting from the Current Model.
9.2 The Coach does not diagnose, prescribe, provide emergency care, interpret the client’s life as an authority, direct major life decisions, promise outcomes, or solve the client’s problems. The Coach does not tell a client that a symptom proves a particular emotion, event or relationship issue.
9.3 The Coach will work within competence, explain limits, make appropriate referrals and end or pause work when needs fall outside scope or the work is no longer useful or safe.
10. Medical, psychological and safeguarding boundaries
10.1 Mickel Therapy is not a substitute for medical assessment, diagnosis, treatment, medication or emergency mental-health care. The Coach must not advise a client to stop, reduce or change prescribed treatment, or discourage appropriate medical or psychological support.
10.2 The Coach must encourage a client to seek qualified help when symptoms are new, worsening, unexplained, urgent or otherwise require assessment. In an emergency, the Coach will direct the client to appropriate emergency or crisis services and act within the law and their safeguarding procedure.
10.3 The Coach must maintain written safeguarding procedures appropriate to the people and places in which they work, complete appropriate training, recognise limits to confidentiality, document decisions and consult or refer without avoidable delay where there is a credible risk of serious harm, abuse or neglect.
10.4 Work with children, protected adults or people who may lack capacity requires appropriate competence, consent/authority, checks, insurance and compliance with applicable law. Unless Mickel Therapy has expressly approved a pathway for minors, the Coach must not provide Mickel Therapy Services to anyone under [18].
11. Client autonomy and avoidance of dependency
11.1 The client remains the decision-maker in their own life. The Coach will support the client to notice and respond for themselves, respect the client’s pace and right to disagree, and obtain informed consent for the nature, practical arrangements and limits of the work.
11.2 The Coach must not use authority, urgency, exclusivity, spiritual or medical claims, repeated unsolicited contact, financial pressure or access to support to create dependency. Frequency and duration should be proportionate and reviewed with the client.
11.3 The client may pause or end coaching subject to clear and fair terms. The Coach will avoid dual relationships, gifts, borrowing, lending, sexual or romantic involvement, and other boundary crossings that could exploit trust or impair judgment.
12. Confidentiality, privacy and records
12.1 The Coach will keep client information confidential except with valid consent, where disclosure is required by law, or where a proportionate disclosure is reasonably necessary to address a serious safeguarding risk. The Coach will explain foreseeable limits before work begins.
12.2 For information the Coach decides how and why to process in their independent practice, the Coach will normally act as a separate data controller. The Coach must comply with the UK GDPR, the Data Protection Act 2018 and, when working elsewhere, applicable local privacy laws. The Parties will document any different controller, joint-controller or processor arrangement before relevant processing begins.
12.3 The Coach must maintain an appropriate privacy notice; identify and document an Article 6 lawful basis and, for health or other special-category data, an Article 9 condition and any required Schedule 1 condition; collect only necessary information; keep it accurate and secure; set and follow a retention schedule; support individual rights; use suitable processor contracts; manage breaches; and complete any required registration or fee payment.
12.4 Records must be factual, relevant, proportionate and distinguish observation from opinion. Identifiable case material may be used for supervision or assessment only under an approved process with an appropriate legal basis, confidentiality safeguards and, where required, explicit informed consent. Recordings require specific advance permission and secure deletion when their purpose ends.
12.5 The Coach must notify Mickel Therapy without undue delay of any personal-data breach or rights request that materially involves Mickel Therapy systems, referrals, Materials or shared processing, while retaining responsibility for notifications required in the Coach’s own practice.
13. Professional conduct and client communication
13.1 Before services begin, the Coach will give the client clear written information about identity, qualifications, current approval, the nature and limits of Mickel Therapy, the Core Course requirement, fees, cancellations, communication between sessions, confidentiality, data use, complaints, emergencies and ending the work.
13.2 Communications must be respectful, timely, accessible and free from harassment, discrimination, retaliation or manipulation. The Coach will make reasonable adjustments where required and will not practise when health, impairment, substance use, workload or another circumstance materially compromises safe service.
13.3 The Coach must disclose any actual or reasonably perceived conflict of interest promptly, discuss safeguards, and withdraw where the conflict cannot be managed in the client’s interests.
14. Marketing and public claims
14.1 Marketing must be accurate, current, evidence-aware and capable of substantiation. It must not guarantee recovery, cure, symptom elimination, a timescale or a particular life outcome; exploit fear or vulnerability; misrepresent testimonials; or imply medical, psychological, scientific or regulatory endorsement that does not exist.
