Please note: This draft document is complementary to Annexure 12 of the ethical rules of conduct for practitioners registered under the Health Professions Act, 1974 – Professional board for psychology rules of conduct pertaining specifically to the profession of psychology.
The draft guidelines are intended to aid psychologists currently using or planning to use internet and telecommunication technologies in the provision of psychological services.
Glossary of terms
Psychologist – a person registered under the act as a psychologist as defined in Annexure 12 within the Clinical, Counselling, & Educational Psychologist categories.
Online therapy – any psychological service provided through E-mail, Skype, texting, synchronous or asynchronous messaging, social networks such as Facebook, Twitter etc, chat rooms and online phone systems with or without cameral or voice options.
Cultural Competence – training in working with people from diverse cultures (this includes familiarity with colloquial expressions, idioms, local variations in word use etc).
1. Competence
1.1 A psychologist shall develop and maintain cultural competence as a prerequisite to practising online therapy.
1.2 A psychologist shall undertake certified training in the use of computers, viruses, firewalls, and the internet in relation to the provision of psychological services.
1.3 A psychologist shall be aware of the effectiveness and evidence of technology-based interventions they use and of any identified risks associated.
1.4 A psychologist shall be competent in educating the client on the technological processes entailed when contracting for this mode of therapy.
1.5 A psychologist shall (following training) receive a minimum of one year of supervision in online therapy before sole practice in this mode of therapy.
1.6 A psychologist practicing online therapy should obtain a minimum of 3 CPD points in this area each year.
1.7 A psychologist practising online therapy must practice within his/her own scope of practice (i.e. Clinical, Counselling, and Educational).
2. Informed Consent
2.1 When the psychologist provides therapy/assessment, he/she should obtain written consent / encrypted signatures electronically.
2.1.1 In the case where written consent cannot be obtained, for example electronically on the psychologist’s webpage, - consent is valid by virtue of checking a box at the end of the web page with information about the process of online therapy. Failure to do so would consequently prohibit access to the next page of setting up an appointment. Consent may also be obtained by completion of a mini multiple choice questionnaire by the client to show understanding of informed consent. See example in Appendix A.
2.2 Informed consent should be educational and informative about the process, benefits, limitations and possible risks of the mode of therapy and the voluntary nature of participation.
2.2.1 In relation to limits, the psychologist shall inform the clients:
· That communications, like face-to-face, telephonic, faxed and other written communications, have the potential to be intercepted and what steps the psychologist has taken to prevent this.
· How information and conversations will be recorded, used and stored.
· Email and SMS messages may not be received for technical reasons, and that this could cause inadvertent distress etc.
2.3 The psychologist shall make available their details, that is, name, qualification HPCSA registration number and postal address with a link to where these details may be verified (e.g. contact details of the HPCSA and HPCSA web register.).
2.4 The psychologist shall explain how information and conversations will be recorded, used and stored.
2.5 The psychologist shall clarify operating hours.
3. Privacy and Confidentiality
3.1 A psychologist shall safeguard the confidential information obtained during the course of his practice i.e.
3.1.1 The psychologist shall ensure encryption of his e-mails and educate his/her client on how to encrypt their e-mails.
3.1.2 The psychologist shall install appropriate antivirus and anti spyware programs on his or her devices and educate his/her clients about the use of this software and the importance of using such software.
3.1.3 Secure password shall be used and changed regularly.
3.2 For provision of services, for example via Skype, the psychologist is to ensure, at least on his/her part that such interactions are done in a private environment.
3.3 The psychologist shall inform the client of possible limits to confidentiality due to the nature of technology, and educate the client on possible ways to protect their information.
4. Fees and Financial arrangements
4.1 A psychologist shall not require upfront payment for services not yet rendered.
4.2 Billing should fall within an acceptable range as set by the HPCSA for this mode of therapy.
4.3 A psychologist shall establish with clients ‘secure’ ways of paying accounts, which may mean obtaining credit card details by phone rather than via email, allowing cheques to be sent after sessions or using secure online payment methods.
4.4 The psychologist is to be clear with the client about the structure of charges for each session (e.g. asynchronous email counselling rates may be different from synchronous email counselling rates).
4.5 The psychologist may charge for single missed scheduled synchronous sessions but may not charge for a series of sessions booked in advance and missed by the client.
5. Advertising and Public Statements
5.1 A psychologist shall not provide false testimonials as part of the advertisement of online therapy.
5.2 The psychologist shall make available their details, that is, name, qualification and registration number with a link to where these details may be verified (e.g. contact details of the HPCSA).
Additional Notes
· Practice as an online psychologist should be certified by the HPCSA.
· For intricate issues such as suicide or illegal substance abuse, the psychologist shall perform adequate pre-assessment checks by use of questionnaires before continuing into therapy.
· As part of the duty to warn, a psychologist shall take on an online client from a different geographical area only if he (psychologist) has adequate information and contacts in the same area as the client in case of emergency referrals.
· A psychologist shall obtain a licence to use any formal online assessments and he/she shall use only reliable and valid online assessments. – the psychologist shall be aware of the limitations of ‘blind’ test interpretation, that is, interpretation of tests in isolation without supporting assessment data and the benefit of observing the test taker.
· A psychologist shall use professional language to maintain appropriate boundaries and convey to clients the anticipated extent of SMS or email use and operating hours.
· Where possible the psychologist is to monitor and take responsibility for the personal information about them available on the internet.
· Psychologists may seek to gain further information about the client from an internet search only if it is in the justifiable best interest of the client and not just to satisfy the curiosity of the psychologist.
· It is essential to keep a secure back-up version of records in an accessible form.
· Any face-to-face meetings with online/electronic clients should be expressly contracted for by both parties, and should not be social in nature or purpose, and should be held in an appropriate professional environment.
References
American Psychological Association. (2002). American Psychological Association ethical principlesof psychologists and code of conduct. Including 2010 amendments. Retrieved from http://www.apa.org/ethics/code/index.aspx
Australian Psychological Society. (2011). Guidelines for providing psychological services and products using the internet and telecommunications technologies. Retrieved from http://aaswsocialmedia.wikispaces.com/file/view/EG-Internet.pdf
Fisher, C.B., & Fried, A.L. (2003). Internet-mediated psychological services and the American psychological association ethics code. Psychotherapy: Theory, Research, Practice, Training, 40, 103-111.
Appendix A
Informed consent
1. Online therapy:
a) Has no risks at all
b) Has some limitations
2. There is need for a secure password
a) Always
b) Never
c) Sometimes
3. I can freely withdraw from the process of online therapy
a) Yes
b) No
4. I am informed and understand the limits and advantages of online therapy
a) Yes
b) No