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Medical Spa Operating System

Clinical and business operating manual for an Ontario medical spa: delegation and oversight, consent, records, infection prevention, privacy and advertising rules.

Written against

  • · Regulated Health Professions Act, 1991 and the Medicine Act, 1991
  • · College of Physicians and Surgeons of Ontario (CPSO) delegation and out-of-hospital premises expectations
  • · Personal Health Information Protection Act, 2004 (PHIPA)
  • · Public Health Ontario / IPAC Core Elements for clinical office practice
  • · Occupational Health and Safety Act (Ontario)
  • · Consumer Protection Act, 2002 (Ontario)

1. Scope of practice and oversight

In Ontario, procedures such as injecting a substance below the dermis and certain energy-based treatments are controlled acts. They may only be performed by an authorized regulated health professional, or by a competent person under a valid delegation with documented supervision. Build your service menu around this before you advertise anything.

  • · Service menu with the responsible regulated professional named for each treatment
  • · Written medical directives or delegations signed and dated by the delegating physician or nurse practitioner, with review dates
  • · Competency assessment and training file for every person performing delegated acts
  • · Professional liability insurance for each practitioner and the clinic
  • · Emergency protocols, including anaphylaxis and hyaluronidase availability where dermal fillers are used

2. Client intake and informed consent

  • · Health history: medications, allergies, autoimmune conditions, pregnancy or breastfeeding, prior treatments, implants
  • · Contraindication screening documented and signed before every treatment, not just the first
  • · Informed consent covering the nature of the treatment, expected results, alternatives, material risks and side effects, aftercare and cost
  • · Separate written consent for photography and any use of images in marketing, revocable at any time
  • · Cooling-off and cancellation terms disclosed in writing before payment (Consumer Protection Act, 2002 applies to prepaid services and packages)

3. Clinical record standard (PHIPA)

  • · One record per client containing intake, consents, treatment notes, product lot numbers and expiry, injector, dose/settings, and aftercare given
  • · Records retained at least 10 years after the last interaction (and, for a minor, 10 years after the client turns 18) — follow your regulator's rule where it is longer
  • · Named Privacy Officer, written privacy policy and posted notice of information practices
  • · Access controls, audit logs, encryption at rest and in transit, and a signed confidentiality agreement for every employee
  • · Privacy breach procedure: contain, investigate, notify the individual at the first reasonable opportunity and notify the Information and Privacy Commissioner of Ontario where required

4. Infection prevention and control

  • · Hand hygiene at the four moments; alcohol-based rub at every station
  • · Single-use needles and cannulas; no reuse, no multi-client vials without documented safe practice
  • · Sharps containers, biomedical waste contract and disposal manifests
  • · Reprocessing of reusable instruments per CSA standards with a sterilizer log, chemical and biological indicators recorded weekly
  • · Surface disinfection between clients with a Health Canada registered disinfectant used at the labelled contact time
  • · Linen handling, treatment room cleaning schedule and annual IPAC self-audit

5. Product handling

  • · Only Health Canada authorized products with a DIN, NPN or medical device licence — record the licence number
  • · Purchase from authorized Canadian distributors only; retain invoices
  • · Cold chain log for refrigerated products with twice-daily temperature records
  • · Lot number and expiry recorded in the client chart for every injectable
  • · Recall procedure and Health Canada adverse reaction reporting

6. Advertising and pricing rules

  • · No testimonials or endorsements for regulated services where your regulator prohibits them — check CPSO and CNO advertising standards before publishing reviews
  • · No comparative or superlative claims that cannot be substantiated (Competition Act, sections on misleading representations)
  • · Prescription drug advertising restrictions apply to products such as botulinum toxin — do not name or price them in public advertising
  • · Before/after images must be unaltered, consented, and labelled with typical results and treatment count
  • · All-in pricing, package terms, expiry and refund policy disclosed before payment

7. Staff, safety and training

  • · Annual competency review and documented CPR/first aid certification for clinical staff
  • · OHSA workplace violence and harassment programs, WHMIS training, laser safety officer where Class 3B/4 devices are used
  • · Laser safety: controlled access signage, eyewear rated to the wavelength, device service log
  • · Incident and adverse event register with root cause review and corrective action

8. Business performance dashboard

MetricTargetFrequency
Chair utilization70–85%Weekly
Rebooking rate60%+Weekly
Product cost per treatmentUnder 25% of priceMonthly
Average client value (12 mo)Track trendQuarterly
Adverse event rateInvestigate every eventMonthly

This template is provided for general business use and reflects Ontario and federal Canadian requirements as commonly applied. It is not legal, tax or clinical advice. Confirm current requirements with Ontario.ca, your local public health unit or municipality, the Ministry of Labour, Immigration, Training and Skills Development, the CRA, WSIB and your professional regulator, and have high-risk documents reviewed by a licensed Ontario lawyer or accountant before use.