Does BACP have guidance on AI therapy notes?

BACP hasn't published specific guidance on AI clinical notes (it has surveyed members about AI). Its Ethical Framework still applies: be open with clients about the tools you use, keep accurate records you've reviewed, and protect confidentiality.

What does BACP say about note-keeping?

BACP expects members to keep adequate, accurate records, store them securely and handle them lawfully. There is no statutory retention period: BACP says private practitioners may keep notes for a minimum of three years after therapy ends. Notes should be written in a way you would be comfortable sharing with the client on request.

Is using AI for therapy notes against BACP ethics?

No. BACP does not prohibit AI-assisted note-writing. To stay within the Ethical Framework, tell clients you use it, review every AI-drafted note for accuracy, and use a tool that is open about where it stores and processes data and signs a DPA.

How long should UK therapists keep therapy notes?

There is no single legal figure. BACP says private practitioners may keep notes for a minimum of three years after therapy ends; BPC guidance gives six years as typical. Many practitioners keep adult records for six or seven years to cover the limitation period for claims. Check what your insurer expects and state your period in your privacy notice.

What should BACP-registered therapists include in therapy notes?

Good clinical notes typically include: date and duration of session, presenting issues and the client's reported experience, your clinical observations, assessment and formulation, interventions used, the client's response, risk assessment if applicable, and the plan for next session. SOAP, DAP and BIRP formats all capture these elements in structured form.

Can I share AI-drafted notes with clients?

Clients have a right to access their personal data under UK GDPR, including clinical notes. AI-drafted notes that you have reviewed and approved are part of the clinical record and are covered by subject access requests like any other record. Write notes in a way that you would be comfortable sharing with a client.

BACP and AI Therapy Notes: What UK Therapists Need to Know

As AI note tools become common in UK private practice, many BACP-registered counsellors and psychotherapists have the same questions: what does BACP say about using AI for notes? Is it acceptable under the Ethical Framework? What record keeping expectations do I need to meet? And how do I judge whether a tool is safe to use?

This guide answers those questions, drawing on BACP's published materials and UK GDPR.

BACP's position on AI in therapy

BACP hasn't published specific guidance on AI clinical notes (it has surveyed members about AI). It does not prohibit AI tools. Its Ethical Framework still applies, and three of its themes matter most here:

Transparency: be open with clients about how you work, including the tools you use
Confidentiality: protect client information, which in practice means handling it lawfully under UK GDPR
Responsibility: you, not the AI, are responsible for the accuracy and quality of your clinical records

Using AI to help with note-writing is not against the Ethical Framework. In principle it is like using a word processor instead of a pen: what matters is whether the notes accurately reflect the session and are stored lawfully.

Record keeping expectations

BACP's Good Practice in Action resources cover record keeping in detail. Well-kept notes should:

Be factual, accurate, and written in a professional style
Record the date, time, and duration of each session
Document the client's presenting issues and reported experience
Record your clinical observations and assessment
Note any risk factors and your response to them
Record the therapeutic interventions used
Note any significant decisions or changes in the therapeutic relationship
Be written with the understanding that the client may ask to see them

SOAP, DAP and BIRP formats can all capture these elements. SOAP is widely used, and BACP doesn't require any particular format.

How long to keep therapy notes

There is no statutory retention period for private counselling records. BACP says private practitioners may keep notes for a minimum of three years from when therapy ended, reflecting its three-year complaints window. BPC guidance gives six years after treatment ends as typical, subject to UK GDPR. Many practitioners keep adult records for six or seven years to cover the limitation period for claims. Records for clients who were children need separate thought, and your insurer may expect longer, so check your policy. Our guide to keeping therapy notes goes into more detail.

Some key points on record retention:

Notes should be stored securely for the full retention period
You should have a documented process for destroying records after the retention period
Clients can make a subject access request at any time while you hold their records
If you use a cloud-based system or AI tool, make sure it can keep data for your chosen period and that you can export your notes if you switch providers

Using AI tools in line with the Ethical Framework

There is a careful way and a careless way to use AI for therapy notes.

What to do

Use a tool that tells you where data is stored and processed, signs a DPA, and is ICO registered
Read and accept the tool's Data Processing Agreement
Update your privacy notice to mention the tool, and any processing outside the UK
Review every AI-drafted note before filing it as part of the clinical record
Edit anything that is inaccurate, misleading, or not in your clinical voice
Mention AI-assisted notes in your therapeutic contract

What to avoid

Using a tool with no DPA or no clear answer on where data goes
Recording sessions without the client's explicit agreement beforehand
Filing AI-drafted notes without reviewing them for clinical accuracy
Using a tool that keeps client audio recordings indefinitely
Using tools that are not open about their data processing

UK GDPR obligations for therapists using AI

BACP membership doesn't replace UK GDPR; the two sit side by side. As a therapist who holds client records, you should:

Pay the ICO data protection fee: £52 a year for most sole practitioners, or £47 by direct debit. Most therapists in private practice need to pay it if they hold client records electronically.
Have a Data Processing Agreement with any third-party tool that processes client data on your behalf.
Keep a record of your processing: what personal data you hold, why, and for how long.
Have a clear privacy notice that explains your data processing in plain language, including how clients can complain to you.
Be able to respond to subject access requests within one month (extendable by two months for complex requests). AI-drafted notes that you have approved are included.

How NoteSono fits

NoteSono was built in the UK with practising therapists, for UK private practice:

Notes stored in the EU; some AI processing uses providers outside the UK and EU under data processing terms that exclude training on your data
ICO registered: registration number ZC045529
No session recording: you summarise after the client leaves
Data Processing Agreement provided to all users
A client consent template included
Notes reviewed and approved by you before filing: the AI drafts, you are responsible for the final record
20 clinical note formats, including SOAP, DAP, BIRP, GIRP, Narrative, Intake, Discharge, Risk, Supervision, CBT, EMDR, Person-Centred, Psychodynamic, Couples, Family and Group
Start free — 5 notes a month, no card, no time limit — with a 7-day trial of everything whenever you want it. Essentials, with unlimited notes and all 20 formats, is £14.99/month

The Supervision format is available on Essentials and Pro, for therapists who want help with their supervision records as well as client notes.

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