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Counsellors in private practice: supervision, CPD and the ICO fee

Counselling isn’t regulated by law in the UK, but most counsellors and psychotherapists belong to a professional body such as BACP, and that comes with rules. Here are the ones that trip up people in private practice.

Based on BACP and ICO guidance, last checked 26 October 2026 · General information, not professional advice

1.5 hoursof supervision every calendar month (BACP accredited)
30 hoursof CPD a year, as BACP normally expects
£52ICO data protection fee, tier 1 (£47 by direct debit)

Supervision

BACP accredited members (and those applying for accreditation) need at least 1.5 hours of supervision every calendar month. It can’t be averaged over the year: one hour every three weeks doesn’t meet the requirement on its own, even though it adds up to more over a year.

Individual, group and peer supervision can be combined. Group time counts like this:

TypeWhat you can count
IndividualThe full session
Group of 4 or fewer superviseesHalf the session time (don’t count the supervisor in the group)
Group of 5 or more superviseesThe session time divided by the number in the group
Peer supervisionAs for groups, counting all members

BACP registered members don’t have a set number of hours. You agree a frequency and length that lets you discuss all aspects of your work, and review it regularly. Supervision is a separate requirement, so don’t count it as CPD.

CPD

BACP says it would normally expect registered members to do at least 30 hours of CPD a year. Keep a record of what you did, the hours, what you learnt and how it changed your practice, with evidence such as certificates or notes.

The ICO data protection fee

If you keep client records on a computer, phone or online system, you will usually need to pay the ICO data protection fee each year unless you’re exempt. For a sole practitioner that’s normally tier 1: £52, or £47 by direct debit. The ICO’s online self-assessment tells you whether you need to pay.

Client notes contain health information, which is special category data under UK GDPR. You need a lawful basis for holding it, a privacy notice that tells clients how you use it, secure storage, and a retention period you stick to.

Other records to keep

Private Practice Workbook - Therapist edition
Templates for therapists

Our Private Practice Workbook (Therapist edition) checks your supervision every month the BACP way, tracks CPD, renewals, sessions and who owes you, and does your tax. The Client Intake & Consent Forms include a therapy agreement and a UK GDPR privacy notice.

Therapist workbook on Etsy Client forms on Etsy

Official sources

General information, not professional advice. Check your own professional body’s requirements. Not affiliated with BACP or the ICO. Last checked 26 October 2026.