Interim Protocols for Online Guidance Counselling

Hardware

Guidance counsellor and student(s)/client(s) will both need

• computer/laptop/tablet
• camera, microphone and earphones
• sufficient broadband width  for the medium proposed

Working online, whether with a group, in a virtual classroom or lecture setting or face to face /one-to-one, requires practice to develop confidence and to feel comfortable.  Practice beforehand creates self-assurance and the conditions necessary to instil confidence in the clients and students involved in the online group delivery or one-to-one session.  For those inexperienced in this medium, members in a branch might consider getting together to set up a Zoom virtual meeting and engage in peer practise together!

Mobile Phones                                                                                                                                                      

The use of a smart phone is not recommended, for privacy and security reasons. Every context is different and guidance counsellors will be aware of the resource limitations of his or her student/client with regard to hardware availability, and, having exhausted every other alternative option, decide that to communicate via phone is the only option available to an individual.  Good practice would suggest using a work mobile number.  In the event that a work mobile phone is not available, it is advisable to block one’s personal number for outgoing calls; and for each call, outgoing and incoming, logging for future reference, the date, time, client, and topic.

• Ensure competency in the technology beforehand
• Have back up plans if meeting  a student one-to- one  – email or phone number in case of breakdown in communication
• Pay attention to privacy and security issues, including disabling screen sharing on Zoom

Platforms/Media/ Security & Remote Working

• Platforms, such as Edmodo, Teams, etc are options for classroom and teaching activities, with training available, via www.teachercpd.ie  and www.pdst.ie/pdst.ie.  Schools will have established practice in many of these platforms already, providing virtual school options which satisfy the school’s Acceptable Use Policy (AUP) position.

• Skype is not generally considered to be an adequately secure platform for meeting with students (3) or conducting guidance counselling sessions online. There are reservations (see e.g., ACTO, the Association for Counselling and Therapy Online) about the use of Skype and VSee and similar, for professional remote working, and, though currently used by some professionals for engaging in one-to-one, they are not recommended (4) Although Skype is an encrypted platform, the use of contact lists and other features fail both GDPR privacy and data protection requirements and regulations for working remotely.

• Guidance counsellors and others increasingly favour the use of Zoom (https://zoom.us ) as it is highly secure. It meets very high standards of HIPPA (5), the USA legal system for online security (6).  It provides a free service which allows one-to-one meetings of 40 minutes duration and clients do not need to install Zoom on their computers.  For ongoing guidance counselling work, an account subscription is obviously advised.  In addition, the guidance counsellor can control recording (7).

• Secure email accounts include, www.hushmail.com   for encrypted email service, and www.protonmail.com.  Hushmail charges an annual fee which varies, depending on whether business or personal account.  Proton offers open source with basic free ProtonMail email service, compatible with other email providers.

• The Data Protection Commission has recently published guidelines in relation to Data Protection for working remotely. These include care and security when using devices, emails, cloud, network access, including paper records (8).

• The use of social media such as Facebook, Twitter, Instagram, WhatsApp, Pinterest, etc , and personal mobile phones, are not considered appropriate social media for engaging with students or clients both on a professional basis perspective and, for security and privacy reasons (9).

• It is recommended that devices such as Google Home and Alexa, along with assistant apps on phones, be switched off when working one-to-one with students.

Where concerns about privacy or security with regard to platforms and media for online guidance counselling exist, the guidance counsellor has responsibility to inform the student/client or their parents/guardians of these concerns, particularly if the medium has been suggested by the client/student.  In the school/college context, guidance counsellors have the responsibility to inform their principals or managers.

Contracting    

‘Contracting’, or, establishing ‘terms and conditions’ ahead of starting work with a student or client, is always an important first step in the one-to-one and allows the guidance counsellor to set  the boundaries, and establish with the student/client, future goals. It is particularly important for working remotely. It is recommended that a guidance counsellor

• Provide a brief description of the online process of guidance to be offered and any limits to this process.

• Outline the responsibility of the guidance counsellor in the future work together.

• Ascertain client /student suitability or readiness for working online

• Determine the extent of future (if more than one session may be required) student  engagement in the process.

• Establish  technology availability and access; it is advisable to have a pre first session try out.

• Clarify ethical and confidentiality issues.

