Yes — at least the fact of the call and what it was about. Ontario's psychotherapy College is explicit about this, and more explicit than the question usually gets credit for.

CRPO's list of what a clinical record contains includes a category headed Client contact, defined as "A notation of all in-session and out-of-session contacts with a client or their authorized representative." Its published examples are "letters, emails, texts, and telephone calls" (CRPO Standard 5.1, Contents of the Clinical Record). A telephone call is named there, not left to inference. That contents list sits in the commentary under Standard 5.1 rather than in its numbered clauses, which is worth knowing — but it is the College's own published description of what a record holds.

Read the wording, though. What it asks for is a notation of the contact. It does not say the recording itself is the record.

Other regulators arrive in the same place by broader routes. The Ontario social work standards list "audio and/or video recordings" among the things a record may include (OCSWSSW 4.1.2). The CCPA standards — adopted by Nova Scotia's counselling therapy College as its own — require a "record of consultations regarding clients, including electronic consultations, telephone calls, text messages, e-mails" (CCPA Standards of Practice).

So: document the substance. What you do with the audio file is a separate question, and a more interesting one.

Is the audio file itself the record, or is the content?

Most practitioners resolve this by documenting the substance in a progress note and not retaining the audio — the same way you would not keep a recording of a phone call, only the note about it.

That is defensible, and it is what CRPO's wording points to: what is asked for is a notation of the contact, not a copy of it. It is also the option that avoids accumulating a library of audio files you now have to store securely, retrieve on request, and destroy on schedule.

Where it stops being defensible is when the audio itself carries something the note cannot. Tone. Distress. A threat. A disclosure whose exact wording matters. In those cases the recording is doing work the summary does not do, and deleting it is a decision you would have to be able to explain.

What is the first-clinic-day version of this?

Three habits cover almost every case.

Note the fact of the call, always. Date, time, who called, and what it was about in a sentence. Even for "please call me back," because the pattern of contact is sometimes the clinically relevant thing.

Note the substance verbatim when the substance matters. A voicemail about risk gets quoted, not paraphrased. This is the same instinct you already have about session notes.

Decide, in advance, whether you keep audio at all. A blanket policy is easier to defend than case-by-case retention, in either direction. What is hardest to defend is having kept some and not others without a stated reason.

Does a voicemail from someone who is not yet a client count?

This is the genuinely awkward one, and it comes up constantly in a practice that takes new enquiries by phone.

Ontario's statute defines personal health information to include identifying information that "relates to the providing of health care to the individual, including the identification of a person as a provider of health care to the individual" (PHIPA, s. 4). The fact that a named person phoned a psychotherapist is, on that wording, information of exactly that kind — before any assessment has happened, before any file is opened.

Whether an enquiry that never becomes a client relationship generates a clinical record obligation is a different question from whether it generates a privacy obligation, and the Colleges are not uniformly explicit about it.

Ontario psychology is the exception, and it is worth having. The College of Psychologists and Behaviour Analysts of Ontario states that registrants "are not obliged to retain personally identifiable information which a person has not provided consent to collect, inquiries about services which did not result in the provision of services" (CPBAO Standard 9.4(d)).

Read that as a permission rather than an instruction. It says you are not obliged to keep the enquiry, not that you have to get rid of it. And it is one College's answer for one profession — the fact that the Colleges differ here is the point, not an oversight.

What practitioners generally do is keep a minimal intake log — enough to show who enquired and what happened next — and treat it with the same confidentiality as everything else, without building a clinical file for someone who never became a client.

What about the transcript, if something transcribes it for you?

A transcript is the same information in a more convenient medium. It carries the same obligations as the audio and the note.

The point worth checking is not whether you may keep a transcript, but who else saw the audio in order to produce it. That is a question about your service provider, not about your record-keeping, and it is covered separately in who can see my client communications.

The short version

Document the substance; be deliberate about the audio. If you cannot say what your policy is on keeping voicemail recordings, you do not have one, and the absence is the thing a reviewer would notice first.

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