2.2.4. Personal working notes

2.2.4 Personal working notes

Personal working notes the psychologist makes do not belong in the file (see Article 1.14, “File”). What exactly should be understood by “personal working notes” seems, in practice, to generate quite a few misunderstandings. It means personal impressions the psychologist has, conjectures they make, and questions they pose – all meant to help them remember their thinking. These notes are usually temporary in nature: when the psychologist believes they are no longer relevant, they must destroy them. If the personal working notes are included in the file, the client also have rights to inspect, and get a copy of, them. It is therefore important to keep personal working notes separate, or screened off – possibly by digital means – from the file. “Personal working notes” decidedly does not mean the notes on conversations, or the observations and impressions the psychologist has about the client. On the contrary: these are relevant to the professional relationship, and thus belong to the file.

The file is, in principle, accessible only to the client, the psychologist, and to employees under the psychologist’s immediate supervision, such as testing assistants and secretarial staff. In the case of proceedings pursuant to a complaint, the file is also accessible to members of the NIP’s disciplinary bodies for inspection, to the extent that it is of significance for the assessment of the complaint. It is advisable for the psychologist to approach with caution their right to defend themselves with the help of the file (see Article 37, “Use of a File in filing a defence”). For the management and contents of the file, see section 2.4, “File management”.