Somewhere in your practice there is a folder, or a drawer, of records for clients you no longer see. You would like to throw it out, or you are afraid you may not. Type how long does a massage therapist have to keep client records into a search box and five different numbers come back, and all five can be right, because no single body sets the number.
In the US it sits in your state board's rule. Texas says two years, and only for the dates, types and billing (16 TAC § 117.90, 2026); Massachusetts says seven, for the whole file (269 CMR 6.06, 2017). In the UK the law names none and your insurer does; in Australia it comes from state acts. The table below shows which number is whose, and where there is none — not legal advice, because rules change, and every row carries the day we read it.
Who sets the clock for you?
Your number comes from one of three places. A state board writes it into a rule (US); a limitation period and an insurance condition stand in for a number the law never gives (UK); a state health-records act sets it and your association repeats it (Australia). Only the first hands you a figure to look up.
The Federation of State Massage Therapy Boards lists 50 US jurisdictions that regulate massage therapy; Kansas, Minnesota and Wyoming are not on the list (FSMTB, 2026). Each state that sets a period writes it into its own rule or statute, and the numbers do not agree. Washington says three years (WAC 246-830-570, 2021), Massachusetts seven (269 CMR 6.06, as amended 2025), Wisconsin five (MTBT 5.02, 2015), New York six (8 NYCRR 29.2, 2026), Texas two (16 TAC § 117.90, 2026). Each is right for exactly one state.
The number that belongs to no state is "HIPAA says seven years". HIPAA sets no period for a client's file; the FAQ below has both texts.
In the UK nobody writes the number down. "The UK GDPR does not set specific time limits for different types of data. This is up to you, and will depend on how long you need the data for your specified purposes" (ICO, 2026). That page now carries a banner saying the guidance is under review after the Data (Use and Access) Act; check it again before you rely on it.
Two things fill the gap. The Limitation Act 1980 says how long a claim can wait: six years for a tort (s. 2), three for personal injury (s. 11). The insurer names the figure everyone repeats: "it is usually a condition of your Insurance policy (Contract Law) that records be kept for at least 7 years, or for 7 years after they reach the age of majority when treating minors" (Balens, 2019).
Even a statutory regulator declines to name one: the HCPC, which does not cover massage, answers "This will vary according to the context in which you practise" (HCPC, 2025). That seven years is a term in your policy, not a law of the country: the document to open is your policy.
Australia looks like the UK from a distance and is not. Ahpra's 15 National Boards do not include massage (Ahpra, 2024), so the Ahpra page that ranks for this question is not addressed to you. The number is in state health-records law.
New South Wales asks for "7 years from the last occasion on which a health service was provided to the individual" (Health Records and Information Privacy Act 2002 (NSW), s. 25). For a client who was under 18, the same section says "until the individual has attained the age of 25 years". Victoria writes the same figures as a ban on deleting earlier (Health Records Act 2001 (Vic), HPP 4.2).
The Association of Massage Therapists repeats "kept for a minimum of 7 years" with no start date and no section cited (AMT, 2023). The association echoes the acts; the text to keep is the act.
How long does a massage therapist have to keep client records? The table
Find your row and you have your number, or the certainty that there is none. One to seven years across the twenty-six US jurisdictions that state a period; no massage rule at all in twenty-five more; seven years in New South Wales and Victoria; no statutory period in the UK. Every row names the text and the day we read it.
The columns are ours; the words in the cells are the rule's. Minimum period is the floor the text sets; Clock starts from and Minors are quoted where the rule speaks and read "not stated" where it does not. That blank is a finding: "at least five years" without an anchor leaves you to pick the anchor. Who this binds is whoever the rule names: the licensee, the establishment, or everyone under a general statute that includes massage.
The table holds 51 US jurisdictions — twenty-six with a stated period, twenty-five with none, Tennessee among them only in part — plus the UK, New South Wales and Victoria. Those twenty-five are not gaps. They are the answer for half the country: no board tells you when to stop, and the number you find online for such a state almost always belongs to someone else.
