For starters, I understand from the new code that sexual or romantic interactions between a counselor and a current client are still prohibited. When a company doesn't have a policy against dating a customer or customer, that doesn't necessarily mean everything goes. Partner relationships between employees and customers can jeopardize the business relationship between the company and the customer. For example, a customer upset about the end of a relationship could stop doing business with the company.
A customer's employee could accuse the company employee of sexual harassment. Some employers choose not to ban this type of relationship or simply overlook the need for a policy, but that doesn't mean that dating a client won't have repercussions for the employer or your career. As a profession, we have learned very well the harms that occur when psychologists become sexually involved with their clients. The harms are so clear that our code, like the codes of all major mental health organizations, absolutely prohibits such involvement.
Sexual relationships with former clients and patients, however, are more complicated from an ethical perspective. Time can dampen the intensity and even the likelihood that a participation will cause harm. A permanent ban on participation may compromise the exercise of the client's autonomy in determining with whom and how to participate in personal relationships. Therefore, the question of sexual relations with former clients requires its own analysis to determine when, if ever, such relationships may be ethically permissible or, in other words, whether and to what extent such relationships should be prohibited.
A typical disclosure policy may require any employee who is dating or has a physical relationship with a co-worker, customer, or vendor to report the relationship to the human resources director and sign a statement agreeing to comply with the company's sexual harassment policy. Instead of keeping the relationship a secret and potentially damaging your professional reputation, decide if the job or relationship is more important to you. If your company has a policy on conflicts of interest that could apply to a romantic relationship with a customer or supplier, it is likely to be similar to a policy on intimate relationships between co-workers. If the business relationship has ended, there is absolutely no reason why a personal relationship should not occur - assuming that both parties want it, of course - perhaps something to consider with a little more caution than normal if there is or was a power dynamic involved.