Dietetic Practice & 
Online Communications

Good communication skills are the foundation of good dietetic practice. With the ubiquity of online platforms — including social media platforms and web-based applications — dietitians often contact the College about developing and maintaining professional communications online.

The same principles of professionalism used by dietitians in face-to-face communications apply online and on social media: common sense, professional judgment and critical thinking. In addition, however, all dietitians should be aware of legal obligations to comply with the law when communicating online.
1.  Complying with Anti-Spam Legislation
Canada's anti-spam legislation (CASL) came into effect July 1, 2014. It applies to emails, text, instant messages, and any similar messages sent to electronic addresses. This law may affect you if you use electronic channels to promote or market your services, organizations, or products. If you are sending messages of a commercial nature (e.g., seeking client consent to sign up for a newsletter), consider seeking legal advice on CASL and consent requirements. For compliance basics, visit the Government of Canada's anti-spam legislation information
2.  Protecting Privacy and Confidentiality
Dietitians must maintain the confidentiality of client information and comply with all relevant privacy legislation, including the Personal Health Information Protection Act, 2004 (PHIPA). Dietitians should also be aware of legislative requirements and recent amendments to PHIPA.

Privacy legislation requires that you adopt reasonable safeguards to protect the personal health information under your control as a regulated health professional. The College recommends dietitians:
Obtain informed consent for online communications.
When communicating directly with clients online, it is important to inform clients of the security issues surrounding communicating personal health information online. Informed consent must be obtained. In many cases, consent may be implied when clients choose to communicate online. Use your professional judgment about when you can rely on implied consent versus a more formal written or verbal consent to communicate with clients online. For more information, please refer to the Professional Practice Standard on Consent.
Encrypt mobile devices having personal health information.
Online and social media communication include the use of laptops, USB keys, tablets, smartphones, and other mobile devices. Ontario's Information and Privacy Commissioner require that health care professionals encrypt all mobile devices that contain personal health information. As these devices are prone to theft, password protection is not enough, and encryption is also required.

The College does not provide recommendations regarding encryption for devices. For more information, consult an information technology expert or conduct an online search for encryption devices available. The Office of the Privacy Commissioner has published a fact sheet on this topic. If you work in an organization, consult your information technology personnel to determine the best approach to securing client information privacy. Many employers also have rules and policies for employee use of online communications and social media.
3.  Maintaining Online Professionalism
Professional Conduct
The professional conduct and obligations online are the same as your behaviour in other settings such as hospitals, public health, long-term care, clinics, or private practice. Be just as professional online as you are in face-to-face interactions with clients.

In keeping with the College's Professional Misconduct Regulation, when practising dietetics online, use the same name that appears in your profile on the College Register of Dietitians. You must also use your professional designation to identify yourself (either Registered Dietitian, RD or their French equivalents).
Dual Relationships
Avoid dual relationships with clients (i.e., personal and professional). Social networking sites tend to be more casual and informal than meeting clients face-to-face. This makes building or maintaining a professional relationship online more challenging. Wherever possible, separate your professional online presence from your personal one. Avoid having interactions with your clients on your personal social networking or social media sites.

Accepting a client's "friend" invitation on Facebook, or other social media platforms, even with strict privacy settings, may involve you in the client's private life and expose some information about your own private life. Also, accepting the invitation characterizes your relationship as social as well as professional. Therefore, if a client invites you to be their "friend," the best approach is to decline the request and discuss personally with the client why you cannot accept friend requests from clients. For information on boundary-crossing, please see the Boundary Guidelines for Professional Therapeutic RD-Client Relationships.

A dietitian (or their organization) can create a professional social networking page (e.g., on Facebook or Instagram) that outlines services, posts nutrition information, links to resources, and more. Clients or public members can "like" the page, receive updates, comment on postings, and ask questions. However, this professional page should not be connected to the dietitian's personal social networking page (if they have one).

Dietitians need to respect clients' personal lives and avoid conducting online searches for information about a client.
The Reputation of the Profession
Be cautious about what you or others post on your professional and personal social networks, as it may affect not only your professional reputation but that of the dietetic profession. Always maintain a respectful and professional image, even on your personal social media. Your personal status updates and photos, even if marked private, can be shared and distributed to a broader public by someone in your network. What you do in your personal life can impact your professional life and the reputation of the profession.
Never Identify Clients Online
While dietitians may discuss their practice experiences using social media and social networking, they should never refer to clients by name or provide information that could be used to identify clients. As a health professional, it is your responsibility to take all necessary steps to create a secure practice environment and prevent unauthorized access to client information online or on your personal mobile devices.
Respect for Others 
It is essential always to maintain respect for clients and colleagues online. Everything you post — personally or professionally — can be linked back to your practice and your colleagues. Defamation, copyright, and plagiarism laws also apply to social media and social sharing. Therefore, always provide attributions and links back to original sources when sharing information.
Maintain high standards of integrity when communicating online. For example, avoid airing workplace issues on social media. Instead, use proper communication, and conflict resolution approaches to discuss, report and resolve workplace issues in your workplace, not online.