Check the date on any rule you find. A reputable host can carry an old version with nothing on the page to say so. A live link is not a current rule.
| Jurisdiction | Minimum period | Clock starts from | Minors | Who this binds | Source (cite + date read) |
|---|---|---|---|---|---|
| Alabama | 4 years | "from the termination of the therapeutic relationship" | not stated | the licensee | Ala. Admin. Code ch. 532-X-3 (2024), the Board's published chapter; read 10 Sep 2026 |
| Alaska | 5 years | not stated | not stated | the establishment; the board's standards are adopted by reference and licensees must adhere to them | 12 AAC 79.900, adopting the Board's Establishment Standards of Operation (Sept 2019); read 10 Sep 2026 |
| Arizona | 6 years | "after the last date the adult patient received medical or health care services from that provider" | 3 years past the 18th birthday or 6 years after the last service, whichever is later | not the massage rules, which have none: a general statute binding "a person who is licensed pursuant to title 32 and who maintains medical records", and massage is title 32. It is conditioned on keeping "medical records" and excludes title-32 licensees who are employees. Both texts are shown; this article does not say which one governs you | A.R.S. 12-2297(A) with the definition at 12-2291(5)(a); the massage rules (A.A.C. tit. 4 ch. 15) have no records provision; read 10 Sep 2026 |
| Delaware | 3 years | "from the last date that services were provided to the client" | not stated | the licensee; the establishment keeps intake forms "and any other client records" on its premises for the same 3 years | 24 Del. Admin. Code 5300, §§ 11.1.15 and 12.6.5 (2024); read 10 Sep 2026 |
| District of Columbia — board regulation | 3 years | "past the date of last contact" | 3 years after the age of majority | the licensee | DC Health, Massage Therapy Regulations, updated 7 June 2019; read 10 Sep 2026 |
| District of Columbia — D.C. Code | 5 years. The regulation above says three; both texts are shown, and this article does not say which one governs you | "from the date of last contact" | 5 years after the age of majority | records covered by the Health Occupations Revision Act | D.C. Code § 3-1210.11(c); read 10 Sep 2026 |
| Florida | 1 year | "after a service or treatment is provided" | not stated | the establishment, not the therapist; the board's own rules require a patient care record but name no period | Fla. Stat. § 480.043(14)(f); rule at Fla. Admin. Code r. 64B7-23.009; read 10 Sep 2026 |
| Indiana | 6 years | "from the date of service" | not stated | "the license holder" | 847 IAC 1-2-4(2), as amended eff. 13 Jul 2022 — the PDF the state agency still hosts says four years and is superseded; read 10 Sep 2026 |
| Kentucky | 5 years | not stated | not stated | the licensee | 201 KAR 42:061 (eff. 5 Jul 2022), text via Cornell LII; read 10 Sep 2026 |
| Louisiana | 5 calendar years | "after the last service is performed for that client" | not stated | the licensee | LAC 46:XLIV.4101(A)(5) (2013), read on a legal publisher's copy — the official Louisiana viewer refused; read 10 Sep 2026 |
| Maryland | 5 years | "after termination of treatment" | not stated | the licensee or registrant | COMAR 10.65.03.04A(4); read 10 Sep 2026 |
| Massachusetts | 7 years | "from the date of the last client encounter" | minor at the last visit: seven years from the last encounter "or until the client reaches the age of eighteen, whichever is the longer retention period" | the licensed establishment; a practitioner working alone holds a Solo Establishment License under 269 CMR 6.03 | 269 CMR 6.06(1)(b)–(c), as amended effective 7 Nov 2025; read in the official mass.gov PDF, because mass.gov blocks automated reading; read 10 Sep 2026 |
| Michigan | 7 years | "from the date of service to which the record pertains" | not confirmed in the current rule set; a 2012 massage rule said one year after 18 and was not re-checked | every licensee under the Public Health Code; the massage rules point back to it | MCL 333.16213(2)(a) (2023); read 10 Sep 2026 |
