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AI Therapy – Policy and Procedure for Number 11 counselling

 

Policy Purpose

Artificial Intelligence (AI) tools are being explored for their usefulness in therapy. Here, we define our stance on the use of AI as part of, or alongside, therapeutic process. The aim is to support ethical and legally compliant practice whilst supporting the autonomy of therapeutic participants.

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Policy Statement 

As a counsellor/ psychotherapist/private practitioner, we recognise the increasing use of AI in mental health. Clients might use AI to support their journal writing and reflections. However, AI is not a replacement for professional therapy/counselling due to its inability to hear nuance, provide empathy, assess risk, provide trauma-informed care, apply clinical judgement, or work in the best interests of the AI user.

  • We do not use AI to deliver therapy.

  • We do not use therapy to process sensitive personal information.

  • We do not use AI for record keeping.

  • We do not use AI to assist me in making clinical decision-making.

  • We do not use AI for clinical supervision purposes.

  • We may use automative tools for scheduling and invoicing.

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Procedure

Boundaries: Therapists conducting therapeutic practice for Number 11 counselling will not review AI-generated content as part of therapy unless it is both appropriate and mutually agreed with the therapeutic participant.

Discussion: If therapeutic participants mention using AI for support, the therapist will help the client to support its role, relevance and value to the therapeutic process. Potential risks, benefits and self-care will be explored as part of the therapy sessions.

Documentation: Any discussions about AI will be recorded briefly in client notes for the purposes of evidencing therapeutic process.

Review: The policy will be reviewed at least annually.

 

The types of AI tools used in therapy.

In alphabetical order:

Administrative and Workflow Automation Tools automate administrative tasks such as scheduling, billing, report generation and compliance documentation.

AI-Assisted Note-Taking Tools are used to transcribe and summarise therapy sessions, generate structured clinical notes and reduce administrative workload for practitioners.

AI-Enhanced Supervision and Training Tools analyse recorded sessions for core skills and adherence to therapeutic models.

Client Self-Monitoring and Insight Tools provide a tool where clients to track moods, journaling data, and daily reflections.

Conversational Support Chatbots intend to provide AI-based early-stage support for text-driven emotional support and self-help.

Emotion and Sentiment Analysis Tools analyse voice tone, facial expressions, or text to detect emotional states. 

Ethical and Data Governance Tools are AI tools that audit bias, privacy and bias in AI-automated decision. 

Predictive Analytics and Risk Detection Systems analyse behavioural, linguistic, or biometric patterns to identify early signs of crisis, relapse or disengagement.

Therapeutic Content Personalisation Engines are online platforms where digital therapeutic materials and exercises provide tailored interventions based on engagement and progress.

Virtual Counselling Assistants engage users to assist clinicians in screening or monitoring mental health indicators.

 

Written by Samantha Crapnell

October 2025

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