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CRPO record-keeping compliance

CRPO record-keeping compliance: intake, consent, and contingency planning

What Standard 5.1 requires

Every client interaction should be documented in an accurate, complete, and legible clinical record. That includes intake and consent documents alongside session notes and treatment plans. Records must be retained for at least 10 years from the last client interaction, or from the client's 18th birthday, whichever is later.

CRPO registrant count in Ontario exceeded 17,381 in 2025 — most solo practitioners are their own record custodian.

Successor custodian gap

Standard 6.4 requires a contingency plan for practice closure — including a designated successor custodian for client records. CRPO survey data suggests many practitioners have not completed this step: 76 of 173 respondents in one survey had not designated a successor custodian.

Hivi-X does not ship a built-in successor-custodian template in v1. Add those items to your own intake checklist, or start from the free lead-magnet PDF.

PHIPA custodian duties

Solo CRPO registrants in private practice are typically health information custodians under PHIPA. Reasonable safeguards may include encryption and access controls. Hivi-X provides Canadian hosting and encryption; you set retention, clinical record policies, and PHIPA compliance programs.

General information for Ontario psychotherapists and counselling practices only. Not legal, clinical, privacy, or psychotherapy advice. Not affiliated with or endorsed by CRPO or any college. Hivi-X is document-collection software — it is not a licensed psychotherapist, does not provide psychotherapy or clinical assessments, does not certify PHIPA or CRPO compliance, and does not replace your EMR or clinical record obligations. You remain the health information custodian under PHIPA. Consult qualified counsel and your professional liability insurer.

Sources: CRPO Clinical Records Standard 5.1 · CRPO Town Hall 2025 materials

Answers are general operational information only — not legal, tax, regulatory, clinical, privacy, immigration, or professional advice. Requirements vary by matter, client, and regulator.

Frequently asked questions

How long do I keep psychotherapy records?
CRPO requires clinical records retained for at least 10 years from the last client interaction, or from the client's 18th birthday, whichever is later. Hivi-X helps store electronic intake records but does not set your retention or destruction policy.
What is a successor custodian?
A successor custodian is the person designated to take custody of client records if you close practice, become incapacitated, or die (CRPO Standard 6.4). CRPO survey data suggests many practitioners have not completed this step.
Is Hivi-X a CRPO-compliant clinical record system?
No. Hivi-X is document-collection software for intake. It does not replace your EMR, automate amendment tracking, or manage secure destruction schedules.

Collect complete intake before session one

Hivi-X helps Ontario CRPO psychotherapists and counsellors collect informed consent, biopsychosocial forms, insurance cards, and telehealth consent with reusable checklists, a secure guest link (no account needed) or my-id.ca portal, self-hosted AI summaries, and exportable intake packages for Jane, Owl Practice, or your EMR.

CRPO Record Keeping Compliance | hivi-x Docs