Counseling Boundaries Policy

This Rules/Policy document is provided to you and your organization as a starting point or maturity checkpoint for existing rules/policies. It is brought to you on behalf of Jim McConnell, Principal Owner, and Ask McConnell, LLC — A Converged Security Services Provider. The content is not meant to cover every circumstance, industry, law, regulation, contractual requirement, threat, environment, or risk, but it provides an easy, defendable, highly accountable starting point for any organization. Please consult with your legal counsel and insurance provider about added requirements. If you know of peers that you think would find value in these resources, please have them contact us. These will be updated on our website regularly. We are not legally protecting these documents; we just ask for credit, shout-outs, and referrals if you find them helpful. If you have recommended updates, we are all ears. And if you need Converged Security Consulting and Training, please reach out, we would be honored to serve you and your organization.

Jim McConnell  |  info@askmcconnell.com  |  askmcconnell.com

Counseling Boundaries Policy

Updated: 22 June 2026

Counseling — whether in a corporate, NGO, or faith-based setting — can be a powerful tool to help individuals overcome personal and professional challenges or prepare them to seek further professional help. In a corporate context, this may take the form of a supervisor or HR professional discussing performance or personal matters. In an NGO or faith-based organization, counseling sessions are far more likely to involve deeper, more sensitive, and more serious disclosures.

With that depth comes the need for clear boundaries — not as guidelines, but as policy. Violations of these boundaries, or any allegation or actual criminal act (intimate violations, fraud, physical altercations, threats, etc.) arising from a counseling session, may constitute a crime that the organization and law enforcement must manage and investigate.

Key Definitions:

Counseling — The process by which a professional (preferably licensed) assists a person or persons in coping with professional issues, mental or emotional distress, managing health conditions, and addressing life stressors.

Scope: These rules apply to all counseling functions performed by a staff member or volunteer, including topical counseling that can escalate — such as marriage, debt, or career counseling.

Note: Do not attempt to re-label counseling activities as “mentoring,” “discussions,” “leadership development,” “performance improvement plans,” “therapy,” or any other term to avoid the requirements of this policy. The nature of the activity — not its label — determines scope.

Requirements:

  • I will not conduct a counseling session:
    • With a member of the opposite biological sex, without a second person present
    • In a room without a door window or visibility from outside
    • Without a physical barrier between all parties (such as a coffee table)
    • With me, as the counselor, positioned by the door — this can create the perception of detainment
    • If I am not trained, preferably by a nationally recognized accrediting organization
    • If I am not licensed in an area that requires a licensed professional
  • I will report to law enforcement and the organization’s security team any mention of what might be perceived as violence or a threat — whether against another person or against the person in the room.
  • I will only provide personal experience and expert guidance that I could defend in a court of law or in the court of public opinion.
  • In a corporate setting, I will report any significant emotional response to HR and Security for a possible EAP referral.
  • I will only refer individuals to outside organizations that have been vetted by my organization and for which I have personal due-diligence knowledge of their integrity and value to the person being counseled.
  • I will not counsel a close personal friend in matters that introduce a conflict of integrity or confidentiality.
  • I will maintain HIPAA-level (USA) confidentiality unless explicitly instructed otherwise. Even when not legally required, I will maintain strong confidentiality practices.
  • I will maintain written records of each session and any recommendations provided.
  • I will not promise complete confidentiality, as certain disclosures may require reporting.
  • I will recognize and navigate the balance of any ethical, organizational, or religious principles that arise during counseling activities.

Final note: True counseling can be a powerful tool — but the caution bears repeating: do not re-label counseling activities as “mentoring,” “discussions,” “leadership development,” “performance improvement plans,” or “therapy” to sidestep this policy. The activity defines the obligation.

Related Resources

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