Report of the IPA Confidentiality Committee (English)

wishing to continue to work remotely or to begin doing so, will seek ways to mitigate the risks, and this will mean becoming as fully aware as possible of the nature and extent of the risks. Hitherto, IPA members have been advised only to “satisfy themselves that the technology they are using is secure and protects the patient's confidentiality.” 14 For the reasons given above this advice can no longer be considered sufficient. Members need to be aware that they cannot offer, either explicitly or implicitly, an unlimited guarantee of confidentiality in relation to work conducted using telecommunication. If they wish to undertake such work they will therefore need to consider carefully how this affects the nature of the analytic contract that they enter into with each patient, and how it affects the treatment. One possibility might be to warn the patient at the outset about the risks to privacy and for both analyst and patient to accept any disturbance this may cause to their work, including any interference with the patient’s willingness to say whatever comes to mind, or with the analyst’s freedom to interpret. Currently, most psychoanalysts lack the necessary technical knowledge to enable them to evaluate their own capacity to protect the privacy of their telecommunications. 15 In future, IPA members who wish to make informed decisions about remote working will need to satisfy themselves that they have educated themselves sufficiently about the nature of technology they are using or plan to use. On the most pessimistic view identified in 4.4 above, if personal electronic devices are regarded as now being no less vulnerable to eavesdropping in the classical setting than they are in the telecommunicative setting, even those IPA members who do not work remotely may need to review their practices regarding their allowing such devices to be in or near the consulting room. For example, isolating a mobile phone electromagnetically and acoustically may remove or substantially reduce this vulnerability, but this may depend on how and where it is done. 16 A shielding device also inevitably introduces a parameter into the situation whose full impact is unknowable. 14 IPA (2017) 15 Anecdotal evidence suggests that security precautions adopted by psychoanalysts to protect information in their computers, phones, and other devices, are often weak or non-existent. Unencrypted email, documents with weak or non-existent password protection, out-of-date protection against malware, weak anonymisation of patients, all endanger confidentiality. 16 Electromagnetic shielding devices based on the principle of the Faraday Cage are widely and cheaply available, but their effectiveness varies between different models and depends on other factors. See: Katz (2010). A more sophisticated device, intended for use by journalists, activists and rights workers, is currently under development by Huang and Snowden (2017), who give a detailed account of this work. Note that acoustic isolation would also be required in order to prevent offline recording which could be transmitted at a later time.

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