Your plan sounds like a good approach to be discussed with the custodian of records and to ensure security and appropriate access but also that there are records maintained for any future work with or related to the client. The challenge with enforcing the standards of practice involving records is when the psychologist does not own the records and is not the custodian. Under PHIA legislation, when the psychologist is an employee, the custodian is either the person responsible for running the group practice or the employer, not the employee. Under PHIA, each organization is required to have a custodian.
I think some practices/organizations have put in written policies and practices around clients and their records in the event that a psychologist leaves the practice. It sounds like maybe this not explicitly mentioning the electronic records. In this electronic age, it is probably helpful to include a policy that covers electronic reports stored on a computer or other device. This could clarify that the organization owns these records as well. However, typically if the organization owns the records and the computers, then I believe that the information on the computer would also fall under the original record, which all belong to the custodian.
In summary, I think that your plan sounds appropriate provided you discuss / work with the custodian on your recommendations but not make any unilateral decisions on records for the reasons above. Please feel free to share this email with others if it would be helpful.
All the best with your new position.
