Four recurring risks in psychological practice: mismanaged multiple relationships, poor records and reports, intoxication, and unmanaged impairment.
Psychological practice contains uncertainty. Roles can overlap, reports are written with incomplete information, psychologists become unwell, and medication can have unintended effects. None of these circumstances automatically means that a psychologist has acted negligently or engaged in professional misconduct.
The greater risk often lies in how the situation is managed.
A competing role is allowed to continue without examining the conflict. Important clinical reasoning never reaches the record. A practitioner notices that alcohol or medication is affecting their performance but continues working. A health condition begins interfering with judgement or reliability, yet there is no independent advice, modification of duties or plan for continuity of care.
Borrowing loosely from the “four horsemen” metaphor used in relationship research, four recurring failure points can be identified:
These four are not equivalent legal or regulatory categories. Intoxication while practising and impairment are expressly addressed in the mandatory notification framework. Multiple relationships and record-keeping usually require a more contextual assessment of the psychologist’s conduct, the risks created and the seriousness of any departure from accepted professional standards. A minor delay in completing a note is not equivalent to providing a service while intoxicated.
The categories nevertheless have something important in common. Each can remove safeguards that would otherwise help a psychologist notice risk, explain their reasoning, seek advice and change course before a client is harmed.
The term “dual relationship” is widely used, but the current Psychology Board of Australia Code of conduct uses the broader term multiple relationships.
A multiple relationship can arise when a psychologist provides different services to the same person, has another personal or professional association with the client, works with people connected to the client, or provides a service to several connected clients. This might include acting as both a treating psychologist and forensic assessor, treating someone the psychologist supervises or employs, or providing individual and family-based services where the interests of the people involved may diverge.
The existence of more than one role is not the whole ethical analysis. Some overlapping relationships are avoidable. Others arise in rural communities, small professional networks, multidisciplinary services, schools, organisations or other settings where complete separation may not be realistic. The relevant questions are what risks the roles create, whether the arrangement should continue, and whether those risks can actually be managed.
Section 4.9 of the Code is relatively direct. Psychologists must avoid or discontinue multiple relationships unless they reasonably believe they are ethically, legally or organisationally obliged to enter or continue them. If a psychologist does proceed, the Code describes safeguards that include:
This is where multiple relationships are often mismanaged. The psychologist may recognise that the situation feels complicated but never clearly defines the roles. Consent is treated as a one-off form rather than an ongoing process. Confidential information obtained in one role begins influencing decisions made in another. The psychologist informally reassures themselves that they can remain objective, but does not obtain consultation or record the reasoning behind that conclusion.
Power also matters. A client, employee, supervisee or provisional psychologist may technically agree to an arrangement while having limited freedom to refuse it. Consent does not remove a conflict of interest or make an unsafe arrangement safe.
The practical response may involve clarifying roles, separating decision-making, changing supervisors, referring one component of the work, establishing limits on information-sharing or ending one of the relationships. The response depends on the setting, but it needs to address the actual mechanism of risk.
For a more detailed discussion, see Dual Relationships in Psychology: What the Ethics Actually Say.
Record-keeping is sometimes treated as an administrative task that sits beside clinical work. In practice, the record is part of the clinical work.
Section 8.5 of the Code requires records to be accurate, current, factual, objective, legible and accessible. They should contain relevant details of the service, be understandable to other practitioners, support continuity of care, remain secure, and be completed at the time of the event or as soon as possible afterwards.
The requirement is not to document every thought or produce a transcript of every session. A useful record should allow another appropriately qualified practitioner to understand what occurred, what mattered clinically, what decisions were made and what needs to happen next.
Depending on the service, that can include:
Sparse records create obvious continuity problems, but excessive records can create different problems. Notes filled with irrelevant personal detail, speculation or emotionally charged descriptions may obscure the clinical information and expose clients to unnecessary privacy risks. The Code requires records to be respectful and not contain demeaning or derogatory remarks.
Records also should not be reconstructed later to create the appearance that a decision was made contemporaneously. If a late entry is necessary, it should be identifiable as a late entry. The record should show what was known and decided at the time, not a cleaner version of events assembled after a complaint or adverse outcome.
Formal reports create an additional set of risks. Section 8.9 requires psychologists to make statements they know, or reasonably believe, are true and objective. It also requires them to identify the limits of their knowledge and competence, take reasonable steps to verify content, avoid deliberately omitting relevant information, and remain honest and unbiased.
That becomes particularly important when a report may influence diagnosis, employment, education, parenting arrangements, legal proceedings, access to funding or another practitioner’s treatment decisions. A confident tone cannot compensate for missing data or an opinion that extends beyond the psychologist’s evidence.
Good documentation does not guarantee that a decision was correct. It makes the decision visible enough to be reviewed, questioned and corrected.
Practising while intoxicated by alcohol or drugs is one of the four concerns expressly identified in the AHPRA mandatory notification guidelines.
The guidelines use intoxication in its ordinary sense of being under the influence of alcohol or drugs. “Drugs” can include illicit substances, prescribed medication and over-the-counter medication. The relevant issue is not whether the substance was lawful or medically prescribed. It is whether its effects impaired or adversely affected the practitioner’s reasonable care and skill while practising.
