By

Adam Simmons

· Last checked

August 2026

What your College says about electronic communication

What your College says about electronic communication

What your College says about electronic communication

Less prohibition and more expectation than most practitioners assume — and one Ontario College publishes no messaging standard at all. Here is the wording each regulator actually uses, quoted, so you can read the standard rather than a summary of it.

Less prohibition and more expectation than most practitioners assume — and one Ontario College publishes no messaging standard at all. Here is the wording each regulator actually uses, quoted, so you can read the standard rather than a summary of it.

Less prohibition and more expectation than most practitioners assume — and one Ontario College publishes no messaging standard at all. Here is the wording each regulator actually uses, quoted, so you can read the standard rather than a summary of it.

The consistent theme across the published standards is not prohibition. It is that electronic practice is normal practice, held to the same expectations, with three extra duties attached: get consent, choose the technology deliberately, and document what you exchange.

Ontario's psychotherapy standard opens with the point that surprises people: "Registrants adhere to all professional standards, whether their practice is electronic, by telephone, in person, or a hybrid thereof" (CRPO 3.4.1).

There is no lower bar for the channel that feels casual. A text is practice.

Below is what each body actually publishes, in its own wording. Read yours in full — the summaries in circulation are where the errors come from.

The consistent theme across the published standards is not prohibition. It is that electronic practice is normal practice, held to the same expectations, with three extra duties attached: get consent, choose the technology deliberately, and document what you exchange.

Ontario's psychotherapy standard opens with the point that surprises people: "Registrants adhere to all professional standards, whether their practice is electronic, by telephone, in person, or a hybrid thereof" (CRPO 3.4.1).

There is no lower bar for the channel that feels casual. A text is practice.

Below is what each body actually publishes, in its own wording. Read yours in full — the summaries in circulation are where the errors come from.

Ontario — registered psychotherapists

Standard 3.4 has seven clauses. In full:

  • 3.4.1 "Registrants adhere to all professional standards, whether their practice is electronic, by telephone, in person, or a hybrid thereof."

  • 3.4.2 "Registrants obtain informed consent from clients regarding the use of electronic communication media in the provision of services."

  • 3.4.3 "Registrants take reasonable steps to ensure that the technology employed is secure, confidential, and appropriate, given the needs of the client."

  • 3.4.4 "Registrants ensure that their professional liability insurance provides sufficient coverage for electronic services prior to treating clients."

  • 3.4.5 "Registrants comply with relevant professional licensing requirements in the jurisdictions where clients are located."

  • 3.4.6 "Registrants offering modalities requiring written communication (secure text- or email- based) include copies of correspondence and treatment-related communication in the clinical record."

  • 3.4.7 "Registrants do not rely on information obtained from computer-generated assessments, reports, or statements without exercising their own professional judgment."

(CRPO Standard 3.4)

The standard's own definition settles a question the clauses do not: "Electronic practice: Providing assessment or treatment to a client by means of communication technology, e.g., telephone, text, email, video-calling." The telephone is named. None of this is confined to video.

Two of those are quietly consequential. 3.4.4 — check your insurance actually covers electronic services, which is a five-minute email and almost nobody sends it. 3.4.5 — the jurisdiction question is determined by where the client is, not where you are. The College's guideline puts it as: "a registrant who provides services to a client in another jurisdiction should become familiar with relevant laws of the jurisdiction(s) in which the services are provided, which is generally determined by the location of the client" (Electronic Practice Guideline).

The accompanying confidentiality standard adds the baseline: "Registrants familiarize themselves and comply with relevant privacy laws" (CRPO 3.1.2).

Ontario — social workers and social service workers

The third-edition standards put three requirements in a single clause. Registrants using online platforms and providing virtual services shall "explain to clients the limits of confidentiality (including any particular limits associated with online platforms and/or virtual practice) prior to or during the first online meeting and document this conversation"; "ensure that the collection, use and storage of client information complies with applicable privacy legislation"; and "ensure that client information is stored in a jurisdiction where the privacy laws are consistent with Ontario laws or, where applicable, Canadian federal laws" (OCSWSSW, Principle V, 5.3.1).

That third bullet is the strongest published Ontario sentence about where client information may sit, and it is a professional standard rather than a privacy statute — which means it is enforceable through the College.

The definition it works from is broad: "Electronic communication refers to texting, email, video chat platforms, social media platforms, websites, faxes or other types of online communication." And one expectation is unusual enough to notice on a first read — when sending client information electronically, registrants "shall mark it confidential when possible, and shall ensure that it has been received by the intended recipients" (5.3.3).

The College's practice notes add the practical layer. On the channel's limits: "One risk associated with communication technology is the fact that it is not a secure form of communication. Members cannot guarantee that client information will be kept confidential when they communicate with clients online or texting." On availability: "Members would also be well advised to reflect upon how often and when they will check emails and other correspondence from their clients, and when or under what circumstances they will respond. This information should be clearly communicated to clients at the beginning of the professional relationship as well as later, if necessary" (OCSWSSW practice notes).

