PRACTICAL APPLICATIONS 
Practical Applications have been developed to provide clarity, guidance, and examples for some Standards.

APPLICABILITY
For the purposes of Ontario Regulation 801/93 Professional Misconduct, section 1.2., the Standards of Professional Conduct (2017) are to be considered “standards of the profession”.

DEFINITIONS
Administration:  the administration of psychological services as opposed to administrative duties that are of a clerical or business-related nature. For greater clarity, administration of psychological services refers to the planning, implementation, monitoring and evaluation of items a) through h) under “Psychological Services” below.

Best Efforts: taking, in good faith, all steps, that would not require undue hardship, that a reasonable member would take in the circumstances, depending on the facts of the particular case and the level of risk that would result from inaction, to achieve an objective and carry out the process to its logical conclusion.

The College: the College of Psychologists of Ontario.

Consultation: the provision of information, within a relationship of professionals of relatively equal status, generally based upon a limited amount of information that offers a point of view that is not binding with respect to the subsequent professional behaviour of the recipient of the information.

Client: an entity receiving psychological services, regardless of who has arranged or paid for those services. A client can be a person, couple, family or other group of individuals with respect to whom the services are provided. A person who is a “client” is synonymous with a “patient” with respect to the administration of the Regulated Health Professions Act (1991). 

Formal Correspondence: documents that contain information about a psychological service that is intended for use beyond the practice or organization.

Fulfilling the Requirements to Become a Member of a College: obtaining the necessary education, training or experience required for registration with that College.

Member: an individual registered with the College of Psychologists of Ontario to provide psychological services, including those holding a certificate of registration authorizing autonomous practice, interim autonomous practice or supervised practice; or those holding an academic, inactive or retired certificate of registration.

Organizational Client: an organization, such as a business, community or government that receives services that are directed primarily at the organization, rather than to the individuals associated with that organization.

Public Statements: statements in any medium that include, but are not limited to paid or unpaid advertising, grant and credentialing applications, brochures, printed matter, directory listings, personal resumes or curricula vitae, comments for use in media including print and electronic transmission, statements in legal proceedings and contained in the public record, lectures and public presentations, and published materials.

Psychological Records: records that include all forms of information collected in relation to the provision of psychological services, regardless of the nature of the storage medium.

Psychological Services: services of a psychological nature that are provided by or under the supervision of a member. Psychological services include, but are not limited to, one or more of the following:

a. Evaluation, diagnosis and assessment of individuals and groups;
b. Intervention with individuals and groups, including but not limited to, therapy, counselling, crisis intervention and psychoeducation;
c. Consultation;
d. Program development and evaluation;
e. Supervision;
f. Research;
g. Education and training;
h. Scholarly activities; and,
i. Administration.

Supervision: an ongoing educational, evaluative and hierarchical relationship, where the supervisee is required to comply with the direction of the supervisor, and the supervisor is responsible for the actions of the supervisee.

Note:  Capitalized terms not defined in these Standards shall have the meaning ascribed to them in the Psychology Act, 1991, the regulations made thereunder, and/or the By-laws of the College.

1.1 Compliance with College Authority

Members of the College must comply with the regulatory authority of the College.

1.2 Responding to a College Request

When requested by the College, members must promptly provide an account of their activities, responsibilities and functions.  When employed by an institution or other non- member, members must also provide a description of the organization and the types of service that the organization provides.

1.3 Agreements with the College

Members must adhere to any undertaking or agreement that they have made with the College.

1.4 Participation in Quality Assurance

Members must participate fully in all mandatory aspects of the College’s Quality Assurance Program.

1.5 Provision of Regulatory Information to Clients

If requested by a client, members must provide information regarding the mandate, function, location and contact information of the College, and provide information about where the client can obtain:

a) the statutes and regulations that govern the provision of psychological services; and
b) the College’s Standards, guidelines, and codes of ethics.

2.1 General Conduct

Members must conduct themselves so that their activities and/or those conducted under their direction comply with those statutes and regulations that apply to the provision of psychological services.

Practical Application: A hierarchy of rules applies to the services of members. When reviewing one’s obligations one should apply the following hierarchy: 
1. Legislation 
2. Regulations under the legislation 
3. The Standards of Professional Conduct 
4. The Canadian Code of Ethics for Psychologists 
5. Other ethical guidelines

3.1 Responsibility for Psychological Services

3.1.1 Private Practice Settings

Members, whether working individually, in partnership or as shareholders of a psychological corporation, must assume responsibility for the planning, delivery, supervision and billing practices of all psychological services they provide to clients. 

3.1.2 Employment Settings

Members must assume responsibility for the planning, delivery, and supervision of all psychological services they provide to clients.  Members working as employees must make best efforts to ensure that their work setting adheres to the Standards of Professional Conduct (2017) in the planning, delivery, supervision and billing practices of all psychological services provided.

3.2 Clarification of Confidentiality and Professional Responsibility to Individual Clients and to Organizations

In situations in which more than one party has an interest in the psychological services rendered to a client or clients, members must, to the extent possible, clarify to all parties, prior to rendering the services, the dimensions of confidentiality and professional responsibility that must pertain in the rendering of services.  The provision of psychological services on behalf of an organizational client does not diminish the obligations and professional responsibilities to individual clients.

Practical Application: The need for clarification may arise, for example, in the provision of an assessment of a claimant in an insurance matter, where the insurer has retained the assessor. Regardless of the wishes of the insurer, members are under all of the obligations that pertain to a client within these Standards and the relevant privacy legislation.   This includes providing access to the individual or their authorized representative to their personal information and any reports or records which members have in their possession unless prohibited by law or they are otherwise permitted to refuse access.  

4.1 Responsibility of Supervisors of Psychological Service Providers

If members are supervising psychological services provided by a member holding a certificate for supervised practice or any other unregulated or regulated service provider who is not an autonomous practice member of the College, the clients are considered to be clients of the supervisor.

Members must assume responsibility and accountability for, and review, the actions and services of all supervised providers of psychological services who are not authorized by the College to provide those services autonomously. Supervising members must be authorized to provide the relevant services with the relevant populations, autonomously. 

These provisions apply to, but are not limited to, supervisees who are employees, students, trainees, members holding certificates of registration authorizing supervised practice, members holding certificates of registration authorizing autonomous practice who are providing services for which they are not authorized and service providers who are not members.

The responsibilities and obligations of the supervisor depend on the qualifications of the supervisee; that is whether the supervisee is a member holding a certificate of registration authorizing supervised practice, a non-member or an Autonomous Practice member.  The requirements for all supervision undertaken, as well as additional/alternate responsibilities for supervision in specified circumstances, are set out below.  

Practical Application:  A service provider, for the purpose of this Standard, is a person who provides psychological services. The supervision Standards are not intended to apply to situations in which, for example, an employee of a member provides support or assistance to a member who is providing the service. Examples of those working under the direction of a member but not subject to the formal requirements under this section, are staff members performing administrative tasks, supervising children in a waiting room or assisting in the administration of questionnaires for a member. It is important to note that when a member receives assistance from a non-member in providing psychological services, the member remains fully responsible for ensuring that all services comply with the Standards of Professional Conduct (2017), pursuant to Standard 3.1 (Responsibility for Psychological Services). 

Non-members performing tasks on behalf of members, when those tasks require professional education, training and/or experience, are considered to be under the supervision of members and subject to the Standards within this section. Examples of such tasks are administering measures involving the application of clinical knowledge and judgment, and/or interpreting test results.    

4.1.1 All Supervision

1) Supervising members must be competent to provide the services undertaken by their supervisee;

2) Supervising members must assess the knowledge, skills and competence of their supervisee and provide supervision as appropriate to the supervisee’s knowledge, skills, and competence, based on this assessment;

3) Supervising members must keep a record of supervision activities and contacts between themselves and their supervisee and such a record must include, at a minimum:

a) the date and length of time of each supervision meeting;
b) information that will permit the identification of each client discussed at each supervision meeting;
c) a summary of discussions regarding each assessment and intervention matter occurring at each supervision meeting;
d) a summary of discussions regarding any relevant ethical, professional and jurisprudence issues discussed at each supervision meeting;
e) a notation of any directives provided to the supervisee at each supervision meeting; and
f) a notation of the supervisee’s strengths and needs for further development identified at each supervision meeting.

Practical Application:  It is not necessary to include a client’s name within a supervision record, however, sufficient information must be included to allow the member to determine the identity of the client referred to. For example, a member may use initials or a client identification number, if this would enable the member to distinguish between different clients being discussed.

Practical Application:  Supervision records are meant to record the interaction between the supervisor and supervisee and focus on the supervisor’s evaluation, direction and support of the supervisee as well as the supervisee’s response to the input of the supervisor; supervisors are responsible for ensuring that those under their supervision maintain records as required under section 9 (Records and Record Keeping) and reflect the contribution of the supervisor to the service delivery.  

4) Supervision records must be retained for at least two years after the last supervisory contact;

5) Supervising members must ensure that there is an individual supervision agreement, signed by both themselves and their supervisee, for each supervisory relationship and such an agreement must include, at a minimum:

a) the date upon which the agreement is effective and the expected expiry date;
b) the specific duties and obligations of the supervisee;
c) any limitations imposed upon the activities of the supervisee;
d) the specific duties and obligations of the supervisor;
e) the expected frequency and length of supervision meetings;
f) the manner in which the supervisor will be directly involved in the planning, monitoring and evaluation of the services provided to clients;
g) contact information and emergency contact information for both the supervisor and supervisee;
h) confirmation that the supervisee will comply with all requirements under the legislation and regulations relevant to the service and the Standards of Professional Conduct (2017); and
i) identification of a plan for appropriate support for the supervisee in the event of the supervisor’s unavailability.

Practical Application: A supervision agreement must set out the nature of the supervisor’s direct involvement and reflect consideration of the education, skill, and training of the supervisee.  

Note: In institutional settings, such as school boards, hospitals and correctional facilities, employment contracts which address the terms of supervision referred to in these Standards may be considered to constitute a supervision agreement.  

6) Supervising members must not make supervisory arrangements for the sole purpose of facilitating billing and payment for services by a third-party payer;

7) Supervising members names, clearly identified as the supervisor, and their contact information, must be clearly identified on all psychological reports and formal correspondence related to psychological services;

8) Supervising members must ensure that billing and receipts for services are in their name, psychology professional corporation or employer and clearly identify the name of the supervising member and the name, relevant degrees and professional designations of the supervised psychological service provider; and

9) Supervising members must make best efforts to ensure that the supervisory relationship is conducive to professional development and in the best interests of their supervisee.

4.1.2 Supervision of Supervised Practice Members

In addition to the responsibilities outlined in 4.1.1:

a) Supervising members, when acting as primary or alternate supervisor for a member holding a certificate authorizing supervised practice, must provide reasonable training and mentoring to assist the supervised member in the registration process; and,
b) Must co-sign all psychological reports and formal correspondence related to psychological services prepared by their supervisee.

4.1.3 Supervision of Non-Members

In addition to the responsibilities outlined in 4.1.1:

a) Supervising members must co-sign all psychological reports and formal correspondence related to psychological services provided by their non-member supervisees;
b) Supervising members must have a direct supervisory relationship with their supervisee who is the service provider, unless the psychological service is provided in the context of an organized program where supervisors are accountable for the services by legislation; and
c) Supervising members may not permit a supervisee to assign services to, or to supervise another service provider, unless the supervisee is in the process of satisfying the requirements to become a member of the College. 

Note: For the purposes of this part, in addition to those services defined within these Standards as Psychological Services, any services provided by a supervisee under the supervision of a member that falls within the scope of practice of psychology as defined in the Psychology Act, 1991 is deemed to be Psychological Services.

