Guide

Process notes vs session notes

Session notes are the clinical record. Process notes are private reflection. Under UK GDPR, both can be personal data.

Updated 4 October 2026.

Information, not legal advice. This page is a practical overview for practices. It is not a substitute for advice on your own contracts, insurance or registration.

Counsellors and psychotherapists in the UK often keep two kinds of writing about a client. Session notes are the clinical record: what happened, what was agreed, any risk, and the plan. Process notes are the therapist’s private reflections: feelings stirred by the work, half-formed hypotheses, material for supervision. Training courses often require process notes. Many practitioners keep them for years afterwards.

The distinction is useful clinically. It is much weaker legally than many people assume. This guide explains the difference, what UK GDPR means for each, and a sensible way to handle both.

This is information, not legal advice. Your professional body, insurer and supervisor are the people to ask about your situation.

Session notes

Session notes are the record another professional should be able to rely on. They are usually short and factual:

• date, length and type of session, and attendance;
• the focus the client brought;
• anything said or observed about risk, and what you did about it;
• anything agreed, including referrals, letters or a change of frequency;
• the plan for the next session or the ending.

Structures such as SOAP and DAP help. BACP and UKCP do not require a particular format. They expect records that are accurate and appropriate to the work.

Process notes

Process notes record the therapist’s inner experience of the session. They might include countertransference, a dream image you want to think about, or a question for supervision. They are tools for learning and reflection. They are not meant to be read by the client, and they are often written quickly.

The legal point many people miss

In the US, federal health privacy law treats “psychotherapy notes” as a separate category with extra protection. That rule does not apply in the UK. Under UK GDPR, the question is simpler: is the information about an identifiable living person? If process notes name or can identify the client, they are personal data, and usually special category health data, whatever you call them and wherever you keep them.

That has practical consequences:

• Subject access. A client can ask for a copy of their personal data. Notes kept in a separate notebook or a separate folder can still fall within the request. There are limited exemptions, including where disclosure would be likely to cause serious harm, but they are narrow and need careful handling. The ICO publishes guidance on subject access requests.
• Courts. Records of any kind can be ordered to be disclosed in legal proceedings. Calling them private does not prevent that.
• Retention and security. Process notes need a retention period and secure storage, just like the record. A notebook in a car is a data breach waiting to happen.

Two short fictional examples

The examples below are invented. No client record was used.

Session note. “Session 6 of 12, 50 minutes, attended. A. brought conflict with a manager after a meeting on Tuesday. Explored the pattern of withdrawing when criticised. No risk disclosed; asked directly about self-harm, denied. Agreed A. will note one moment this week when they want to withdraw. Next session booked.”

Process note. “Felt protective and slightly impatient. Noticed I talked more than usual when A. went quiet. Is this the same withdrawal pattern playing out in the room? Take to supervision.”

The session note is what a colleague covering your leave would need. The process note is about you and the work. Notice that the process note still uses an initial and describes the client’s behaviour. It is still about an identifiable person, so the same data protection rules apply.

Supervision and training

Trainees are often asked to bring process notes to supervision and to submit them, anonymised, as part of assessed work. Check what your course requires, how long it keeps submitted work and whether clients have agreed. Remove names, dates of birth, workplaces and other details that would identify someone to a reader who knows the area. Anonymisation that a colleague in the same town could see through is not anonymisation.

Supervisors who keep their own notes about supervisees’ clients hold personal data too. The same principles apply: keep only what you need, store it securely and set a retention period.

When a client asks to see everything

If a client makes a subject access request, do not panic and do not destroy anything. Note the date, confirm their identity, and gather every record that relates to them, including process notes. Then consider whether any exemption applies, and take advice from your professional body or insurer if you are unsure. Respond within the time limit the ICO sets out.

A sensible way to handle both

1. Decide, and write in your contract, which notes you keep and why.
2. Keep session notes factual, signed and on the client’s record.
3. If you keep process notes, avoid identifiers where you can. Use initials or a code, and keep the key separately.
4. Write process notes as if the client might one day read them. That is a good discipline for supervision anyway.
5. Set a retention period for process notes that is no longer than you need. Training notes often need only to last until the course is assessed.
6. Destroy them securely when that period ends.
7. Tell supervisors and trainees how your practice handles both kinds.

For retention periods quoted from BACP, UKCP and HPCSA sources, read how long to keep therapy records. For the wider privacy picture, read GDPR and therapy notes.

Where software fits

Clinical notes software is for the session note: the record that sits beside the booking and the invoice, closed to admin staff, with an audit trail of who opened it. In Within, the session note lives on the client file. You can write it yourself, or sign a draft Assist prepared from a recording the client agreed to. The clinician always reviews and signs.

Whether process notes belong in the same system is a practice decision. Some practitioners prefer to keep reflective writing out of the record entirely. Others want everything in one secure place rather than a notebook. Either can be reasonable if the contract says so and the storage is secure. Clinical notes software explains how the record side works.

Related reading

• Clinical notes software
• SOAP notes for counselling
• How long to keep therapy records