Standard 3.4: Electronic Practice

Technology provides various ways of communicating with clients and may enable registrants to work with clients who have limited mobility, who live in isolated areas, or to continue providing therapy during public health emergencies. It also poses new challenges.

Generally, rules that apply to the provision of professional services also apply to the provision of services by electronic means. For example, registrants must follow established professional practices, such as assessment, developing a plan of therapy, maintaining records, and communicating appropriately with other providers.

Confidentiality must be maintained no matter what medium is used.

A registrant may provide professional services using electronic communication technology only when the registrant receives consent from the client for use of such technology. In addition:

• Before providing services via electronic communication technologies, a registrant enters into an agreement with the client concerned. This does not preclude using electronic communication technologies in developing the agreement.
• Registrants should outline appropriate uses of technologies with clients (e.g., emailing or texting only for booking appointments, secure online platforms for the provision of therapy).
• Registrants do not provide psychotherapy to anonymous clients.
• Registrants should employ caution in providing advice, clinical assessment, or clinical information accessible to the general public on websites, blogs, forums, or other communication platforms.

Registrants must take reasonable steps to ensure that the electronic communication technology employed is secure, confidential, and appropriate in the circumstances. When a registrant intends to use an electronic medium, clients should be made aware of any potential risks, particularly an inability to ensure security and confidentiality that could arise from the use of the technology.

Additional information about information security in electronic practice can be found in the Security Practices Checklist: Electronic Practice below.

Registrants must ensure that services provided through electronic communication technologies are covered by their professional liability insurance. Insurance coverage varies and may not cover all clients or clients in all locations. Registrants should consult their insurance provider.

One unique aspect of electronic practice is the potential for clients to be located in a different province, territory, or country than the registrant. Some jurisdictions require those practising psychotherapy or counseling to have a license. Some may have a restricted title or activity (similar to the controlled act of psychotherapy in Ontario). Some jurisdictions do not regulate psychotherapy or counseling. Registrants should familiarize themselves with the limits on practising in particular jurisdictions where potential clients may be located.

In emergencies, registrants may need to know who to contact in other jurisdictions, e.g., client’s emergency contact, emergency services, crisis lines, child welfare agencies.