1. Purpose

This policy sets out how privacy and confidentiality are maintained when clinical supervision is undertaken as part of counselling services. It aims to protect clients’ personal information, support ethical counselling practice, and ensure that information shared during supervision is handled securely and appropriately.

Clinical supervision is an essential part of safe and effective counselling practice. It enables counsellors to reflect on their work, maintain professional standards, identify risks, and improve outcomes for clients.

2. Scope

This policy applies to all counsellors, psychotherapists, clinical supervisors, trainees, placement students and relevant staff involved in providing or overseeing counselling services.

It covers information shared verbally, in writing, electronically, during online supervision, and through supervision notes or case presentations.

3. Principles of confidentiality

All individuals involved in clinical supervision must:

• Respect clients’ privacy, dignity and right to confidentiality.
• Share client information only where necessary for supervision, care, safeguarding or another lawful purpose.
• Use anonymised information wherever reasonably practicable.
• Protect personal and sensitive information from unauthorised access, disclosure, loss or misuse.
• Explain the limits of confidentiality to clients before counselling begins.
• Comply with applicable data protection legislation, professional ethical standards and organisational policies.

4. Sharing client information during supervision

Counsellors may discuss their clinical work with an appropriately qualified or competent supervisor to support safe, ethical and effective practice.

All client information must be anonymised. Names, addresses, contact details, workplaces and other identifying information should not be disclosed unless necessary and appropriately justified.

Supervision discussions should be limited to information relevant to the clinical issue being considered.

Supervisors must maintain confidentiality and must not disclose information obtained through supervision to unauthorised individuals.

Where supervision is provided within an organisation, the roles of the clinical supervisor, line manager and safeguarding lead must be clearly defined. Information should not automatically be shared with management simply because supervision has taken place.

5. Client information and informed consent

Clients will be informed at the beginning of counselling that their work may be discussed in clinical supervision.

They will be advised that supervision supports the quality, safety and ethical delivery of the service, and that confidentiality may have legal, professional or safeguarding limitations.

Where identifiable client information needs to be shared beyond routine, appropriately anonymised supervision, the counsellor must consider whether consent is required or whether another lawful and ethically justified basis applies.

Clients will be given clear information about how their personal data is used, who may access it, how it is stored and their applicable data protection rights.

6. Exceptions to confidentiality

Confidentiality may need to be limited where there is an appropriate legal, safeguarding or ethical justification, including:

• A serious and credible risk of harm to the client or another person.
• Concerns about the abuse, neglect or exploitation of a child or an adult at risk.
• A legal obligation or valid court order requiring disclosure.
• Another disclosure that is permitted or required by applicable law.
• A serious professional or clinical concern requiring appropriate action to protect a client or others.

Where disclosure is being considered, the counsellor should consult their supervisor or designated safeguarding lead where practicable and appropriate.

Any disclosure must be necessary, proportionate and limited to the information required for the relevant purpose. The decision, rationale, information disclosed and recipient must be documented securely.

Where safe and appropriate, the client should be informed about the disclosure. This may not be appropriate where doing so could increase risk, compromise a safeguarding response or conflict with legal requirements.

7. Supervision records and documentation

Supervision records must be accurate, proportionate, relevant and securely maintained.

Records should generally document the key issues discussed, professional reflections, decisions, risk assessments and agreed actions. They should avoid unnecessary identifying details about clients.

Supervision records must be stored separately from general clinical records where appropriate, with access restricted to authorised individuals.

Records must not be retained longer than necessary under the applicable retention schedule, legal obligations, professional requirements and organisational policy.

8. Data security and storage

All client-related and supervision information must be protected through appropriate security measures, including:

• Password-protected devices and systems.
• Secure electronic storage and encrypted transmission where appropriate.
• Locked storage for physical records.
• Restricted access on a need-to-know basis.
• Secure disposal of paper and electronic records.
• Appropriate confidentiality safeguards when using remote supervision platforms.

Client information must not be discussed in public places or shared through unauthorised messaging services, personal email accounts or insecure storage systems.

9. Online and remote supervision

Remote supervision must take place in a private environment where conversations cannot reasonably be overheard by unauthorised individuals.

Supervisors and counsellors must use suitable communication platforms and take reasonable steps to protect confidentiality, including securing devices, preventing unauthorised access and avoiding the use of shared or public equipment.

Recording supervision sessions is not permitted unless there is an agreed, lawful and appropriate purpose, with the necessary consent, safeguards and retention arrangements in place.

10. Confidentiality responsibilities

Counsellors and supervisees are responsible for presenting cases appropriately, protecting client identities and raising clinical or safeguarding concerns.

Clinical supervisors are responsible for maintaining confidentiality, handling information securely, supporting ethical decision-making and clarifying the limits of confidentiality.

The organisation or practice owner is responsible for implementing appropriate policies, access controls, staff guidance and data protection procedures.

All relevant individuals must undertake appropriate training and report suspected confidentiality breaches promptly.

11. Data breaches and complaints

Any suspected loss, unauthorised access, accidental disclosure or other breach involving client or supervision information must be reported promptly in accordance with the organisation’s data breach procedure.

The incident must be assessed, documented and addressed appropriately. Where legally required, the relevant supervisory, regulatory or data protection authority must be notified within the applicable timeframe, and affected individuals must be informed where required.

Clients may raise concerns about privacy or confidentiality through the organisation’s complaints procedure. All complaints will be handled sensitively and without inappropriate disclosure of further personal information.

12. Compliance and review

This policy will be reviewed at least annually, or sooner if there are changes to legislation, professional guidance, organisational arrangements or identified risks.

All staff and practitioners covered by this policy are expected to understand and follow its requirements.

Authorised by: Joanne Gibson
Date: 28/10/2026