Closing a practice does not close the record. The retention period runs from the last interaction, so on the day you stop seeing clients you are still holding files you are obliged to keep, secure, and be able to produce — in Ontario, typically for another decade.

Ontario's psychotherapy standard states it plainly. Registrants acting as health information custodians "maintain records in a secure manner for the period set out in Standard 5.1, even after the closure of their practice, unless the records are transferred to another health information custodian" (Standard 6.4.4) (CRPO Professional Practice Standards).

The period it points at is ten years, with a wrinkle worth knowing about. Standard 5.1's numbered clauses set out no period at all — the figure lives in the commentary beneath them, where a registrant who is the custodian is "expected to retain the record for at least 10 years from the date of the last interaction with the client, or for 10 years from the client's 18th birthday, whichever is later." The standard that survives your practice points at a number the standard itself does not state. That is worked through in how long do I have to keep client records.

The Ontario social work standards give the same two-option structure. A self-employed registrant who ceases practice "shall either: (i) maintain their client records in accordance with Interpretation 4.2.2; or (ii) make arrangements to transfer the records to another College registrant or other regulated professional" (OCSWSSW 4.2.8).

Keep them, or hand them to someone who will. There is no third option.

Telling clients

Ontario's psychotherapy standard sets a figure and a method, and both are more specific than practitioners expect.

The figure: registrants demonstrate the standard by "Providing as much notice to clients as reasonably possible when closing or relocating a practice, with an expected minimum notice of 30 days for foreseeable closures." The College's own definition adds the case where thirty days is impossible — "In cases of emergency or sudden and unexpected incapacitation, registrants or their representatives shall provide as much notice as reasonably possible."

The method is where the phone comes in:

"When closing or relocating a practice, registrants are expected to first attempt to provide direct notice (in person during a scheduled appointment or through a telephone conversation, direct letter, personal email, etc.) of the change to clients. If not all clients can be reached, registrants are expected to use at least two forms of indirect notice (posting a message on one's website, using an automatic reply on emails, updating a voicemail to note closure or sale, publishing closure in a newspaper, etc.). Regardless of the method of communication, registrants are expected to document their attempts to alert clients."

— CRPO Standard 6.4, commentary

Two things are easy to miss there. Indirect notice is at least two forms, not one. And the attempts themselves have to be documented — so the record of who you tried to reach, and how, is part of the closing work rather than an afterthought.

The notice does two jobs besides. Clinically, it opens the ending. Administratively, it tells people where their records will be and how to reach them, which is much harder to communicate after the fact.

Transferring records to someone else

If you hand the files on, the social work standards set three conditions. The registrant shall "ensure that the other College registrant or regulated professional first agrees in writing to comply with Principle IV"; "make reasonable efforts to give notice to their clients of the future location of their records, unless they are required, under any applicable privacy or other legislation, to obtain their clients' consent to such transfer, in which case they shall obtain their clients' consent"; and "ensure that they meet all requirements regarding the transfer of records set out in any applicable privacy and other legislation" (OCSWSSW 4.2.9).

Note the consent question sitting inside that clause. Whether notice is enough or consent is required depends on the privacy legislation you are under, and it is worth resolving before you start moving files.

The part nobody plans for: what if you cannot do it yourself

This is the strongest reason to read your College's material rather than a summary of it, because the failure mode is not a fine — it is a family member being handed a filing cabinet of clinical records.

Ontario's psychotherapy College advises registrants who are custodians "to designate a successor in writing (with the successor's consent)," and explains what happens without one: under PHIPA, "an estate trustee or administrator would become responsible for the deceased registrant's records, until custody of the records passes to another legally authorized person" (CRPO, health information custodian successor). The standard also requires registrants to have "a contingency plan in place to promote continuity of care in the event of an unexpected interruption to their practice" (6.4.2), and to give the College "up-to-date information about who would take custody of the records in their care in the event of the registrant's death or long-term inability to fulfill their obligations related to this position" (6.4.3) (CRPO Professional Practice Standards).

Ontario psychology says the same in one sentence, including the part about telling the College: registrants who are custodians "must arrange for the security and maintenance of client records in case of expected or unexpected incapacity or death, and inform the College of these arrangements prior to ceasing to provide services or at the earliest reasonable opportunity. In making such arrangements, where possible, the designate should be a registrant of the College" (CPBAO Standard 9.6).

