The potential implications of the accreditation of the Society of Homeopaths (SoH) as a voluntary register by the Professional Standards Authority (PSA) were discussed in a previous post. As discussed in the last post, the Advertising Standards Authority (ASA) did rule against Teddington Homeopathy's promotion of CEASE Therapy. Teddington Homeopathy chose not to comply.
This ruling does set a precedent and one that the SoH would do well to take notice of. As another previous post pointed out some members of the SoH do have a problem with the ASA. The SoH deleted the news item that it was associated with but it can be found here. The reason for its deletion is unknown.
Mark Taylor, Chief Executive of the SoH has made some bullish remarks whilst not quite understanding the PSA requirements for a voluntary register.
ASA Ruling on Teddington Homeopathy
It is worth examining the ruling in some detail.
The complainant challenged whether:The ASA tend to consider only a few number of items in a complaint. It must be understood that it does not necessarily mean that the rest of the advertising is compliant. Generally only the most serious items are considered.
1. the claims that CEASE therapy could treat autism were misleading and could be substantiated; and
2. the ad discouraged essential treatment for autism, a condition for which medical supervision should be sought.
Teddington Homeopathy stated that the page correctly referenced the clinical work of a medical doctor and contained no claims. They stated that in clinical practice Dr Smits found CEASE to be of benefit to individuals suffering from autism and other conditions on the autistic spectrum, and that this was substantiated by his patient records. They stated that the text was not an advertisement or form of marketing, but was intended to provide the general public with correct information about different healthcare options. They removed the testimonial and the section regarding removal of toxins.There is a failure to understand that text forms part of a website that is designed to promote goods and services is de facto marketing. The anecdotes of Smits do not constitute substantiation. As shown in the last post, there are serious reasons to believe that information on CEASE therapy is not correct.
1. & 2. Upheld
The ASA acknowledged that the web page included information about the history of CEASE therapy. However, we noted that the advertiser provided the therapy in question and considered that the page constituted marketing for the purposes of the CAP Code. The page also contained references to Tinus Smits' experiences with "helping" patients with autism as well as other references to the benefits of CEASE therapy for autism, including material within the testimonial. We considered that visitors to the website would understand the claims in the testimonial as factual, regardless of the disclaimer, and that the claims within the testimonial would therefore be understood as relating to the objective benefits of CEASE therapy. We therefore considered that the ad made claims for the efficacy of CEASE therapy in treating autism.
We welcomed Teddington Homeopathy's decision to remove the testimonial and other material from the page, but considered that the information about Tinus Smits and the URLs still implied a benefit for homeopathy and CEASE therapy for autism, and that the intention of CEASE therapy was to treat autism. Although advertisers may provide information about the history of a therapy, care should be taken not to make unsupported claims for the treatment when describing this background. The Code also stated that marketers must not discourage essential treatment for conditions for which medical supervision should be sought, and that this included offering specific advice on, or treatment for, such conditions unless that advice or treatment was conducted under the supervision of a suitably qualified health professional. We considered that autism was a condition for which medical supervision should be sought. In the absence of evidence to demonstrate that CEASE therapy could treat autism and that any treatment was carried out by a suitably qualified healthcare professional, we concluded that the ad was misleading and breached the Code.The concept that linked to websites can be considered to create an implication for marketing purposes is important. The ASA do not recognise UK lay homeopaths as suitably qualified health professionals despite what some might think. That is because UK law does not.
The Blue Guide is produced by the Medicines and Healthcare product Regulatory Agency (MHRA). It is a guide to advertising of medicines and, to a degree, medical services. It represents an understanding of medicines legislation and regulations. The SoH Code of Ethics now includes Blue Guide compliance as a requirement for members in addition to the CAP Codes. Bear in mind that whilst the ASA may refer non-compliant advertisers to Trading Standards on the basis of the provision in consumer law that it is illegal to -
17. Falsely claiming that a product is able to cure illnesses, dysfunction or malformations.The MHRA don't have to. They can mount prosecutions themselves. The Blue Guide states -
5. Advertising homeopathy services Homeopathic practitioners may promote the service they provide for the public, e.g. the availability of a homeopathic consultation service. Details of products in any advertising must be limited to those licensed by the MHRA and must comply with the requirements set out in section 4 above.
These restrictions apply equally to advertising on the internet. Product information, including sales material and any online purchase facility, may only be provided for licensed products.Mention of unlicensed products is problematic to say the least.
Society of Homeopaths Position Statement
The SoH made a statement about vaccination, if couched in weasel words but the core of it is -
Currently there is no homeopathic alternative to vaccination or anti-malarial drugs which has been proven beyond doubt to be clinically effective. It is therefore unethical for a homeopath to advise a patient against the use of conventional vaccines or anti-malarial drugs.As the CEASE Therapy website states that "Autistic children should never again be vaccinated!" and the question of linkage was established above, the SoH should at least be aware of the implications of linkage if nothing else. Linking to anti-vaccination websites could be considered advice. Pretending a false balance that the risks of vaccination are somehow equivalent to the risk of death or harm from preventable diseases is a distortion.
No UK lay homeopath has the competence to treat ASD. They can treat people with ASD for minor self-limited conditions but beyond that, nothing. The CEASE therapy training course, given its concentration on debunked theories about the causes of ASD does not make a lay homeopath competent. Nor is anyone who uses it.
