Criminal record checks for therapy staff in Canada: what regulators and funders require

Do therapy clinics have to run criminal record checks on staff?

We found no statute in any province or territory that requires a private therapy clinic to run vulnerable sector checks on its staff, on the official pages we read. The RCMP says no federal law requires any organization to conduct these checks. The requirements we did find come from three other places: a clinician’s own regulator, a funder’s provider list or registry, and one provincial Act on criminal record checks for employers.

The answer therefore depends on who works in the building. A clinic that employs a speech-language pathologist and an occupational therapist registered with different regulators can face two different rules, plus the conditions of any funder list it joins. Each rule below is linked to its official page. Confirm it at the source before acting.

What a vulnerable sector check is, and who requests it

The RCMP describes a vulnerable sector check as a police information check plus a check for record suspensions (pardons) for sexual offences, governed by section 6.3(3) of the Criminal Records Act. It applies to a position of trust or authority over children, meaning anyone under 18, or over other vulnerable persons. The RCMP adds that having contact with children is not enough on its own to make a position one of trust or authority.

The hiring organization makes the request, and the person being checked provides consent. The check is conducted by the local police service where the applicant lives, or in British Columbia by the Criminal Records Review Program. The RCMP states that it is an offence to conduct a vulnerable sector check if the position does not meet the Act’s requirements, and that results are released only to organizations located in Canada.

Ontario adds rules on how any police record check is requested. Under the Police Record Checks Reform Act, 2015, a provider may not conduct a check unless the request contains the individual’s written consent to the particular type of check. Results go to the individual, who may then consent in writing to a copy going to the requester. Ontario’s police record check page adds that vulnerable sector checks must be completed by the local police service rather than a third-party provider.

Criminal record check rules by province and territory

The table shows what we found for a private therapy clinic and its staff in each jurisdiction. A cell that says “not found on the official pages we read” is not a statement that no rule exists. Some government and regulator sites blocked our automated access, and the gaps section below lists them.

Regulator requirements for registered clinicians

These requirements bind a person registered with the regulator, wherever that person works. A clinic that employs registrants should check each clinician’s own regulator, because the rule differs by profession and by province.

• Manitoba speech-language pathology: the College of Audiologists and Speech-Language Pathologists of Manitoba requires a satisfactory criminal record check, child abuse registry check and adult abuse registry check on application (General Regulation, section 2.5) and every five years after registration (section 2.32). The registrar may ask for additional checks if information suggests a risk to the public (section 2.33).
• Nova Scotia audiology and speech-language pathology: every five years, an original criminal record check and vulnerable sector check dated within six months. A digital check that can be authenticated is also accepted.
• Nova Scotia occupational therapy: a vulnerable sector check at licensing and at renewal every five years. The regulator accepts only checks issued within the past three months and tells registrants to apply well before the deadline.
• Saskatchewan physical therapy: every applicant for a practising licence must provide a satisfactory criminal record check (Regulatory Bylaws, section 12, consolidation dated 14 April 2022).
• Saskatchewan occupational therapy: an applicant for practising membership provides a criminal record check as evidence of good character (Regulatory Bylaws, section 4(2), consolidation dated 30 September 2022).
• British Columbia, College of Health and Care Professionals: a criminal record check authorization with a licence application, and at renewal if the previous authorization was submitted more than four years earlier.
• Newfoundland and Labrador audiology and speech-language pathology: the registration requirements in NLR 47/13 include, as requested by the registration committee, a Certificate of Good Conduct, a vulnerable sector check, consent for release of information and a declaration about convictions.
• Northwest Territories psychology: the psychologist application package lists a criminal record check and vulnerable sector search dated within six months of the application.

Funder and program requirements

A funder can set a condition for every provider it lists or pays, whether or not the provider’s regulator asks for a check. The programs below differ in how binding the condition is, so read each program’s own page.

