Do I need client consent to use AI for therapy notes in the UK?

BACP has not published specific guidance on AI clinical notes. Its Ethical Framework still applies: be open with clients about the tools you use, keep accurate records you have reviewed, and protect confidentiality. Telling clients and seeking their agreement is good practice and fits that commitment to transparency. Under UK GDPR your lawful basis for clinical notes is usually contract plus the health-care condition rather than consent, but your privacy notice must still explain how notes are written and who processes them.

What should an AI therapy notes clause include?

It should explain that you use an AI tool to help write session notes, that the session itself is not recorded and only your post-session summary is processed, that you use reference codes rather than names, where notes are stored, that AI providers process your summary under data processing terms, that you review every note, and how the client can ask you to write their notes by hand instead.

Can I add an AI clause to my existing therapeutic contract?

Yes. A single paragraph added to your existing contract and privacy notice is usually enough. If clients have already signed your contract, tell them about the change and give them the chance to ask questions or opt out.

What happens if a client does not want AI used for their notes?

You write that client's notes by hand instead. This applies only to that client; you can keep using AI for other clients who are happy with it.

AI Therapy Notes Consent Template for UK Therapists

If you're using, or planning to use, an AI tool to help write your clinical notes, your clients should know about it. BACP hasn't published specific guidance on AI clinical notes, but its Ethical Framework asks you to be open with clients about how you work, keep accurate records and protect confidentiality. Telling clients about AI note-writing, and seeking their agreement, fits that commitment.

This page gives you a clause you can copy, explains what it needs to cover, and answers the questions UK therapists most often ask about it.

Free AI notes clause for UK therapists

Copy this paragraph into your therapeutic contract, information sheet or privacy notice, and adapt it to the tool you use. The version below describes how NoteSono works; if you use a different tool, check each line against that tool's own terms.

AI-assisted clinical notes

To help me keep accurate clinical notes, I use an AI-assisted tool called NoteSono. After each session, I speak or type a brief clinical summary in my own words. This summary is processed by AI to draft a structured session note.

Please note the following:

Our sessions are not recorded. Only my post-session summary is processed.
I refer to you by a reference code rather than your name in the summary, and I keep identifying details out of it.
My notes are stored securely in the EU. Some AI processing uses providers outside the UK and EU under data processing terms that exclude training on your data. Your information is handled in line with UK GDPR.
I review and approve every AI-drafted note before it is saved, and I take full professional responsibility for the accuracy of my records.
If you would prefer that I do not use this tool for your notes, tell me at any time and I will write your notes by hand instead.

Please let me know if you're happy with this, or if you'd prefer I write your notes by hand. If you have any questions, you're welcome to raise them with me at any point in our work together.

This clause is free to use and adapt. It reflects how NoteSono handles data today: no session recording, notes stored in the EU, and AI processing by providers outside the UK and EU under data processing terms.

How to use this template

For new clients

Add the paragraph to your standard therapeutic contract or information sheet, and make sure your privacy notice says the same thing. Go through it with new clients at the contracting stage, as you would any other part of the contract. Many clients are reassured once they understand that the session itself is not recorded.

For existing clients

If you start using AI notes with an existing client, tell them first and give them the chance to ask questions or opt out. You can do this in session as part of a brief contracting review, or by sending an updated contract. Do not start using AI notes for an existing client without their knowledge.

For clients who decline

Some clients will decline. That is their right and should be respected without pressure. You simply write those clients' notes by hand, and you can keep using AI for other clients.

What BACP says about AI and consent

BACP hasn't published specific guidance on AI clinical notes. Its Ethical Framework still applies: be open with clients about the tools you use, keep accurate records you've reviewed, and protect confidentiality. Telling clients about AI note-writing and seeking their agreement is good practice and fits the Framework's commitment to transparency.

If you belong to another body, such as UKCP, NCPS or COSCA, check its current position directly.

What UK GDPR requires alongside this

Being open with clients is the ethical side. UK GDPR has requirements that run alongside it:

Lawful basis: record your lawful basis for processing (usually contract, Article 6(1)(b)) and your condition for health data (usually health care, Article 9(2)(h))
Privacy notice: say that you use AI-assisted note-writing, which tool, where notes are stored and whether data goes outside the UK
Data Processing Agreement: you need a DPA with your AI notes tool provider
ICO fee: pay the ICO data protection fee (£52 a year for most sole practitioners, or £47 by direct debit)
Client rights: clients can ask to see, correct or, in some cases, delete their data; have a process for handling these requests

Common questions from UK therapists

"What if a client asks to see the AI-drafted note?"

A client can make a subject access request (SAR) for personal data you hold about them, including clinical notes. Whether notes were AI-assisted or written by hand makes no difference. Write your notes with this in mind, and take advice before withholding anything.

"Does using AI affect my professional indemnity insurance?"

Check with your insurer. Some insurers are starting to ask about AI tool use at renewal. Being open with clients and keeping a record of what you told them reduces your risk.

"What if the AI makes a mistake in my notes?"

You are responsible for the accuracy of your clinical records however they were produced. This is why reviewing every AI-drafted note before saving is not optional. AI tools draft; clinicians approve records.

Using NoteSono with this template

NoteSono does not record your sessions: you summarise afterwards. We ask you to use reference codes rather than names, and the app never needs a client's name. Your 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. You review and approve every note before it is saved.

When you sign up, a consent template is also available in the app. Create a free account (free plan, no card needed).