Practical Application: Delivery of Applied Behavioural Analysis (ABA) and Intensive Behavioural Intervention (IBI) services in Ontario must conform to the guidelines set by the Ontario Ministry of Children and Youth Services.

Practical Application: For the purposes of Standard 4.1.3, those who are in the process of satisfying the requirements to become a member of the College include, for example, graduate students enrolled in programs intended to prepare them for registration with the College or post-Masters individuals acquiring the required four years of supervised experience to be eligible to apply for registration. 

4.1.4 Supervision of Autonomous Practice Members of the College   

All of the requirements under 4.1.1 are applicable to supervisors of Autonomous Practice members who are seeking to provide services outside of their authorized areas of practice and/or client groups, except for:

a)  identification of supervisor (4.1.1 [7]) and billing and receipts (4.1.1 [8]); and,
b) Supervisors are not required to sign final drafts of reports and formal correspondence but must approve them and document such approval.

4.1.5 Members Providing Non-Supervisory Consultation and Other Services

Members providing formal, ongoing consultation, but not supervision, regarding psychological matters to other service providers who may or may not be members of the College, must have a clear agreement, signed by both parties, confirming the understanding that the member is not taking on responsibility for client care and that the person receiving such consultation retains responsibility for the individual client or the organizational client care. Notwithstanding the above, members should be aware that in all circumstances they are accountable for providing competent information.

4.2 Informing Clients

Supervising members must confirm that clients have been informed of the following at the onset of service provision:

a) the professional status, qualifications, and functions of the individual providing the service;
b) that all services are reviewed with, and conducted under the supervision of, the supervisor;
c) the identity of the supervisor and how the supervisor can be contacted;
d) that meetings with the supervisor can be arranged at the request of the client, supervisor, and/or supervisee; and,
e) with respect to the limits of confidentiality, that the supervisor must have access to all relevant information about the client.

4.3 Controlled Acts

Only members of the College may perform the controlled acts which they are legally authorized to perform and members must not permit non-members to perform them except as described in 4.3.1 below.

4.3.1 Supervision of Members Holding Certificates Authorizing Supervised Practice and Other Individuals in the Course of Fulfilling the Requirements to become a Member of the College

Supervising members may permit the performance of controlled acts only by members holding certificates authorizing supervised practice or other individuals in the course of fulfilling the requirements to become a member of the College and who demonstrate the required knowledge, skills and competencies. The supervising member must determine the process for the performance of the controlled acts taking into consideration the knowledge, skills, and competence of the supervisee.

Practical Application: For the purposes of Standard 4.3.1, those who are in the process of satisfying the requirements to become a member of the College of Psychologists of Ontario will include those who are graduate students enrolled in programs intended to prepare them for registration with the College of Psychologists of Ontario. Members may not supervise performance of the Controlled Act by individuals intending to register with a different College.   

 
4.3.2 Supervision of Non-member Providers who are Not Authorized to Perform the Controlled Act of Communicating a Diagnosis

Only the supervising member may perform the controlled act of communication of a diagnosis, either in person or through ‘real time’ communication such as by telephone, teleconferencing or videoconferencing.

Please also see Standard 6.4 (Public Announcements) and 9.1.2 (Record Keeping)

5.1 Practising Within Areas of Competence

Members may only provide services within their authorized areas of practice and with their authorized client populations, and then only when competent to provide those particular services.

Members wishing to provide services that are beyond their competence but are within their authorized areas of practice and with their authorized client populations may only do so under the professional guidance of a member who is authorized and competent to provide the services being delivered.

Practical Application: In deciding whether one is authorized and competent to provide a service, the nature of the client’s presenting difficulties will generally determine whether the member has the appropriate and required authorization. For example, if a client who has suffered a traumatic brain injury has been referred because of a need to assess the nature of their neuropsychological deficits, it is expected that the member providing the assessment would have Clinical Neuropsychology as an authorized area of practice. If the person was referred because of difficulty performing activities of daily living or occupational requirements, it is expected that the member would be authorized in Rehabilitation Psychology. If the person was referred because of suspected anxiety or depression, then it is expected that the member would be authorized in Clinical Psychology.   

In cases where the focus of the services is not the person’s neuropsychological functioning, as long as the member has obtained the opinion of someone authorized in the area of Clinical Neuropsychology that the person’s symptoms are not caused primarily by problems attributable to their neuropsychological functioning, and that the intervention would be appropriate to use with a person with such injury, it may not be necessary to have authorization in the area of Clinical Neuropsychology, although this would be preferable.

Practical Application: There are not always clear demarcations with respect to population groups, particularly with respect to age. Members are expected to use their professional judgment to determine whether in all of the circumstances, the person’s status is consistent with the status of those with whom they are authorized to work. For example, when determining whether a client is a child or adolescent, it would be important to consider whether the person’s abilities, life circumstances and challenges are consistent with those which would normally be expected within the population groups for which the member is authorized to work.   

5.2 Changing/Expanding Areas of Competence

Members who are interested in changing or expanding their professional practice to include a new area or client group, beyond their current authorized area of practice and/or client group, must inform the College, undertake appropriate training, education and supervision, and satisfy any other formal requirements specified by the College.

Members wishing to provide services outside of their authorized areas of practice or their authorized populations may do so only under supervision.

6.1 Presentation of Qualifications

In presenting their qualifications, members must conform to the following practices:

a) members must show their registration certificate to a client upon request;

b) members must represent themselves to the public as a member of the College by using the title Psychologist or Psychological Associate.  This may be abbreviated to C.Psych. or C.Psych.Assoc., or they may indicate that they are a “Member of the College of Psychologists of Ontario”;

c) any of the following applicable limitations must immediately follow a member’s title: “Supervised Practice”, “Retired” or “Inactive”;

d) the highest academic degree upon which registration is based, or the highest degree otherwise recognized by the College, must immediately precede the professional title;

e) only use the title “Doctor” or a variation, abbreviation or equivalent in another language in the course of providing or offering to provide, psychological services if the member:

i. has been registered as a Psychologist on the basis of a doctoral degree; or

ii. was registered as a Psychologist on the basis of a master’s degree but subsequently was awarded a doctoral degree which was recognized by the College.

f) clarification of area of psychological practice may be made by the addition of a qualifier either to the title Psychologist or Psychological Associate (e.g., Clinical Psychological Associate, Clinical Neuropsychologist) or by citing one or more areas of practice (e.g., practice in school psychology, practice limited to school psychology). The qualifier or citation must be consistent with one or more of the areas of practice in the registration guidelines;

g) other degrees or professional titles, such as MBA, P.Eng., must be specified when the area of study is relevant to the member’s psychological practice;

h) members must not qualify their title by citing membership in professional associations (e.g., OPA, OAPA, CPA, APA, CRHSP); and

i) members may qualify their title by citing a credential relevant to the practice of psychology in Ontario and issued by a recognized professional credentialing body where that organization conducts a formal written or oral examination of each applicant’s knowledge, skills and qualifications.

Practical Application: A member should make reasonable effort to correct others who misrepresent the member’s professional qualifications or associations. Similarly, a member should not permit, counsel or assist individuals who are not members to represent themselves as offering psychological services, except under supervision, or as either a psychologist or psychological associate.

Practical Application: Members may not use titles or designations such as “sport psychologist” or “community psychologist” as these titles do not represent areas of practice as set out in the registration guidelines.  Members with expertise in such areas may, however, use descriptors such as “having expertise in…” or “practice restricted to…”   

6.2 Accuracy of Public Statements

Members must not knowingly make public statements that are false, misleading or fraudulent, concerning their psychological services or professional activities or those of persons or organizations with which they are affiliated.  Accordingly, members must not misrepresent directly or by implication their professional qualifications such as education, experience, or areas of competence.  Moreover, members must not misrepresent their qualifications by listing or displaying any affiliations with an organization that might be construed as implying the sponsorship or certification of that organization.  Members may list or display an affiliation only if such sponsorship or certification does, in fact, exist.

6.3 Promotion of Professional Practice

Members may advertise their practices. A paid advertisement must be identified, or be clearly recognizable, as an advertisement.   Members who engage others to create or place advertisements or public statements that promote their professional practice, products, or activities retain professional responsibility for such statements.  Any advertisement of a member’s practice must comply with the O.Reg. 209/94 General Regulation: Quality Assurance; Advertising) under the Psychology Act, 1991.

6.4 Public Announcements

Public announcements of psychological services and fees must be offered in the name of an autonomous practice member of the College.

6.5 Compensation for Publicity

Members must not compensate a representative of the media, in any way, in return for free publicity.

 
6.6 Provision of Information to the Public

Members who provides information, advice or comment to the public via any medium must take precautions to ensure that:

a) the statements are accurate and supportable based on current professional literature or research;
b) the statements are consistent with the professional standards, policies and ethics currently adopted by the College; and
c) it would reasonably be expected that an individual member of the public receiving the information would understand that these statements are for information only, that a professional relationship has not been established, and that there is no intent to provide professional services to the individual.

7.1 Limits of Confidentiality

At the onset of the provision of psychological services, or at the earliest reasonable opportunity, members are responsible for ensuring that their clients are informed of the limits of confidentiality maintained by the member and anyone they may supervise, in accordance with the legislation relevant to the service.

Practical Application: In some settings, informing clients of the limits of confidentiality may be performed by other staff, for example, intake workers. In such situations, members must confirm that the procedures for performing this function are in accordance with the standards of the profession and legislation relevant to the service and if they are not, the member must ensure that clients are appropriately informed about the limits of confidentiality.  

7.2 Obtaining Consent

Members are responsible for ensuring that informed consent is obtained with respect to the delivery of all psychological services unless otherwise permitted or required by law.

Practical Application: In some settings, informed consent may be routinely obtained by others in the organization, for example, intake workers. In such situations, members must confirm that the procedures for performing this function are in accordance with the standards of the profession and legislation relevant to the service and if they are not, the member must ensure that consent is appropriately obtained. 

8.1 Collection, Use and Disclosure

Members are responsible for ensuring that consent is obtained with respect to the collection, use and disclosure of personal information and personal health information in a manner required by legislation applicable to the relevant service.

Practical Application: In some settings, decisions concerning collection, use and disclosure of information may be made by others in the organization, for example, intake workers and/or records personnel. In such situations, members must determine who the health information custodian is, under the relevant privacy legislation, and who is responsible for obtaining such consent and entitled to make such decisions.    

8.2 Access by Client or Client’s Authorized Representative

Members are responsible for ensuring that access to an individuals’ personal or personal health information is provided to the individual and/or their authorized representative unless prohibited by law or the member is otherwise permitted to refuse access.

Practical Application: In some settings, decisions concerning access to information may be made by others in the organization, for example, records personnel. In such situations, members must determine who the health information custodian under the relevant privacy legislation is and who is responsible for obtaining such consent and entitled to make such decisions.

Practical Application: Standard 10.8 requires that when reasonable and appropriate, raw data from standardized psychological tests and other test data must, upon request and with proper authorization, be released to clients and others. Only the publisher of a test may provide authorization for a member to share proprietary test materials, including copyrighted test forms. Members are therefore advised to seek such permission before copying or distributing any copyrighted materials. When permission is not granted by a test publisher to copy a form containing test scores, members may report raw test data by transferring the information to a document which is not protected by copyright, for example, a blank page. See Standard 10.8 for additional information regarding protection of test security.    

9.1 General Conditions

Members must make best efforts to ensure that their records are complete and accessible; this applies whether the record is kept in a single file or in several files and whether the record is housed in one location or at several locations.

Members supervising psychological services provided by a psychology intern, trainee, member holding a certificate for supervised practice or any other unregulated or regulated service provider who is not an autonomous practice member of the College, are responsible for the protection and retention of all individual client and organizational client records.