Society of Homeopaths Members "treating" ASD
This is by no means an exhaustive list. Examining each website in forensic detail for breaches of legislation and regulations would be time consuming and result in a massive document hence only a few aspects of each website will be examined. Also, depending on when this is read, the websites may have been amended.
Mike Andrews was mentioned in the last post. It makes many dubious claims. Most unfortunate of all, the blog on his website states -
This has been a delightful case and profound changes have taken place over the last four months, what other therapy for Autism Spectrum Disorder could achieve so much in such a short time.As the blog is part of his website promoting his services, it is considered advertising.
Jonathan Stallick does not say anything specific about autism but this from his website is problematic.
Len Marlow seems to get about. Practises in Greenwich and the Midlands and is a "clinical" supervisor for the College of Practical Homeopathy. Here he talks about DPT vaccination as a cause of autism. The SoH position on vaccination applies.
Ursula Kraus-Harper makes the statement on her website -
Please note that because I treat many children who are on the autism spectrum and talk about vaccination, I am constantly under attack from some people who will have to consult their own conscience as to why they do this. On the Internet you will find several links to articles about me, claiming all manner of things. If you have any concerns or doubts, please phone me.Kraus-Harper is one of those homeopaths who inspired the SoH to seek legal advice on the domain of the ASA which the SoH removed as a news item as seen above. The page on her website that relates to vaccination could be interpreted, in terms of linkage and false balance as in breach of the SoH statement above.
Kraus-Harper has a page where she discusses treating ASD which links to the CEASE therapy website. It is full of unsubstantiated claims and offers no evidence of competency to treat ASD. Quite the reverse. There is considerable irony in the above quote.
Clare McGennon claims to be a CEASE therapist and links to the CEASE therapy website. Her list of conditions seen is also problematic but that might be due to not understanding SoH guidance.
Clare Allsop claims to be a CEASE therapist and links to the CEASE therapy website.
Julia Lockwood claims to be "qualified to treat people with persistent and deep-rooted chronic conditions using CEASE" and links to the CEASE therapy website.
Gill Upham claims to be a CEASE therapist and links to the CEASE therapy website.
Merran Sell unlike most of the other homeopaths listed here has a background in special education and is a Special Educational Needs Co-ordinator. She states -
I have worked with autistic, Asperger’s, ADD and ADHD children for over 20 years as a special education needs teacher, in specialist schools and as a Special Education Needs Coordinator in a mainstream junior school. During this time I have also worked with these children in my homeopathic clinic.Hopefully she does not see the same children in her clinic. There is a potential conflict of interest, especially if money is changing hands.
Renata Wild claims to be a CEASE therapist but does not to the CEASE therapy website.
Gill Marshall does not make the wild claims that others do and has done voluntary work with autistic children. If it were not for the use of homeopathy this would seem quite sensible.
Emma McGuire's entry on Yell is unfortunate in that it contains a blank list of conditions.
Lucinda Torabi is another of the homeopaths who demanded the SoH take legal advice on the status of the ASA. Unsurprisingly, much of the content of her website would appear to be in breach of the CAP Codes and guidance on advertising. Her page on ASD links to the CEASE therapy website.
Donna Draper offers more than just homeopathy. SCENAR is basically a glorified TENS machine although all sorts of bonkers claims are made for it. The Asyra device is also bonkers and the claims made for it are extraordinary. The section on CEASE therapy is very problematic and links to the CEASE therapy website.
Penelope Harrington claims to be a CEASE therapist but does not link to the CEASE therapy website.
Cathryn Brooks claims to be a CEASE therapist but does not link to the CEASE therapy website.
Jennifer Hautman has had dealings with the ASA and has attracted the attention of other bloggers. It is very strange to read her blog post on the subject - it would appear to be a storm in a tea cup and the initial complaint is odd that it only focuses on one issue. Her website is not compliant with the CAP Codes in many areas but the SoH may not be aware of this. It would seem very likely from her pronouncements on her own website and other places that Hautman has no intention of complying.
The information on vaccination is likely in violation of the SoH position. It is not clear whether Hautman treats those with ASD but the information presented is problematic.
Jacquie Haylett claims to be a CEASE therapist but does not link to the CEASE therapy website.
Suzie Reye-Nichols claims to be a CEASE therapist and links to the CEASE therapy website.
Candice Francis Joyce doesn't make any claims but this item is interesting as it mentions homeopathic secretin.
Samantha Pereira claims to be a CEASE therapist but does not link to the CEASE therapy website.
Niki McGlynn claims to be a CEASE therapist and links to the CEASE therapy website.
Margaret Kincade claims to be a CEASE therapist but does not link to the CEASE therapy website.
Rebecca Maunder has this
on her website. Blank lists of conditions can be interpreted in several different ways.
Nick Cripps does mention any particular method but this testimonial is problematic.
Mary English makes a great deal out of Indigo Children. It is just plain odd. If you aren't familiar with the concept it is New Age nonsense.
Karenza Grant claims to have treated autism.
Elaine Watson claims to be a CEASE therapist but does not link to the CEASE therapy website.
There is little point in raising complaints with the SoH. Their complaints process allows them to dismiss "vexatious" complaints. Whilst they do have a poor history of responding to public (media) concerns about their members, placing concerns into the public domain is more likely to result in action than direct complaint.
All of the information above is in the public domain. There is nothing confidential about it. There are no privacy concerns. Pointing that this information exists can not be construed harassment or defamatory.
What others choose to do with this information is a moot point but is suggested the problems lie more with the SoH than the individuals named. Harassment of individuals is not condoned.