BACP and AI Clinical Notes: What the Ethical Framework Means in Practice

AI tools for clinical note writing are becoming common in private practice. With that come fair questions from BACP members: what does BACP actually say about this? Am I allowed to use AI? What do I need to tell clients? Could I face a complaint?

This guide sets out where BACP stands and what you practically need to do to use AI note-writing tools in a way that fits its Ethical Framework.

BACP's position on AI in therapy practice

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 for the Counselling Professions still applies, and it asks you to put clients first, be honest and open with them, keep adequate records and protect confidentiality. Applied to AI note-writing tools, that suggests:

• Clients should know that you use AI assistance for documentation
• Clients should be able to ask questions, and to ask you not to use it for their notes
• You keep professional responsibility for the accuracy of your notes
• You handle client data in line with UK GDPR

AI-assisted notes can meet the expectation of accurate, relevant records, provided you review and approve the AI-drafted content before saving it.

Being open with clients

This is the most important practical step. Before using an AI tool for a client's notes, tell them. Clients should understand:

• What you do after the session (speak or type a brief summary into an app)
• That this summary is processed by AI to draft a structured note
• That the session itself is not recorded
• That you use reference codes rather than their name
• Where their notes are stored, and that some processing may happen outside the UK under data processing terms
• That they can ask you to write their notes by hand instead

Under UK GDPR your lawful basis for clinical notes is usually contract plus the health-care condition, not consent. Telling clients and seeking their agreement is still good practice, and it fits the Ethical Framework's commitment to transparency. A single paragraph in your contract and privacy notice is usually enough. Our consent template gives you wording to adapt.

Who is responsible for the accuracy of AI-drafted notes?

You are. The Ethical Framework places professional responsibility with the practitioner, not with any tool they use. This means:

• You must review every AI-drafted note before saving it
• You must correct any inaccuracies or omissions
• You cannot use "the AI wrote it" as a defence if notes are inaccurate
• Your professional judgement about the clinical content takes precedence

In NoteSono, every note is a draft until you approve it.

What about client confidentiality?

Confidentiality is central to the Ethical Framework, and it is one of the most important things to consider when using any third-party tool. The key question is what data the AI actually receives. In NoteSono's case:

• The session is not recorded: the AI never hears the therapy session
• You work from your own summary, and we ask you to use reference codes rather than names; NoteSono never needs a client's name
• We don't keep your recording
• Notes are stored in the EU; some AI processing uses providers outside the UK and EU under data processing terms that exclude training on your data

Used this way, the AI processes your clinical summary rather than the session, which is materially different from, say, pasting a full session transcript into a chatbot. What goes into the summary is still up to you, so keep identifying details out of it.

Introducing AI notes with existing clients

You can introduce AI-assisted note writing with an existing client by talking it through openly and updating your contract and privacy notice. Many clients are comfortable once they understand what actually happens: you summarise, the AI drafts, you review.

Some clients will prefer you not use AI for their notes. That's their right and should be respected. You can write those notes by hand; it's not an all-or-nothing decision across your practice.

Complaints: where the risk lies

A complaint about AI notes would most likely arise from:

• Using AI without telling the client, which cuts across the Framework's commitment to honesty and openness
• Inaccurate notes that harmed the client or the work
• A data breach resulting from an insecure tool, which cuts across confidentiality

You reduce all three by telling clients, reviewing every AI-drafted note before saving, and choosing a tool that is open about where it stores and processes data and signs a DPA.

UKCP, BPS, NCPS and COSCA

Check your own body's position directly. To our knowledge, none of these bodies has published AI-specific guidance on clinical notes either, so the same principles apply: transparency with clients, professional responsibility for the record, and lawful data handling.

The practical bottom line

You can use AI clinical notes tools in a way that fits BACP's Ethical Framework. What you need:

1. A clear AI paragraph in your contract and privacy notice
2. A tool that doesn't record sessions and doesn't need client names
3. A habit of reviewing every note before saving
4. The UK GDPR basics: the ICO fee, a privacy notice and a DPA with your provider

NoteSono is built with this in mind: a consent template is included, sessions are not recorded, and the app never needs a client's name. If you want to see it in practice, create a free account.