Practical Application: Due to the potential for harm from misinterpretation of raw data and a member’s duty to protect the security and respect the copyright of psychological tests, a member should make reasonable efforts to avoid placing raw data and test materials in a common file.

9.1.2 Members Responsible for Supervising Supervised Practice Members and Non- Members

Members supervising Supervised Practice members and non-members are responsible for the security, accessibility, maintenance and retention of records.

9.1.3   Use of Technology in Maintaining Records, for example, Electronic Record Keeping

Members are required to ensure the security of records kept in an electronic form and are required to maintain current knowledge of risks and associated risk mitigation strategies and to apply this knowledge to all technologies they may use to ensure that all records are secure and accessible to the member for the required retention period.

9.2 Individual Client Records

1) Members must keep a record related to the psychological services they provide for each client who has engaged them to provide psychological services, or for whom such services have been authorized;
2) The record must include the following:

a) client’s name(s), address(es) and (if available) telephone number(s), as well as any other identifying information needed to distinguish the client from other clients;
b) the client’s date of birth;
c) the date of every relevant and material contact between the member and the client;
d) the date of every material consultation, either given or received by the member, regarding service to the client;
e) a description of any presenting problem and of any history relevant to the problem;
f) relevant information about every material service activity related to the client that is carried out by the member or under the responsibility of the member, including, but not limited to: assessment procedures; resulting assessment findings; diagnoses; goals or plans of service developed; reviews of progress on the goals and/or of the continued relevance of the plan of service; activities related to crises or critical incidents; and interventions carried out or advice given;
g) relevant information about every material service activity that was commenced but not completed, including reasons for the non-completion;
h) relevant information about every controlled act, within the meaning of Section 4 of the Psychology Act, 1991 and subsection 27(2) of the Regulated Health Professions Act, 1991, and the regulations under both statutes, performed by the member;
i) all reports or correspondence about the client, received by the member, which are relevant and material to the member’s service to the client; members may choose to return information that is not relevant or material, to the party that provided the information or to securely destroy that material after confirming that the sender has retained a copy;
j) all reports and communications prepared by the member regarding the client;
k) a copy of every written consent and/or documentation of the process of obtaining verbal consent related to the member’s service to the client; and
l) relevant information about every referral of the client, by the member, to another professional.

3) All information recorded and/or compiled about an individual client must be identifiable as pertaining to that client.
4) All information recorded and/or compiled must be dated and the identity of the person making the entry, must be discernible.
5) Despite the requirements of Section 3, members are not required to retain personally identifiable information on persons receiving prevention, public education, group training, emergency or post emergency group services, or group screening services.  
6) Members must explain or interpret a record written in a language other than that in which the service was provided, if requested by a client.

Practical Application: Translation generally refers to conveying the meaning from one language to another in writing. Interpretation generally refers to communicating this information orally.

Relevant legislation may require a member to provide a copy of the client’s health record, upon request. While a member is not required under this Standard to provide a written translation of the record, they may voluntarily agree do so. As there is no requirement to provide a translation, a translation which a member has agreed to provide need not be a certified translation.

There must be a reasonable expectation that the information provided will be understandable to the intended recipient. Factors that may help determine the nature of information to be conveyed include the purpose for which the recipient has requested the information; the recipient’s ability to read and/or comprehend the information; and the effect of regional dialects, cultural terms, expressions, and idioms.

Practical Application: When a member is maintaining a record written in a language other than that in which the service was requested it is expected that, at the onset of services, the member will obtain an agreement with the client with respect to whether or not a translated record will be made available upon request, as well as what additional fees may be applied for any translation, explanation or interpretation of the record.

Practical Application: The decision about whether to retain a document, including raw test protocols, within the record, might be answered by the following question: “Could the reliability of my conclusions or the reasonableness of my actions be confirmed without reference to the information in the document or test protocol?”

9.3 Organizational Client Records

1) Members must keep a record related to the services provided to each organizational client.
2) The record must include the following:

a) the name and contact information of the organizational client;
b) the name(s) and title(s) of the person(s) who can release confidential information about the organizational client;
c) the date and nature of each material service provided to the organizational client;
d) a copy of all agreements and correspondence with the organizational client; and
e) a copy of each report that is prepared for the organizational client.

9.4 Retention of Records

Unless otherwise required by law:

a) The individual client record must be retained for at least:
i) ten years following the client’s last relevant clinical contact; or
ii) if the client was less than eighteen years of age at the time of their last relevant clinical contact, ten years following the day the client became or would have become eighteen.

b) The organizational client record must be retained for at least ten years following the organizational client’s last contact.  If the organizational client has been receiving service for more than ten years, information contained in the record that is more than ten years old may be destroyed if the information is not relevant to services currently being provided to the client.

 
9.5 Billing Records

A record of fees charged to and received from clients must contain the following information: the payer, the recipient of psychological services, the service provider(s), the date, nature, and unit fee of the service, the total charged, the payment received and the date of payment.  Such records must be maintained on the same retention schedule as the individual or organizational client record.

9.6 Security of Client Records

9.6.1 Storage 

Members must make best efforts to ensure that client records are secure and protected from loss, tampering or unauthorized use or access. 

9.6.2 Transmission and Disclosure

Members must make best efforts to ensure that the disclosure or transmission of information protects the privacy of the client record.

9.7 Client Records in a Common Filing System

Members must exercise appropriate care when placing information in a common record in an effort to ensure that their reports and recommendations are not misunderstood or misused by others who may have access to the file.  

Practical Application: Due to the potential for harm from misinterpretation of raw data and a member’s duty to protect the security and respect the copyright of psychological tests, a member should make reasonable efforts to avoid placing raw data and test materials in a common file.

9.8 Client Records of Members Who Cease to Provide Psychological Services

9.8.1 In Private Practice Settings

1) Members planning to, or who cease to, provide psychological services must:

a) take ongoing responsibility for the maintenance and security of client records or arrange for the security and maintenance of client records. In making such arrangements, members must make best efforts to ensure that the designate is a member of the College;
b) ensure that former clients have access to the client record for the prescribed retention period; and,
c) inform the College of these arrangements prior to ceasing to provide psychological services or at the earliest reasonable opportunity.

2) Members in private practice must arrange for the security and maintenance of private practice client records in the event of their incapacity or death and must inform the College of these arrangements.  Members must make best efforts to ensure that the designate is a member of the College.
  
Note: For the purposes of (1) and (2) above, if a member is unable to designate another member of the College as custodian of the records, then the member must make best efforts to designate another regulated health professional and if unable to that, then a person who is familiar with the requirements of the applicable legislation.

 
9.8.2 In Employment Settings

1) Members planning to, or who cease to, provide psychological services must:

a) take reasonable steps to ensure the maintenance and security of client records;
b) take reasonable steps to ensure that former clients have access to the client record for the prescribed retention period.

10.1 Familiarity with Tests and Techniques

Members must be familiar with the standardization, norms, reliability, and validity of any tests and techniques used and with the proper use and application of these tests and techniques.

Practical Application: At times, a member may provide services in what would be considered an emerging area of practice. In such situations, a member should inform clients that the services being offered may not, as yet, have been subjected to extensive research and validation. As with any informed consent process regarding the provision of services, clients would be informed of the risks, benefits and alternatives available.

Practical Application: A member should not provide or offer to provide services to a client who is known or should be known to be receiving similar from another provider, except in exceptional circumstances. Before agreeing to provide such services, the member should discuss with the client the reasons for seeking services and the potential disadvantages of receiving similar services from two providers at once. A member should seek the client’s consent to notify the other provider and coordinate service provision.

10.2 Familiarity with Interventions

Members must be familiar with the evidence for the relevance and utility of the interventions used and with the proper use and application of these interventions.

10.3 Rendering Opinions

Members must render only those professional opinions that are based on current, reliable, adequate, and appropriate information. 

10.3.1 Review Without Evaluation

When, as part of a psychological service, members conduct a review of a client record, and the evaluation of the client is not necessary, the members must document this and indicate the sources of information used to form their opinions.

10.4 Identification of Limits of Certainty

Members must identify limits to the certainty with which diagnoses, opinions, or predictions can be made about individuals or groups.

10.4.1 Documentation of Sources of Data

In situations in which all reasonable attempts have been made to conduct an evaluation of a client but a complete evaluation is not possible, a member must ensure that the efforts made to conduct the evaluation and the obstacles encountered are documented.  Additionally, members must indicate the extent to which the availability of only limited information influenced the certainty of their opinion.

10.5 Freedom from Bias

Members must provide professional opinions that are clear, fair and unbiased and must make best efforts to avoid the appearance of bias.

10.6 Clarity of Communication

Members must make best efforts to present information in a manner that is likely to be understood by the client.

10.7 Use of Computer-Generated Reports

Information obtained from computer-generated assessments, reports or statements must not be substituted for a members professional opinion. 

10.8 Protection of Test Security

Members must protect the security of tests and respect test copyright.  To this end members must distinguish between test data and test materials.  When reasonable and appropriate, raw data from standardized psychological tests and other test data must, upon request and with proper authorization, be released to clients and others.  Test material, such as test questions and stimuli, manuals, and protocols should not be released, except as required by law. 

11.1 Fees and Billing Arrangements

Members must reach an agreement with an individual, group or organization concerning the psychological services to be provided, the fees to be charged and the billing arrangements prior to providing psychological services.  Any changes in the services to be provided must be agreed to by the client before service is delivered or fees are changed.  Fees must be based on amount of time spent and complexity of the services rendered.

Practical Application: Fees for services should be determined on a consistent basis, regardless of the payer. A member may however, offer pro bono services or apply a sliding scale to ensure access to services and affordability.

11.2 Ancillary Charges

11.2.1. Interest and Missed Appointments

Members may charge:

a) interest on an overdue account; or
b) a fee for a missed appointment or late cancellation when prior notice is not given within an agreed upon period of time.

Note: The client must be informed of such charges at the time that billing arrangements are discussed.

11.2.2. Administrative Fees

Members may charge a fee for other services such as:

a) preparing special reports;
b) copying, interpreting, or translating records; or,
c) completing forms (e.g., disability tax credit forms, insurance forms). Such fees must be discussed prior to the service being undertaken

11.3 Collection of Unpaid Fees

Members must inform their clients of the intention to use a collection agency or other legal options to collect fees and must provide an opportunity for payment to be made before doing so.

11.4 Retainers

Members must not require clients to prepay for any psychological services including preparation of reports.  Members may request retainer funds in advance, but these funds must be held in a segregated account, separate from the member’s practice operating account funds or personal funds. These segregated funds must only be applied to services rendered, when such services are rendered and invoiced, and any excess segregated funds must be returned to the client following the termination or conclusion of services.

12.1 Impairment Due to Health Factors

Members must not undertake or continue to provide psychological services when they are, or could reasonably be expected to be, impaired due to mental, emotional, physiological, or pharmacological or substance abuse conditions.  If such a condition develops after psychological services have been initiated, members must discontinue the psychological services in an appropriate manner.  Members must make best efforts to ensure that clients are notified and assisted in obtaining replacement services to ensure continuity of care.

13.1 Compromised Objectivity, Competence or Effectiveness Due to Relational Factors

Members must not undertake or continue to provide psychological services with an individual client when their objectivity, competence or effectiveness is, or could reasonably be expected to be, impaired. This could be due to the members present or previous familial, social, sexual, emotional, financial, supervisory, political, administrative, or legal relationship with the client or a relevant person associated with the client.  This prohibition does not apply if the services are delivered to an organizational client and the nature of the professional relationship is neither therapeutic nor vulnerable to exploitation. 

