This article was first published in March 2020 and updated September 2024
Before working with a client using electronic practice technologies, consider the following key issues and review all related resources on electronic practice, linked below.
Suitability
Assess the suitability of electronic practice, considering each client’s needs and other relevant factors. Look at whether the client has the capacity to access technology in a safe and private setting. Is there a strong possibility that they could have an adverse reaction to the session (such as a panic attack)? Are they suicidal or do they pose some other risk to themselves or others? Can you verify their identity when using a non-visual platform?
Competence
Ensure that you are competent to use whatever electronic means you decide to employ. In this context, competence refers to both clinical and technical competence.
Keep in mind that electronic practice is its own therapeutic milieu that requires you to possess the knowledge, skills and judgement to be able to provide safe and effective care with clients remotely.
You must know how to use any equipment and software or applications properly and in a way that ensures you protect the client’s personal health information and their privacy. We would strongly recommend that you practice with whatever technology you choose before you use it in clinical practice.
Other questions that you should consider before offering online psychotherapy include:
- Is the client located in a jurisdiction besides Ontario, and would your ability to provide services to that client be restricted in any way by regulations in that jurisdiction?
- Does your liability insurance provider cover electronic practice?
Informed Consent
Standard 3.4, Electronic Practice, requires the client’s express consent before a registrant can use the communications technology with the client. The client needs to understand the risks and benefits of using a particular platform. It would be essential to also consider client factors before using electronic communication technology for your practice, for example:
- Is the client capable of understanding the risks associated with using electronic communication technology?
- Will the client have enough privacy in their location to engage meaningfully in therapy?
- Is the client in a safe location?
- Is the client familiar enough with technology to take measures to protect their own privacy online?
You need specific informed consent to provide services electronically. As part of that, you should consider discussing the following topics:
Confidentiality and privacy
When using communications technology in practice, assuring the privacy and confidentiality of the client becomes a main concern. Registrants have a duty to take measures to safeguard the client’s personal health information from theft, loss and unauthorized use and disclosure, in accordance with the Personal Health Information Protection Act. This duty is more straightforward to manage in face-to-face interactions and becomes complex when interacting with clients using communications technology, where technology comes with different features and security settings. Whatever method you choose to use in your practice, it must be sufficiently equipped to prevent theft, loss and unauthorized use and disclosure of the client’s health information.
Make sure the client knows what you are doing to protect their privacy. You also need to discuss what they should be doing to make sure that they have their own security in place. For example, that any computer they use is password protected and that they are connecting with you from a place that is private.
Technology
Registrants offering electronic practice should be mindful that they may be expected to assist with technical issues that arise before, during, or after a session. Discuss what you will do if there is any unplanned disruption because of equipment or internet issues. Will you move to a telephone call? Will you reschedule?
Recordings
Take extra care in your informed consent process if you want to record a session or if a client suggests they want to. If sessions are recorded, you will have to consider how to store, transmit or dispose of the recordings.
Unless you have a good reason to make a recording, you may wish to let the client know that you won’t be recording the session and suggest that they shouldn’t either.
Risk of harm
If a client is at risk of harm to themselves or others, online psychotherapy will likely not be appropriate. Have a plan for online crisis intervention. Make sure your client understands when you would terminate online sessions because of the risk of harm and how you would facilitate a referral to another service or provider if that happened.
Written agreement
Ideally, you should enter into a written agreement with your client at the end of this informed consent discussion. The Electronic Practice Guideline provides more information about service agreements.
Jurisdiction
Jurisdictions may have different standards and/or laws to regulate the practice of psychotherapy (some may have none at all). Registrants are urged to contact the regulator in the jurisdiction in which the client resides, if one exists, to develop an understanding of any requirements that may apply. If no regulator exists, you would need to confirm that there are no other restrictions or considerations in providing counselling or psychotherapy services in that location. Consider consulting a lawyer, accountant, and/or professional associations in any unregulated locations.
Insurance Coverage
In accordance with Standard 3.4, Electronic Practice, you are required to assure that your practice is covered by your insurance policy. This includes ensuring your practice is covered for any therapy you provide via electronic communication technology in your own and in other jurisdictions.
In addition to reviewing the relevant Professional Practice Standards, the Information and Privacy Commissioner’s website also has helpful information on safeguarding privacy in settings where technologies are used. See the IPC resources for health organizations linked below.
If you have any outstanding questions, please email them to practice@crpo.ca.