If you're unsure whether you should be seeing clients face to face, see the guidance on our Working within the restrictions page.
Factors to consider
Once you're clear on the guidance that applies to your circumstances, you must decide how you will work with your clients by going through a decision-making process on a case by case basis.
Factors to consider include:
- the client's need and safety
- your need and safety
- the context of the service
- the premises you practise from
- whether other options are possible and the ethical and practical risks of any decision
- the known risk factors of age and any pre-existing health conditions for both yourself and your client
- particular needs of clients who may not be able to engage using online platforms or by phone
- whether any risk to the client, either from others or from themselves. can be managed remotely
- your supervisor’s feedback
- your insurance cover
We encourage you to work through the ethical decision-making process with your supervisor to make a personal decision that takes these factors into account.
Preparing for face to face work
If you're thinking about working face to face, you need to:
- consider your clients on a case by case basis – is the risk to the client of working remotely greater than the risk of working face to face?
- consider whether the space you plan to work from allows for social distancing of two metres or at least one metre with mitigation – this includes any areas such as entrances, exits, corridors and waiting areas
- decide whether you need protective equipment such as masks or visors
- conduct and publish a risk assessment of your premises and create a procedure checklist to mitigate the risk of contamination before, between and after seeing clients. This is a legal requirement.
- if you work with others from a shared space, ensure they're also applying appropriate measures and there's no risk that any of these will be compromised
- if you work from rented premises, check whether your landlord has any risk assessment or sanitisation process you need to follow
- check if your indemnity policy covers you for face to face work
- ensure your supervisor supports your decision
- check whether you need to make any amendments to your contract with clients and asked them about the possibility of returning to or starting face to face work
Carrying out risk assessments
It is a legal requirement for all businesses to complete a COVID-19 risk assessment. If you have fewer than five workers, or are self-employed, you don’t legally have to produce a written risk assessment. However, this may be a helpful exercise and a useful document to have if asked by insurers or concerned clients.
The face to face conversational element of therapy, combined with the length of exposure during a typical therapy session, puts you and your clients at particular risk. We advise you read the guidance in full, considering especially:
- how will you comply with the social distancing guidelines or considering and setting out the mitigations you will introduce in your risk assessments (p8)
- if people must work face to face for a sustained period with more than a small group of fixed partners, whether the activity can safely go ahead. The closer someone is to the source of the virus, the greater the risk of transmission. Pay particular attention to avoiding contact with surfaces near to the client and thoroughly cleaning those surfaces after each client (p9)
Different rules and restrictions apply across the four nations of the UK. Please check the guidance that relates to your area.
The government has not provided any specific risk mitigation guidance for counselling or psychotherapy, but does provide advice on how to stop the spread of coronavirus.
Wearing face coverings is currently mandatory in most indoor settings, including in premises where personal services are provided to clients.
We encourage the use of face coverings for clients receiving therapy face to face, where appropriate, to protect the safety of both the client and the therapist.
If you have concerns about the possible effect on the therapeutic relationship of wearing a face covering, consider working online instead.
If you practise within a service setting or from a rented space, you should also check your employer or landlord’s COVID-19 risk assessment and associated procedures.
Do clients need to wear a face covering?
There are some circumstances where people are exempt from wearing face coverings. They do not have to prove that they are exempt.
These exceptions can include:
- young children under the age of 11 (Public Health England do not recommend face coverings for children under the age of 3 for health and safety reasons)
- not being able to put on, wear or remove a face covering because of a physical or mental illness or impairment, or disability
- if putting on, wearing or removing a face covering will cause severe distress
- if travelling with or providing assistance to someone who relies on lip reading to communicate
Face coverings may also be removed include if speaking with people who rely on lip reading, facial expressions and clear sound.
You should consider these exceptions before meeting with a client and agree if an exception should be applied.
Do therapists need to wear a face covering?
Government guidance states that where a distance of two metres is not possible, a face mask (type 2 surgical) should be worn as well as a clear visor that covers the face.
How this works in the therapy room depends on individual circumstances. Even if you can maintain the two metre distance, you and your client are at increased risk due to the face to face position and prolonged exposure during a therapy session. This is particularly important where the client is exempt from wearing face. You should consider:
- can you maintain the recommended social distance?
- if you can maintain social distancing, could the risk to you and your client be reduced by using face coverings?
- if you can't maintain social distancing, would it safer for you and your client to continue to work online?
Many practitioners have moved to remote methods of practice, which may have presented benefits to both the client and the therapist. It's likely clients will ask therapists to provide a blended or hybrid approach to offering therapy, offering both remote and face to face methods.
There are several factors to consider if offering a blended approach. These are explored in our Counselling under localised and rapidly changing lockdown resource.
Further information and guidance
Walk and talk therapy
Walk and talk therapy is a recognised working practice and can be continued in accordance with government guidelines for working safely during coronavirus. (This is different to government guidelines regarding daily exercise.)
However, there are various ethical considerations when offering outdoor therapies and these may differ depending on whether you already offer this type of therapy. You need specific knowledge and skills to offer outdoor therapies safely and effectively.
We recommend that you should only offer outdoor therapies during the pandemic if:
- you are competent to do so
- outdoor therapy is suitable for the needs of the individual client
- it is not possible to offer indoor, online or phone therapy
Further information and guidance
Other things to consider
Informing clients of changes to your practice and re-contracting
As the guidance and restrictions change, you should revisit any amendments you made to your contracts at the start of the outbreak to check whether they are still relevant or need updating. You may also want to provide your clients with additional information relating to any changes to your practice, for example:
- any practical changes to your practice, such as location, access, sanitisation procedures, reduced access to facilities
- any requests of your clients - for example do they need to bring their own hand sanitizer, face masks or visors. What should they do if they have symptoms of COVID-19, or have been in contact with someone who has the virus?
- what actions you would take if you have symptoms of COVID-19 or have been in contact with someone who has the virus?
- what would happen if there was a local lockdown?
- any changes to your method of payment and cancellation fees
- any potential implications to confidentiality, for example contact tracing, trusted others contacting them in your absence
If you test positive for coronavirus, the NHS Test and Trace service will ask you about people you've been in contact with. The NHS will then contact them to provide support and testing. This has raised concerns about whether you can identify your clients to the NHS.
The government recommends that businesses keep a temporary record of clients and visitors that they’ve had in the last 21 days. See the guidance for information on what this record should include and how to keep it in accordance with GDPR.
If you incorporate any form of touch in your therapy, you must adhere to the close contact guidance includes displaying a QR code, as used by the NHS Test and Trace app.
You may need to revisit your contract with your clients. Your existing contract may refer to the limits of confidentiality relating to the balance of public interest. Public interest is the general welfare and rights of the public that must be recognised, protected and advanced. Disclosures in the public interest, based on the common law, are made where this is essential to prevent a serious and imminent threat to public health, national security, the life of the individual or a third party, or to prevent or detect serious crime.
You could explain to clients that, under this clause, you may need to share their name and contact details with the NHS if you or another client contract the virus. If you want to make it clearer to clients, you could add a separate coronavirus contingency clause, stating that confidentiality will be broken if necessary for reasons of public interest in the area of public health.
Further guidance for practitioners
Guidance and resources for members
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