13.2 Compromised Objectivity, Competence or Effectiveness Due to Other Factors

Members must not undertake or continue to provide psychological services when personal, scientific, professional, legal, and financial or other interests could reasonably be expected to:

a) impair their objectivity, competence or effectiveness in delivering psychological services; or
b) expose the client to harm or exploitation.

13.3 Avoidance of Undue Influence on Clients

Members must not persuade or influence a client to make gifts or contributions of any kind.

13.4 Avoidance of Exploitation

1) Members must not use information obtained during the provision of psychological services to directly or indirectly acquire advantage over or exploit the client or to improperly acquire a benefit.

2) A member must not exploit persons over whom they have supervisory, evaluative or other authority such as clients, students, supervisees, research participants or employees.

13.5 Relations with Current or Former Clients

Members must not enter, or make plans to enter, into an intimate or sexual relationship with a current client or a former client where the psychological services were provided within the previous two years. Even after two years, members must not enter into an intimate or sexual relationship with a former client when they know or reasonably ought to know that the former client is vulnerable to exploitation or may require future service or some other professional involvement specifically from them.  This does not apply to relationships with employees of an organizational client unless the psychological service provided to a particular individual was either intended to be therapeutic or the individual is vulnerable to exploitation.

Practical Application: The Standards state that a member must not enter into a sexual relationship with a current or former client for two years following the last professional contact. Even after two years however, a member should avoid such relationships except in the most exceptional circumstances. If a member is considering entering into a sexual relationship with a former client, there are a number of relevant factors a member should consider including: 
1. the likelihood of adverse impact on the client;
2. the client’s current mental status;
3. whether there continues to be a power imbalance that may be influencing the client’s decision;
4. the client’s personal history and any particular difficulties of which the member ought to have been aware;
5. the nature, duration and intensity of the professional service; and
6. the amount of time, over two years, since the last professional contact.

13.6 Gifts from Clients

Members must not accept a gift of more than token value from a client.  In accepting even a small gift, members must carefully consider the potential clinical implications of this. 

14.1 Sexual Harassment

Members must not engage in sexual harassment in any professional context.  Sexual harassment includes, but is not limited to, any or all, of the following:

a) the use of power or authority in an attempt to coerce another person to engage in or tolerate sexual activity including, but not limited to, explicit or implicit threats of reprisal for noncompliance or promises of reward for compliance;
b) engaging in deliberate and/or repeated unsolicited sexually oriented comments, anecdotes, gestures, or touching, where the member knows or ought to know that such behaviours are offensive and unwelcome, or creating an offensive, hostile, or intimidating professional environment; and
c) engaging in physical or verbal conduct of a sexual nature when such conduct might reasonably be expected to cause harm, insecurity, discomfort, offence, or humiliation to another person or group.

14.2 Other Forms of Abuse and Harassment

Members must not engage in any verbal or physical behaviour of a demeaning, harassing or abusive nature in any professional context.

14.3 Sexual Relationships with Students and Psychology Interns, Psychology Trainees and Supervisees

Members must not engage in a sexual relationship with an individual with whom they have a current evaluative relationship or with whom they might reasonably expect to have a future evaluative relationship.

The College has adopted the Association of Canadian Psychological Regulatory Organization (ACPRO), Model Standards for Telepsychology Practice as a Practice Advisory for all members which are reflected in the following Standard:

Regardless of the modality used for service delivery, members are expected to practice according to all of the statutes, regulations, Standards, and Codes of Ethics applicable to them in Ontario and those jurisdictions in which any of their clients receive services.

In addition to the general responsibilities for providing psychological services as noted above, the following must be observed in the provision of services via telepsychology:

15.1 Registration in Ontario

Members must be authorized in Ontario to provide any service they are providing outside of Ontario. When practicing outside of Ontario, members must conform to any and all rules, regulations, and Standards established within Ontario. As with any other services, members holding certificates authorizing supervised practice must be supervised in all telepsychology practice by a member authorized to provide such services.

15.2 Services Outside of Ontario

Members delivering telepsychology services to individuals who are located outside of Ontario must ensure they are legally entitled to do so.

Practical Application: The College does not have the authority to determine what is permissible in jurisdictions outside of Ontario.  A member who wishes to provide services to individuals outside of Ontario must seek direction from the relevant regulatory body. The College recognizes that in exceptional circumstances, in order to prevent harm to vulnerable clients, it may be necessary to provide emergency services to a client. The College cannot provide permission to members to contravene statutes in another jurisdiction.   

Practical Application: A member who wishes to provide services to individuals outside of Ontario where there is a lack of clarity regarding jurisdiction, for example, in military or diplomatic situations, is advised to obtain independent legal advice before providing those services.     

15.3 Complaints

Members must inform clients that the College of Psychologists of Ontario is the regulatory body with authority to address complaints about the services received and must provide contact information for the College on request.

15.4 Familiarity with Jurisprudence

Members must be familiar with the local jurisprudence and standards for practice in the jurisdiction in which the service is being delivered. Where there is a conflict between such laws/regulations/standards and those of Ontario, members must act according to the higher standard.

15.5 Liability Insurance

Members delivering telepsychology services outside of Ontario must ensure they carry appropriate liability insurance with respect to such service.

15.6 Competence in Use of Technology

Members must be competent in the use of the technology of the service delivery medium.

15.7 Privacy

To minimize the possibility of someone impersonating a client and gaining access to confidential health information, or influencing a member’s assessment or opinion of the client, members must use some form of coded identification of the client in cases where live visual verification is not possible.

15.8 Technological Failure

Members must make plans with clients regarding what will happen in the event of technological failure.

These Standards are applicable to the practice of psychology and applied behaviour analysis (“the professions”) and other professional activities requiring the application of knowledge and skill associated with the practice of the professions, by all registrants of the College and all individuals providing services under the supervision of a registrant.

The Standards are intended to assist registrants in making professional judgments of an ethical nature and are not intended to determine clinical, technical, or legal matters. For the purposes of O. Reg. 195/23: PROFESSIONAL MISCONDUCT, made under the Psychology and Applied Behaviour Analysis Act, 2021, “standards of the profession” include the Standards of Professional Conduct (2024) as well as the nature of conduct reasonably expected of registrants.

PRACTICAL APPLICATIONS 

Practical Applications have been developed to provide clarity, guidance, and examples for some standards.

DEFINITIONS

The College: The College of Psychologists and Behaviour Analysts of Ontario.

Client: an entity receiving psychological or behavioural services, regardless of who has arranged or paid for those services. A client can be a person, couple, family, or other group of individuals with respect to whom the services are provided. A person who is a “client” is synonymous with a “patient” for the purpose of the Regulated Health Professions Act, 1991.

Consultation: the provision of information or advice, in a relationship where the recipient of the information or advice is not required to act on the information or advice and the consultee is not accountable to the consultant. Consultation is not supervision and does not include assessing, diagnosing or intervening with a client, regardless of whether there is direct contact between the registrant and the client. In these cases, the requirements applicable to the practice of the profession with those service recipients will apply.

Delegation: delegation under the Regulated Health Professions Act, 1991, is not specifically defined but is understood to be a process whereby a regulated health professional authorized to perform a controlled act procedure under a health profession Act confers that authority to someone – regulated or unregulated – who is not so authorized.

Organization: an entity, such as a business, community or government that receives services that are directed primarily at the organization, rather than to the individuals associated with that organization, regardless of who funds the services.

The practice of psychology: the assessment of behavioural and mental conditions, the diagnosis of neuropsychological disorders and dysfunctions and psychotic, neurotic and personality disorders and dysfunctions and the prevention and treatment of behavioural and mental disorders and dysfunctions and the maintenance and enhancement of physical, intellectual, emotional, social, and interpersonal functioning (Psychology and Applied Behaviour Analysis Act, 2021).

The practice of applied behaviour analysis: the assessment of covert and overt behaviour and its functions through direct observation and measurement, and the design, implementation, delivery, and evaluation of interventions derived from the principles of behaviour in order to produce meaningful improvements (Psychology and Applied Behaviour Analysis Act, 2021).

Professional services: services of a professional nature, whether psychological or behavioural, as described in the scopes of practice in the Psychology and Applied Behaviour Analysis Act, 2021, provided by or under the supervision of a registrant. Such services also include, but are not limited to, one or more of the following which require application of graduate level education, training and experience relevant to the profession:

a.         Consultation;

b.         Program development and evaluation;

c.         Supervision;

d.         Research;

e.         Education and training;

f.         Scholarly activities; and

g.            Administration

Registrant: a Behaviour Analyst, Psychologist or Psychological Associate registered with the College; synonymous with the term “member”.

Supervision: an ongoing educational, evaluative, and hierarchical relationship, where the supervisee is required to adhere to the Standards of Professional Conduct and comply with the direction of the supervisor, and the supervisor is responsible for ensuring that the service provided to each recipient of services is competent and ethical. It is not consultation or delegation.

Note: Capitalized terms not defined in these Standards shall have the meaning ascribed to them in the Psychology and Applied Behaviour Analysis Act, 2021, the regulations made thereunder, and/or the By- laws of the College.

1.1 General Conduct

Registrants must practise in alignment with the following hierarchy:

1. Legislation;
2. Regulations under the legislation;
3. Standards of Professional Conduct; and
4. College-endorsed Codes of Ethics.

1.2 Participation in College Programs

Registrants must fulfill all requirements relevant to their registration status, including, but not limited to, the Quality Assurance program. Registrants must notify the College immediately if there is any reason they are unable to do so.

1.3 Responding to the College

Registrants must be responsive to and cooperate with the College. This includes:

1. Promptly providing requested information to the College when asked;
2. Complying with the regulatory authority of the College; and
3. Abiding by agreements, undertakings and/or commitments made to and/or with the College.

1.4 Provision of Regulatory Information to Clients

Registrants must be transparent in their communications with clients about the College. Upon request from any service recipient, registrants must:

1. Furnish information about the College’s mandate and functions;
2. Provide contact details for the College; and
3. Supply information about governing statutes, regulations, Standards, and relevant ethical codes endorsed by the College.

1.5 Employment Settings

Registrants  working as employees must demonstrate efforts to ensure that their work settings adhere to applicable statutes, regulations, standards, codes of ethics, and guidelines.

(See also: 2.1 Organizational Constraints and Conflicts)

2.1 Organizational Constraints and Conflicts

The well-being and rights of individuals receiving professional services from, or under the supervision of, registrants take precedence over organizational constraints, except where mandated by law. In instances of conflicting requirements, registrants should strive to resolve these conflicts in the recipients’ best interests, unless doing so poses serious personal or professional risk to the registrant.

If the practices of an organization are contrary to the legislation, regulations or Standards of the Profession, registrants are required to demonstrate efforts to educate those in a position to authorize a change to the practices and adopt practices which are in keeping with the relevant rules.

Practical Applications: Registrants required by an employer to engage in conduct which is contrary to the standards of the profession are expected to advocate for changes within the workplace but are not expected to put livelihood at risk. Examples of such conflicts include, but are not limited to, the presentation of professional credentials, supervision arrangements and contents of records. Where an employer expects a registrant to act in a way that is contrary to a statute or regulation, including the Professional Misconduct Regulation, registrants are encouraged to seek independent legal advice as lack of compliance with statute or regulation is tantamount to engaging in an illegal activity. Examples of such conflicts include, but are not limited to, breach of confidentiality, bypassing the need for appropriate consent or failing to make a report concerning harm to an individual as required by law.

2.2   Responsibility for Services

Registrants, who issue invoices for services, whether operating individually, in partnerships, or as shareholders within a health professional corporation, must assume responsibility for the planning, delivery, supervision, and billing procedures for all services provided.

