Policies & Procedures

Why are Policies and Procedures Important to Sacred Circle?

The thing about policy is that it often seems dry, boring and a tick box exercise. What it can be is a really useful barometer of the health and consciousness of an organisation. As a community interest company Sacred Circle is bound by law to have the main four in place: safeguarding, data protection, equality and inclusion and health and safety; we fear not the law! At the core of our values is safety and inclusivity. We cannot ensure that we are completely inclusive (sometimes we have to exclude some people to create a more inclusive space – one of life’s paradoxes!) nor can we even be sure to be “safe” (particularly when emotional safety is subjective) but we can strive and work towards being the best people and the best organisation that we can be. And these policies set out how we are doing that.

Policy Overview

There are 4 main policies underpinning Sacred Circle Training Co. CIC and they are as follows;

·         Data Protection

·         Safeguarding

·         Equality and Inclusion

·         Health and Safety (Risk Assessment)

Data Protection Policy Statement: GDPR Compliance

Sacred Circle Training Co. CIC only gathers personal data for the purposes of communications on matters relating to our business from people who sign up to do our training; or express interest in our training. We keep a simple list of data in password secure folder on a personal computer also password protected; the relevance of that data will be reviewed twice yearly and if not currently relevant to business will be deleted.

The only storage of data is in the form of name, address, phone and email contact lists and may be stored in the Gmail contacts lists or on the Employees/Directors’ mobile phones; or in a secure spreadsheet. The computers and mobiles we use are not shared, they are code/password protected as is our email account.

We undertake not to collect any more data than is necessary; to only use the data for the purpose for which we collect it (communications) and we will not use it for other purposes and never will we share personal data with a third party.

If we collect names and contact details of people who attend workshops and trainings on paper then these details will be transferred to Gmail and the paper shredded.

We do receive, as part of our application process, an individual’s religious or spiritual views which is one of the areas considered “sensitive” information by GDPR. The emails that applicants send to us are only seen by Alexandra Wilson and need only be kept for the duration of that individuals 12 months training period. The emails are saved to a folder and reviewed regularly to ensure anything over 12 months is purged.

At any time any one can ask us what data we have for them and we will respond as soon as is reasonably possible; definitely within a week. This policy sets out the parameters of what we gather and why but we will issue a statement to the individual of what we hold on them and how securely.

At any time any one can ask that their personal data is deleted from our records and we will act immediately to do so.

The Sacred Circle EOL Doula prep courses will be rolled out within the EU from 2019 and beyond from 2020. Sacred Circle Training Co. CIC will retain the responsibility for ensuring that any data collected is held securely; we will ask any individual or organisation that we work with to ensure that they comply with GDPR (if within EU) and when we travel further afield we will retain control of the data and any third party assisting us on the ground will not have access to it unless they become an employee or associate of Sacred Circle Training Co. CIC and in which case they would be subject to our policies.

The following statement will be issued with any request for data (name, contact details, religious/spiritual beliefs):

“Red Tent End of Life Doula Preparation is the delivery name of Sacred Circle Training Co. CIC and we gather basic personal data from each of our students for the purpose of communication. We store this data in Gmail contact lists and in an excel sheet; these are secure and no one but us has access to them. We will never share your data with anyone else. We will keep your data for the duration of your training with us (12 months) after which time your application email will be deleted and you will be asked whether you wish to remain on our contacts and mailing lists. You can request from us at any time details of what data we hold and you can also ask at any time for us to delete it and we will do so.”


The directors of Sacred Circle Training Co. CIC recognise their legal responsibility with regards to safeguarding vulnerable adults and children and young people. As a Community Interest Company we are not a statutory body which means that in the event of a disclosure of abuse our first course of action is to report what we know to a statutory body such as the police, the person’s GP, Social Services or (in the case of minors) their educational establishment.

As a training establishment our safeguarding response is two-fold. Firstly, in working with our students we must ensure we do no harm and we need to know what to do in the event of a disclosure of abuse; we also need to remember what the definition of vulnerable is as almost all of our students will not fall under the legal definition of a “vulnerable adult”; and we also remain conscious that the nature of this work and enquiry takes people to a vulnerable place.
Secondly, we are preparing people to work with potentially vulnerable people. So safeguarding must form part of our discussion around how to act and behave in people’s homes and with vulnerable people. Our students need to be prepared with the knowledge of what to do should they encounter abusive situations in the course of their work. Our Doulas must also safeguard their own wellbeing.

The definition of a vulnerable person by law is someone who lacks capacity to advocate for themselves. Just because someone appears “vulnerable” to us doesn’t mean that they are vulnerable by law. The definition of “abuse” is any action direct or indirect which causes harm; this can be physical, mental/psychological, financial, emotional, sexual or spiritual. The essence of an abusive situation is an imbalance of power; the abuser is wielding and/or taking power.

So in the first instance, in the course of our training, while we recognise the inherent rank that comes from our position as trainers, we also strive to empower our students and community to take full responsibility for themselves. We in turn, equally take full responsibility for ourselves. We undertake never to abuse our student body or community by removing their agency; and we will never neglect a member of our community who needs support. This is our promise to all who come to this work.