• Ontario Autism Program Provider List: speech-language pathologists, occupational therapists and clinical supervisors of behavioural services who join the list provide a vulnerable sector check completed within the past 12 months. Listed providers confirm a declaration of compliance each year by 31 December and complete a full renewal every three years with a new check. The Ministry’s 2026-27 service objectives describe the list as voluntary for that period, so families can still hire registered providers who have not joined.
• British Columbia Registry of Autism Service Providers: providers complete a criminal record check every five years. The page says results are accepted only through the Criminal Records Review Program, and that a provider whose check is not received by the deadline is removed from the registry, which stops all payments. Members of a professional college can share results through the eCRC system.
• Saskatchewan Registry of Autism Service Providers, used for Autism Spectrum Disorder Individualized Funding: a criminal record check including a vulnerable persons check done within six months before applying, renewed every five years. Applicants agree to inform the Ministry of Health within five days of an arrest or charge.
• Manitoba Children’s disABILITY Services: the Security Check Policy approved in June 2019 applies to agencies funded to deliver services for the program. Agencies adopt and enforce a policy requiring a criminal record check with a vulnerable sector search, a child abuse registry check and an adult abuse registry check. Checks may not be more than three months old at the point of hire.
• Prince Edward Island Preschool Autism Funding: the guidelines updated in June 2026 say a criminal record check and vulnerable sector check is recommended for an autism assistant hired by a parent or a licensed early learning and child care centre.

British Columbia’s Criminal Records Review Act: when it may apply to a clinic

British Columbia’s Criminal Records Review Act, in the version consolidated to 22 September 2026, is the one statute we found that sets criminal record check duties for employers. It applies to listed categories of “employer”, and an “employee” includes an independent contractor who has entered into an agreement with an employer.

Two categories in the definition could matter to a therapy clinic. One is an individual or corporation that receives operating funds from the government, where the Act defines operating funds as ongoing, regular funding for core programs or staff. The other is a registered service provider who employs one or more individuals to assist in practising that provider’s profession. The Province’s page for organizations also lists organizations or people who receive annual provincial funding, and names the College of Health and Care Professionals of BC among the governing bodies it covers. Neither the Act nor that page says in terms whether a private fee-for-service clinic is covered, so the question belongs with the Criminal Records Review Program.

A covered employer must not employ an applicant in a job that involves working with children unless the applicant has provided a criminal record check authorization (section 9). An employee who works with children must undergo a check at least once every five years (section 10). The Act sets fines of up to $5,000 for the contraventions it lists (section 28). A covered employer registers an organization account with the Criminal Records Review Program and screens applicants online; an organization the Act does not cover can use the applicant’s local police or RCMP detachment.

Registry and record checks that are not vulnerable sector checks

Two jurisdictions describe checks that sit beside a police vulnerable sector check. In Manitoba, an employer or other person can apply for access to the Child Abuse Registry, with the person’s written consent, to assess someone whose work involves the care of a child or may permit unsupervised access to a child. The initial application fee is $20, and the page lists exemptions for some purposes, such as assessing a volunteer or a student trainee.

In Alberta, a Child Intervention Record Check draws on records of intervention services provided to a child; Alberta.ca says the records are used to determine whether a person has caused a child, of whom they are the guardian, to be in need of intervention. The page says some organizations require one before an employee or volunteer works with children, that it can be accepted only from the person it concerns, and that it is released only to that applicant. The page does not describe it as a vulnerable sector check.

What we did not find on the official pages we read

Absence from this page is not evidence that a rule does not exist. These are the gaps in our reading.

• Alberta: no statute, college or funder requirement for private therapy clinic staff.
• New Brunswick: no statute or therapist requirement. The speech-language pathology regulator’s and the physiotherapy college’s sites blocked our automated access.
• Prince Edward Island: no statute or college rule. The preschool autism funding guideline above recommends a check but is the only mention we found.
• Yukon, Nunavut: no requirement found. Yukon and Nunavut government pages blocked our automated access when we read them.
• Northwest Territories: no statute for staff other than the psychology application rule above.
• Where a row or list above names one profession only, such as speech-language pathology, the other professions’ rules were not found on the official pages we read.

Where TherapyCRM fits

TherapyCRM does not order, run or verify criminal record checks. A clinic keeps those records under its own policy and decides which roles need a check and how often. The staff profile in TherapyCRM can hold the regulatory body, registration number and expiry date a practice enters, and the staff list shows each person’s registration status. Those fields do not record criminal record checks.

The funding programs named on this page appear for context only.

• TherapyCRM’s funding tracking is built around the Ontario Autism Program; it does not support BC Autism Funding.
• TherapyCRM’s funding tracking is built around the Ontario Autism Program; it does not support Saskatchewan’s Autism Spectrum Disorder Individualized Funding.
• TherapyCRM’s funding tracking is built around the Ontario Autism Program; it does not support Manitoba’s Children’s disABILITY Services.
• TherapyCRM’s funding tracking is built around the Ontario Autism Program; it does not support Prince Edward Island’s Preschool Autism Funding.

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