Client Data Policy

Client creations

Anything created by the client during the therapy time (art work, written stories, photographs and other items) will be kept for the duration of the therapy in the client’s personal folder (or if paint/glue is still wet at the end of the session, they may be stored in a suitable drying area and transferred to the client’s personal folder by the therapist at a later time). The therapist may look at items created by the client unless they put them into a sealed envelope. At the end of the therapy, all the items will be returned to the client who may then choose to take them home, dispose of them or gift them.

This material is not part of the therapists file but is owned by the client, as such they are exempt from most of the conditions of the privacy policy. No one may be granted access without the clients awareness.

Privacy Policy for information in the Therapist’s client file

The therapist has collected personal and sensitive information about the client as part of the therapy referral and initial assessment. The therapist will also take notes about the therapy sessions. These forms and notes make up the therapist’s client file and will be stored in a locked filing cabinet or encrypted in a read only format on a removable hard drive or USB devise.

In most situations, what is shared by the client will be kept confidential by the therapist and will not be shared. These are the situations where information may be shared:

1. Request for data:

The client has a right to request to see a copy of any information held about them and to correct anything which is factually inaccurate. Clients may be charged a processing fee for requests for copies of their notes, particularly where this is a repeat request. Clients can be denied access to all or part of their notes when the therapist is able to show that allowing access may be damaging to the client.

Recognised applicants

  • the client, provided that he or she is of an age and capacity to understand the documents;
  • a person with ‘parental responsibility’ for a child in common law, subject to a declaration by the parent that the child is not of sufficient age or mental capacity to understand. The interests of the parents should be compatible with those of the child. If there is a possibility of serious harm to either the child or a third party by allowing access, it can be denied;
  • an agent, such as a legal representative acting for a client, subject to receipt by the record holder of a duly signed and dated declaration from the client consenting to disclosure of the records by a third party;
  • when the client has died, that person’s personal representative or anyone who has a claim arising out of the death.

2. Referring agency:

If the client has been referred by another agency, the therapist will contact that agency to confirm that the client has started therapy. Where the referrer is paying for the therapy they will be contacted again to confirm when the client has finished therapy and how many sessions were attended in total. Any requests for extensions and reasons for this request will also need to be discussed with the referrer. Sensitive information about the therapy content will not be shared. A record of this communication will be kept in the therapist’s clients file.

3. Medical referrals:

If the client becomes unconscious or otherwise incapacitated during a session, or if the therapist believes the client is a serious risk to themselves or others, the therapist may contact the client’s GP and / or emergency services and / or the client’s emergency contact related to the specific health needs of the client. Where possible this will be done with the informed consent of the client. Information about substance use, self-harm, suicide attempts and current medication may be shared as medically appropriate, on a need to know basis. Non relevant information will not be shared. A record of this communication will be kept in the clients file.

If the therapist believes the client would benefit from a referral to another agency this will only be done with the client’s permission and informed consent. A record of this communication will be kept in the therapist’s client file.

4. Crime referrals:

Where a client discloses that they are embezzling money or involved in terrorism or violent extremism, or practising female genital mutilation (FGM), all therapists have a legal duty to refer this to the police.

Dramatherapist who are accredited by the Health and Care Professions Council (as I am), are also obliged to follow the statutory guidance to report to the local authority children’s social care immediately if they think a child may have been, or is likely to be, abused or neglected. This guidance is set out in Working Together to Safeguard Children”. The HCPC clarifies this guidance by stating:

5 Respect confidentiality

Using information

5.1 You must treat information about service users as confidential.

Disclosing information

5.2 You must only disclose confidential information if:

– you have permission;

– the law allows this;

– it is in the service user’s best interests; or

– it is in the public interest, such as if it is necessary to protect public safety or prevent harm to other people.

6 Manage risk

Identify and minimise risk

6.1 You must take all reasonable steps to reduce the risk of harm to service users, carers and colleagues as far as possible.

6.2 You must not do anything, or allow someone else to do anything, which could put the health or safety of a service user, carer or colleague at unacceptable risk.

Manage your health

6.3 You must make changes to how you practise, or stop practising, if your physical or mental health may affect your performance or judgement, or put others at risk for any other reason.