2.3   Continuity of Services

Unless there has been an agreement with the client at the outset of services that services are time-limited and the time limit has been reached, registrants are responsible for ensuring continuity of services that are needed by each recipient whose services they provide directly or supervise. Barring a client’s withdrawal or request to discontinue services which remain needed, services may only be discontinued if reasonable efforts are made to secure alternative services, the client is afforded a fair chance to arrange alternatives, or the continuation of services would pose a serious personal or professional risk to the registrant.

3.1    Respect and Dignity in Professional Practice

Registrants must demonstrate dignity and respect in their professional conduct towards all individuals, in all aspects of their practice. This includes being culturally responsive and practising consistent with relevant legislation on harassment and discrimination and published practice guidelines.

Practical Application: The main pieces of legislation applicable in Ontario in this regard include the Canadian Charter of Rights and Freedoms,1982  the Ontario Human Rights Code, 1990,  and the Criminal Code of Canada, 1985 . These statutes require, among other things, consideration of each individual’s experience including, but not limited to, considerations of age, ancestry, colour, culture, race, citizenship, ethnic origin, place of origin, creed, disability, family status, marital status, gender identity, gender expression, receipt of public assistance, record of offences, sexual orientation, and language. Relevant guidelines are posted on the College’s Equity, Diversity, and Inclusion page.

Practical Application: When working with an individual whose cultural background the registrant is not sufficiently familiar with, the registrant is encouraged to seek consultation from knowledgeable colleagues, other professionals, and/or relevant community members including elders and spiritual or religious leaders. Registrants are also encouraged to remain current with evolving literature in this regard, seek relevant professional training and consult clinical practice guidelines. For links to several relevant documents, please visit the College’s Equity, Diversity, and Inclusion page.

4.1    General

a. Clients receiving supervised services are the supervisor’s clients. All professional responsibilities regarding supervision flow from this fundamental premise;

b. Supervisors must be competent to provide the services undertaken by their supervisees;

c. Supervisors must assess the knowledge, skills and competence of their supervisees and provide supervision as appropriate to their assessments;

d. Supervision must be sufficiently intensive to enable active monitoring of goals and progress concerning each service recipient;

e. Supervisors must regularly review the list of active clients and actively monitor all matters to determine the optimal frequency of discussion of each client;

Practical Application: Supervisors are encouraged to meet with supervisees in real time, although they may meet with them more or less frequently, based on the supervisee’s demonstrated knowledge, experience, and the degree of independence the supervisor deems appropriate.

Practical Application: In addition to any group supervision provided, supervisors should ensure that there is sufficient one to one supervision to allow the supervisee and supervisor to raise confidential individual concerns.

f. Supervisors bear full responsibility for all aspects of service, including marketing, public statements, intake procedures, case assignment, obtaining appropriate consents, billing, receipt issuance, and service termination;

g. Supervisors may not conduct supervision if it places them in a real or apparent conflict of interest. Supervisors must also avoid dual and/or multiple relationships (see also Standard 12: Objectivity);

h. Supervisors must ensure that a plan is in place for continuity of services, provided either under supervision or directly, in the case of unexpected circumstances preventing supervision from occurring. Such a plan must include communication of the changed circumstances to service recipients;

i. When supervising a registrant of a profession other than their own profession, the service is considered to be the practice of the supervisor’s profession, and is subject to the legislation, regulations, and Standards applicable to the supervisor; and

j. Supervisors are expected to consider the activity of supervision when conducting self-assessment and demonstrate efforts to maintain competence as a supervisor through appropriate continuing professional development.

4.2    Purpose of Supervision

Supervisors may engage in supervision only when the supervisee requires it to competently deliver services, when a non-registrant is assisting a registrant in performing a service by the registrant, or to fulfill the College’s registration requirements. Outside of these circumstances, registrants should consider offering consultation, training, or mentorship. Supervision may not be provided for the purpose of facilitating third-party payments.

Practical Application: Assisting a registrant in performing a service by the registrant may include permitting an employee or colleague to administer and score measures which require professional knowledge, skill and judgment. For example, one may supervise a psychometrist, therapist or unregistered behavioural service provider. A supervisor may also obtain assistance in performing intervention, such as therapy or counselling, so long as they ensure that the client is made aware that they are the client of the supervisor and that the therapy is being provided on behalf of the supervisor and under the supervisor’s direction.

4.3    Communication Regarding Supervised Services

Supervisors must ensure that clients receiving services under their supervision, and relevant other parties, are informed of the following:

1. The supervision status of the direct service provider, including their credentials;
2. Any change in supervisors;
3. The supervisor’s contact information;
4. That they may contact the supervisor directly and/or request a meeting, should they wish;
5. That, with respect to the limits of confidentiality, the supervisor must have access to all relevant recorded information about the client; and
6. The identity of the Health Information Custodian (HIC), and that the HIC will control and have access to the file.

4.4     Supervision Agreements

Supervisors must establish individual supervision agreements, jointly signed by themselves and their supervisees, for each supervisory relationship. These agreements should include, at a minimum:

1. The effective date and anticipated expiry date of the agreement;
2. Specific duties and responsibilities of the supervisee;
3. Any constraints placed on the supervisee’s activities;
4. The specific duties and responsibilities of the supervisor;
5. Expected frequency and duration of supervision meetings;
6. Method of direct involvement of the supervisor in planning, monitoring, and evaluating services for each client;
7. Contact information and emergency contacts for both the supervisor and supervisee;
8. Confirmation of the supervisee’s commitment to comply with relevant legislation, regulations, and the Standards of Professional Conduct, 2024;
9. In circumstances where an individual is supervised by more than one supervisor, information about the roles and involvement of each supervisor that would prevent confusion about responsibility of the supervisors for client care;
10. A plan outlining appropriate support for the supervisee and clients in case the supervisor becomes unavailable; and
11. A mechanism for dispute resolution.

Practical Application: In institutional settings, such as school boards, hospitals and correctional facilities, only those items listed above which are not included in any employment contracts need be included in a supervision agreement.

4.5    Supervision Records, Documents and Billing

4.5.1  Contents of supervision records

Supervising Registrants must maintain comprehensive records of supervision activities and contacts with their supervisees. These records must include, at minimum:

1. The date and duration of each supervision meeting;
2. Information enabling identification of discussed clients at each meeting;
3. A summary of discussions related to professional services, including but not limited to assessment, intervention and consultation matters per meeting;
4. A summary of discussions regarding ethical, and jurisprudence issues per meeting;
5. Documentation of any directives given to the supervisee at each meeting; and
6. The supervisee’s identified strengths and developmental needs identified or discussed at each  meeting.

Practical Application: It is not necessary to include a client’s name within a supervision record, however, sufficient information must be included to allow identification of the client referred to. For example, a registrant may use initials or a client identification number, if this would enable the registrant to distinguish between different clients being discussed.

Practical Application: Supervision records are meant to record the interaction between the supervisor and supervisee and focus on the supervisor’s evaluation, direction, and support of the supervisee, as well as the supervisee’s response to the input of the supervisor; supervisors are responsible for ensuring that those under their supervision maintain records as required under Section 9: Records and Record Keeping and reflect the contribution of the supervisor to the service delivery.

4.5.2  Retention of Supervision Records

Supervision records must be retained for a minimum of ten years following the client’s last relevant clinical contact for any client discussed, or if the client was less than eighteen years of age at the time of their last relevant clinical contact, ten years following the day the client became or would have become eighteen.

(See also Section 9: Records and Record Keeping)

4.5.3  Formal Correspondence

A supervisor must be clearly identified by name as the supervisor, and their contact information must be clearly identified on all reports and formal correspondence related to supervised services.

4.5.4  Co-signing documents

A supervisor must co-sign all documents which may be reasonably relied upon to make a decision affecting client care, rights or welfare. (See also Section 9: Records and Record Keeping)

4.5.5  Billing of Supervised Services

All billing of services provided under supervision are the direct responsibility of the supervising registrant, who must ensure that billing and receipts for services are in their name, or the name of the health professional corporation or their employer. Additionally, invoices and receipts must clearly identify the name of the supervising registrant and the name, relevant degrees, and professional designations of the supervised service provider.

4.6    Supervision of Controlled Acts

Psychology registrants acting as supervisors may permit the performance of controlled acts only by individuals holding certificates authorizing supervised practice or those in the process of fulfilling registration requirements, and who demonstrate sufficient knowledge, skills, and competencies to perform the acts under supervision. Supervisors must ensure that those performing the controlled acts under their supervision offer competent and ethical service, adhering to all relevant legislation and regulations. The supervisor is responsible for determining the process of performing controlled acts, considering the supervisee’s knowledge and competence.

The controlled act of communicating a diagnosis may only be performed by the supervising registrant, unless the supervisee holds a Certificate of Registration for Autonomous Practice, a Certificate of Registration for Supervised Practice or is performing the act under supervision in the course of fulfilling the requirements to become a registrant of the College.

Practical Application: For the purposes of Standard 4.6, those who are in the process of satisfying the requirements to become a registrant of the College include, for example, graduate students enrolled in programs intended to prepare them for registration with the College or those who have satisfied the academic requirements for registration and are acquiring the required supervised experience to be eligible to apply for registration.

4.7     Consultation

Registrants providing ongoing formal consultation (as opposed to supervision) to service providers, regardless of the consultee’s registration with any regulatory organization, must establish a clear agreement, signed by both parties. This agreement must acknowledge that the registrant is not assuming responsibility for the service provided, and that the recipient of the consultation retains full responsibility for service planning and delivery. Nonetheless, registrants remain accountable for offering competent information in all circumstances.

4.8 Familiarity with Guidelines for Supervised Practice

Supervisors overseeing Registrants with Certificates of Registration for Supervised Practice, and those possessing such certificates, must familiarize themselves with, and adhere to, the relevant registration guidelines and supervision resource manual.

4.9 Second-level Supervision

A Supervisor may allow a supervisee to oversee another service provider only if the supervisee holds a Certificate of Registration for Autonomous Practice or conducts supervision in order to meet College registration requirements. A Supervisor may permit a supervisee to obtain training and mentorship from others, however, all other supervisory responsibilities, including but not limited to ensuring the provision of competent and ethical care of each recipient of service is the direct responsibility of a supervisor registered with the College.

Practical Application: In some contexts, such as the institutional provision of ABA services, a supervisor may allow a supervisee to obtain training and mentorship by someone the supervisor deems qualified and competent, but the supervisor must ultimately monitor the services provided under their supervision and must ensure that the care provided is competent and consistent with the relevant legislation, regulations, Standards of Professional Conduct and codes of conduct. In permitting a non-supervisor to assist with a task in respect of a supervisee, such as training, mentorship or consultation, the supervisor must ensure that all individuals involved in the arrangement understand and agree that the person delivering the services is accountable directly to the supervisor and not the individual who has been assigned the task by the supervisor. In other words, there may only be one supervisor and the supervisor remains fully accountable for the service.

4.10 No Delegation

Psychology registrants may not delegate Controlled Acts in any circumstances. Behaviour Analysts do not have access to the Controlled Acts.

5.1    Authorized Areas of Practice and Client Groups

5.1.1 Behaviour Analysts

Although Behaviour Analysts are not subject to limitations related to authorized areas of practice or client groups, Psychologists and Psychological Associates have limitations on their certificates of registration that prohibit them from practicing outside of their particular authorized areas of practice and client groups. Registration as a Behaviour Analyst does not, however, imply that one can practice with any client, in any situation, and for any purpose within the scope of applied behaviour analysis. Practitioners must remain aware of practicing within the bounds of their own scopes of competence.

5.1.2 Psychologists and Psychological Associates

When providing psychological services, registrants are required to adhere to their authorized areas of practice and client groups. Registrants may provide other professional services outside of their authorized areas of practice and groups, where those services do not require specialized knowledge, skill and training.

