Coaches and psychologists: destroying session notes
A coach, psychologist or therapist works with what people share least with others: what preoccupies them, their stress, relationships, fears and sometimes a diagnosis. Session notes and client files therefore contain highly sensitive data, often under a strong confidentiality. On top of that the retention period varies greatly: a registered healthcare psychologist falls under a long statutory period, a coach does not. This guide shows what you keep and how to destroy the files confidentially.
The quick answer: the administration you keep for seven years for the tax retention obligation. For a registered healthcare psychologist a medical treatment law applies with twenty years. A coach without a medical title keeps session notes until a set period after completion. Because the files are highly sensitive and fall under confidentiality, you destroy them at a fine level, with a certificate.
Why session notes are highly sensitive
A session note is about a client's inner world: thoughts, feelings, events and sometimes a psychological diagnosis. That is exactly the kind of information someone writes down nowhere else. For a registered healthcare psychologist it is health data, special-category personal data with the strictest rules. For a coach without a medical title it is often not formal health data, but highly sensitive information that calls for the same care.
The GDPR requires storage limitation and an appropriate level of security. Do not keep the file longer than the applicable period and destroy it so that nothing remains reconstructable. The confidentiality that applied during the supervision applies at its end too.
Retention periods: healthcare psychologist versus coach
The period depends greatly on your role. The overview below gives the main line. Count the tax period from the end of the financial year and the other periods from the completion of the trajectory.
| Situation | Starting point | Period |
|---|---|---|
| Administration and invoicing | Tax retention obligation | 7 years |
| File of a registered healthcare psychologist | Medical treatment law | 20 years |
| Session notes of a coach (no medical title) | Policy and professional rules | period after completion |
| Health or diagnosis data | Special-category data | destroy finely |
| Intake and contact details | While the trajectory runs | + period |
| Working notes and drafts | No retention obligation | clear out at once |
Use this as a guideline, not a final legal ruling. If you are a registered healthcare psychologist, the medical treatment law applies, as described in the 20-year retention of patient files. If you are not, set the period in your own policy. The tax side is in the 7-year tax retention obligation.
Know which regime applies to you
The biggest misconception is assuming the same period applies to everyone. A registered healthcare psychologist falls under the medical treatment law and keeps the file in principle for twenty years. A life coach, career coach or non-registered therapist does not fall under it and sets the period themselves, matching the sensitivity of the data and any professional rules. So know which regime applies to you before you destroy anything, so you do not throw away too early or keep unnecessarily long.
Confidentiality through to destruction
Coaching and therapy are all about trust. What a client shares stays within the session, often recorded in an agreement or professional code. That confidentiality carries through to the clearing out and destruction of the file. So a session note never belongs in the ordinary paper bin or a shared waste container. Treat the most sensitive parts separately and destroy them at a fine level once the period has expired.
How to handle it in 6 steps
- Determine your regime: registered healthcare psychologist, or coach with own policy.
- Split the file into administration, session notes and sensitive data.
- Clear out working notes without a retention obligation confidentially at once.
- Assess per file whether the trajectory is completed and the period expired.
- Collect what may go in sealed containers, not in the paper bin.
- Have it destroyed confidentially with a certificate and record it in your register.
Destroy confidentially with a certificate
Client files are destroyed confidentially at a fine level, because they contain highly sensitive and sometimes medical data. The paper and any data carriers travel sealed and stay that way until destruction, so the chain is closed. An old computer or backup with files belongs with it too.
Afterwards you receive a certificate of destruction with the date, quantity and level. That certificate is your proof towards the GDPR that you upheld confidentiality to the end. Record the destruction in your record of processing. We collect within 20 km of Amsterdam with no call-out charge, work nationwide through pooled collection rounds and charge a fixed price per box or roll container. Drop-off on site is not possible; it works by appointment through collection.
Client files to be destroyed?
Tell us what you have and you get a fixed price. We collect it sealed, destroy it at a fine DIN level and you receive a certificate for your GDPR file. No call-out charge within 20 km of Amsterdam.
Request a quoteCommon mistakes
- Thinking a single period applies. Registered healthcare psychologists fall under the medical treatment law (20 years), coaches do not.
- Destroying too early as a registered psychologist. The statutory period is long and binding.
- Forgetting confidentiality when clearing out. Confidentiality applies through to destruction.
- Throwing away unshredded. A session note on the street is a serious data breach.
- Keeping no proof. Without a certificate you cannot demonstrate the destruction.
Frequently asked questions
How long does a coach or psychologist keep session notes?
The administration falls under the seven-year tax retention obligation. For a registered healthcare psychologist a medical treatment law applies with a twenty-year period. A coach without a medical title keeps session notes until a set period after completion, based on policy and professional rules.
Do session notes fall under special-category personal data?
Often yes. Notes about mental health, stress, addiction or relationships are sensitive data and sometimes health data. Treat the file with extra care and destroy it at a fine level.
Does a duty of confidentiality apply to coaching?
Yes. What a client shares in a session is confidential, often recorded in an agreement or professional code. That confidentiality carries through to the clearing out and destruction of the file.
How do I destroy client files in line with the GDPR?
Confidentially and at a fine level, with a certificate of destruction. Paper and data carriers travel sealed and the destruction is recorded in the record of processing.
Conclusion
A coach or psychologist works with the most sensitive data there is, under a strong confidentiality. Know which regime applies to you: a registered healthcare psychologist keeps the file for twenty years under the medical treatment law, a coach sets the period themselves. Keep the administration seven years, treat health and diagnosis data separately and assess per file whether the period has expired. What may go you have destroyed confidentially at a fine level, with a certificate as proof. That way you uphold your clients' trust to the end.
Read also: gyms and fitness clubs: destroying member data, tattoo and piercing studios: destroying consent forms, beauty salons: destroying client data and the GDPR retention periods cheatsheet.
Have client files collected? Request a quote via desnipperaar.nl. Within a few minutes you have a fixed price, including a certificate as proof.