Ontario — psychologists and psychological associates

This is the genuine contrast in the set, and worth knowing before you go hunting for a clause that is not there. Reading the Standards of Professional Conduct of the College of Psychologists and Behaviour Analysts of Ontario — the renamed College of Psychologists — there is no standard specifically about email or text messaging. "Email" appears as a field of client contact information to record. There is no electronic-communication consent clause and no messaging standard.

What binds instead is general, and in one respect harder than anything above. On records held in someone else's system: "When using an electronic record management service, even if hosted externally, the registrant must ensure the service operator acts in compliance with legislation. The HIC remains responsible for information collection, use, disclosure, and secure destruction by the agent" (Standard 9.5(b)). On transmission: "Electronic records must be encrypted before transmission. Registrants must verify the practices of their technology provider and seek guidance from relevant authorities (for example, the relevant Information and Privacy Commissioner) if uncertain about the current minimum requirements" (9.5(c)).

And on where a service is hosted, registrants using cloud services must ensure the hosting jurisdiction "has security features which would be consistent with privacy requirements under Ontario legislation" (17.3(a)) (CPBAO Standards of Professional Conduct).

Same destination, different door. The duty arrives through records and technology rather than through a communication standard — and 9.5(c) is a firmer line on encryption than either of the two Colleges above draws.

British Columbia

The regulator here is the College of Health and Care Professionals of BC, formed in 2024 out of seven former colleges, and psychologists are among the professions it licenses. Its communications standard names the channels directly and permits them conditionally: licensees are to "Use electronic communications—including virtual care, email, text, patient portals, and social media—only when appropriate in the context of the Ethics and Practice Standards and when the expectations of the Standards can be met through their use" (§5.1), and to "Meet the privacy and confidentiality requirements of the Ethics and Practice Standards in all forms of professional communication" (§6.1) (CHCPBC, Practice Standard: Communications).

Read what that is and is not. It is a conditional permission — no required response time, no required written communications policy, no encryption clause. If you have been told BC requires a written electronic-communication policy, that requirement comes from the counselling therapy standards below, not from BC.

There is also a fact a BC counsellor should have before reading any of this. The College states plainly that "Psychotherapy is not currently regulated in BC", and that "Starting November 29, 2027, psychotherapy practitioners in BC must be licensed by CHCPBC if they wish to practise" (CHCPBC, Regulating Psychotherapy). Until then there is no College standard to cite at a BC counsellor, which is why the BC Association of Clinical Counsellors' own standards do so much of the work in that province.

Other provinces

The shape differs enough that a summary would mislead. Three worth naming.

Alberta psychologists. The College's technology guideline is a caution rather than a prohibition, and it names the telephone first — its scope covers "Telephone (landline, cellular or smartphone). Email. Text messaging." On text-only practice: a psychologist "should exercise caution in the sole use of technologies that necessarily limit the interaction with a client to text-only information," and psychologists "are cautioned to not solely rely on such modalities as a sole form of providing services" (CAP, Use of Technology).

Alberta social workers. The obligation is framed as consent that addresses the medium itself. A social worker "will address the identifiable risks, benefits, and limitations of social work services provided through the electronic medium chosen when obtaining consent to provide services electronically" (E.3(k)), and "will make reasonable efforts to verify client identity and contact information" when working by telephone or other electronic means (E.3(f)) (ACSW Standards of Practice).

Counselling therapists. The CCPA standards — which the Nova Scotia College of Counselling Therapists publishes as its own — are the only ones here that require a written policy: "Counsellors/therapists shall maintain a written policy with respect to electronic communication with clients. This policy must be shared with clients as part of an informed consent process." The standard then sets out what it must convey at minimum: "in what instances these communications will be used (e.g., scheduling versus therapy)"; "what technologies will be used (text, email, other online messages apps)"; "any risks to privacy/confidentially associated with the particular technology being used"; and "anticipated response times" (CCPA Standards of Practice).

Quebec, Saskatchewan and Manitoba are not covered here. If you practise in one of them, your own College's standard is the document to open — not this page.

What none of them will do

Recommend a product. Ontario's psychotherapy College says so directly: "CRPO can't recommend a specific platform because technology is constantly evolving and there are so many options available," and "CRPO cannot attest to the effectiveness or appropriateness of these platforms" (CRPO).

Which means the choice, and the reasoning behind it, is yours to make and yours to be able to explain. That is worked through in is a second-line app compliant.

The four things most versions of this ask for

Strip the wording differences away and the same four expectations recur — sometimes as a communication standard, sometimes, as in Ontario psychology, through records and technology clauses instead.

Consent before you start, informed by the risks of the channel.

A deliberate technology choice, which you can justify — not necessarily the most secure option available, but a reasoned one.

Documentation of what was exchanged, in the clinical record.

The same professional standards as in the room. Boundaries, competence, scope and confidentiality do not soften over a text message.

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