7 Report concerns about safety

Report concerns

7.1 You must report any concerns about the safety or well-being of service users promptly and appropriately.

7.2 You must support and encourage others to report concerns and not prevent anyone from raising concerns.

7.3 You must take appropriate action if you have concerns about the safety or well-being of children or vulnerable adults.

7.4 You must make sure that the safety and well-being of service users always comes before any professional or other loyalties. Follow up concerns

7.5 You must follow up concerns you have reported and, if necessary, escalate them.

7.6 You must acknowledge and act on concerns raised to you, investigating, escalating or dealing with those concerns where it is appropriate for you to do so.”

HCPC Standards of conduct, performance and ethics

Where a client is involved in other serious crime such as ‘Murder, manslaughter, rape, treason, kidnapping, or other cases where individuals have suffered serious harm’ the therapist may have a moral duty to report this to the police which may cause them to break client confidentiality to protect the client or others.

Where information is disclosed, only relevant information may be passed on, this may include copies of notes with non-relevant sections blacked out or may be in the form of a crime report. A record of this communication will be kept in the therapist’s client’s file but may not be shared with the client.

In other criminal cases, the police do not have a right to see a copy of any therapy notes without a special warrant issued by a judge or the Crown Prosecution Service, the therapist is not required to answer any police questions which they believe are not in the interest of their client. However, if the therapist is called as a witness in a court case, they may state to the judge their objection in disclosing information but, where the judge rules this should be disclosed, the therapist is then required under oath to break client confidentially and fully answer any questions asked.

5. Therapist Investigation

Dramatherapists are regulated by the HCPC who have a right to see copies of client notes if they are investigating a therapist’s professional conduct.

The ICO also have a right to investigate any data breaches where the therapist has misused or endangered client information in breech of UK data regulation.

6. Therapist supervision:

The therapist may discuss client information and details of sessions with their clinical supervisor to ensure they are delivering a high standard of care and to assist with the therapist’s continued professional development as a mental health practitioner. This will not include the clients name, contact details or date of birth.

Contact between sessions:

The therapist will only initiate personal communication with the client between session when required. This will be kept to a minimum and will only use forms of communication which the client has consented to on page 1 of the referral form. In an emergency, or exceptional circumstances, the therapist may try other forms of communication. Where communication is initiated by a client the therapist may respond to the specific request using the same method of communication. Any communication will be recorded (printed copies of written communication and a log of the time, duration and main issues discussed in verbal communication) and kept with the therapist’s client notes.

Notes stored:

The therapist’s client notes will be kept for six years after the final therapy date. Where the client is a child the notes will be kept until six years after the child has turned 18. After this date the notes will be securely destroyed.

If the therapist dies or is struck off before the notes are destroyed, the notes will be passed to their clinical supervisor who will arrange for their appropriate disposal.

Optional additional consents

As a profession, Dramatherapists are interested in adding to the evidence base for advances in the treatment of mental health. If clients consent to be included, all names will be changed to pseudonyms and all client information will be anonymised to remove all identifying details.

The nature of client confidentiality for anything published in the public domain should reflect an appropriate level of client confidentiality. This may include changing or disguising identity details about the client and/or focusing on the therapist intervention rather than the clients material. Any changes should be consistent in any subsequent publications so as not to draw attention to discrepancies which could lead to a client’s identification.

All clients are free to consent to being included in this or to opt out. Clients who do give consent are free to withdraw that consent at any time prior to publication. Where consent is withdrawn any information which has already been collected can continue to be used in collated form (e.g. 75% of clients reported…), but personal case study information and quotes from the client must be removed and destroyed.

All data collected (session notes, photographs or reproductions of client material, any recorded content, assessment forms and data) will be held securely and deleted once no longer required or no later than 6 years after being collected.

Clients will be asked to opt in using the below question, the form should be signed and dated.

Do you consent for your anonymised information to possibly be included in:

Info from my file Quotes I said / wrote Client art / content No  
        Journal articles, research papers & academic publications
        Published books, including e-books and audiobooks
        Teaching to other mental health professionals (seminars, workshops, lectures)
        Other content including blog posts, videos, podcasts, news articles, interviews





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