Security clearance applicants often assume that what’s said in therapy stays in therapy. And for the most part, that’s true—except when you’re undergoing a security clearance investigation. In this setting, mental health records, treatment history, and even past disclosures to a therapist may be reviewed to help adjudicators understand potential risk factors.
This can be an unsettling realization for those who have disclosed highly personal or sensitive issues during therapy—especially when those disclosures touch on areas covered by Guideline D (Sexual Behavior) or Guideline J (Criminal Conduct).
If you’ve ever made statements in therapy about unusual sexual behavior, past criminal actions, or conduct that raises questions about impulse control or judgment, you may be at risk of having those statements interpreted as derogatory during the clearance process. The good news is: you’re not disqualified simply because something concerning appears in your records. But you do need to respond to it appropriately.
This blog will walk you through what these guidelines mean, why therapy records may come under scrutiny, and what steps you can take to protect your clearance while preserving your dignity and integrity.
Understanding Guideline D and Guideline J
This guideline addresses sexual behavior that is criminal, compulsive, or indicative of poor judgment or risk of coercion. Adjudicators are not concerned with private, consensual sexual behavior between adults—what they look for is:
- Sexual activity that violates the law (e.g., solicitation, sex with minors)
- Sexual addiction or compulsivity that impairs functioning
- Non-consensual acts or patterns of exploitation
- Risky behavior that could lead to blackmail or coercion
- A pattern of conduct that suggests a lack of control or reliability
This guideline applies when there is any history of criminal behavior, regardless of whether it led to a conviction. Even actions that are not prosecuted—if they reflect poor judgment, unreliability, or disregard for the law—can raise Guideline J concerns.
How Therapy Records Come Into Play During a Security Clearance Investigation
If you disclose a mental health history on your SF-86 or during an interview or if you are referred for a security clearance psychological evaluation, the investigator and the evaluating psychologist may request access to your treatment records or speak with your current or former providers—with your written consent.
You are not required to release these records, but declining to do so may force the adjudicator to proceed without meaningful context, often resulting in greater scrutiny or even clearance denial.
Therapy notes may contain information that, when viewed outside the therapeutic relationship, appears problematic. For example:
- Disclosure of past illegal behavior (e.g., theft, assault, sexual misconduct)
- Descriptions of compulsive or risky sexual behavior
- Admissions of past trauma or abuse leading to poor decision-making
- Ongoing struggles with impulse control, substance use, or law enforcement interactions
Even though therapy is meant to be a nonjudgmental space, the language used by clinicians may include diagnostic labels or interpretations that could be misunderstood or overemphasized in the clearance context.
Security Clearance Investigation Case Example: When Therapy Notes Raise Flags
Consider this common scenario:
An applicant sees a therapist for issues related to compulsive pornography use and sexual behavior outside of his marriage. Throughout therapy, he discusses episodes of infidelity, high-risk sexual encounters, and guilt. The therapist documents these behaviors as signs of sexual addiction in the clinical notes.
Later, when the applicant is referred for a psychological evaluation as part of a Top Secret clearance investigation, the evaluator reviews the records. The behavior described in the notes prompts concerns under Guideline D, and the adjudicator questions whether the applicant exhibits patterns of compulsivity and poor judgment.
Had the applicant worked with his therapist ahead of time to document clinical progress, the narrative could have been reframed as one of insight, accountability, and recovery, not risk.
What You Can Do If Therapy Records Raise a Security Clearance Concern
1. Understand What’s in Your Record
Ask to review your mental health records, especially if you’ve discussed anything related to sexual behavior or criminal conduct. Make sure you know what your provider has documented—and how it might appear to someone outside the therapeutic context.
If there are inaccuracies, exaggerations, or outdated entries, request an addendum or updated summary from your provider that reflects your current status, growth, and insight.
2. Request a Provider Letter That Puts Your Progress in Context
A well-written clinical letter can be an invaluable mitigation tool. Ask your therapist or treating psychologist to summarize:
- The original concern or diagnosis
- The treatment provided
- Your compliance with recommendations
- Observable improvement or behavioral change
- Their clinical opinion about your current level of functioning and reliability
Providers should avoid unnecessary clinical jargon or speculation, and instead focus on facts that align with adjudicative criteria: judgment, reliability, stability, and trustworthiness.
3. Pursue a Clearance-Focused Psychological Evaluation
If your therapy history has raised questions under Guideline D or J, consider obtaining an independent evaluation from a provider who understands the security clearance adjudication process.
At ClearancePsych, we evaluate whether the past behavior:
- Reflects a current risk
- Was part of a resolved or treated condition
- Demonstrates a pattern versus an isolated incident
- Shows rehabilitation, insight, and improved behavior
If you had a misstep in the past and are doing better, we can also help frame your history in a way that acknowledges your past while supporting your present stability.
What Security Clearance Adjudicators Want to See
Contrary to popular belief, adjudicators are not looking for perfect records. They understand that people have complicated pasts. What matters is whether you:
- Have taken responsibility for past behavior
- Have demonstrated personal growth
- Are no longer engaging in high-risk conduct
- Have a clinical record of improvement or recovery
- Show good judgment and honesty in how you respond to the concerns
Don’t Panic—But Don’t Ignore Concerning Therapy Records
Having a complex history doesn’t disqualify you. But ignoring it, hiding it, or hoping it doesn’t show up in your records can make things worse.
We’ve seen many clients who—after clarifying their records, submitting provider letters, and completing a clearance-oriented psychological evaluation—were granted or reinstated clearances despite initial concerns.
Final Thoughts About Guideline D and J Concerns
Therapy should remain a safe place to heal, grow, and explore your experiences. But if you’re applying for or renewing a security clearance, you must also recognize that some disclosures—even from years ago—may raise adjudicative questions.
By proactively working with your therapist and obtaining a well-structured psychological evaluation, you can mitigate concerns under Guideline D (Sexual Behavior) and Guideline J (Criminal Conduct)—and provide adjudicators with the complete picture of who you are today.
Don’t let outdated notes or misunderstood disclosures define your future. With the proper preparation, your story can be one of growth, resilience, and restored trust.
Need help reviewing your therapy records or preparing for a clearance-related evaluation?
Dr. Scott Edwards is President and Chief Psychologist at ClearancePsych. He is a licensed, board-certified psychologist with over 30 years of experience conducting psychological evaluations for military personnel, government contractors, and federal employees. ClearancePsych specializes in: psychological evaluations for security clearance concerns, clinical mitigation letters for Guideline D, E, F, G, H, I, collaboration with treating providers to support adjudicative mitigation, and SF-86 review and coaching for mental health and personal conduct disclosures