• Clarify for the student  the ownership of email and other data generated.

• Advise client /student in relation to guidelines  under GDPR in relation to image, voice or call recording (10).

(10) https://iapp.org/news/a/how-do-the-rules-on-audio-recording-change-under-the-gdpr/

• Create an awareness of  the student/client responsibility in the decision making process.

• Manage client expectations in relation to ongoing or future online availability

In relation to boundary limits, it is good practice for the guidance counsellor to have to hand a list of appropriate referrals in their locality and to develop a network of colleagues in various specialist agencies and services locally.

For the student/client, the process of contracting will: 

• Help to clarify the potential advantages and disadvantages of working online.

• Establish clarity around goals for the ‘contract’ period.

• Provide  boundaries of engagement e.g., availability, punctuality, length of time etc,  and an understanding of the limitations of the contract.

• Establish appropriate communication channels for contacting you as guidance counsellor electronically. It is advisable, if possible, to not use one’s private phone.  Setting a specific appointment date and time communicates to the student that the guidance counsellor is not available at the drop of a hat!

• Clarify what personal information will be gathered, how it will be stored and for what purpose.

Private Practice

For the guidance counsellor and client in private practice, In addition to the above, other considerations may include

• Inserting into the contract clarity with regard to ownership of recorded  or written information.

• Providing clarity, in advance of contract agreement, around how  payment of professional fees will be made (payment in advance is recommended).

• Making available, in advance of entering a contract, a schedule of fees for different guidance counselling services offered and contracting for the number of sessions that will be involved.

• Guidelines with regard to a client’s right to withdraw from the contract.

• Completion of a pre-session  background questionnaire.

• Ensure that the indemnity schedule entered into with the insurance company, covers online guidance counselling.

Confidentiality

Guidance counsellors are encouraged to continue to provide online guidance counselling for their students, and, for the duration of the Covid-19 emergency, in consultation with their principal. Confidentiality between the student/client and guidance counsellor, is owned by the client (11). While respecting the client’s right to confidentiality, it is the responsibility of the guidance counsellor to clarify for the client/student, any limits to confidentiality, where legal obligations require breaking confidentiality, such as concerns about potential harm to self or others, or where a guidance counsellor may be subpoenaed to testify in court.

Security

The obligations under the General Data Protection Regulation (GDPR) in relation to the collection and storage of client/student personal information, is mandatory and relates to both soft and hard copy data held on electronic systems, in network drives, email, voice recordings and other locations.

This obligation extends also to the security of such personal information (12).  GDPR requires that personal information is:

• processed lawfully, fairly and in a transparent manner;

• collected for a legitimate and specified purpose;

• adequate, relevant and limited for the purposes obtained;

• limited in storage for no longer than is necessary for the purpose of the data collection;

• processed confidentially and that there is integrity with regard to security, protection, loss or damage.

In a school context, notes made in the course of working one-to-one and filed securely, remain the property of the school.  Guidance counsellors generally maintain records of their meetings with students and may also take brief case notes which are held in a locked file. In the absence of a secure location to store such documentation, a conversation with one’s principal about appropriate procedures to safeguard the security of student information might be appropriate, or at least, informing on procedures being undertaken to secure student data.  If recording online, computerised notes, contact details need to be stored in protected files, such as secure cloud data software platforms.

Informed Consent

In the new GDPR climate, consent can no longer be taken for granted; it must be actively sought rather that passively assumed. It is recommended that guidance counsellors working remotely, whether in an educational setting or in private practice, have a privacy policy (13). For example, the guidance counsellor is responsible for ensuring that there is informed consent for the medium to be used, and in the case of minors, this will need to be obtained from parents or guardian.

Guidance counsellors working in a school context could clarify with principals/boards of management if consent for students’ participation on the platform/media being used for remote online work e.g., virtual class work, group work or one-to-one, has been sought by the school from the parent body, and clarify any specific online media of their guidance counselling practice which may need to be instanced, if not the normal in-school resource.  

Indemnity

Guidance counsellors working in the school context need to clarify with their principals that their online guidance counselling work is covered, as per normal, as part of the school’s indemnity policy.

For Private Practitioners it is suggested that guidance counsellors check that online work is covered by the insurance policy entered into with their insurer.