Privacy & Compliance

1. PHIPA Overview for RMTs

Under PHIPA, Registered Massage Therapists in Ontario are typically health information custodians when they have custody or control of personal health information (PHI) in connection with providing care.

Key obligations include:

• Obtaining appropriate consent to collect, use, and disclose PHI
• Collecting only what is necessary for the purpose
• Implementing reasonable safeguards (administrative, technical, physical)
• Allowing clients access to their own PHI and responding to correction requests
• Notifying individuals and the IPC of certain privacy breaches
• Maintaining information practices (policies) for how PHI is handled

CMTO’s Standard of Practice: Privacy and Confidentiality requires RMTs to comply with PHIPA and to use electronic tools in a way that protects client privacy.

2. How RMT Flow Is Designed

• No client legal names required — use private labels only (e.g. “Client A – Visit 2”)
• Client email addresses are not stored — one-time handout sends only, with explicit consent
• Session notes stay private per therapist — other clinic members cannot see your private sessions
• Clinic analytics are aggregated only — no client identifiers
• No diagnostic language — assessment considerations and clinical decision support only
• Login required — access controls and role separation (therapist / clinic admin)

If you choose to enter identifiable client information into free-text fields, you become responsible for treating that content as PHI under PHIPA.

3. Practical Compliance Checklist

Use this as a self-review checklist for your practice. Check items as you confirm them. Status is stored only in your browser (localStorage), not on the server.

Checklist progress is saved in this browser only.

4. Your Responsibilities vs RMT Flow’s Role

5. Authoritative References

• Personal Health Information Protection Act, 2004 (PHIPA)
• CMTO Standard of Practice: Privacy and Confidentiality
• Information and Privacy Commissioner of Ontario (IPC)
• College of Massage Therapists of Ontario