14.2 The Coach must accurately describe their approval and any separate qualifications. Historical Training must not be used to imply current approval. Testimonials, case studies and images require lawful, informed permission and must not compromise confidentiality.
14.3 Mickel Therapy may reasonably require correction or removal of non-compliant public material. Unless urgent, the Coach will be given the concern and a reasonable correction period.
15. Name, marks and public descriptions
15.1 While approval is current, Mickel Therapy grants the Coach a limited, personal, non-exclusive, non-transferable, revocable permission to use approved names, marks, logos and descriptions solely to identify approved Mickel Therapy Services and in accordance with brand guidance.
15.2 Ownership and goodwill remain with Mickel Therapy or the relevant rights owner. The Coach must not register or use confusingly similar business names, domains, social handles or marks; alter logos; grant permissions to others; imply ownership; or use the marks for another method or product.
15.3 Permission ends automatically when approval expires, is surrendered or withdrawn, and is paused during suspension unless Mickel Therapy agrees otherwise in writing. Accurate historical references may remain only in a form agreed or permitted by law and must state clearly that the person is not currently approved.
16. Intellectual property and Materials
16.1 Materials are licensed, not sold, for the Coach’s personal training and approved practice. The Coach must keep them secure and must not share, publish, upload, sell, teach from, distribute or make them available to any third party except as expressly authorised in writing.
16.2 The Coach must not reproduce, translate, record, adapt, summarise into substitute materials, remove notices from, create derivative training from, use to train an AI system on, or commercially exploit Materials without prior written permission. Limited client-facing extracts may be used only where expressly designated for that purpose and without alteration beyond approved accessibility adjustments.
16.3 The Coach will promptly report suspected loss, unauthorised access or infringement and reasonably assist protective steps. These obligations survive the end of this Agreement.
17. Directory, referrals and recognition
17.1 Directory listing, referral eligibility, badge use and other public recognition are benefits of current approval, not guaranteed entitlements. Mickel Therapy may set objective criteria relating to availability, location, language, insurance, good standing and accurate profile information.
17.2 Mickel Therapy does not guarantee referrals or income. The Coach must promptly update material profile changes. Listing may be temporarily hidden during a lapse, investigation, leave of absence or where information is inaccurate, with reasons given where appropriate.
18. Insurance and legal compliance
18.1 Before practising and throughout approval, the Coach must maintain professional indemnity and public liability insurance appropriate to the services, clients, territories, online work and any other modalities offered, with a reputable insurer and limits of at least [£ amount] or such other level notified reasonably by Mickel Therapy. Evidence must be provided on request.
18.2 The Coach is responsible for all registrations, licences, checks, consents, tax obligations and local laws applying where the Coach or client is located. A coach working outside the UK must comply with local practice, consumer, privacy, safeguarding, advertising and cross-border data-transfer requirements and confirm that the service and insurance are permitted there.
18.3 The Coach must promptly disclose any restriction, investigation, complaint finding, criminal matter, regulatory issue, insurance lapse or other circumstance reasonably relevant to safe practice or public trust, subject to applicable law and fair treatment.
19. Supervision, case review and quality assurance
19.1 The Coach will participate in reasonable supervision, peer learning, case review, practice observation, feedback and quality-assurance activity specified for approval. Requirements will be proportionate to experience, activity, risk and identified learning needs.
19.2 Client information will be anonymised wherever reasonably possible. Any sharing of identifiable information must have a lawful basis, be necessary and proportionate, and follow the approved privacy and safeguarding process.
19.3 Quality assurance is intended to support fidelity, reflection and client protection. It is not a promise by Mickel Therapy to supervise every client interaction or assume responsibility for the Coach’s independent practice.
20. Annual renewal and re-approval
20.1 Approval lasts until the renewal date stated in Mickel Therapy’s written confirmation, normally 12 months, unless suspended, withdrawn or surrendered earlier.
20.2 Annual renewal may require: confirmation of active contact details and directory information; evidence of insurance; completion of Required Updates; a declaration of compliance, conflicts and material complaints; a learning/practice record; payment of any clearly notified fee; and participation in proportionate quality assurance.
20.3 Renewal is not automatic, but will not be unreasonably withheld. Where a remediable gap exists, Mickel Therapy should normally offer conditional renewal, a reasonable action plan or a defined period of inactive status before withdrawal.
20.4 A substantial change to the model or an extended absence may require additional training or re-assessment. Mickel Therapy will recognise relevant prior learning and explain the requirement.
