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Psychologist suspended for failure to maintain professional boundaries

23 Jan 2020

A Western Australian psychologist has been suspended for a repeated failure to maintain professional boundaries.

On 29 October 2018, the State Administrative Tribunal in Western Australia (the tribunal) found Mr Anatole John Hudson, a registered psychologist, had engaged in professional misconduct for failing to maintain professional boundaries with two clients.

The Psychology Board of Australia (the Board) referred Mr Hudson to the tribunal on 26 July 2018 following an investigation by the Australian Health Practitioner Regulation Agency (Ahpra) into allegations he failed to manage professional boundaries with clients between 2015 and 2017, including allowing a 10-year-old boy to stay on his property.

The tribunal found that Mr Hudson had failed to consult with a senior psychologist to find an appropriate resolution that was in the best interests of his clients when managing multiple relationships, which had the potential to impair his effectiveness, objectivity and ability to render psychological services, and that he failed to refer his concerns about the safety of a minor to the Department of Communities, Child Protection and Family Support in Western Australia.

Mr Hudson agreed that his behaviour amounted to professional misconduct and the matter was resolved by consent between the parties.

In considering the matter, the tribunal took into consideration Mr Hudson’s professional isolation due to practising in a regional area, his personal mental health issues that are being suitably managed by way of ongoing counselling, the fact he is subject to ongoing supervision which offers opportunity for personal and professional development and his cooperation throughout the course of the proceedings. 

The tribunal reprimanded Mr Hudson for non-sexual boundary violations and a lack of insight into his professional dealings with clients. Mr Hudson’s registration was suspended for 10 weeks from 29 October 2018 and conditions were imposed on his registration requiring further education in relation to managing professional boundaries, including the expectations of clients and the psychologist’s role in maintaining appropriate professional boundaries and managing multiple clients. Mr Hudson is also required to submit a reflective practice report following the completion of further education.

Mr Hudson was also ordered to pay a contribution to the Board’s legal costs in the sum of $5,000. 

The conditions imposed on Mr Anatole John Hudson’s registration are published on the Register of practitioners with links to the full tribunal decision on the eCourts Portal of Western Australia.

At the time of the proceedings, Mr Hudson was subject to conditions imposed by the tribunal following separate disciplinary proceedings brought by the Psychology Board of Australia (the Board), in February 2017.

Page reviewed 23/01/2020