Purpose and Scope

This policy outlines how RALII Psychotherapy, Coaching & Wellness (“RALII”) manages virtual therapy sessions and email communication with clients in a safe, ethical, and confidential manner.

It applies to all clients, clinicians, interns, contractors, and administrative staff who participate in or support online therapy, telehealth, or electronic correspondence.

This policy ensures compliance with:

• College of Registered Psychotherapists of Ontario (CRPO)Professional Practice Standards
• Personal Health Information Protection Act (PHIPA, 2004)
• PIPEDA(Personal Information Protection and Electronic Documents Act)
• Canadian Anti-Spam Legislation (CASL)

Guiding Principles

RALII is committed to:

1. Providing clients with accessible, safe, and high-quality virtual care.
2. Protecting client privacy and personal health information.
3. Maintaining ethical and secure communication practices.
4. Ensuring clients understand the benefits and limitations of virtual therapy.
5. Upholding the same professional standards in virtual care as in-person sessions.
6. Definition of Virtual Therapy: Virtual therapy (teletherapy or online counselling) refers to psychotherapy sessions delivered via:

• Secure video platforms (e.g., JaneApp, Owl Practice, or encrypted Zoom or Google meet).
• Telephone sessions.
• Email or text-based follow-up, as clinically appropriate.

Virtual therapy provides access to care for clients who cannot attend in-person due to location, mobility, health, or scheduling limitations.

Client Eligibility and Informed Consent

Before starting virtual therapy, clients must provide informed consent acknowledging that:

• Virtual sessions involve electronic communication that may pose confidentiality risks.
• There are limits to privacy and technological control.
• Emergencies may require contacting local supports.
• Sessions are not recorded or shared without mutual written consent.
• The client has the right to withdraw consent for virtual therapy at any time.

Clients will complete a Virtual Therapy & Email Consent Form confirming their understanding and acceptance of these conditions.

Technology and Security Requirements

RALII uses PHIPA-compliant platforms to conduct virtual therapy.
All technologies used must:

• Provide end-to-end encryption.
• Require password-protected access.
• Disable automatic recording unless explicitly authorized.
• Allow both therapist and client to control video/audio privacy.
• Use secure Wi-Fi connections (no public networks).

Clients are responsible for:

• Ensuring privacy in their environment.
• Using secure and personal devices.
• Informing the therapist if others are present during a session.

Confidentiality in Virtual Therapy

Confidentiality remains the same as in-person therapy.
However, clients are advised that:

• Technical breaches (e.g., hacking, misdirected messages) are rare but possible.
• Emails or texts may not be fully secure despite encryption efforts.
• Confidentiality may also be affected by who has access to their devices or accounts.

Therapists document any potential privacy concerns and review mitigation strategies with the client.

Emergency Procedures for Virtual Sessions

At the beginning of each virtual session, the therapist confirms:

• The client’s current location and address.
• An emergency contact person.
• The nearest local crisis resources.

In case of a crisis or disconnection during a high-risk situation:

• The therapist will attempt to reconnect immediately.
• If unsuccessful and there is concern for safety, the therapist may contact emergency services or the client’s designated contact.
• All actions taken are documented in the client’s file.

Email and Electronic Communication

RALII uses email primarily for administrative purposes (e.g., scheduling, invoices, receipts, or resources).

Email is not a secure medium for sharing personal or sensitive clinical information.
Clients are advised to use email for limited purposes only and acknowledge the following risks:

• Emails can be intercepted or misdirected.
• Unauthorized access to email accounts may compromise confidentiality.
• There may be delays in therapist response time.

All clinical discussions or disclosures should occur during scheduled sessions, not via email.

Email Consent Agreement

Before using email communication, clients must provide explicit written consent confirming that they:

• Understand the risks of email communication.
• Will not use email for emergencies or crisis support.
• Authorize RALII to use email for administrative or scheduling purposes only.
• Will notify the therapist of any change in their contact information or access to their email account.

Consent can be revoked at any time in writing.

Record Keeping and Documentation

• Copies of relevant emails (e.g., scheduling, consent, or session summaries) are stored securely in the client’s electronic record.
• Personal information shared via email is minimized.
• Email correspondence is retained and destroyed in accordance with PHIPA and RALII’s Record Keeping Policy/

Technical Difficulties and Backup Plans

If technical issues disrupt a session:

• The therapist will attempt to reconnect for 5–10 minutes.
• If connection cannot be restored, the session may continue by phone.
• If unresolved, the session will be rescheduled at no cost.

Clients are encouraged to keep their therapist’s phone number accessible for emergency contact.

Limitations of Virtual Therapy

Clients are informed that:

• Virtual therapy may not be suitable for all clinical concerns (e.g., active psychosis, severe crisis).
• Internet connectivity or environmental distractions can affect session quality.
• Therapists may recommend in-person or community-based alternatives when clinically appropriate.

Therapist Responsibilities

RALII clinicians agree to:

• Use only secure, approved platforms for sessions.
• Store and transmit data in compliance with PHIPA.
• Obtain and renew informed consent regularly.
• Maintain professionalism, confidentiality, and emergency readiness.

RP (Qualifying) clinicians review virtual therapy practices with their supervisors regularly.

Client Responsibilities

Clients agree to:

• Ensure privacy during sessions.
• Avoid driving or multitasking during therapy.
• Report any technical or privacy concerns promptly.
• Use email appropriately and not for urgent clinical matters.

Withdrawal or Change of Consent

Clients may withdraw consent for virtual or email communication at any time.
If consent is withdrawn, alternative arrangements (e.g., in-person sessions, postal correspondence) will be offered where possible.

Review and Policy Updates

This policy will be reviewed annually or as required by changes in legislation or CRPO standards.
Updates will be communicated through RALII’s website and client documentation.

Effective Date: 9^th November 2025
Next Review Date: 8^th November 2026