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The CRPO path, by Canada Therapy & Wellness
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Virtual and cross-border practice
CRPO's electronic practice standard, whether virtual therapy suits a client, what to agree first, clients outside Ontario, and how CRPO says to choose a platform, with PHIPA's safeguards.
Study aid, not legal advice.Last verified against the official sources linked below on .
The standard, 3.4
- Every standard applies, in person, by phone, by video or a mix (3.4.1).
- Informed consent to the specific technology and its risks (3.4.2), and an agreement before services start, ideally in writing.
- Technology that is secure, confidential and suited to the client (3.4.3); never social media as a platform for therapy.
- Liability insurance that covers electronic services before you treat (3.4.4).
- The licensing rules where the client is located (3.4.5).
- Copies of written exchanges, secure text or email, in the record (3.4.6); your own judgment over any computer-generated assessment or AI output (3.4.7).
- No psychotherapy to anonymous clients.
Does virtual suit this client?
- Weigh their concerns, reliable access to the technology in a safe and private place, their comfort with it, their capacity to take part, and local supports.
- Think twice with psychosis, a risk of an acute reaction such as panic, a risk of harm to self or others, or the impact of trauma: in person or a referral near the client may fit better.
- Keep checking that the technology still serves the therapy; if not, supervision, local resources, an in-person session or a referral.
Agree before the first session
- The platform, and its risks and limits.
- What happens if the connection drops or the client is in crisis, and where they are: crisis services there.
- Confidentiality, its limits, and what the client can do to protect their privacy.
- Recording only with consent covering its purpose, storage, transmission and deletion.
- Your hours and reply times between sessions; fees and cancellations.
- That you are regulated in Ontario and CRPO handles complaints.
Clients outside Ontario
- The rules that apply are generally those of where the client is, as well as Ontario's and CRPO's.
- Find out whether psychotherapy or counselling is regulated in that place, and ask the regulator there: some license the work, some restrict a title or an act, some do not regulate it.
- Confirm your insurance covers clients in that province or country.
- Know the emergency contacts there: emergency services, crisis lines, child welfare.
- With a client outside Canada, data cannot stay in Canada: discuss it as a limit of confidentiality.
Choosing a platform
- End-to-end encryption; if you cannot ensure it, use another platform or tell the client the risks as part of consent.
- Data stored and moved within Canada where possible; if not, a limit of confidentiality to discuss.
- The vendor and its staff cannot see the content; metadata does not identify clients and is not sold or shared.
- A written confidentiality commitment, a way of handling breaches and vulnerabilities, independent security checks, and a log of your own activity.
- Test it with colleagues first, and work from a private, professional setting.
- PHIPA s. 12 (1): take reasonable steps to protect health information against theft, loss and unauthorized use or disclosure.
- PHIPA s. 12 (2): if it is stolen, lost, or used or disclosed without authority, notify the client at the first reasonable opportunity.
Same standards on screen: consent to the technology, secure tools, the client's location, insurance and a crisis plan.