As we move out of lockdown, many practitioners will be continuing to work with children and young people remotely, providing crucial services during what still remains a critical time.
We recommend that CYP practitioners continue to refer to our adult telephone and e-counselling competences and curricula and undertake appropriate training, linking this with the additional social, neurodevelopmental, psychological and legal knowledge required for working with this age group.
Educational settings across the UK are working to different time scales. Schools, colleges, community settings and private practitioners will be adopting risk assessments best suited to local need.
“Supply teachers, peripatetic teachers and/or other temporary staff can move between schools. They should ensure they minimise contact and maintain as much distance as possible from other staff. Specialists, therapists, clinicians and other support staff for pupils with SEND should provide interventions as usual. Schools should consider how to manage other visitors to the site, such as contractors, and ensure site guidance on physical distancing and hygiene is explained to visitors on or before arrival.”
We anticipate more blended counselling and psychotherapy offers will develop. This will differ between settings with a range of contributing factors determining whether services return fully to face to face provision or continue to provide some counselling remotely.
Consent, accountability and data protection
As with face to face work, the issue around consent when working online is complex and depends on the setting in which therapy is offered. We advise reading the full ICO guidance relating to children and young people, but the key points when offering an online service directly to a child in the UK are:
- if you're relying on consent as your lawful basis for processing, only children aged 13 or over can provide their own consent
- for children under 13 you need to get consent from whoever holds parental responsibility for the child - unless you’re offering a preventive or counselling service
- when relying on consent, make sure the child understands what they are consenting to, and that you do not exploit any imbalance of power in the relationship
You need to be able to account for decisions made to either seek parental consent or to adopt the principles of informed consent from the child or young person. If data protection law is challenged in the future, it’s vital to demonstrate a clear process of accountability.
If you opt to seek parental consent, clear accountability includes checking with the child or young person beforehand to see whether the parent or guardian can be contacted. Ethical considerations arise if the child or young person refuses. It's important to accurately document any decisions made, and the justification for these, in case they are later challenged as a data breach.
There should be no change in the way data is processed, whether providing an online service or face to face counselling. It needs to be in line with current guidance and law in with reference to working competently and safely within the online environment.
It’s important to be cautious as both therapists and clients may be using devices which unknowingly collect client data.
Data protection impact assessments
Schools and voluntary sector agencies will usually have a data protection impact assessment (DPIA) in place for how they manage data. If not, it's recommended one is carried out before therapy is provided to children and young people online:
This DPIA could consider a variety of risks including:
- whether the therapist is using a device provided by their employer or school solely for work use
- whether there is a secure platform which can be used for contacting clients by email or for online therapy sessions, and if the platform has any age related restrictions
- whether the school or agency is subject to any guidance from the DfE regarding contact with pupils at home
- what is the impact of providing or not providing therapy if the child or young person refuses to seek parental consent. Would this leave them more vulnerable?
- if choosing to accept informed consent from the child or young person, how to explain and document how this was established
This list is not exhaustive and we advise all therapists new to working with children and young people online to seek guidance from experienced online CYP practitioners, supervisors or specialists in the field of GDPR relating to therapy, via relevant guidelines, training and CPD.
Security and privacy
As children and young people return to educational settings at different times across the UK, we recommend confidential spaces are made available to talk to counsellors remotely. Re-contracting with schools is an essential part of this process.
While some children and young people remain at home, they may struggle to find a space that feels private, safe, and free from distractions.
Young clients may find regular check-ins supportive, providing a way of holding them emotionally between sessions or over lengthy breaks from therapy.
We recommended you plan check-ins thoughtfully and use a secure platform. Private and secure communication cannot be guaranteed when communicating using text via a mobile phone. The most secure form of asynchronous communication is via a secure email platform. You need to consider this in any initial assessment of what is in the best interests of the client.
It's also likely that texting could easily move into therapeutic ‘chat’ – a therapist could be drawn into providing a therapeutic response when the medium cannot be guaranteed as secure and private.
If a therapist does not have appropriate training and experience in providing chat or IM therapy, we recommended that therapy is provided via video. Video enables the therapist to engage directly with the child or young person, offering the closest medium to working face to face. It becomes more complex to ensure an appropriate assessment of the client when more physical and verbal cues are absent.
If possible, we recommend encouraging a child or young person to make eye contact with the therapist by the end of a session. This helps to ensure or assess an appropriate and safe ending to the session is achieved.
Some young people might feel they can’t engage safely or privately using video. In this case, and if assessed as appropriate, you can communicate via audio function or phone. Some young people may prefer to speak by audio or phone as they may feel video platforms invite therapists directly into their private spaces. Some may find it easier to communicate in an outside space.
Further aspects to consider, as part of broader risk and cyber security measures related to offering support via phone calls or text chat, include:
- appropriate contracting
- potential safeguarding issues and related management
- ability to make an accurate assessment
- therapist competence in the use of different mediums - the knowledge and experience required to ensure safety of the young client along with the ability to ensure there are no misunderstandings
- understanding of disinhibition online, transference and countertransference specific to the online relationship
- ensuring use of end to end encrypted platforms
Chat and IM sessions are different to texting via a mobile phone. They can be secure and private if set up via a platform offering appropriate security and privacy. If you do not have appropriate training, experience and supervision, we recommend you consider the use of chat or IM carefully. Therapists working using chat or IM within organisations will be supported by appropriate guidelines, protocols and clinical supervision.
Remote safeguarding considerations
A therapist needs to have appropriate knowledge, experience and supervisory support, and the ability to meet particular levels of competence, to ensure a young person is not left in a more vulnerable situation if they share an issue that requires a safeguarding response while working remotely.
- establishing a safety boundary checklist before the start of each session as part of the recontracting process. This includes checking the exact location of the young person at the beginning of each session, who else might be in the room or area and what they can do if interrupted. It's important to remain aware of any risks, explicit or not, checking out concerns in the moment they arise
- scheduling sessions within normal working hours to ensure access to appropriate support services
- ensuring a designated safeguarding lead is contactable at any time that remote therapy is taking place
- agreeing clear contracting between all responsible parties.
Working with under 10s online
Working with younger children adds further dimensions to assessment and contracting and can be considered a specialist area.
Therapists working within an organisation will be supported by appropriate guidelines, protocols and clinical supervision. However therapists in private practice or within school settings, who do not have appropriate training and experience, are likely to find that working online with younger children poses further challenges and complexities for both themselves and the young client.
For instance, the family dynamic and possible presence of family members will bring additional therapeutic needs and considerations compared to therapy provided within a school setting. The possibility of online disinhibition is also likely to pose further unexpected challenges.
There are additional considerations for consent and confidentiality, including:
- what are the differences between agreeing consent within a school environment and contracting with a parent, guardian or carer when seeking their consent for working therapeutically online with a young child?
- how can or should a three-way contract be formatted and agreed between the school, therapist and parent, guardian or carer?
- is the therapist likely to be providing therapy with an adult present?
- does the child have a competent level of understanding of the agreed platform and are they able to interact with their therapist online?