Psychologist software in Switzerland: what it must do

Psychologist software in Switzerland is the set of tools that hold your client records, session notes and reports and, often in a separate tool, your calendar and your invoices to health insurers. What matters is that every obligation you carry (the Swiss data protection act, professional secrecy, cantonal health law, billing rules) maps to a specific function in the tool.

Before you choose: how you practise

Your needs depend first on how you work. To practise psychotherapy under your own professional responsibility, the Psychology Professions Act (LPsy, art. 22) requires authorisation from the canton where you work. Since 1 July 2022 you can bill basic health insurance (AOS) on a doctor's prescription.

• You bill basic insurance: you need billing software that follows your canton's tariff, tracks prescriptions and produces electronic invoices.
• You work mostly privately or under LCA: a clear invoice, possibly with a QR bill, is often enough; the main issue becomes the client record.

What the law requires, and the function that answers it

Quotes are our translations of the official French texts.

1. Sensitive data, so security to match

The FADP lists as sensitive data (art. 5(c)(2)) data on health, private life or racial or ethnic origin. Art. 8(1) adds that controllers and processors must ensure data security that is adequate to the risk, through appropriate technical and organisational measures. The Data Protection Ordinance (OPDo) (art. 3) spells out what this covers, including access control and rapid restoration after an incident.

Function to expect: encryption in transit and at rest, a personal account for each user, two-factor authentication, automatic lock after inactivity, backups whose restoration has been tested.

2. A vendor under a processing agreement

Art. 9(1) FADP allows you to entrust data to a processor if a contract or the law provides for it, and if no legal or contractual duty of secrecy forbids it. Art. 9(3) says the processor may only bring in a further subprocessor with the controller's prior authorisation.

Function to expect: a signed agreement, the vendor's list of subprocessors (hosting, SMS and email delivery, AI provider) and a commitment to tell you before adding one.

3. Professional secrecy, including towards your assistants

Art. 321 of the Swiss Criminal Code punishes psychologists "and their assistants" who disclose a secret entrusted to them because of their profession. The LPsy (art. 27(e)) makes secrecy a professional duty, and the FSP code of ethics (art. 16) requires members to instruct assistants about secrecy, in writing.

Function to expect: role-based access. The assistant or colleague who handles the calendar sees appointments, not notes. No reason for consultation in an appointment title or in an SMS reminder.

4. Knowing where the data is

The FADP does not require hosting in Switzerland. Art. 16 allows disclosure abroad to a state whose data protection the Federal Council has recognised as adequate; the list is in annex 1 of the OPDo. Our FADP guide for psychologists and therapists (in French) covers this and the other cases.

Function to expect: the country of storage and processing written into the contract, for every subprocessor, AI included.

5. Answering an access request

Under art. 25 FADP, anyone can ask the controller whether personal data about them is processed, and receives in particular the personal data itself. Cantonal law adds its own rules. Vaud explains that clients can consult their file and obtain copies, in principle free of charge, but that the practitioner's personal notes and information about third parties are excluded (art. 24 LSP).

Function to expect: exporting a client's complete record in a few clicks, with a clear line between the record and your personal notes.

6. Keep for a long time, then destroy

The FADP sets no retention period, but requires data to be destroyed or anonymised once it is no longer needed (art. 6(4)). Cantons set the period. In Geneva, art. 57 of the health act requires at least ten years after the last consultation, and destruction after twenty years at the latest unless there is an overriding interest. In Vaud, the file is kept at least ten years after the last consultation (art. 87(5) LSP). The FSP code (art. 20) also requires files to be kept for at least ten years.

Function to expect: a full export in a format you can read without the software (PDF, text), a plan for what happens if you cancel, and the ability to delete a file once its period has ended.

7. Being told about a breach

Art. 24(3) FADP requires the processor to report any data security breach to the controller as soon as possible. It is then up to you to assess whether to report it to the Federal Data Protection and Information Commissioner (FDPIC).

Function to expect: that commitment written into the contract, with a contact you can reach.

Billing in 2026: TARMED, TARDOC or something else?

According to the Federal Office of Public Health, since 1 January 2026 outpatient medical services are billed with a global tariff system (TARDOC plus flat rates) that replaces TARMED. Psychotherapy provided by psychologists has its own tariff. According to the provider page of the insurer CSS, where the canton has set a provisional tariff, you bill with that tariff directly to the insurer (tiers payant). A definitive tariff structure was submitted to the Federal Council on 18 December 2025, with entry into force planned for 1 January 2027, according to the FSP. We suggest asking your vendor where approval of this structure stands and how it follows your cantonal tariff until then.

CSS asks that a basic insurance invoice sent to it include in particular:

• the tariff, item number, quantity, tariff points and point value;
• your RCC number, and the GLN of both the responsible therapist and the therapist who delivered the session;
• the prescribing doctor's RCC number and GLN;
• the diagnosis coded in ICD-10.