21. Complaints, concerns and fair process
21.1 The Coach must maintain a clear client complaints route and notify Mickel Therapy promptly of concerns that reasonably affect the Current Model, approval, safeguarding, serious conduct, public claims, Materials or reputation. Mickel Therapy may receive concerns directly and may share relevant information lawfully and proportionately.
21.2 Except where urgent interim action is necessary, the Coach will receive: a clear summary of the concern; a reasonable opportunity to respond and provide evidence; an impartial decision-maker without a material conflict; a written outcome and reasons; proportionate measures; and an internal review or appeal on stated grounds.
21.3 Confidentiality will be respected but cannot be guaranteed where information must be shared to investigate fairly, protect a person, comply with law or notify an insurer or authority. Retaliation against a complainant, witness or person raising a good-faith concern is prohibited.
21.4 The detailed procedure in Schedule 3 applies. Mickel Therapy may adapt timings or steps where reasonably necessary, explaining why and preserving fairness as far as possible.
22. Suspension and withdrawal
22.1 Mickel Therapy may impose advice, a corrective action, enhanced supervision, conditions, temporary suspension or withdrawal of approval where the evidence supports a proportionate response to a breach, competence gap, risk, non-cooperation, non-renewal or loss of eligibility.
22.2 Interim suspension may be imposed before a final decision only where reasonably necessary to protect clients, evidence, confidentiality, intellectual property or public trust. It is neutral, not a finding, and must be reviewed promptly.
22.3 Except in urgent cases, the Coach should receive reasonable notice and an opportunity to remedy a remediable breach. Serious misconduct, dishonesty, exploitation, material safeguarding failure, persistent misleading claims, unauthorised sharing of Materials or practising during suspension may justify immediate withdrawal after a fair review.
22.4 During suspension the Coach must stop taking new Mickel Therapy clients, pause restricted mark use and comply with directions for current clients. On withdrawal, the exit obligations in clause 23 and Schedule 4 apply.
23. Leaving, lapse and client continuity
23.1 The Coach may surrender approval by written notice. Approval may also lapse at expiry if renewal is incomplete. Historical Training is not erased, but the person must stop representing themselves as currently approved and stop all uses that depend on approval.
23.2 The Coach must remove approval claims, logos, directory references and restricted descriptions from public materials within [10] working days, or sooner where necessary to prevent harm. Materials must be returned, securely deleted or retained only as expressly authorised.
23.3 The Coach remains responsible for an orderly, client-centred transition: explaining the change truthfully without unnecessary detail, safeguarding records, offering reasonable notice where safe, providing appropriate referrals or transfer options, refunding prepaid undelivered services where required, and not abandoning clients at risk.
23.4 Mickel Therapy and the Coach will cooperate on continuity where practicable. Neither Party may transfer identifiable client information without a lawful basis and appropriate transparency. Clauses on confidentiality, data protection, intellectual property, accrued rights, liability and governing law survive as necessary.
24. Liability, indemnity and relationship with clients
24.1 The Coach contracts directly with clients unless a separate written arrangement states otherwise and remains responsible for their acts, omissions, business and client care. Mickel Therapy does not guarantee the Coach’s services or outcomes merely by granting approval.
24.2 Each Party remains responsible for loss caused by its own breach, negligence or unlawful conduct. Any indemnity, exclusion or cap on liability must be set out here only after legal advice and must not exclude liability that cannot lawfully be excluded. [Solicitor to advise on proportionate wording, insurance alignment and consumer-law implications.]
25. General terms
25.1 Changes. Mickel Therapy may update operational Standards where reasonably needed to protect clients, reflect the Current Model or comply with law. Material changes will be notified in writing with a reasonable implementation period. Changes to core contractual rights should be agreed or introduced at renewal, except where law or urgent safety requires otherwise.
25.2 Notices. Formal notices must be sent to the email or postal address last notified by the receiving Party. A notice is treated as received [insert fair delivery rules after legal review].
25.3 Entire agreement and priority. This Agreement and incorporated Schedules contain the agreement about current approval, except for any separate written licence, fee or data-processing agreement. If terms conflict, the document expressly stated to take priority will prevail.
25.4 No waiver; severability. Delay in enforcing a right is not a waiver. If a provision is unlawful or unenforceable, it will be adjusted to the minimum extent necessary or removed without affecting the rest, subject to legal advice.
25.5 Assignment. The Coach may not transfer this Agreement or approval. Mickel Therapy may assign it only as part of a genuine transfer of the Mickel Therapy business or rights, on notice and without materially reducing the Coach’s protections.
