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Guide

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

CRPO Standard 5.1 requires a complete, legible clinical record retained at least 10 years from the last client interaction (or from the 18th birthday, whichever is later). Standard 6.4 requires a contingency plan including a designated successor custodian. Hivi-X supports intake documentation collection and export — not full clinical record lifecycle management.

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.

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.

Collect intake documents without the email chase

Share a checklist via secure guest link (no account needed) or my-id.ca portal, track what's missing, and export an organized intake package.

FAQ

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.

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). Many practitioners have not completed this step. Add successor-custodian items to your intake checklist or use the free lead-magnet PDF as a starter.

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. Last updated 2026-07-09.

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.

CRPO Record Keeping Requirements | Hivi-X