Talks with Representatives of the Polish Psychotherapy Council on a Code of Conduct

Representatives of the Personal Data Protection Office met with delegates of the Polish Psychotherapy Council. During the meeting, they discussed issues related to the processing of personal data in connection with the provision of psychotherapeutic support, as well as the possibilities of developing a code of conduct for this sector.

Polish Psychotherapy Council representatives outlined the specific nature of the profession and the work of psychotherapists, drawing particular attention to the absence of a single, comprehensive legal framework for the sector that would set out the rules for providing psychotherapeutic assistance, including the manner in which personal data are processed. They emphasised that psychotherapists collect information on mental health, emotions and other intimate aspects of the lives of those to whom they provide psychotherapeutic support.

During the meeting, staff of the Personal Data Protection Office discussed issues related to planning work on the code of conduct, highlighting the essential elements such a code should contain, in line with EDPB Guidelines 1/2019 on Codes of Conduct and Monitoring Bodies under Regulation 2016/679. Among other things, they discussed the material and personal scope of the proposed code. The discussion also covered the procedure for approving the code of conduct by the President of the Personal Data Protection Office. Staff encouraged participants to consult the information available on the Office’s website in the Codes of Conduct section. They also drew attention to the guidelines of the European Data Protection Board, which—similarly to case law—should be appropriately taken into account by the authors of the code (point 38 of EDPB Guidelines 1/2019).

Representatives of the Polish Psychotherapy Council stressed that the meeting had provided them with a great deal of practical information that would help accelerate their work on the code of conduct.