Whether a professional service falls within a registrant’s authorized areas of practice is determined by the nature of the client’s difficulty to be addressed. If associated difficulties arise subsequent to the initiation of services, and those difficulties are not the focus of the contracted service provision, if addressing the additional issues would fall outside of the registrant’s authorized area of practice or client group, the registrant must consult with another Registrant authorized to provide services in that area of practice and with that client group.

In considering a registrant’s authorized populations, the service recipient’s abilities, life circumstances and challenges, must be considered. The ability to work with the service recipient will be established in accordance with the registrant’s reasoned determination of which group the recipient falls into. When uncertain, registrants should consult with another registrant with authorization for the specific relevant population and area of practice.

Practical Application: In deciding whether one is authorized and competent to provide a service, the nature of the client’s presenting difficulties will generally determine whether the registrant has the appropriate and required authorization. For example, if a client who has suffered a traumatic brain injury has been referred because of a need to assess the nature of their neuropsychological deficits, it is expected that the registrant providing the assessment would have Clinical Neuropsychology as an authorized area of practice. If the person was referred primarily because of difficulty performing activities of daily living or occupational requirements, it is expected that the registrant would be authorized in Rehabilitation Psychology. If the person was referred primarily because of suspected anxiety or depression, then it is expected that the registrant would be authorized in Clinical Psychology. In cases where the focus of the services is not the person’s neuropsychological functioning, as long as the registrant has obtained the opinion of someone authorized in the area of Clinical Neuropsychology that the person’s symptoms are not caused primarily by problems attributable to their neuropsychological functioning, and that the intervention would be appropriate to use with a person with such injury, it may not be necessary to have authorization in the area of Clinical Neuropsychology, although that would be preferable.

Practical Application: There are not always clear demarcations with respect to authorized population groups, particularly with respect to age. Registrants are expected to use their professional judgment to determine whether, in all the circumstances, the person’s status is consistent with the status of those with whom they are authorized to work. In doing so, one might consider such things as the person’s abilities and life circumstances. For example, when determining whether a client should be considered an adolescent or young adult, it may help to consider whether, like an adolescent, they are experiencing the challenges of late-stage puberty, or still actively involved in navigating developmental milestones such as the development of personal identity, social autonomy, intimate relationships, vocational capability, and financial independence. If that is the case, one might reasonably consider them to fall within the category of adolescents. If they have achieved physical maturity, and levels of emotional, social, and financial independence typically expected in adulthood, one may make a reasonable argument that they be considered an adult.

5.2    Specialized Knowledge

Even when a service falls within a registrant’s authorized area of practice or population, a registrant is expected to self-monitor and refrain from conducting activities with which they may be unfamiliar or not competent to engage in, and which require specialized knowledge, skill or experience. Registrants who are not competent with respect to the use of a particular tool or technique, or in addressing specific issues, may use the tool or technique only following consultation with a registrant with the relevant authorized areas of practice and client group, and competence.

Practical Application: Although registrants are required to work within their authorized areas of practice and client groups, in circumstances where the service is unrelated to a client service a registrant may provide services more generally. For example, a registrant may, without regard to client group, do such things as:

• act as an administrator of an agency that serves the lifespan of development without regard to their authorized areas of practice or client groups;
• act as an administrator of an agency that serves the lifespan of development without regard to their authorized areas of practice or client groups;
• teach an undergraduate course, as long as they have the requisite knowledge themselves, as opposed to a graduate level course intended to prepare a registrant or future registrant for clinical practice.

5.3 Changing/Expanding Area of Authorized Competence

Psychology registrants seeking to change or expand their professional practice to include a new authorized area of practice or client group must inform the College. Pursuant to the College’s direction, they must undertake appropriate training, education and supervision, and satisfy any other formal requirements directed by the College. Registrants wishing to provide services outside of their authorized areas of practice or their authorized populations, where specialized knowledge, training and experience are required, may do so only under supervision.

6.1    Presentation of Qualifications

1. Registrants must identify themselves by the title granted by the College, specifying the nature of their College-issued Certificate and the degree upon which their registration was granted upon request;
2. Any of the following applicable limitations must immediately follow a registrant’s title: “Supervised Practice”, “Retired” or “Inactive”;
3. The highest academic degree upon which registration is based, or the highest degree otherwise recognized by the College, must immediately precede the professional title;
4. The title “Doctor” or a variation, abbreviation or equivalent in another language may only be used in the course of providing or offering to provide, services if the registrant:
   • has been registered as a Psychologist on the basis of a doctoral degree; or
   • was registered as a Psychologist on the basis of a master’s degree but subsequently was awarded a doctoral degree which was recognized by the College;
5. Additional relevant degrees may be included in a title or job description, following the degree upon which registration was granted;
6. Registrants may not reference professional association memberships in titles or service descriptions. However, credentials relevant to practising the profession, requiring successful formal evaluation, may be identified; and
7. As the College doesn’t issue specialist designations, registrants may not claim specialization. They may indicate the focus of their practice, specify that their services are limited to certain activities, or highlight areas of expertise.

 Practical Application: Acceptable identifiers include:

• Dr. John Smith, Ph. D, C. Psych., Retired
• John Smith, Ph. D., P. Eng., M.A., C. Psych. Assoc., Supervised Practice; Practice limited to Industrial/Organizational Psychology
• Alex Jones, M.ADS., R.B.A. (Ont.), BCBA
• Alex Jones, M.ADS., Behaviour Analyst
• Alex Jones, M.ADS., R.B.A. (Ont.), Registered Behaviour Analyst, BCBA, Expertise in behavioural intervention with individuals experiencing dementia
• Alex Jones, Ph.D., R.B.A. (Ont.), BCBA-D
• Alex Jones, M.ADS., Behaviour Analyst (Supervised Practice)
• Alex Jones, M.ADS., R.B.A. (Ont.) (Supervised Practice)

Practical Application: As the College doesn’t issue specialist designations, registrants may not claim specialization. They may indicate the focus of their practice, specify that their services are limited to certain activities, or highlight areas of expertise. One may clarify an area of psychological practice by the addition of a qualifier either to the title Psychologist or Psychological Associate (e.g., Clinical Psychological Associate, Clinical Neuropsychologist) or by citing one or more areas of practice (e.g., practice in school psychology, practice limited to school psychology). The qualifier or citation must be consistent with one or more of the areas of practice in the registration guidelines, in which you are authorized to practice. Modifiers which are not consistent with the formal areas of practice, such as “sport psychologist” or “community psychological associate” are not permissible, however, Registrants with expertise in such areas may, however, use descriptors such as “having expertise in working with issues related to athletic performance” or “practice restricted to promoting community change at individual and systemic levels”.  

6.2       Public Statements

6.2.1      Accuracy of self-representation

Registrants must not knowingly make false, misleading, or fraudulent public statements regarding their professional activities or associations with individuals or organizations. This includes the direct or implied misrepresentation of their education, experience, or areas of competence. Additionally, registrants should refrain from misrepresenting their qualifications by displaying affiliations that could wrongly imply sponsorship or certification by an organization unless such sponsorship or certification genuinely exists and can be verified.

6.2.2     Correction of Misrepresentation

Registrants may not permit others to misrepresent their qualifications and must demonstrate efforts made to correct misrepresentations made by others, where possible.

6.3    Promotion of Professional Practice

1. Registrants may advertise their practices, but the advertisements must be clearly identified as such;
2. Registrants may not name a practice in a manner that is misleading or suggests anything untrue;
3. Public announcements or advertisement may only be permitted in the name of a registrant with a Certificate of Registration for Autonomous or Interim Autonomous Practice;
4. Registrants may not compensate media for promotion of a practice;
5. Testimonials may not be used to promote a registrant’s practice; and
6. Registrants may not engage in direct solicitation of individuals requiring service provision via any medium.

(See also: General Regulation O. Reg 194/23: Advertising)

6.4    Provision of Information to the Public

Registrants who provide information, advice, or comment to the public via any medium must take precautions to ensure that:

1. The statements are accurate and supportable based on current professional literature or research;
2. The statements are consistent with the professional standards, policies and ethics currently adopted by the College; and
3. It would reasonably be expected that an individual registrant of the public receiving the information would understand that these statements are for information only, that a professional relationship has not been established, and that there is no intent to provide professional services to the individual.

Practical Application: Registrants who identify themselves as registrants of the College and wish to make public statements must consider whether they are contravening any of the limits of freedom of expression which are set out in relevant legislation, including: hate speech, harassment, discrimination, and defamation (Please also see Standard 3: Equity, Diversity and Inclusion).

6.5    Communicating via Social Media

Registrants may not publish information on social media about an identifiable service recipient if that information will be accessible to anyone other than the service recipient or their authorized substitute decision maker. Collecting personal health information about an identifiable service recipient using any medium, including social media, requires the service recipient or an authorized substitute decision maker’s consent; even if collecting information about service recipient with appropriate consent, registrants must consider how collecting information from a public source may impact on ones’ professional relationship with a service recipient (See also Section 8: Confidentiality and Privacy).

Registrants may not respond publicly to on-line reviews if the review would allow the identification of a current or past service recipient. Even if no identification is possible, the registrant must consider the possibility of harm resulting to the client or former client as a result of the response.

Practical Application: When communicating via social media registrants should:

1. Consider whether their communications could reasonably amount to a public statement or in the alternative, would reasonably be considered private and accessible only to specific individuals , with the onus on the registrant to understand who may have access to their posting;
2. Consider whether they could be reasonably identified as a registrant, and if so, that they may be considered to be speaking as a registrant, even if they don’t identify themselves as one;
3. Avoid the possibility of a dual or multiple relationship with a recipient of services, for example, by indicating that one is a “friend” of a recipient of services or by corresponding about personal matters of a social, recreational, or business nature;
4. Not make statements that interfere with, or are likely to interfere with, the ability to collaborate with others, the delivery of high-quality services or the maintenance of safety or perceived safety of others; and
5. Not use degrading, demeaning, intimidating or abusive language or behaviour in circumstances where they may reasonably be known to be a registrant.

7.1 Obtaining Consent

Registrants must ensure they have obtained informed and capable consent from all individuals receiving services, prior to the commencement of services and whenever changes are made to the nature of services offered or provided. The following principles apply to obtaining appropriate consent:

1. Registrants should ensure they are familiar with and are following the legal requirements for obtaining consent, or proceeding without consent, particular to the service they are providing;
2. Consent obtained in writing, physical or via secure technology, is preferred. However, oral consent is acceptable and must be documented in the client’s file; and
3. In the event of lack of clarity or uncertainty concerning consent between substitute decision makers of equal ranking within the hierarchy of substitute decision makers listed in statute, or between a substitute decision maker and an incapable service recipient, registrants should not provide services until they receive clarification of who is authorized to give consent via relevant legislation, court order, or formal and documented agreement. 

 Practical Application: If authority as a substitute decision maker is either unclear or in dispute, registrants may wish to seek independent legal advice.

Practical Application: In some situations, registrants may believe that third parties have exerted pressure on clients to consent to services or risk a loss of benefits or other rights. When in doubt about whether a client’s consent is freely given, registrants should ensure that they do not exert any pressure on the client to agree and clarify that the client may refuse the service if they choose to do so. In this context, the registrant should encourage the client to seek clarification about their options should services not proceed. Registrants should proceed only if the client expresses a clear wish to proceed (See also Section 3: Equity, Diversity and Inclusion).

8.1      Limits of Confidentiality

Before or at the onset of service provision, registrants must ensure that service recipients are advised of the limits of confidentiality relevant to the services provided.

8.2     Applicable Privacy Legislation

Members are responsible for ensuring that access to an individual’s personal or personal health information is provided to the individual and/or their authorized representative unless prohibited by law or the member is otherwise permitted to refuse access.

