Escalation Pathway for Flagged Issues, Risks & Safeguarding Concerns
Recovery Trauma™ maintains a documented escalation pathway for reviewing and responding to flagged content, user reports, complaints, potential safeguarding concerns, privacy and compliance incidents, technical risks, and other significant platform issues. The pathway establishes clear decision points, responsibilities, documentation requirements, and circumstances in which external escalation may be appropriate. It forms part of the Recovery Trauma™ Compliance & Governance documentation.
Review: At least annually, and following significant regulatory, safeguarding, privacy, security, organisational, or platform changes.Next scheduled review: 13 September 2027Last updated: September 2026
Important boundary
This pathway relates to platform governance, moderation, safeguarding procedures, compliance, privacy, and risk management. It does not constitute clinical assessment, diagnosis, therapy, counselling, healthcare, crisis intervention, or emergency response.
Where a situation requires professional, emergency, regulatory, law-enforcement, or other specialist intervention beyond Recovery Trauma™'s role, the appropriate external service or authority should be considered in accordance with applicable law, policy, and the circumstances of the case.
The pathway at a glance
Report / flag received
Step 1
Platform Administrator review
Routine?
Resolve · record · close
Elevated risk?
Escalate to Step 2
Step 2
Founder & Product Compliance Lead review
Risk / governance decision
Moderation or account action
Policy or governance action
Technical action
External consultation or escalation
Document · follow up · close
1
Platform Administrator review
Owner: Platform Administrator — currently Jana Burkhardt
Jana Burkhardt currently performs the Platform Administrator role in addition to her separate role as Founder & Product Compliance Lead. The Platform Administrator provides the first operational review of reports and incidents arising through the platform.
Scope of review — this may include
Flagged community content
Reported posts or comments
User reports
User complaints
Potential policy violations
System or administrative alerts
Potential safeguarding concerns
Potential privacy concerns
Compliance-related incidents
Repeated harmful or inappropriate behaviour
Suspicious account activity
Administrative or operational issues
Decision A — resolve at Platform Administrator level
A matter may be resolved at this stage when it is routine and can appropriately be handled through established platform policies or procedures. Examples may include:
Routine moderation
Spam
Minor community-rule violations
Duplicate reports
Administrative issues
Account-support issues
Routine content-management matters
Technical issues requiring standard troubleshooting
Matters clearly covered by an existing moderation procedure
Required action, where appropriate
Take the necessary moderation or administrative action
Record significant actions
Inform the user where required
Document the outcome
Close the case when no further action is necessary
Decision B — escalate to Founder & Product Compliance Lead
Escalation is required where the issue involves, or may involve, one or more of the following:
Potential safeguarding concerns
Significant user-safety concerns
Threats of serious harm
Ethical concerns
Repeated or escalating harmful behaviour
Serious harassment or abuse
Significant community safety concerns
Policy uncertainty
Significant privacy concerns
Potential personal-data breaches
Compliance concerns
Significant security concerns
Illegal or potentially illegal content or activity
Situations requiring interpretation or amendment of platform policy
Elevated reputational or operational risk
Significant platform risk
A matter outside the Platform Administrator's routine authority
Escalate if one or more criteria are reasonably identified
2
Founder & Product Compliance Lead review
Owner: Jana Burkhardt — Founder & Product Compliance Lead
At present, Jana Burkhardt also performs the Platform Administrator role. Where an issue moves from Step 1 to Step 2, this therefore represents an escalation in governance level and decision-making responsibility, rather than necessarily a transfer to another individual.
Scope of review
Safeguarding-related platform concerns
Significant user-safety concerns
Trauma-informed platform considerations
Ethical concerns
Emerging risk patterns or trends
Repeated serious policy violations
Whether existing policies adequately address the situation
Significant privacy concerns
Potential personal-data breaches
GDPR-related risks
Compliance incidents
Policy exceptions
Significant security concerns
Serious community incidents
Potentially illegal activity or content
Significant operational risks
Significant reputational risks
Whether external specialist advice or escalation may be appropriate
3
Founder-level decision
Following review, the Founder & Product Compliance Lead determines the appropriate platform and governance response.
Close with no further action
Where the concern has been reviewed and no additional action is reasonably required.
Moderation or account action
Where appropriate under platform policies, this may include:
Content removal
Warning
Restriction of platform functionality
Community moderation action
Temporary suspension
Account suspension or termination where permitted under applicable Terms and policies
Policy or governance action
This may include:
Policy clarification
Policy amendment
Additional moderation guidance
Safeguarding procedure review
Compliance review
Additional platform controls
Admin guidance
Risk-register update
Additional monitoring where appropriate
Technical action
Where a platform feature or technical behaviour contributes to risk, appropriate technical remediation may be requested. This may include:
Access-control changes
Feature changes
Additional warnings
Reporting improvements
Security remediation
Privacy controls
Moderation controls
User-interface changes
External consultation or escalation
Where an issue cannot appropriately be managed solely within Recovery Trauma™, external consultation or escalation may be considered or required.