| Mississippi | 2 years | not stated | not stated | the licensee, "unless the massage establishment has the responsibility for maintaining such documentation" | 30 Miss. Admin. Code Pt. 2501, Rule 7.5(17), as quoted in the Board's FAQ of 4 December 2025; read 10 Sep 2026 |
| Missouri | 3 years | "from the last date of service" | not stated | the licensee, personally when working outside a licensed massage business | 20 CSR 2197-3.010, read on a legal publisher's copy — the Missouri publisher sits behind a bot check; read 10 Sep 2026 |
| Montana | 4 years | two rules, two anchors: "from the last date of service to the client" (24.155.402) and "from the termination of the therapeutic relationship" (24.155.902) | not stated | the licensee | ARM 24.155.402(3) and 24.155.902(3)(d) (2020); read 10 Sep 2026 |
| Nevada | 5 years | "after their receipt or production" — the record's date, not the session's | no destruction while the person is under 23 | the statute binds a "provider of health care", and NRS 629.031's definition does not name massage therapists — but NRS 629.053 names 640C boards, and the massage board publishes the section to its licensees. Both texts are shown; this article does not say which one governs you | NRS 629.051(1) and (7), as republished by the Nevada State Board of Massage Therapy (revised 2023); read 10 Sep 2026 |
| New Jersey | 7 years | "from the date of the most recent entry" | not stated | the licensee | N.J.A.C. 13:37A-5.2(a), and the Board's FAQ; read 10 Sep 2026 |
| New York | 6 years | not stated in the rule; the regulator's consumer page: "six years or until the client turns 22, whichever is longer" | until one year after age 21 | every profession named in 8 NYCRR 29.2, massage therapy included | 8 NYCRR 29.2(a)(3); NYS Office of the Professions, consumer page; read 10 Sep 2026 |
| North Carolina | 4 years | "after the termination of the client/therapist relationship" | not stated | the licensee; ownership sits with the establishment or the licensee, with release within 30 days of a written request (21 NCAC 30 .1005) | 21 NCAC 30 .0505(2); read 10 Sep 2026 |
| Oklahoma | 3 years | "from the date of service" | not stated | "a licensee" | Okla. Admin. Code 175:20-9-2(b); read 10 Sep 2026 |
| Pennsylvania | 3 years | "from the last date that services were provided to the client" | not stated | the licensee | 49 Pa. Code § 20.42(a)(19); read 10 Sep 2026 |
| Texas | 2 years, and only for "the dates of massage therapy services, types of massage therapy and billing information" | not stated | not stated | the licensee | 16 TAC § 117.90(f), text via Cornell LII; TDLR's sanctions page cites the same rule; read 10 Sep 2026 |
| Vermont | 7 years | not stated | not stated | registered massage therapists, bodyworkers and touch professionals — the statute names the profession in those words | 3 V.S.A. § 129a(a)(9), tied in by 26 V.S.A. § 5427; read 10 Sep 2026 |
| Washington | 3 years | "from the date of last treatment" | 3 years after the client turns 18 | the licensee | WAC 246-830-570(1)–(2) (2021); read 10 Sep 2026 |
| West Virginia | 4 years | not stated | not stated | the licensee | W. Va. Code R. § 194-1-4.1.r, read on a legal publisher's copy — the state's own file is a scan with no text layer; read 10 Sep 2026 |
| Wisconsin | 5 years | not stated | not stated | the licensee | Wis. Admin. Code MTBT 5.02(8) (2015) — not 5.02(27), which is the duty to report another licensee; read 10 Sep 2026 |
| Arkansas | no period found; records required ("Treatments must be noted on the client's assessment form") | — | — | the licensee | 17 CAR pt. 52; A.C.A. 17-86; read 10 Sep 2026 |
| California | no state rule at all — the state does not license massage, it recognises voluntary certification by a nonprofit council, and leaves the rest to cities. The seven years shown online is for licensed clinics and facilities that close, not for a massage practice | — | — | no state licensee to bind; a city ordinance may | Cal. Bus. & Prof. Code §§ 4600–4621, § 4612(b); the seven years is Cal. Health & Safety Code § 123145(a); read 10 Sep 2026 |