If during the training weekend, or over the course of the 12 months, any member of Sacred Circle received a disclosure of abuse we will take the following action;

● We will write down everything that we have been told
● We will encourage the person making the disclosure to also write down everything
● We will remind them that we are obliged by law to share reports of harm with a statutory body
● Since they are likely an adult with full capacity we will in the first instance encourage them to make the report
● If they are unwilling or unable we will act to do so ourselves, probably to the local police
● The Directors of Sacred Circle will provide additional support to that person

Regarding our counsel to our students regarding safeguarding in their private practice we will cover this topic as part of the training and there is also ongoing discussions about the topic in our student and community forum. We also now work internationally so our Doulas need to familiarise themselves with the law of their country and good safeguarding practice. Each Doulas is different. Some may work for organisations like hospices or social services and therefore find themselves subject to those safeguarding procedures.
For those that work alone in their local community before they start practicing they need to assess the risks and have a plan in place both to protect themselves and to protect their clients. An essential tool for clarifying the scope of the doulas role is the initial contact and contract with each new client. The contract must set out what that Doula will do in the event of a disclosure of abuse, or in the event of them witnessing abuse. If the law is broken our Doulas will go to the police. If our Doulas have concerns about welfare they will write to the clients GP. It is part of our code of conduct that our Doulas will never take the power or agency of their client; they couldn’t do that and still call themselves a Doula.

Equality and Inclusion

It seems to be a signature of this work (unplanned for and unforeseen) that the very nature of sitting with death and dying has blown open the topic of Equality and Inclusion such that this policy simply cannot look like a standard Equality and Inclusion Policy.

One of the important side benefits of our sacred circle work is that we are healing the toxic void at the heart of “white” Europe. This work addresses the spiritual hunger that led our white European ancestors to travel hungry into other cultures and consume without conscience. Many of us who come to this work have an impressive CV of culturally appropriated spiritual qualifications but the last question to be answered for many of us is “What does my land and my ancestry have to teach me?”. What started as an enquiry into death and dying has led us into political territory, our primary goal here is to decolonize the narrative around death and despite a background in Equality and Inclusion (Alexandra) it has become apparent to her that the very notion of inclusion is woven through with white supremacy.

Inclusion in what, exactly?
If we strive to be “inclusive” we will by the very action become exclusive. The diversity of an organisation is a measure of its “inclusivity”. The beauty of the training package is that is can be gifted to different facilitators and adapted by them both to their language and their culture, so rather than seeking to “include” we are open to inspire and surrendered as to where the work ends up.

The Work is slowly healing the spiritual deficit of “white” Europe and at the same time can be translated and adapted to meet all and any cultural requirements. The dominant cultural narrative around death and dying, borne of patriarchy, is that death is to be feared and avoided. By reclaiming death as a community event, thawing it of its clinical medical constraints we are championing a return to a feminine, cyclical, authentic response to life and death. Thus this Work with death and dying is a feminist act (regardless of the gender of the people we work with). Moreover the conventional view that End of Life Doulas sit by hospice beds is also a byproduct of white supremacy; if End of Life Doulas believe in a good death for all then we have to recognise that only the very privileged get to die of old age in their beds. Since we believe in a good death for all we are drawn again into the political domain, since black people are disproportionately dying by violence, war, displacement, hunger, poverty; young men die disproportionately of suicide and in sudden and violent deaths on our roads, in street violence or fighting wars, it becomes incumbent upon us to show up and champion a good death not just for the few but for everyone.
What unites us all as human beings is the experience of grief, by educating our End of Life Doulas to be the griefkeepers of their community we are opening a truly inclusive space (beyond words) where all of humanity can find solace in an understanding of, and release of stagnant grief.

How does Sacred Circle Training Co. CIC ensure that we are not discriminating in our practice?
● We consider anti oppression to be our active responsibility
● We offer bursaries to marginalized groups
● We are tackling the root cause of Eurocentric oppressive practices
● We accept that we are emerging from a dominant culture of oppression
● We understand, therefore, there are gaps in our awareness around oppression
● We undertake to receive without defence, feedback if we are being discriminatory
● We do not believe it is the job of the oppressed to educate us
● We are committed to ongoing self-education and growth around tackling white supremacy, racism, oppressive practice from within
● We will “call in” any discriminatory language we encounter within our student community (to “call in” is similar to “calling out” except it means we take time and compassion to explain gently to someone how they might reframe what they say in a more equitable way)
● In the event of a complaint against a member of our community the directors will support that person to undergo education on anti oppression practice

Sacred Circle Training Co. CIC actively celebrates diversity as a strength. We meet every individual in their uniqueness and offer the training programme in many different media and we commit to meeting the needs of our students, to the best of our ability, conscious of and working with, curious about and in celebration of their ability, background, race, religion, age, gender, sexuality and socio-economic status.

Health & Safety (Risk Management)