• Professional Practice

    The College has not set out specific, concrete age boundaries between the various client populations:  children and adolescents; adolescents and adults; adults and seniors.  One usually goes by conventional definitions.  That is, children to age 12 or 13; adolescents to age 19 or so; adults to 65 or 70.  While age is not an issue when considering providing service to a client who falls within these conventional age groups, problems can arise at the boundary ages, i.e., 12-13; 18-20; 65-70.  When determining whether it is within one’s area of competence to provide service to a “boundary age” individual, many things other than just chronological age come must be considered.

    The concern that arises should a member, with demonstrated competence in working with adults, decide to provide service to an older, boundary age adolescent is that one may impart to the older adolescent some adult traits, characteristics or difficulties based on one’s training and experience.  Conversely, a member may not recognize some adolescent trait, as one is approaching the client from an "adult" perspective.  Issues can also arise with the use of assessment measures and intervention techniques as one may be most familiar with both the objective and subjective norms related to working with adults. 

    The Registration Regulation (O. Reg. 74/15) requires that members practise the profession only within those areas of the member's competency that are authorized by the College [s. 10 (2) 1.]  There is some room at the boundary ages however, for a member to provide service to a client who might fall, by convention, just outside of one’s authorized population group.  Whether a member is practicing within one’s area of competency, as required by the Regulation, is a determination a member must make on a case by case basis, based on the characteristics of the individual client.

    A member whose area of competence is Clinical Psychology with adults may occasionally see a boundary age adolescent (18-20 age range), who many might consider a young adult, dependent upon the evaluation of his/her level of development and maturity.    It is important to stress however, that should such requests for service become a more regular occurrence, it would be prudent for the member to one consider expanding one’s authorized population groups.

    While the above information relates to a boundary age adolescent and a member whose area of competency is with adults, the principles can be applied to a member considering providing psychological service to the other boundary age client groups.


    Autonomous practice members wishing to add an area of practice or a client group must undertake training and supervision to achieve competency comparable to other members of the College who are recognized for similar practice.

    Members are required to make a written request to the Registration Committee specifying the practice area or client group they wish to add and to provide detailed information about how they have or plan to acquire the knowledge and skills in this new area.

    The College’s Guidelines for Change of Area of Practice, outline the process in more detail:


    The Registration Committee meets approximately every other month, dates of upcoming meetings are posted on the College’s website. 

    The question of the release of raw test data involves an understanding and interpretation of the Personal Health Information Protection Act (PHIPA) which speaks to responding to requests for personal health information.  It should be noted that the College does not provide legal advice or legal interpretations of legislation but recommends that members seek legal advice on such matters.  While not providing legal advice, the College does offer some comments which may be helpful in understanding this question and informing the discussions with legal counsel

    The Personal Health Information Protection Act (PHIPA) gives a client, or legal guardian, the right of access to, or the right to consent to the disclosure of, his/her personal health information.  This would include much of the information in the psychology file.  There are some exceptions however, to this right.  These include information which could pose a risk of harm and confidential third party information.  As well, “raw test data from standardized psychological tests” [PHIPA 51.(1)] is excluded from this right.   Therefore, the legislation does not appear to provide a right to access raw data. 

    In considering PHIPA 51.(1), it is important to recognize the distinction between a right and a permitted disclosure.  There does not appear to be any statements in PHIPA that prohibit the release of “raw test data from standardized psychological tests”.  The difference to be understood is between what the client may have a right to obtain, and what they may be permitted to receive.  In this regard, the legislation is permissive, rather than prescriptive.

    Recognizing this permissive language in the legislation, the College position related to the release of raw test data may be found in Principle 14 – Assessment and Intervention of the Standards of Professional Conduct; specifically section 14.9.  This section notes that the College recommends that when the request is reasonable and appropriate, and with proper authorization, the raw data should be released to clients and others.

    It is important to note that Principle 14.9 emphasizes the member’s responsibility to distinguish between raw test data from standardized psychological tests and test materials or forms.  This suggests that test protocols, test items, summary sheets, etc., most of which are materials copyrighted by the publisher, should not be reproduced based on a voluntary consent.  Rather, one may have to recopy the information ensuring not to include any copyrighted materials.  Of course, should one receive a court order, summons to appear and bring materials to court, or some other legal vehicle compelling the release of the entire file, then this could also include the raw test data protocols.  In such cases, members are encouraged to consult with legal counsel and/or the test publisher.

    In Canada, the practice of psychology is regulated at the provincial/territorial level.  That is, each province/territory is responsible for the regulation of psychological services delivered within its borders.  Within the United States, psychology is similarly regulated.

    At this time, most jurisdictions regulating psychology in Canada and the US, including the College of Psychologists of Ontario, view services to be delivered in the province/territory/state in which the client is located whether such service is provided in person or through telepsychology.  That is, the service is deemed to be provided where the client is, regardless of where the psychologist or psychological associate may be located.  Given this, many regulatory bodies expect the practitioner to be registered/licensed in the jurisdiction in which the service is being provided.

    At this time, there is some variability in the expectations of the various Canadian jurisdictions with regard to what is required of a practitioner providing services by telepsychology into their province/territory.  Some may have temporary or courtesy registers which permit a member to practise within their jurisdiction for a limited period of time without formal registration with them.  For members considering providing service by telepsychology into another jurisdiction, it is recommended that they contact the regulatory body of the jurisdiction into which they may be considering practising to determine what may be required of them in terms of registration/licensing or formal notification of the regulatory body for psychology. The College of Psychologists of Ontario has adopted, as advice to members, the Model Standards for Telepsychology developed by the Association of Canadian Psychology Regulatory Organizations (ACPRO).  In addition, a joint task force of the Association of State and Provincial Psychology Boards (ASPPB), the American Psychological Association (APA) and the American Psychological Association Insurance Trust (APAIT) has recently developed Guidelines for the Practice of Telepsychology.  The Canadian Psychological Association has also published Draft Ethical Guidelines for Psychologists Providing Psychological Services Via Electronic Media.

    Members considering providing telepsychological services will find these documents very useful as they provide guidance on a variety of issues related to this type of service.  This includes ensuring one is legally entitled to practise in another province, territory or state and one is familiar with the relevant laws and regulations applicable within that jurisdiction.