Practical Application: In most cases, the applicable privacy legislation is the Personal Health Information Protection Act, 2004 . In some circumstances services may be governed by other privacy legislation, as is often the case with services provided within organizations operated or funded under municipal, provincial, or federal legislation; if guidance in this regard is required, it is advisable to confirm the applicable legislation with the management of the organization within which services are provided.

Practical Application: Eligibility to act as a custodian of personal and personal health information may vary between different privacy statutes. The Personal Health Information Protection Act addresses privacy with respect to most services provided by Regulated Health Professionals. It allows for, among other things, a health care practitioner or a person who operates a group practice of health care practitioners to act as an HIC. In situations where more than one entity may be considered to be the HIC, consensus should be established between the HIC, the client and other eligible custodians. Registrants and others working within some institutions may also be considered agents of HICs. Information about when one may be considered the agent of a HIC is available from the Office of the Privacy Commissioner of Ontario.

8.3 Collection, Use and Disclosure of Personal and Personal Health Information

Registrants must ensure that the collection, use, and disclosure of information occurs only with the consent of the person about whom the information applies, or as permitted by legislation. When the service provider is not considered the HIC, Registrants must demonstrate efforts to ensure that the HIC acts in accordance with these requirements.

Practical Application: When unsolicited information is received without appropriate consent or does not appear to meet any of the statutory exceptions to the requirement for consent to collect information, the HIC must return the information to the sender, If possible. In so doing, Registrants should not even acknowledge that they are providing services to the relevant individual without consent.

8.4 Information about Third Parties

Information about a party other than a recipient of service that is contained in a record, may only be disclosed if permitted or required by law, or with consent of the parties to whom the information relates.

8.5 Access by Client or Client’s Authorized Representative

Registrants are responsible for ensuring that access to an individual’s personal or personal health information is provided to the individual and/or their authorized representative, unless prohibited by law, or the registrant is otherwise permitted to refuse access, even when contrary to the wishes of a third-party funder.

Practical Application: While recipients of a service may agree to waive their rights with respect to the control or access of their personal health information, if a client wishes to rescind such an agreement, a registrant is encouraged to seek independent legal advice before withholding any information the client may have a statutory right to obtain.

Practical Application: Factors that may help determine the nature of information to be conveyed include the purpose for which the recipient has requested the information; the recipient’s ability to read and/or comprehend the information; and the effect of cultural terms, expressions, and idioms.

8.6 Protection of Test Security

Registrants must respect test security and copyright restrictions. As such, they must prevent the distribution of materials and information that could adversely affect the integrity and validity of tests. Test questions, items, and other proprietary materials should not be released without permission of the publisher of the documents. When prevented from providing proprietary information by copyright protections, registrants are expected to seek the permission of the publisher of the document or, if necessary, provide transcribed responses to test items without revealing test questions or other proprietary information.

9.1    General

a. All recorded or compiled information must be dated, and the identity of the person making the entry must be clear;

b. When collaborating with professionals from other disciplines and generating interdisciplinary information, registrants must include relevant notes from other professionals in their clinical records;

c. When providing services within a group, separate records must be maintained for each group participant;

d. If requested by a client, registrants must explain or interpret documents they have authored and/or signed in a language other than the language in which the service was provided; and

e. Client Records must be presented in a way which is understandable to another health professional if a client requests that the records be provided;

Practical Application: When a registrant is maintaining a record written in a language other than that in which the service was provided it is expected that, at the onset of services, the registrant will obtain an agreement with the client with respect to whether or not a translated record will be made available upon request, as well as what additional fees may be applied for any translation, explanation or interpretation of the record.

Practical Application: Relevant legislation may require a registrant to provide a copy of the client’s health record, upon request. While a registrant is not required under this standard to provide a written translation of the record, they may voluntarily agree do so. As there is no requirement to provide a translation, a translation which a registrant has agreed to provide need not be a certified translation.

Practical Application: Information provided from a client record is expected to be legible and understandable to the intended recipient.

f. All documents that contain conclusions, judgments, decisions, diagnoses, or recommendations must be signed by the registrant responsible for the service; a document authored by a person who is not a registrant authorized for autonomous practice must be signed by both the registrant and supervisee;

g. The record keeping requirements applicable to organizational clients are applicable to the provision of consultation;

h. Registrants who are not health information custodians (HICs) must take reasonable steps to ensure the maintenance and security of service records and ensure that current and former recipients of service are informed about how they may gain access to the service record for the prescribed retention period;

Practical Application: In the absence of an institutional or organizational HIC, a registrant who is supervising service provision is the HIC. When uncertain about who the HIC is, registrants are encouraged to seek independent legal advice.

i. Records in the control of a registrant must identify if any information that the registrant knows or ought to know is false or misleading.

9.2    Individual Client Records

Registrants must keep a record regarding the services they provide to each client. Each record must contain:

1. Identifying information about the client, including name, date of birth, address and (if available) telephone number and email address of each service recipient;
2. Dates and details of every relevant or material service contact or consultation;
3. A description of any presenting problem and of any history relevant to the problem;
4. Relevant information about every material service activity that is carried out by the registrant or under the responsibility of the registrant, including, but not limited to: assessment procedures; assessment findings; diagnoses; goals or plans of service; reviews of progress with respect to goals and/or of the continued relevance of the plan of service; activities related to crises or critical incidents; and interventions carried out or advice given;
5. Relevant information about every material service activity that was commenced but not completed, including reasons for the non-completion;
6. When providing group therapy, a separate record must be maintained for each individual recipient of services;
7. Relevant information about the performance of every controlled act performed by the registrant;
8. All reports or correspondence about the service recipient(s), received by the registrant, which are relevant and material to the service to the client. Registrants may return information that is not relevant or material, to the party that provided the information, or to securely destroy that material after confirming that the sender has retained a copy;
9. All reports and communications prepared by the registrant regarding the service recipient(s);
10. A copy of every written consent and/or documentation of the process of obtaining verbal consent related to the service;
11. Relevant information about every referral of the service recipient by the registrant to another professional; and
12. Any other documents that provide information relevant and material to service that is not included elsewhere in file, and which is relevant to the opinions, recommendations and decision making with respect to client service.

Practical Application: The decision about whether to retain a document within the record, including raw test protocols or other raw data, might be answered by the following question: “Could the reliability of my conclusions or the reasonableness of my actions be confirmed without reference to the information in the document or test protocol?”

9.3 Organizational Client Records

When an organization, as opposed to an individual within the organization, is the entity receiving service, the record must contain:

1. The name and contact information of the organizational client;
2. The name(s) and title(s) of the person(s) authorized to release confidential information about the organizational client;
3. The date and nature of each material service provided to the organizational client;
4. A copy of all agreements and correspondence with the organizational client;
5. A description of the problems which were the focus of the service, the methodology utilized, the recommendations made and any other material information available about the progress and outcome of the matter; and
6. A copy of each report that is prepared for the organizational client.

Practical Application: Professional consultation is typically provided to an organization or entity providing services, rather than directly to an individual requiring psychological or behavioural services. When recording consultation activities, it is expected that registrants would keep records in line with the requirements for organizational clients.

9.4  Record Storage and Retention

1. Individual Client Service records must be retained for a minimum of 10 years after the service recipient reaches the age of 18 or after the last professional contact, whichever comes later;
2. Unless otherwise required by law, organizational service records must be maintained for at least ten years following the organizational client’s last contact. If the organizational client has been receiving service for more than ten years, information contained in the record that is more than ten years old may be destroyed if the information is not relevant to services currently being provided to the client;
3. Different components of a record can be stored across multiple locations. If so, each location must reference the other locations;
4. 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, or for recipients of prevention, public education, group training, emergency or post- emergency group services, or group screening services;
5. Records regarding fees, billing, and financial matters must be retained in the same manner as other service records.

9.5 Record Security

1. Registrants must ensure that disclosure or transmission of personal health information protects the privacy of the client record;
2. 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;
3. 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;
4. When others within an organization have access to client records, measures should be taken to prevent misunderstanding or misuse. Raw data or potentially misinterpreted information should be stored separately or, if not possible, marked with a warning that misinterpretation, misunderstanding or misuse could cause harm to clients and the information should only be available to registrants of the relevant profession or a specified supervisee of the registrant that the registrant authorizes.

9.6 Maintenance of Client Records

Registrants who are HICs 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.

Practical Application: If a registrant is unable to designate another registrant as custodian of the records, then the registrant must make best efforts to designate another regulated health professional and if unable to do that, then a person who is familiar with the requirements of the applicable legislation.

10.1    Familiarity with Tests and Techniques

Registrants must understand and adhere to the standardized norms, reliability, validity, and/or appropriate application of tests and techniques.   Registrants must also avoid using outdated, obsolete, or invalid tests. In cases where no appropriate tools are available, they may use individual test items or stimuli for clinical assessment purposes, avoiding use of outdated norm-based data, or the otherwise inappropriate use of such data. Any departure from proper use should be documented with a clear rationale.

Practical Application: Norms which may be appropriately used as comparators for some populations may not be applicable to all populations. Similarly, criteria referenced measures may not be applicable to all circumstances. In such situations, registrants must use their knowledge, skill, and clinical judgment (See also Section 3: Equity, Diversity and Inclusion). Familiarity with tests and techniques extends to all psychological or behaviour analysis practices, regardless of whether they are standardized and norm-based or idiographic, such as in the case of functional behavioural assessments.

10.2    Controlled Access to Test and Materials

Unsupervised access to tools or materials must not be provided to individuals lacking the necessary user qualifications as stipulated by the publishers or vendors. Registrants may not provide information or describe test content in any way in circumstances that could invalidate the tests or compromise the proper use and application of the tests or techniques.

Practical Application: Care must be taken to avoid providing such materials as instruction manuals or actual test items or answers, where providing such information could reasonably be expected to invalidate a test or otherwise affect the integrity of the material. Unless sharing such information can be justified by the need to train individuals in the practice of the profession, or to comply with a legal requirement to make such information available in specified circumstances, registrants are encouraged to explain the risks of sharing the information and may wish to consider providing materials which they construct for demonstration purposes.

10.3    Familiarity with Intervention Tools and Techniques

Registrants must be familiar with the evidence supporting the utility and effectiveness of the interventions they employ. They should be prepared to provide a reasoned explanation for their choice of tools and techniques, if requested.

10.4    Adherence to Evidence-Based Practice

Registrants must be familiar with evidence-based tools and techniques. If they choose not to use such tools or techniques, they must be able to justify their decision and demonstrate competence in the tools and techniques they use. When evidence-based tools and techniques are not available or suitable, then registrants must evaluate and use any new or emerging tools or techniques with caution, ensuring safety to recipients. Recipients of all services must be informed about the potential risks, benefits and alternative options.

Practical Application: Drug assisted therapy is an emerging practice area and registrants must exercise caution if considering offering this service. Unless also a registrant of a College whose registrants have access to the controlled acts of prescribing or dispensing a drug, registrants can neither perform those acts nor provide or administer any drug, and in particular any psychedelic or dissociative drug (one that can alter a person’s perception of their surroundings, sense of self, or perception of reality, e.g., psilocybin, LSD, Ayahuasca, Ketamine, MDMA ). If providing therapy to a person under the influence of a psychedelic or dissociative drug which has been provided by an authorized health care professional, a registrant should be able to demonstrate that use of drug assisted therapy is supported by evidence, appropriate based upon client needs, legally permitted, and that a practical plan has been established to address adverse side effects which might arise from the intervention, including a plan for emergency medical care. This guidance is not meant to apply to the provision of services to individuals using conventional and well-established psychotropic medications such as antidepressants, anxiolytics, antipsychotics, and stimulants (e.g., fluoxetine lorazepam, risperidone, methylphenidate, etc.) that are prescribed and managed by a health care provider authorized to provide those services.