These are one insurer's requirements: we suggest checking those of your clients' other insurers. CSS accepts electronic invoices in the current XML standard. Also according to CSS, one prescription covers at most 15 sessions (or 10 for crisis intervention or brief therapy, where applicable), and if therapy continues beyond 30 sessions, a case assessment request goes to its medical adviser service. For supplementary insurance, the invoice goes to the client (tiers garant), and CSS states that an RCC number has been required for LCA psychotherapy since 1 March 2025.

Functions to expect from billing software: up-to-date cantonal tariff, a session counter per prescription with alerts, XML export, rejection tracking. Function to expect from the clinical tool: the report to the medical adviser, drafted from the record. See our article on the report to the insurer (in French).

Who does what: splitting tasks between tools

• Calendar and reminders: calendar tool or practice software. No clinical notes.
• Billing (AOS, LCA, private, XML): Swiss billing software.
• Session notes, record, follow-up: clinical tool.
• Insurer reports, letters to doctors, certificates: clinical tool.

Two examples of Swiss tools aimed at psychologists. According to its site, Le Cabinet is designed for psychologist-psychotherapists in Switzerland and offers billing with PsyTarif, sending invoices to insurers via MediData, QR bills, a calendar and data stored exclusively in Switzerland, for CHF 49 per month including VAT. According to its site, ePsyo offers a calendar, electronic billing with rejection handling, QR bills, a client record and AI functions (transcription, summaries), with hosting in Switzerland, for CHF 39 per month excluding VAT; its list of subprocessors is not stated on its product page. For a wider overview, see our guide to psychologist software (in French).

Fictional example: Léa's set-up, psychologist-psychotherapist in Lausanne

Léa (a fictional name) works alone, sees mostly adults and bills most sessions to basic insurance on prescription.

• Calendar: appointments labelled with initials, SMS reminders with no reason given. The colleague who helps her two mornings a week has received written instructions on secrecy.
• Billing: Swiss software on the provisional Vaud tariff, XML sending, session counter. It warns her at Marc's (fictional) 13th session so she can ask for the follow-up prescription in time.
• Clinical tool: processing agreement signed, subprocessor list read, a test record exported and opened without the tool.
• What Marc's record holds: the prescription and the doctor's details, the intake history, agreed goals, a note for each session, progress, and the report to the medical adviser prepared before the 30th session.
• Retention: at least ten years after the last consultation, with a yearly export filed away.

10 questions to ask the vendor

• In which country is data stored and processed, for each subprocessor?
• Will you sign a processing agreement that meets art. 9 FADP?
• What is your list of subprocessors, and how am I told about changes?
• Can I create an admin account with no access to notes?
• How do I export a client's complete record, and in what format?
• What happens to my data if I cancel, and for how long?
• If there is a breach, how fast and through which channel am I told?
• If the tool uses AI: where does processing take place, is audio kept, is data used to train a model?
• For billing: which cantonal tariff do you follow, and how will you handle the structure planned for 1 January 2027?
• What is the total price, including SMS, invoice delivery and options?

Checklist before you sign

• Processing agreement signed and filed.
• Storage country written down for each subprocessor.
• Two-factor authentication on every account.
• Separate accounts, with no note access for calendar staff.
• Written secrecy instructions given to each assistant.
• A test record exported and readable without the software.
• Your canton's retention period noted, with a plan to meet it after a subscription ends.
• Client information updated (tools used, where data is held).

Common mistakes

• Writing the reason for consultation in the calendar. Calendars are often shared and synced to a phone: keep them to the time and the name.
• Thinking Swiss hosting solves everything. It replaces neither the processing agreement, nor access control, nor the export.
• Confusing TARDOC with the psychological psychotherapy tariff. If a vendor mentions TARDOC for your sessions, ask exactly which tariff it applies.

Why Delta fits this case

Delta is the clinical tool in this split: no calendar, no billing, no XML invoices. It is the clinical assistant that keeps the memory of every client. It transcribes what is said in session or takes your dictation afterwards, produces the session report (short summary, detailed summary, topics for next session) in line with your approach, and updates the record with a summary of the therapy and the goals being tracked. It also drafts reports, letters and certificates in your own wording, learned from your existing assessments; our clinical document templates show the kind of writing involved.

On protection: data stays in Europe, in France, on infrastructure certified for health data; names and identifying details are pseudonymised before the AI; no audio file is kept; data is never used to train a model and is encrypted in transit and at rest. On the question of an AI provider and secrecy, see our article on AI and professional secrecy in Belgium and Switzerland. Delta has a free plan (10 sessions a month) and a Pro plan at €35 a month including VAT, or €29 a month billed yearly, with a 14-day trial and no card required.

Sources

• Federal Act on Data Protection (FADP/LPD), SR 235.1, fedlex (French text) (art. 5, 6, 8, 9, 16, 24, 25)
• Swiss Criminal Code, SR 311.0, art. 321, fedlex (French text)
• Canton of Vaud, Access to the file (art. 24 and 87 LSP)
• CSS, Psychotherapy provided by psychologists (provider information)
• FSP, Tariff structure for psychological psychotherapy submitted for approval, 18 December 2025