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The Confidentiality Imperative: Why Therapy Should Remain Independent from Your Organization

By March 26, 2024No Comments


As part of meetings with prospects, I am often asked why we insist on mental health professionals delivering wellbeing services sitting outside the organization. Many of our BPO customers understand the need to have any therapy solution sitting outside their operation, and in many cases, the end client has also insisted. For our direct customers, they understand the need to boundary the work carried out by our therapist and ensure protection on both sides. 

Any organization that wants to provide a valuable therapy service to their employees must ensure the therapist is employed by a separate company, and that session notes and calendars are not held on internal systems.  

A new poll commissioned by NAMI of more than 2,000 working adults in the United States found that nearly three-quarters (74%) of employees indicated that it is appropriate to discuss mental health concerns at work, but only 58% say they would personally feel comfortable doing so. There is extensive research around the stigma of talking about mental health issues at work, and a high proportion of people are genuinely concerned that if they talk about depression or anxiety, it will be held against them in some way.  

Especially with Content Moderators, where the role is recognized to be deeply challenging with the potential to result in mental health difficulties or exacerbation of existing mental health challenges, we need to ensure that they can access services with no concern about it being held against them in the future by their managers or peers. Encouraging people to access therapeutic services will help ensure that their well-being is not impacted in the short term and that they can remain a team member for the medium to long-term. Psychological safety – the shared belief that it is acceptable to take risks, admit mistakes, express ideas and concerns, and speak up with questions without being penalized – plays a huge role in mental health service engagement at work, and having external professionals delivering these services will enhance this feeling amongst Content Moderators. 

Conflict of Interest 

The main reason you need to ensure therapists and clients (your employees) don’t work for the same company is conflict of interest – you need to ensure that the client is given the best guidance and support by the therapist without any potential harmful consequences. Internal therapists may face conflicts of interest when dealing with issues involving colleagues or superiors, whereas external therapists are free from these conflicts, allowing them to focus solely on the wellbeing of the individual. 

It’s important to note that clinically sound practitioners follow clear professional and ethical guidelines. However, the water can be muddied much more easily when therapists work for the same company as their clients. Governing bodies often outline practices related to conflict of interest to minimize these concerns. For example, under section 4.4 Conflicts of Interest and Exploitation from the Psychological Society of Ireland’s Code of Professional Ethics, it is stated that practitioners should: 

Be acutely aware of the problematic nature of dual relationships (with, for example, students, employees or clients), and recognise that it is not always possible to avoid them (for example, when offering services in a small community, or engaging in person-centred teaching or training). Where it is possible, psychologists shall avoid such relationships; where it is not, they take active steps to safeguard the students’, employees’ or clients’ interests (p. 18). 

Whilst it may not always be possible to avoid dual relationships and conflicts of interest, mitigating this risk by sourcing external therapists is an intelligent and feasible solution that will better serve your employees in the long run. 

Understanding More About Dual Relationships 

Potential impacts of utilizing internal therapists

Internal therapists may have pre-existing relationships with employees or management within the organization, such as friendships or professional connections. When these relationships overlap with their therapeutic role, these are considered dual relationships and can create conflicts of interest. For example, an internal therapist who provides regular consultation to a manager about their team may find it more difficult to maintain impartiality when providing counseling to that manager’s subordinates. 

In organizations with clear hierarchies, internal therapists may feel pressure to prioritize the interests of senior management or executives over those of lower-level employees. After all, their jobs may also be on the line. This can compromise their ability to provide fair and equitable treatment to all individuals within the organization. For instance, an internal therapist may hesitate to address issues of workplace bullying or harassment involving a high-ranking executive for fear of repercussions. 

Internal therapists may also face challenges in maintaining confidentiality when dealing with sensitive issues that have implications for the organization. For example, if an employee discloses unethical behavior or legal violations during therapy sessions, the therapist may feel conflicted about whether to report this information to management, potentially breaching the trust of the client. 

Other Reasons for Pause 

Conflict of interest is the main concern, but there are others.  

  • Confidentiality – Employees may feel more comfortable sharing sensitive information with an external therapist, knowing that their discussions are confidential and won’t impact their career within the organization. This can facilitate more open and honest communication, leading to more effective therapy outcomes.  
  • Objective Perspective – External therapists are not influenced by internal politics, biases, or preconceptions. They can provide an unbiased perspective on organizational issues and individual challenges without being swayed by internal dynamics. 
  • Neutrality – External therapists can maintain neutrality in situations where there are interpersonal conflicts or organizational tensions. Their impartiality can help facilitate conflict resolution and mediation processes more effectively. 
  • Fresh Perspective – External therapists can introduce new ideas, techniques, and approaches that may not be readily available within the organization. Their fresh perspective can stimulate innovation and growth in the therapy process. 
  • Crisis Intervention – In times of crisis or organizational change, external therapists can provide timely support and intervention without being directly affected by the situation. Their external viewpoint can help navigate through turbulent times more effectively. For example, when redundancies occur, internal therapists may be concerned about their own roles whereas external therapists will not be impacted. 

The Zevo Way 

Our experience over the years has demonstrated that any customer employee can become a therapy client at any stage therefore, minimizing the development of any dual relationships to avoid conflicts of interest is imperative.  

One of the most important aspects of our Wellbeing Specialist training and policy development is around boundary setting practices. We highlight the potential harms of engaging in dual relationships and provide clear guidance on how to handle any such cases. For example, if a Wellbeing Specialist is newly employed with Zevo and realizes that they have a pre-existing relationship with a customer employee (a childhood friend, for example), we ask our Wellbeing Specialists to redirect this employee to another Wellbeing Specialist for support to avoid any potential conflict of interest. 

Other measures we put in place include discouraging Wellbeing Specialists from “hanging out” socially with any of our customer’s employees in the office environment. We encourage friendliness to support effective relationship building and service engagement such as saying hello in micro-kitchens or common areas, but if someone begins disclosing concerns or challenges that should be explored and addressed in a therapeutic space, we train them to redirect the conversation to protect confidentiality and anonymity of all end clients. If our Wellbeing Specialists see customer employees outside the office environment, we follow the rule of thumb to allow the customer employee to “make the first move”. We also suggest that our Wellbeing Specialists do not accept invites from customer employees on social media, as the online space reflects our physical space. 

Finally on the topic of session notes, we have heard some horror stories where highly confidential notes from sessions were accessible on internal customer systems where managers or other personnel could view them. If you consider what is disclosed in a counselling session or group intervention space, this is deeply personal and highly sensitive data that needs to be protected. External therapists will have dedicated devices and case management systems that are separate from their customers, ensuring the employee has trust in the process and that their confidentiality is protected while engaging in services. 


Whether the moderation work is being done internally within the organization or externally with an outsourced BPO, we believe the therapeutic services must be delivered by a separate supplier. This enhances psychological safety in the organization, which enhances support seeking – or service engagement. It also ensures risk mitigation of conflicts of interest and the maintenance robust confidentiality practices.  

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