The introduction of the Data Protection Act 1998 has presented significant challenges to counselling recording, through its detailed requirements for the processing of personal data. The impact of these changes on recording in Higher Education counselling services in the UK is explored, using responses from an electronic survey of universities and colleges. The material is presented in terms of three themes, namely transparency, accountability and professional autonomy. The Act has encouraged more transparent and accountable recording practice by counsellors, while discouraging the use of "personal notes" held in permanent form outside the remit of formal recording systems. Some key implications for redefining practitioner autonomy in relation to recording, consistent with the principles of transparency and accountability, are briefly explored. (Contains 5 figures.)