First published in the January 2025 Communique
CRPO’s Practice Advisory Service has received questions about how to meet the Professional Practice Standards in settings where clients might not provide their full name or address.
Professional Practice Standard 3.4, Electronic Practice, discusses issues of consent for electronic practice and notes that “Registrants must not provide psychotherapy to anonymous clients.”
But what about access to psychotherapy services in settings such as call-in centres, drop-in service providers, or shelters where asking vulnerable individuals to provide their full name or an address might present a barrier?
Anonymous Clients
Understanding that clients in these settings are not entirely “anonymous”, there are several reflection questions to consider in interpreting the Standard. These include the following:
- Is the service clinicians are providing primarily within or outside psychotherapy? While not clear cut, CRPO is less likely to take issue with services outside the scope of psychotherapy.
- What are the risks of not knowing the client’s full name, birthdate and/or location?
- How will the clinician protect the client if the client discloses a risk of harm to themselves or others? See the Guideline on Disclosing Information to Prevent Harm linked below for reference.
- Is the client aware of the risks of not sharing their name and/or location (e.g., the clinician may not be able to contact someone to help them in an emergency), and has the client provided informed consent to these risks?
- Do the clinicians have the necessary competence to provide services to clients in a single-session/brief therapy model?
- Can the clinicians maintain an appropriate therapeutic relationship with the client?
- How will the clinicians maintain adequate records?
- Are there circumstances, such as urgency or client needs, that justify providing services without some of the typical information a registrant would collect?
Record-keeping considerations
Recognizing that partial anonymity is important in some situations, CRPO is aware that some agencies have used “identifiers” for clients, i.e., a way to consistently refer to a person without using their name. This would allow an RP to track continuity of attendance, without needing to unnecessarily reproduce an individual’s full name or other identifying information. The client could provide consent to this arrangement verbally and the registrant could document consent in the record using the identifier. This could be a reasonable way to meet the standard while respecting a client’s need for privacy.