If you share your nutrition expertise online, the best way to maintain the connection between online participants and safe, competent dietetic practice is through reliable and transparent communications. This means that any information you provide online is accurate, current, and, most of all, easy for clients to understand. Your opinions must be supported by evidence and best practice and must never be misleading or deceptive.

Communicating online and using social media makes information easy to publish. As dietitians, it is important to reflect on your practice and aim for clear, professional, and audience-appropriate communications.
4.  Application of Professional Principles
Communicating with clients online
  • When texting or emailing personal health information to clients, obtain informed consent from your client. Discuss the risks.
  • Avoid using devices in public places where people around you may view confidential information.
  • Always password-protect your mobile electronic devices and encrypt personal health information stored on your mobile equipment.
  • Adopt practices for protecting the privacy of health information being transmitted online, such as, using initials to identify a client rather than a full name, password protection, assigning a numeric code or using encryption.
Interprofessional Communication – Text Orders
While the College does not have a policy regarding text orders from other healthcare professionals, the performance expectations and regulatory obligations remain the same as when accepting orders via other means such as telephone or verbal orders. With the increased use of electronic communications by organizations and other individual employees, dietitians must use new measures to protect clients' privacy to meet their professional obligations. If your organization allows texting of orders, follow your employers' policies and ensure you take reasonable steps to keep client personal health information safe and secure.
Record Keeping
Therapeutic Client Relationships
All significant social media communication with any therapeutic client-dietitian relationship should be documented. Follow organizational policies for documentation if there are any. If there are none, the documentation may include:
  1. a summary of the social media correspondence between dietitians and clients in the client health record.
  2. cutting and pasting social media correspondence in the electronic client health record; and/or
  3. printing hard copies or attaching copies of electronic social media correspondence in the client health record.
Non-Client Care
Where social media is used to provide education to the public, employers, or health care providers, use professional judgement to determine how much record-keeping is required. It may be good practice to document the nature of the topics communicated over social media and keep a log of significant comments and interactions with users.
Access to Records
Dietitians should also think about whether they might need future access to the original information they posted on social media that continued access (e.g., usernames and passwords) to original social media correspondence may be imperative if a client, the College, or a court order requires a dietitian to submit those records.
How to Document When Using Apps
Whenever dietitians use a secure online client portal to practice or an app to exchange information with clients, the online interactions must be documented. Dietitians should transfer or summarize the information into the health record if clients send personal health information using an app on a smartphone.

A new entity subject to PHIPA is "Consumer Electronic Service Providers" (e.g., apps and online portals in which clients can access and store personal information about themselves). Details will be set out in future regulations but dietitians or their companies who access, modify, or manage PHI records electronically through an app or portal will need to become familiar with the rules about sharing, or managing requests to disclose information with Consumer Electronic Service Providers (e.g. dietitians who manage or process PHI electronically such as through an app or portal for online claim submissions). 
Web-Based Counselling
Always obtain informed consent when providing web-based services and interacting with clients online. Web-based counselling sessions through video transmission can be done either through various platforms. As the technology is constantly evolving, the College encourages dietitians to research options and take reasonable steps to ensure that clients' personal health information is protected against theft, loss, unauthorized use, or disclosure. If you are employed, ask your employer first. If you are in private practice, the Information and Privacy Commissioner has guidelines for the health sector — Privacy and Security Considerations for Virtual Health Care Visits
Generally, sending personal health information through regular email should be avoided. Acceptable options include obtaining the person's consent to use email, encrypting the email, or making the information anonymous. This would involve informing clients of the security issues (e.g., the Internet is not 100% secure, and email is subject to hacking). Dietitians should also consider that email can be unreliable, arriving hours or even days later, or not at all.  This resource on communicating health information by email from the Information and Privacy Commissioner can be helpful.
User Agreements
We recommend that dietitians develop a user agreement for all their Internet sites (Facebook pages, Instagram, websites, blogs, etc.). The user agreement should clearly indicate the purpose of the site and user responsibility for posts, respecting others, and that comments will be moderated and may be deleted by the moderator if inappropriate. It should also indicate the limitations of the information shared on the site, for example, by using a disclaimer such as "information is general and is not intended to replace advice obtained from your physician, dietitian or another health professional."

Some websites have implemented a declaration box that needs to be checked before joining a group and/or viewing or commenting on a site. This could be something that dietitians implement on the site they are personally managing to ensure all readers are aware of the expectations for appropriate conduct.

This article is based on "Professional Communications Online and on Social Media" by Carole Chatalalsingh, PhD, RD, which was published in the Winter/Spring 2016 issue of Résumé, the former newsletter of the College of Dietitians of Ontario. It was updated in October 2021.
For more on this topic, please read Dietetic Practice and Social Media.
Steinecke, Richard. A Complete Guide to the regulated Health Professions Act. Aurora: Canada Law Book, updated annually.
DeJong, S.M. (2014) Blogs and Tweets, Texting and Friending- Social Media and Online Professionalism in Health Care.
Greysen S.R., Kind T., Chretien K.C. “Online professionalism and the mirror of social media.” J Gen Intern Med. 2010;25:1227–1229.