Practical Application: Behaviour Analysts may receive requests, for example, from parents of a nonverbal child to implement a technique they read about on the internet.  Before considering doing so, the Behaviour Analyst should review academic literature to see whether there is credible evidence for the method.  In the absence of support for their intervention, they should explain why they cannot use such an approach.

10.5    Coordination of Services

Registrants should not provide or offer services to someone already receiving similar services from another provider, except in exceptional circumstances. In such cases, the registrant must coordinate services with the other provider(s).

11.1 Rendering Opinions

Registrants must base professional opinions on current, reliable, adequate, and appropriate information.

11.2 Review Without Evaluation

If conducting a review of a record and direct evaluation is not required, registrants must document this and indicate the sources of information used to form opinions.

11.3 Identification of Limits of Certainty

Registrants must identify limits to the certainty with which diagnoses, opinions, or predictions can be made about individuals or groups.

11.4 Documentation of Limitations

If a complete evaluation is not possible after reasonable attempts have been made, registrants must document the efforts made to obtain additional information, the obstacles existing and the impact of limited information on their opinions.

11.5 Clarity of Communication

Registrants must present information in a manner likely to be understood by the recipients of service.

12.1 Professional Objectivity

Registrants must not undertake or continue to provide services where objectivity, competence or effectiveness is, or may reasonably be perceived as, compromised by bias or conflict of interest.

12.2 Disclosure of Impartiality Concerns

Where any potential lack of objectivity exists or arises, registrants must disclose this to the relevant parties, unless this would reasonably present a risk of harm to an individual or constitute a privacy breach.

12.3 Avoidance of Dual or Multiple Relationships

Registrants must avoid dual or multiple relationships wherever possible. If not possible, registrants must seek guidance from a neutral colleague to manage such relationships professionally.

12.4 Independence in Disputes

Registrants must remain impartial in disputes between clients with other service recipients or organizations; while registrants may provide their own objective professional opinions and objective information, they should refrain from advocating on behalf of any party.

Practical Application: Registrants may find themselves in a situation where a service recipient wants or expects them to advocate on their behalf. This may occur in the context of an application for school or workplace accommodations, insurance matters or even familial disputes. Advocacy is a skill and if performed on behalf of others, should be performed by those with appropriate training, experience and liability insurance. Well intentioned efforts to rectify what may be perceived as unfairness may fail and expose the client to loss and the registrant to liability. Unsuccessful advocacy can also damage an otherwise productive professional relationship with the client.

12.5 Gifts and Contributions

Registrants may not accept gifts of more than token value unless a rationale for doing so can be provided and documented. Any rationale should include careful consideration of the potential clinical impact of accepting or not accepting the gift. Registrants may not influence a recipient of services to make gifts or contributions of any kind.

12.6 Avoidance of Exploitation

Registrants may not use their professional knowledge, title, or position to acquire advantage directly or indirectly over, or exploit, any person in any professional context, or improperly acquire a benefit of any kind.

12.7 Priority of Service Recipient’s Interests

The interests of a recipient of services must be a registrant’s primary consideration. Interests of others, including insurers and other third-party funders must not take precedence over the interests of the person who is the subject of the service.

13.1 Impairment Due to Health Factors

Registrants must not undertake or continue to provide services when mental, emotional, medical, pharmacological or substance use conditions could be reasonably expected to adversely affect their ability to provide competent services.  If such a situation develops after services have been initiated, registrants must discontinue the services in an appropriate manner. Registrants must make efforts to ensure that clients are notified that they are unable to continue providing services and, where possible, assist in obtaining replacement services to ensure continuity of care.

14.1 Relationships with Current or Former Clients

Registrants must not enter, or make plans to enter, into an intimate or sexual relationship with a current or past service recipient or a close relative of the service recipient, unless at least five years has passed since the last professional contact, and it can be demonstrated that the individual is not vulnerable and will not be reasonably expected to require additional services from the registrant. This does not apply to relationships with employees of an organizational client unless the service provided to the individual was either intended to be therapeutic or the individual is vulnerable to exploitation.

Practical Application: Non-sexual intimacy can take the form of mutual sharing of personal information, thoughts and feelings for personal, nonprofessional reasons. In this context, an inappropriately intimate relationship includes one in which a registrant expresses their personal needs to a service recipient with an expectation that they will be fulfilled. Intimacy with a client and the creation and maintenance of appropriate professional boundaries are mutually inconsistent. This can take the form of quasi- familial relationships, personal friendships, or borrowing or giving money to the other.

14.2 Sexual Relationships with Students, Trainees, and Supervisees

Registrants must not enter, or make plans to enter, into an intimate or sexual relationship with a current research participant, student, employee, or supervisee, or with any person the registrant could reasonably expect to be in a position to evaluate.

14.3 Sexual Harassment

In addition to the adhering to the legislated prohibition of sexual abuse of clients, which is an act of Professional Misconduct, registrants must not engage in sexual harassment in any professional context. Sexual harassment includes, but is not limited to, any or all of the following:

1. The use of power or authority in an attempt to coerce another person to engage in or tolerate sexual activity including, but not limited to, explicit or implicit threats of reprisal for noncompliance or promises of reward for compliance;
2. Engaging in deliberate and/or repeated unsolicited sexually oriented comments, anecdotes, gestures, or touching, where the registrant knows or ought to know that such behaviours are offensive and unwelcome, or create an offensive, hostile, or intimidating professional environment; and
3. Engaging in physical or verbal conduct of a sexual nature when such conduct might reasonably be expected to cause harm, insecurity, discomfort, offence, or humiliation to another person or group.

14.4 Other Forms of Abuse and Harassment

Registrants must not engage in any verbal or physical behaviour of a demeaning, harassing or abusive nature in any professional context.

15.1    Fees and Billing Arrangements

1. Registrants must reach an agreement with payers regarding fees and payment arrangements before providing services or implementing changes to services or fees;
2. Fees must be based on the time spent and complexity of services delivered;
3. Rates for services should remain consistent across payers, although registrants may offer pro bono services or sliding scale fees to allow for affordability;
4. Provision of services by a supervisee must be clearly noted on invoices and receipts; and
5. Regardless of the payer, invoices and receipts related to supervised services rendered to clients or third party payers must be in the name of supervising member, the supervisor’s employer or the supervisor’s professional corporation, unless the supervisee is a registrant of the College with a Certificate of Registration for Autonomous Practice, in which case the supervisee may issue invoices and receipts independently in their name, or the name of the health professional corporation or their employer. Additionally, invoices and receipts must clearly identify the name of the supervising registrant and the name, relevant degrees, and professional designations of the supervised service provider. For further clarity, a supervisor may not permit a supervisee who is not an autonomous practice member of the College to issue invoices or receipts in their own name.

15.1    Prepayment and Retainer Funds

1. Registrants may request retainer funds in advance, but these funds must be held in a segregated account, separate from the registrant’s practice operating account funds or personal funds. These segregated funds must only be applied to services rendered. When such services are rendered and invoiced and  any excess segregated funds must be returned to the client following the termination or conclusion of services;
2. Payment for a specified multiple session treatment plan or group series may be charged and accepted at the beginning of the series, as long as clients agree that unused fees will not be refunded;
3. Registrants may not require clients to prepay for any psychological services including preparation of reports, except in the context of multi session or group programs as described above; and
4. Registrants may not withhold reports for non-payment of fees.

15.3   Collection of Unpaid Fees

 If they have informed clients of their practice in advance, registrants may:

1. Charge Interest on an overdue account;
2. Charge a fee for a missed appointment or late cancellation when prior notice is not given within an agreed upon period; and
3. Registrants may take legal action or use a collection agency to collect unpaid fees from clients provided they have first given clients an opportunity to resolve payment. In using a collection agency or filing documents in a legal process, registrants may provide only that information necessary for the recovery of funds.

15.4   Additional Charges

Registrants may charge a fee for other services such as:

1. Preparing special reports;
2. Copying, interpreting, or translating records; and
3. Completing forms (e.g., disability tax credit forms, insurance forms). Such fees must be discussed prior to the service being undertaken.

16.1 Authorization for Cross-Jurisdictional Practice

1. Registrants must ensure they are legally authorized to provide services outside Ontario and comply with Ontario’s service requirements while practising elsewhere;
2. Registrants providing services in another jurisdiction in which that service is regulated must be authorized to provide the same services in Ontario;
3. Registrants must inform service recipients that the College has authority to address complaints about the services received and must provide contact information for the College on request; and
4. Registrants providing services outside of Ontario must ensure they carry appropriate liability insurance with respect to such service.

Practical Application: The College does not have the authority to determine what is permissible in jurisdictions outside of Ontario and cannot provide permission to registrants to contravene statutes in another jurisdiction. A registrant who wishes to provide services to individuals outside of Ontario must therefore seek direction from the relevant regulatory body. The College recognizes that in exceptional circumstances, to prevent harm to vulnerable clients, it may be necessary to provide emergency services to an existing client located outside of Ontario. A registrant who wishes to provide services to individuals outside of Ontario where there is a lack of clarity regarding jurisdiction, for example, in military or diplomatic situations, is advised to obtain independent legal advice before providing those services.

16.2  Adherence to Local Jurisprudence

Registrants must be familiar with and adhere to the local jurisprudence and standards for practice in the jurisdiction in which the service is being delivered. Where a conflict exists between the requirements of two jurisdictions, the registrant must comply with the obligations affording greater client protection.

17.1 General

1. Registrants considering providing service virtually (via technology) must determine whether virtual vs. in- person services is clinically indicated. If in person service is clinically indicated and the Registrant does not wish to provide in person services to an existing client, they must demonstrate efforts to facilitate a referral to an appropriate service provider.
2. Registrants are expected to maintain current knowledge of all technologies that they use and be sensitive to cultural, regional and local issues which may impact service delivery. Registrants are also expected to adhere to the Association of Canadian Psychology Regulatory Associations (ACPRO) Model Standards for Telepsychology Service Delivery, as amended from time to time, and to maintain current awareness of guidance by relevant professional associations.

Practical Application: Relevant information about best practices is available from the Canadian Psychological Association (CPA), the American Psychological Association (APA), the Ontario Psychological Association (OPA), the Association of Canadian Psychology Regulatory Associations (ACPRO) and the Ontario Association of Behaviour Analysts (ONTABA).

c. Registrants must make plans for the management of a client emergency, ensuring they possess information about emergency services in the client’s location and alternative services locally available to the client.

17.2 Technological Knowledge and Competence

1. Registrants using technology must maintain and address current knowledge of the risks associated with that use;
2. Registrants must be competent in the use of technology they adopt;
3. Registrants are free to responsibly utilize technological advances, including computer assisted scoring and test interpretation and non-human mediated artificial intelligence, but technology may not be used instead of registrants’ own professional knowledge, skill and judgment. Such professional activities must always be actively reviewed by registrants who are authorized to provide the services and registrants must take full responsibility for the content of reports and any opinions or recommendations expressed in their names; and
4. Registrants must ensure, as part of the informed consent process that clients understand how technology is being used to assist them, any risks of technological error, and what risks there are to their privacy when personal information is being used, stored, or transmitted within an external technological application.

17.3 Security in the Use of Technology

1. If using cloud services, registrants must ensure that the jurisdiction within which the cloud service is hosted has security features which would be consistent with privacy requirements under Ontario legislation and that that all provisions of the Standards of Professional Conduct apply with respect to transmission of information; and
2. To minimize the possibility of someone impersonating a client and gaining access to confidential health information or influencing a registrant’s assessment or opinion of the client, registrants must take steps to verify the identity of the client using some form of coded identification of the client, in cases where visual verification is not possible.