British Columbia's regulator turns it into four obligations that read like a checklist. Make a succession plan "in the event the licensee discontinues practice, moves to a different jurisdiction, or becomes incapable of practice" (§7.2). Transfer custody "to another regulated healthcare professional or to a health organization or records management service" if you can no longer hold them and answer access requests (§7.3). Give current clients "advance written notice, to the extent possible... including explanation of how patients can continue to access their records" (§7.4). And if the records move, "notify CHCPBC of their new location within 30 business days" (§7.6) (CHCPBC, Practice Standard: Records).

Nova Scotia's psychology regulator goes furthest on what the designated colleague actually needs, and its list is unusually concrete: they must know "the location of all clinical records past and current," have "the keys and passwords that will allow access to clinical information," and know "the location of the appointment book and phone numbers for all active clients." Their duties include "canceling upcoming appointments, alerting all active clients of the death/incapacity, making immediate referrals or otherwise taking action should a client be in crisis" (NSRP, Arrangements for Retirement; Death or Incapacity).

Read that last one as a phone problem as much as a records problem. Someone has to be able to reach your clients, which means someone has to be able to reach your line.

The electronic-records problem

Paper records survive a closed practice. Electronic records survive a closed practice only if someone keeps paying for something.

Three questions to answer before you cancel anything.

Can you export everything, in a form that is readable without the software? Test the export while you still have an account, not after.

Does your successor have access, or only a promise of access? A named successor with no credentials is not a plan.

What happens to the vendor's own copy? If your subscription lapses, the vendor's retention schedule takes over, and it is unlikely to match your College's.

Nova Scotia's psychology regulator says this part out loud, which is rare: "Cloud or subscription-based storage depends on an account that someone must keep active for the full retention period. An arrangement should identify who is responsible for maintaining it, so that records are not lost through lapse or non-payment." The same document names the other way it fails — "Encryption keys, passwords and account credentials must be held by the person responsible for the records. Encrypted media secured with no one able to open it is, in practical terms, a lost record" (NSRP).

Disposal, when the time comes

The retention period does eventually end, and the standards are specific that ending it is an act rather than a lapse. Registrants "shall dispose of the contents of records in a way that ensures that the confidentiality of the information is not compromised" (OCSWSSW 4.2.5).

For electronic records that means confirming the deletion reached backups, which is a question to put to whoever holds them rather than a setting you can toggle yourself.

If you are winding down for a while rather than for good

Parental leave, illness, a sabbatical. The retention obligation does not pause, and neither does the need for someone to be reachable about records.

What the standards ask for here is narrower than a closure, and it splits along a line worth noticing: most of them address the unexpected interruption, not the planned one.

CRPO's contingency-planning commentary is written for the unexpected case and says so — registrants "must have in place a plan to address unforeseen interruptions to their practice, such as unplanned leave, illness, or death and even natural disaster." The plan "should include backup and storage of contact lists and, where possible, client records, directions for contacting clients or their authorized representatives, and contact information for alternative service providers." Note what is first on that list. The client contact list is named as part of the plan, which makes it a phone question as much as a records one.

Alberta is the outlier that reaches a planned absence directly. A psychologist "shall ensure that an appropriate professional is willing and available to deal with the needs of a client during the psychologist's absence, planned or otherwise, from professional practice" (CAP §8.1). Alberta social workers get a narrower version, scoped to emergencies: arrangements are made "for another social worker or suitable professional to deal with the emergency needs of clients during periods of reasonably foreseeable absence by the social worker" (ACSW B.10(a)).

Ontario social work sits between the two: registrants "who anticipate the termination or interruption of service to clients shall ensure that clients are notified promptly and that arrangements are made for the termination, transfer, referral, or continuation of service in accordance with clients' needs and preferences" (OCSWSSW 3.12).

The absence worth naming is the one nobody publishes. Reading the Ontario psychotherapy and psychology standards and the BC standards, none of them sets a requirement to arrange coverage for an ordinary two-week holiday. If someone tells you your College requires a named covering practitioner while you are away, the fair question is which clause.

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