Closing a practice is not the reverse of opening one, because one thing does not close: the records, and your responsibility for them.

That single fact sets the whole sequence. You cannot cancel the software the records live in, you cannot let the number go if it is the route people use to request them, and you cannot finish in a month.

The order that works:

1. Read what your College actually requires for closing a practice — retention, notice, and what clients must be told.

2. Give clients notice, in writing, with a date.

3. Transfer or refer anyone continuing in care.

4. Export and secure the records, before cancelling anything they live in.

5. Keep a contact route open so records requests can reach you afterwards.

6. Cancel the operational accounts, last, in writing, with confirmation.

Steps 4 and 6 are the ones people reverse, and it is expensive: a subscription cancelled before the export is a set of records you may not be able to reach.

How long do I have to keep the records?

This is set by your College and by applicable legislation, not by convenience, and it is measured in years rather than months. It also depends on the client — records for someone who was a minor are commonly treated differently.

In Ontario the published figure is ten years in each of the three professions. What differs is the clock. Social workers and social service workers keep each record "for at least ten years from the date of the last entry or, if the client was less than eighteen years of age at the date of the last entry, at least ten years from the day the client became or would have become eighteen" (OCSWSSW 4.2.2). Psychologists and behaviour analysts keep individual client records "for a minimum of 10 years after the service recipient reaches the age of 18 or after the last professional contact, whichever comes later" (CPBAO 9.4). Psychotherapists are expected to keep them ten years as well, though that figure appears in commentary rather than in the numbered standard and is scoped to "where the RP is the custodian of the clinical record" (CRPO 5.1).

Read your own, in the current edition — the retention period sets how long everything else here has to keep working.

Two related questions belong with it.

What form they are kept in. They have to stay secure after you stop. Psychotherapists acting as 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" (CRPO 6.4.4). They may be split across more than one place, so long as "each location must reference the other locations" (CPBAO 9.4) — which is the rule that covers notes in one system and a message history exported out of another.

What happens at the end. Disposal is neither automatic nor casual. Social workers "shall dispose of records only after the time frames described in Interpretation 4.2.2 have elapsed", and "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).

Who holds them, and how do people reach them?

Someone still has to be able to answer a request for a client's record — from the client, from a subsequent clinician, occasionally from a court.

Two things to settle.

Where the records physically live. If they are inside software you are cancelling, they have to come out into something you control and can still read years from now. If they stay with a provider, you are depending on a company continuing to exist and continuing to let you in. Neither is wrong; the choice should be deliberate.

Who a client contacts. An email address and a phone number that will still work. This is the reason to think hard before releasing your practice number: reassigned to a stranger, it sends a former client's records request to that stranger.

Both Colleges that address it want a named person on file, not a private intention. Psychotherapists who are custodians "provide the College with 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" (CRPO 6.4.3). Psychologists and behaviour analysts "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", and "where possible, the designate should be a registrant of the College" (CPBAO 9.6).

Telling clients

Give more notice than feels necessary. Closing is a clinical event before it is an administrative one, and the notice period is what makes an ending possible rather than an interruption.

There is a published floor. Psychotherapists are expected to provide "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 method is set out too: try direct notice first — "in person during a scheduled appointment or through a telephone conversation, direct letter, personal email, etc." — and where not everyone can be reached, 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.)". Whichever you use, registrants "are expected to document their attempts to alert clients" (CRPO 6.4).

That makes the greeting on your old number an answer rather than an afterthought.

The written notice should carry: the date you stop practising, what happens to their care, how to get a copy of their record, and how to reach you afterwards. Written, because they will need it later and a conversation is not retrievable.

Do it in the room as well, and early. The last session should not be where someone learns there will not be a next one.

For anyone continuing in care, a referral is worth more than a list. Naming people, and making an introduction where you can, is the difference between a transfer and an ending someone has to organise while unwell.

What happens to the phone number

Keep it longer than the practice.

While the retention period runs, that number is a route to you for records requests, for a former client with a question, for another clinician following up. Release it and it will be reassigned eventually, and those calls reach a stranger.

The cheapest arrangement is usually the smallest plan that still answers, with a greeting that says the practice has closed, gives the date, and says where to send records requests. That greeting converts a dead end into an instruction, which is more than the rest of this list manages.

Do not simply stop paying and let it lapse. A number that goes dark without a message is what generates complaints.

Cancelling the operational accounts

Last, and in this order:

• Export everything, and open the exports to confirm they are complete and readable

• Store the exports wherever the records are going to live for the retention period

• Confirm in writing what the provider will retain after closure, and for how long, and whether they will delete on request

• Cancel in writing, and keep the confirmation

• Check the next statement, and the one after

Ask the retention and deletion question specifically. Federal privacy rules tell an organization to keep personal information "only as long as it is needed to serve those purposes" (Office of the Privacy Commissioner of Canada) — a direction, not a date. The date lives in their policy and your contract, so get it in writing before you cancel.

Your own duty does not move across to them either way. A custodian using an outside service "remains responsible for information collection, use, disclosure, and secure destruction by the agent" (CPBAO 9.5).

Also your directory listings, your website, your business listing — a listing left live sends people to a practice that no longer exists.

If the closure is not planned

Illness, injury and death do not give notice, and the arrangements above become someone else's problem.

At least one College requires the plan outright. Registrants "have a contingency plan in place to promote continuity of care in the event of an unexpected interruption to their practice", and its expected contents 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" (CRPO 6.4.2 and commentary). The notice rule bends rather than disappears for this case: "In cases of emergency or sudden and unexpected incapacitation, registrants or their representatives shall provide as much notice as reasonably possible."

The useful version is short: a document naming who to contact, where the records are, how to get into them, and what clients should be told — kept somewhere a trusted person can find it.

The short version

Read your College's own words on retention and notice first. Give clients written notice with a date, a referral, and a way to get their record. Export before you cancel, and check the exports open. Keep the number answering with a greeting that says where to send records requests. Cancel the accounts last, in writing. And write the unplanned version down while you are well.

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