25.6 Third-party rights. A person who is not a Party has no right to enforce this Agreement under the Contract (Third Party Rights) (Scotland) Act 2017, except [identify any intended beneficiary or delete exception].
25.7 Governing law and jurisdiction. This Agreement and any non-contractual obligations arising from it are governed by Scots law. Subject to any mandatory rights or agreed mediation process, the Scottish courts have [exclusive/non-exclusive] jurisdiction. [Solicitor to confirm wording for coaches and clients outside Scotland.]
 
Signature and approval record
By signing, each Party confirms that it has read and understood this Agreement and intends to be bound by it. The Coach confirms that information supplied for approval is accurate and will be kept current.
For Mickel Therapy Coach
Name: __________________________ Name: __________________________
Role: ___________________________ Business name (if any): ___________
Signature: _______________________ Signature: _______________________
Date: ___________________________ Date: ___________________________
Approval start: __________________ Approval number: _________________
Renewal date: ___________________ Renewal date: ___________________
 
Schedule 1 — Essential standards and recommended good practice
This Schedule makes the distinction explicit. “Essential” items are conditions of current approval. “Recommended” items support strong practice but are not, by themselves, grounds for adverse action unless incorporated later through the process in clause 25.1.
Area Essential standard Recommended good practice
Approval Current written approval; renewal completed; status described accurately. Use an annual reflection goal and peer-learning plan.
Client pathway Legitimate client access to the current Core Course; coaching grounded in it. Revisit relevant modules jointly when application becomes unclear.
Model fidelity Accurate Current Model; no misleading hybrid or unsupported claims. Keep a short fidelity checklist for self-review.
Scope and safety Work within competence; medical, psychological and safeguarding boundaries; referrals where needed. Maintain a local referral and crisis-resource list.
Autonomy Informed choice, clear endings, no dependency or exploitation. Review purpose, frequency and progress periodically with the client.
Privacy Lawful, secure and proportionate handling of records and health data. Complete an annual data map and retention check.
Insurance Appropriate current cover and evidence on request. Discuss new territories and service formats with the insurer before launch.
Quality Participation in required updates, supervision and review. Join optional peer practice and reflective learning.
Public identity Approved names/marks used only within permission; claims accurate. Use the latest approved biography and client explanation.
Materials Secure, non-shared and not reproduced or adapted without permission. Review access controls when changing devices or contractors.
 
Schedule 2 — Coach Code of Conduct
An Approved Coach will:
24. Put client welfare, dignity, autonomy and informed choice at the centre of practice.
25. Represent Mickel Therapy, personal qualifications, evidence and likely outcomes honestly.
26. Use the current Core Course and Current Model faithfully while allowing the client to guide their own application.
27. Work within competence and make timely medical, psychological, safeguarding or other referrals.
28. Maintain clear boundaries and never exploit trust, vulnerability, money, intimacy, authority or confidential information.
29. Respect equality, diversity, accessibility and each client’s right to disagree, pause or leave.
30. Protect confidentiality and personal data, keeping only proportionate, secure and useful records.
31. Communicate fees, cancellations, availability, complaints, emergencies and endings clearly.
32. Seek supervision, disclose conflicts and respond openly to feedback, mistakes and concerns.
33. Protect Mickel Therapy Materials and intellectual property and use approved names and marks responsibly.
34. Avoid practising when impaired or when personal circumstances materially affect safe judgment.
35. Cooperate with fair quality assurance and take prompt corrective action where standards are not met.
A material or repeated breach may lead to action under Schedule 3. Context, seriousness, insight, remediation, prior history and risk will be considered.
 
Schedule 3 — Approval, quality assurance and concerns procedure
A. Approval and renewal
36. Mickel Therapy publishes the applicable requirements, evidence and deadlines.
37. The Coach submits training/refresh, insurance, declarations, profile and any assessment evidence.
38. A suitably competent reviewer assesses readiness against stated criteria and identifies any gaps.
39. Mickel Therapy confirms approval, conditional approval, further action or non-approval in writing, with reasons and a review route.
40. Annual renewal uses a light-touch declaration and evidence check; deeper assessment is risk-based or event-driven.
B. Routine quality assurance
Quality assurance may include anonymised case reflection, simulated practice, observation with consent, review of public descriptions, Core Course pathway checks, learning records and feedback. Sampling should be proportionate, privacy-preserving and applied consistently.