This does not mean that psychologists taking prescribed medication should be presumed unsafe. Many practitioners use medication without any impairment in their work. The concern arises when the effects interfere with functions required for safe practice, such as:
Timing matters. Alcohol or another substance may have been consumed outside working hours, but residual effects can continue into practice. Conversely, intoxication in a practitioner’s private life is not, by itself, the mandatory notification category of practising while intoxicated. Another concern may arise if the broader circumstances affect practice, but off-duty substance use and intoxication while practising are not interchangeable.
The immediate response to suspected intoxication should focus on safety. This may include stopping clinical work, ensuring clients are not left without support, arranging safe transport, obtaining medical assistance when needed, and escalating the concern through appropriate workplace or regulatory processes.
It should not be handled as gossip or retrospective character judgement. A mandatory notification requires the applicable legal threshold to be met, including a reasonable belief grounded in more than rumour or speculation. The precise threshold also depends on whether the person considering notification is a treating practitioner, another practitioner or an employer.
Western Australia has a specific exception within the mandatory notification framework: treating practitioners who become aware of a concern while providing a health service to a practitioner-patient are exempt from making a mandatory notification in that treating capacity. Other legal, ethical or non-treating obligations may still apply. Psychologists should seek current advice when the distinction matters.
This category requires the most careful language.
Psychologists can experience disability, chronic illness, mental health conditions, trauma, acute stress, grief, pain, sleep disruption or medication side effects. The existence of a diagnosis does not establish that someone is unable to practise safely. Nor does needing treatment or workplace accommodation indicate a lack of competence.
AHPRA’s guidelines distinguish a health condition from an impairment. Under the National Law, impairment concerns a physical or mental impairment, disability, condition or disorder that detrimentally affects, or is likely to detrimentally affect, a person’s capacity to practise. An illness or condition without that functional effect is not an impairment for this purpose.
The regulatory and clinical question is therefore not simply whether the psychologist is unwell. It is whether the condition is affecting functions required for safe practice, what risk follows from that effect, and how the psychologist is responding.
Relevant functional changes might include:
Section 9.1 of the Code says psychologists should recognise how personal and work-related psychological risk factors can affect their health and ability to provide services. If they know or suspect that a health condition or impairment could adversely affect judgement, performance or client wellbeing, they should not rely solely on their own assessment of the risk. The Code directs them to obtain appropriate medical or other professional advice about whether and how service provision should be modified, follow treating advice, and remain aware of relevant notification responsibilities.
That response is deliberately more nuanced than “work as normal” or “stop practising completely”. Depending on the degree and type of functional impact, reasonable controls might include:
AHPRA’s notification guidelines expressly recognise that effective controls can reduce both the risk and the need for notification. Examples include treatment, sick leave, modified scope, strategies addressing the effects of impairment, and compliance with supervision or monitoring.
Insight and follow-through matter. A practitioner who recognises a change, seeks independent advice and adjusts their work presents a different risk from someone experiencing the same symptoms who denies their effect and continues without safeguards. The diagnosis may be identical; the management is not.
Documentation supports this process, but it needs to occur in the right place. A client record should document clinically relevant disruptions, communications, handovers and continuity arrangements. It generally does not need to contain the psychologist’s detailed private medical history. Decisions about workload, treatment recommendations, workplace adjustments or supervision may belong in separate employment, supervision or practitioner-health records, subject to applicable privacy and employment requirements.
The Code also requires reasonable continuity planning for emergencies, foreseeable absences and circumstances such as illness. This matters because unmanaged impairment can affect clients even without a dramatic clinical error. Repeated cancellations, abrupt termination, delayed reports or inaccessible records can each create harm when no contingency plan exists.
The four horsemen do not sit at the same level of seriousness, and they should not be used as a checklist for labelling a psychologist unethical. Their value as a framework is that they draw attention to four places where ordinary safeguards can fail.
| Risk area | What begins to fail | Safeguards that may be needed |
|---|---|---|
| Multiple relationships | Objectivity, role clarity, consent or freedom from undue influence | Avoidance, consultation, explicit role definition, contemporaneous records and ongoing monitoring |
| Records and reports | Continuity, accountability and visibility of clinical reasoning | Timely factual notes, documented rationale, verification, stated limitations and secure information management |
| Intoxication | Immediate cognitive, emotional or physical capacity | Stop practice, protect affected clients, obtain assistance and follow applicable workplace or notification processes |
| Illness or impairment | Capacity may fluctuate or decline without an adequate response | Independent advice, treatment, modified duties, monitoring, supervision and continuity planning |
Across all four areas, the relevant sequence is similar:
This framework does not decide whether a particular event constitutes negligence, unprofessional conduct, professional misconduct or notifiable conduct. Those questions depend on the facts, the applicable law, the seriousness of the departure and the relevant regulatory threshold.
It does show where preventable risk often accumulates. The concern is not simply that a psychologist encountered a complicated relationship, wrote an imperfect note, took prescribed medication or became unwell. It is whether the resulting risk was recognised, communicated, documented and managed in a way that continued to protect clients.
PsychVault's provisional psychology hub brings together practical guidance on boundaries, competence, mandatory notifications, supervision and the systems surrounding safe psychological practice.
Terminology note: The four horsemen are an educational framework used in this article. They are not four equivalent legal findings, regulatory categories or automatic grounds for notification.
This article provides general educational information and is not legal, regulatory or clinical advice. Requirements may vary by jurisdiction, work setting and the role of the person considering a notification. Information is current as at 30 August 2026.
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