4 — External escalation / referral
Recovery Trauma™ is not an emergency, crisis, medical, mental-health treatment, or law-enforcement service. Certain situations may therefore require involvement of an appropriate external service, professional, authority, regulator, technology provider, or emergency service. Depending on the circumstances and applicable legal requirements, this may include:
Emergency services
Appropriate crisis services
Relevant safeguarding services or authorities
Law enforcement
Data-protection authorities
Legal advisers
Cybersecurity or technology providers
Relevant professional or regulatory bodies
Other competent authorities or specialist services
External escalation is considered based on the circumstances, applicable law, Recovery Trauma™ policies, privacy obligations, and the information reasonably available. Recovery Trauma™ does not attempt to perform clinical assessments or make clinical determinations outside its role.
5 — Immediate or serious risk
If information received through the platform reasonably indicates an immediate or serious risk — for example an apparent immediate danger to life or serious harm — the issue receives priority review rather than being handled through ordinary moderation timescales.
The platform's role is to
Recognise the potential seriousness of the report
Avoid attempting to provide therapy or clinical assessment
Provide or signpost appropriate emergency or crisis information where applicable
Preserve relevant records where appropriate and lawful
Consider whether external escalation is required or permitted
Follow applicable safeguarding, privacy, legal, and platform procedures
Recovery Trauma™ cannot promise that it will always identify an emergency or intervene in real time. The platform is not continuously monitored as an emergency service, and users must not rely on Recovery Trauma™ for urgent or emergency assistance. If you or someone else is in immediate danger, please contact your local emergency services or an appropriate crisis service.
6 — Privacy / personal-data incident route
Potential personal-data breaches or significant privacy incidents are escalated to the Founder & Product Compliance Lead for assessment under the relevant privacy and data-breach procedure. The review considers, where applicable:
Nature of the incident
Categories of data involved
Number or category of affected users
Potential consequences
Containment
Remediation
Documentation
User notification requirements
Regulatory notification requirements
Relevant statutory deadlines
Not every privacy incident requires regulatory notification. The applicable legal and privacy assessment determines whether notification to users or a supervisory authority is required, and within what deadlines.
7 — Technical / security incident route
Where the issue relates primarily to technical security or platform infrastructure, the Founder & Product Compliance Lead may escalate the technical component to the relevant technology or service provider. Examples may include:
Authentication problems
Unauthorised access concerns
Security vulnerabilities
Data exposure
Infrastructure incidents
Suspicious system behaviour
Access-control failures
Recovery Trauma™ remains responsible for making its own governance, compliance, privacy, and operational decisions while relevant technology providers address matters within their respective technical responsibilities.
8 — Therapist-related concern
A complaint or concern regarding a therapist listed in the Recovery Trauma™ directory may trigger:
Administrative review
Verification of directory information
Review against Recovery Trauma™ directory requirements
Temporary restriction or removal from the directory where appropriate under platform terms
Request for additional documentation
Escalation under the governance pathway
Signposting to an appropriate professional or regulatory complaint route where relevant
Wichtig
Recovery Trauma™ does not conduct clinical investigations and does not substitute itself for a therapist's professional regulator, licensing body, insurer, employer, or relevant legal authority. Directory administration is an administrative process and is not clinical supervision. Independent therapists remain responsible for their own professional and clinical practice.
9 — Community-related concern
Routine moderation
Spam
Inappropriate language
Duplicate content
Ordinary rule violations
Higher-risk safeguarding / governance escalation
Credible threats
Serious harassment
Exploitation
Dangerous behaviour
Serious safeguarding concerns
Repeated targeted abuse
Potential illegal activity
Significant privacy violations
Higher-risk matters move into the escalation pathway above rather than being closed as routine moderation.
10 — Documentation requirements
For significant or escalated matters, appropriate information is recorded, including:
Date and time reported or identified
Type or category of concern
Source of report where appropriate
Role responsible for initial review
Whether the matter was escalated
Reason for escalation
Decisions made
Actions taken
Relevant policy or procedure used
External consultation or escalation where applicable
Follow-up actions
Closure status
Review outcome
Only information that is appropriate and necessary for the relevant governance, safeguarding, legal, security, privacy, or compliance purpose is collected and retained. Records are handled according to applicable privacy, security, retention, and access-control requirements.
11 — Audit trail
For significant cases, the admin system supports an audit trail so that the following sequence can be determined:
Confidential internal case information is not exposed to ordinary members. Access is restricted to authorised administrator accounts.
12 — Current organisational structure
Recovery Trauma™ is currently founder-led. Jana Burkhardt presently performs both the Platform Administrator and Founder & Product Compliance Lead roles.
These roles remain separately documented because they represent different levels of responsibility within the governance process. An escalation from Platform Administrator to Founder & Product Compliance Lead therefore represents an escalation in decision-making authority and governance review, even where the same individual currently performs both roles.
As Recovery Trauma™ grows, these responsibilities may be delegated to additional authorised personnel and the pathway will be reviewed accordingly.
13 — Compliance purpose
This Escalation Pathway establishes how Recovery Trauma™ identifies, reviews, escalates, documents, and closes significant platform concerns. It supports consistent decision-making, accountability, safeguarding procedures, privacy management, risk management, and audit readiness.
It should be read alongside Recovery Trauma™'s:
Leadership & Governance documentation
Safeguarding Framework
Datenschutzerklärung
Data-breach procedures
Terms
Haftungsausschluss
Community-Richtlinien
Therapist Directory requirements
Security documentation
Compliance documentation
The pathway governs Recovery Trauma™ platform decisions and does not create a clinical, therapeutic, medical, or emergency-response service.
