Location: London / [practising location to be confirmed]
Final determination: 18 December 2019
BPC case reference: COM02-19
BPC Registration No.: 17051
Registrant: Christopher Perryer
Sanction: Termination of Registration and removal from the BPC Register
Institution: [confirm separately — not clearly identified as Perryer’s institution in the determination]
Source: BPC Fitness to Practise Determination
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Case Summary
Christopher Perryer was found to have engaged in serious professional misconduct arising from a sexual relationship with a patient following breaches of therapeutic boundaries.
Perryer had treated Patient A from approximately September 2009 until October or November 2012. The findings included failures to manage Patient A’s erotic transference, sexualised boundary breaches while she remained his patient, and the commencement of a sexual relationship in or around October 2012.
The Panel also found conduct intended to conceal the fact that Perryer had been Patient A’s therapist, conduct encouraging Patient A to divorce her husband, and conduct motivated in part by financial or personal gain.
His fitness to practise was found impaired and his registration was terminated.
Risk Findings
The determination records:
- Patient A was a vulnerable patient;
- Perryer’s conduct was at the highest end of the spectrum of misconduct;
- Patient A was harmed;
- the therapist/patient relationship involved a serious breach of trust and professional boundaries;
- conduct associated with the therapeutic relationship was sexually motivated;
- Perryer sought to conceal the fact that he had been Patient A’s therapist;
- the Panel found conduct motivated in part by financial or personal gain;
- Perryer had limited insight into the impact of his conduct;
- remediation was limited;
- he failed to disclose the relationship to his supervisor until June 2019;
- the Panel could not exclude recurrence and found there was a real chance of repetition.
BPC Outcome
Termination of Registration and removal from the BPC Register.
The Panel concluded that lesser sanctions, including admonishment, conditions or restrictions on training, teaching or supervision, would not adequately address the risk.
It determined that removal from the Register was the only available sanction sufficient to address the serious misconduct and protect the public and the profession.
Wider Public Protection Question
The determination identifies a vulnerable patient, serious sexual boundary misconduct, harm, financial or personal benefit, concealment, limited insight and a real chance of repetition.
The Panel expressly considered protection of the public when determining sanction.
The wider question is:
What safeguarding or external public-protection action, if any, was considered or undertaken in response to those findings, in addition to terminating Perryer’s BPC registration?
Determination Gap
The determination does not clearly evidence:
- police referral;
- safeguarding referral;
- referral to another statutory or professional body;
- structured third-party escalation arising from the findings of harm, vulnerability and risk of repetition.
The determination therefore establishes the disciplinary outcome — removal from the BPC Register — but does not itself establish whether wider safeguarding or public-protection mechanisms were activated.
Cross-Case Context
- In Rushton (COM17-24), serious sexual misconduct and a real risk of repetition resulted in withdrawal of registration, without clear evidence in the determination of wider safeguarding escalation.
- In French (COM11-24), sexualised misconduct involving a vulnerable patient, harm and a high risk of repetition similarly resulted in withdrawal of registration, without clear evidence in the determination of third-party safeguarding or police referral.
- In West (COM04-22), serious boundary breaches were found but the practitioner remained in practice, again without clear evidence in the determination of wider safeguarding action.
Perryer predates those cases but raises substantially the same issue.
Systemic Significance
Perryer is particularly significant because the Panel’s findings were explicit:
the patient was vulnerable; harm had occurred; the misconduct was at the highest end of the spectrum; insight and remediation were limited; and there was a real chance of repetition.
The BPC responded by terminating registration.
What the determination does not show is whether those findings also triggered safeguarding action outside the BPC disciplinary process.
Perryer therefore illustrates the same recurring regulatory question identified in the later cases:
Does removal from a professional register operate as the endpoint of regulatory action, or is serious misconduct involving vulnerability, harm and continuing risk also systematically escalated through wider safeguarding and public-protection mechanisms?