C. Concerns process
41. Receive and triage: acknowledge the concern, identify immediate safety or preservation needs, and check conflicts.
42. Define scope: tell the Coach the substance of the concern and applicable standards, subject to lawful redactions.
43. Gather information: seek proportionate evidence from relevant people and protect confidentiality.
44. Response: allow the Coach normally [10] working days to respond, with extensions where fair.
45. Decision: use an impartial decision-maker applying the balance of probabilities, recording findings and reasons.
46. Outcome: no action, advice, correction, learning plan, supervision, conditions, suspension or withdrawal.
47. Review/appeal: permit a request normally within [10] working days for material procedural error, new evidence, unreasonable finding or disproportionate outcome; use a person not previously responsible where practicable.
48. Close and learn: communicate the outcome to those entitled to know, retain records under schedule, and make systemic improvements.
D. Interim action and fairness safeguards
49. Interim measures are protective, not disciplinary findings, and are reviewed at defined intervals.
50. People involved declare conflicts; an alternative decision-maker is appointed where material.
51. The Coach may be accompanied at a formal meeting by a supporter who respects confidentiality.
52. Anonymous concerns may be considered, but their weight depends on detail, corroboration and fairness.
53. Timelines may change for safety, illness, complexity, parallel proceedings or witness availability; reasons are recorded.
54. Information is shared only on a need-to-know basis and subject to privacy, safeguarding and legal duties.
 
Schedule 4 — Exit and client continuity checklist
55. Confirm the effective date and whether the status is surrendered, expired, suspended or withdrawn.
56. Stop accepting new Mickel Therapy clients and agree safe arrangements for current clients.
57. Give clients clear, neutral information and reasonable notice; identify urgent or vulnerable cases.
58. Offer appropriate options: planned ending, transfer to another Approved Coach, or independent referral.
59. Obtain lawful consent before transferring records; do not transfer by default.
60. Address prepaid fees and contractual commitments fairly and lawfully.
61. Remove current-approval claims, badge/logo use, directory entries and restricted descriptions.
62. Return or securely delete Materials and access credentials as directed.
63. Retain and later destroy client records under the Coach’s lawful retention schedule; preserve records needed for an active complaint or legal duty.
64. Notify insurers or authorities where required; keep an auditable note of continuity and safeguarding decisions.
 
Part II — Supporting notes and implementation
1. Structure and rationale
The Professional Framework is built around a status-and-permission model. Historical Training is an enduring fact; current approval is a renewable assurance that the coach is up to date, insured, working within the current pathway and willing to participate in quality assurance. This avoids rewriting anyone’s history while making public recognition meaningful.
The main clauses set binding expectations in readable language. Schedule 1 separates essential standards from recommendations. Schedule 2 gives coaches and clients a concise conduct standard. Schedule 3 makes approval and concerns processes transparent and proportionate. Schedule 4 protects clients during departures. Square-bracketed items are intentional decisions for Mickel Therapy and its solicitor.
Tone choice The document uses “must” for approval conditions, “should” for a normal fair approach, and “may” for genuine discretion. Remediation is the default for fixable gaps; urgent restriction remains available where the risk warrants it.

2. Matters requiring formal legal advice
65. Correct contracting entity, ownership/licensing of the Mickel Therapy name, marks and Materials, and whether registrations exist in relevant territories.
66. Whether the approval/licence arrangement creates competition-law, franchise, agency, employment-status or tax issues in practice, regardless of the label used.
67. Enforceability and proportionality of suspension, withdrawal, post-termination mark restrictions, intellectual-property restrictions and any future fees.
68. Liability allocation, any indemnity or cap, insurance limits, and alignment with the actual professional-indemnity policy. Do not insert a broad indemnity without advice.
69. Consumer-facing terms: Core Course purchase, coach-client contract, cancellations, refunds, digital content, accessibility, claims and the interaction between Mickel Therapy and coach services.
70. Data roles and flows: referrals, directory forms, course access, case review, recordings, complaints and transfers. Prepare a data map, controller/joint-controller/processor terms, privacy notices, retention periods and breach protocol.
71. Lawful bases for health and other special-category data. Consent is not automatically the best Article 6 basis; an Article 9 condition is separately required.
72. Safeguarding duties and referral routes in Scotland and every territory served, including work with minors, adults at risk and people who may lack capacity.
73. Cross-border practice and data transfers, professional regulation, local licensing, insurance territorial limits and enforceability of Scots-law jurisdiction clauses.
74. A defensible evidence basis for medical/scientific statements, health advertising and testimonials, including review of the specific PAS/hypothalamus wording.
