There’s a gap between what is lawful and what is right. With the therapy harm I experienced, I’ve learned that a clinician’s conduct can be wrong on several levels and still fail to trip a regulatory wire. I should preface this by saying that my complaint is still before the regulators, and she may yet face a sanction. However, getting to this point has been a brutal slog which has led me to ask some serious questions.

Law and regulation require evidence that meets a procedural standard. In my case the question is whether my clinician practised below the standard set out in the Code of Conduct. Ethics, on the other hand, only requires that something was harmful. When therapy harms you, you quickly figure out that regulatory bodies are built to measure the former, leaving the client to drown in the latter. As I have said before, there is no court of law or regulator whose primary concern is to provide accountability for the harm itself.

In my case, that gap looked like three years in a room without a map. I don’t know whether she had one, but if she did, it wasn’t shared with me. I had no clue what was happening. My frantic attempts to regain a sense of safety and control in that space were later reframed as reassurance-seeking. She told one of my other clinicians that the focus of our work was attachment and trauma. A label isn’t the same as a plan. I wasn’t told what that work would involve, how it would be paced, or what would happen when it fell to shit. How can attachment be the active focus when it was only ever discussed at a surface level?

If attachment and trauma were the focus, then the attachment distress that grew in that space was exactly what my therapist was meant to be working with. Instead of holding the container for it, that same distress was later reframed as ‘therapy-interfering behaviour.’ I can’t make those two things fit. If attachment was the work, the unmanaged escalation of it is part of what she needs to answer for. If it was an obstacle to the work, I’d like to know what the actual work was supposed to be. If the therapy was working, how did its focus escalate to the point that it had to end? Her answer was to put it on me.

That’s where the ethical failure lives: in the ambiguity, or, as I’ve crassly called it, the gooch space.

This is the shitty reality of the ‘lawful but awful’ space. Procedurally, a clinician can claim they identified a treatment focus. They tick a box. Ethically, inviting a vulnerable client to attach, offering no structure to hold it, and then blaming the client when the shit hits the fan is a failure of duty.

It leaves almost no paper trail. The harm sits in the omissions: the vague pacing, the boundaries applied unevenly, the conversations that never happened. These are things a client often isn’t equipped to see in the moment. The regulatory system asks whether a baseline procedural standard was met. It doesn’t ask whether you were led into deep water without a line back, or measure what it costs a client when the story shifts to their behaviour. Legally, I consented to therapy. I signed their forms (although that’s another question altogether). Ethically, though, how can I give true informed consent to an unmapped process when I’m the one in the vulnerable position?

Waiting for a regulatory system to validate this kind of ethical harm is a trap, as is waiting for accountability that may never come. As a PDAer, my nervous system doesn’t cope well with systems that feel arbitrary. Falling into the gap between law and ethics is exactly what it feels like. It’s a disorienting limbo where the harm is undeniable to me, and the accountability is nowhere to be found.

When my clinician decided to end therapy, the question she seemed to be asking was ‘is this defensible?’, not ‘is this right?’ If that is the question being asked, it’s fair to ask whose interests sit at the centre of the decision. I know whose I needed it to be.

The Code of Conduct should be the floor of clinical practice, not the ceiling. If a clinician is treating it as their ceiling, they need to take a good, hard look at themselves. That isn’t best practice. That’s just risk management.

The therapy harm survivor community is helping me get to a place where I don’t need a regulatory finding to validate my reality. I know what I lived through.

I’m no longer waiting for the people who built the gap to pull me out of it.