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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.
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:
| Type | What you can count |
|---|---|
| Individual | The full session |
| Group of 4 or fewer supervisees | Half the session time (don’t count the supervisor in the group) |
| Group of 5 or more supervisees | The session time divided by the number in the group |
| Peer supervision | As 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
- A signed agreement with each client: fees, cancellations, and the limits of confidentiality.
- Session notes, factual and brief, stored securely.
- Your indemnity insurance renewal, membership renewal and any DBS check.
- A clinical will: arrangements for your clients if you suddenly can’t work.
- Your income and expenses for Self Assessment – and from April 2026, Making Tax Digital if your self-employment and property income is over £50,000 (£30,000 from April 2027, £20,000 from April 2028).
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