Complaints and Investigations

Record-Keeping Lessons From Regulatory Investigations

Records are the most common evidence in a regulatory file. Good records often end a complaint early; poor ones can become an allegation of their own.

  • Topic Complaints and Investigations
  • Sources checked November 10, 2026
Draft for legal review. This page has not yet been reviewed by Ryan J. Manilla.

Key Takeaways

  • COTO reports record keeping as a frequent theme in complaints and registrar’s investigations.
  • Most regulators publish specific documentation or record-keeping standards.
  • Late entries must be clearly identified as late; originals must never be altered.
  • Electronic audit trails show when entries were made or changed.

Published Standards

Examples include CNO’s Documentation practice standard, RCDSO’s Dental Recordkeeping guideline, CDHO’s Clinical Information Practice Standard, CRPO’s record-keeping and documentation standards, CPBAO Standard 9 (Records and Record Keeping) and CCO’s S-022 on records.

Lessons From Investigations

  • If it is not documented, it is hard to prove it happened.
  • Consent discussions should be recorded, not just assumed.
  • Records should match invoices and billing.
  • Altered records are treated very seriously.

Better Habits

  • Document contemporaneously.
  • Use dated addenda for corrections.
  • Record key conversations, including phone and portal messages.
  • Audit a sample of your own files periodically.

Frequently Asked Questions

Can I add notes after a complaint?

Only as clearly dated addenda that leave the original intact, and preferably after advice.

How long must I keep records?

Retention periods are set by each profession’s regulations and standards. Check yours.

Sources

Statutory references are to the provisions listed below, as consolidated on e-Laws when this page was prepared.

  1. COTO, “Investigations Data Overview: December 2024–May 2025” — Checked November 10, 2026.
  2. CNO, “Standards & Guidelines” — Checked November 10, 2026.
  3. CDHO, “Standards & Resources” — Checked November 10, 2026.
  4. CRPO, “Practice Standards” — Checked November 10, 2026.

Keep Learning About Your Proceeding

Read how Ontario regulatory proceedings typically unfold, or compare how other regulators handle complaints, hearings and appeals.