I recorded most all my sessions with my therapist, and she had no problems with it. She just told me to protect my privacy so that it doesn't get in the wrong hands, especially since I had a teen that sometimes used my ipad and phone.
For me there would be something messy about doing it surreptitiously. I had to be that way with my FO in order to be myself, and I was going to the therapist to help with stopping the duplicity in my life.
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