75. Fair-process details: standard of proof, time limits, appeal grounds, records, data sharing with complainants, whistleblowing and interaction with police, insurers or regulators.
76. The intended effect of the Contract (Third Party Rights) (Scotland) Act 2017, electronic signatures and notice rules.
3. Suggested implementation for existing coaches
77. Preparation (weeks 0–2): appoint an implementation lead; complete legal, insurance, safeguarding, evidence and data-flow reviews; finalise the manual, Core Course pathway, assessment criteria and support route.
78. Listening and notice (weeks 2–4): share a plain-language change note and the approved Professional Framework with Emilia, Franziska, Max, Adie and other existing coaches; hold a group briefing and offer confidential one-to-one conversations. Record concerns and make justified revisions.
79. Status baseline (week 4): write to each coach confirming Historical Training, current public status, existing clients, insurance, practice location, other modalities, access needs and intended participation. Avoid implying non-response is consent.
80. Transition agreement (weeks 4–6): issue the final agreement with at least [14] days to consider it and encourage independent advice. Offer three paths: refresher toward current approval; voluntary inactive/alumni status; or orderly exit.
81. Refresher (weeks 6–14): deliver four focused days covering Current Model, Core Course, manual, pathway and practical application. Provide materials in advance and allow reasonable adjustments.
82. Review day (weeks 14–16): assess practical or simulated work against published criteria. Give specific feedback, allow questions and use targeted follow-up rather than an all-or-nothing result where safe.
83. Decision and transition (weeks 16–18): confirm full, conditional, deferred or declined approval in writing. Agree improvement steps and deadlines. Coordinate directory, marks and client-continuity changes.
84. Stabilisation (first 6 months): offer monthly group supervision or office hours, sample a small number of fidelity reviews, monitor common questions, and publish clarifications consistently to all coaches.
85. First renewal (12 months): use the annual declaration and evidence check, then review whether the agreement, training and support system are proportionate and working as intended.
Fairness safeguard: consider a defined transition window for existing clients, but do not permit new Mickel Therapy clients to start outside the mandatory Core Course pathway once the new standard takes effect.
4. Renewal recommendation
Recommendation Renew current coach approval annually through a light-touch evidence and declaration process, with deeper reassessment only after major model changes, extended absence, material concerns or a risk-based sample.

Annual renewal best matches facts that can change quickly: insurance, required learning, directory information, practice location, complaints and conflicts. It keeps the public meaning of “current” credible. A two-year cycle creates avoidable gaps, while renewal only after major updates would not verify continuing eligibility. To avoid bureaucracy, use a short online declaration, automatic reminders, a reasonable grace period and conditional renewal for fixable administrative gaps. Consider a fuller reflective review every three years, but do not make coaches repeat training without a reason.
5. Current official reference points for legal review
These sources informed the risk flags, but do not replace tailored advice:
86. ICO — Data protection principles and special-category data
87. ICO — Controllers and processors
88. ICO — Conditions for processing special-category data
89. Scottish Government — Adult support and protection
90. Legislation.gov.uk — Consumer Rights Act 2015
91. Legislation.gov.uk — Contract (Third Party Rights) (Scotland) Act 2017
 
Covering email
Subject: Updated Mickel Therapy Coach standards and refresher pathway
Dear [Name],
Mickel Therapy has developed considerably since many coaches first trained. The central principles remain, but the model, language, Core Course, manual and client pathway are now clearer and more consistent.
We are therefore introducing an updated Professional Framework and refresher pathway for anyone who wishes to be recognised publicly as a current approved Mickel Therapy Coach. This is not intended to disregard earlier training. It creates a clear distinction between having trained historically and being up to date and approved to practise within today’s framework.
The proposed refresher includes four focused training days and a fifth practical review day. The attached approved Professional Framework also sets out the mandatory Core Course pathway, role boundaries, professional standards, use of Mickel Therapy materials and a fair process for quality assurance and concerns.
Please read the Professional Framework and send any questions or comments by [date]. We will also hold a group briefing on [date/time] and can arrange a confidential one-to-one conversation if that would be helpful. You are welcome to take independent advice before signing the Professional Standards Agreement.
Our aim is to support coaches, protect clients and steward the integrity of Mickel Therapy collaboratively. No one will be asked to pretend that their historical training did not happen; the question is whether they wish to complete the current pathway and hold current approval going forward.
With thanks,

Dr David Mickel
Director and Founder Mickel Therapy LTD