| Colorado | no period found. The only seven years in the massage rules is on a balance-billing notice form, not on client records | — | — | — | 3 CCR 722-1 (eff. 30 Sep 2025), incl. Appendix A; C.R.S. 12-235-101 to -120; read 10 Sep 2026 |
| Connecticut | no period found. The seven-year medical-records rule quoted online does not reach massage: the section listing who it binds names chapters by number and omits ch. 384a | — | — | — | C.G.S. ch. 384a; R.C.S.A. 19a-14-41 and 19a-14-42; no massage regulations exist; read 10 Sep 2026 |
| Georgia | no massage-specific period found; records required | — | — | the licensee | Ga. Comp. R. & Regs. ch. 345-6; read 10 Sep 2026 |
| Hawaii | no period found. The seven-year statute quoted online does not reach massage: it borrows a closed definition that names physicians, podiatrists, facilities and midwives, not ch. 452 | — | — | — | HAR tit. 16 ch. 84; HRS ch. 452; the statute is HRS 622-58 with the definition at 671-1; read 10 Sep 2026 |
| Idaho | no records provision in the chapter at all | — | — | — | IDAPA 24.27.01 (eff. 1 July 2024); read 10 Sep 2026 |
| Illinois | no records provision in the rules or the act | — | — | — | 68 Ill. Adm. Code 1284; 225 ILCS 57; read 10 Sep 2026 |
| Iowa | no period found; the words client and patient do not appear in the licensure or discipline chapters | — | — | — | Iowa Admin. Code chs. 481-821 to 481-825; Iowa Code ch. 152C; read 10 Sep 2026 |
| Maine | no period found; the only records rule binds the regulator, not the practitioner | — | — | — | 02-041 C.M.R. chs. 100, 200, 300, 400; 32 M.R.S. ch. 127; read 10 Sep 2026 |
| Minnesota | no massage-specific period found; massage is an unlicensed complementary practice under ch. 146A, and the seven years shown online belongs to the Board of Behavioral Health and Therapy | — | — | — | Minn. Stat. § 146A.11; Minn. R. 2150.7535; MDH list of complementary practices; read 10 Sep 2026 |
| Nebraska | no records provision at all | — | — | — | 172 NAC 81 and 82; Neb. Rev. Stat. 38-1701 to -1725; read 10 Sep 2026 |
| New Hampshire | no period found. The three years in the chapter binds massage schools holding student practical-hour records, not licensees | — | — | — | N.H. Code Admin. R. Plc 900 (eff. 17 Oct 2025), Plc 904.03(a)(2); RSA 328-B; read 10 Sep 2026 |
| New Mexico | no period; confidentiality and no falsifying of records | — | — | the licensee | 16.7.2 NMAC (2019); read 10 Sep 2026 |
| North Dakota | no period; records required and stored "not readily accessible to the public" | — | — | the licensee | N.D. Admin. Code 49-03-01-01(8) (2024), text via Cornell LII; read 10 Sep 2026 |
| Ohio | no period found — and here the general statute does reach massage and still names no period | — | — | the general statute expressly covers "a practitioner of a limited branch of medicine", which is what massage is in Ohio | Ohio Adm. Code ch. 4731-1; Ohio Rev. Code 3701.74(A)(4)(h); read 10 Sep 2026 |
| Oregon | no period for client records; the five years in the chapter is for continuing-education records | — | — | — | OAR ch. 334 (eff. 1 Jul 2025), CE rule at 334-010-0050(8); ORS ch. 687; read 10 Sep 2026 |
| Puerto Rico | no period in the act; the implementing regulation is not covered here | — | — | — | Ley Núm. 254-2003, 20 L.P.R.A. §§ 171–187; Reglamento Núm. 7912 not covered; read 10 Sep 2026 |
| Rhode Island | no period for client records; the four years in the rule is for continuing-education documents | — | — | — | 216-RICR-40-05-10 § 10.8(B); R.I. Gen. Laws ch. 5-95 (eff. 26 Jun 2024); read 10 Sep 2026 |
| South Carolina | no period, and no duty to keep records: "If client treatment records are kept…" | — | — | the establishment | S.C. Code Regs. 77-141(1)(j) (2023); read 10 Sep 2026 |
| South Dakota | no period for client records; the five years in the article is for continuing-education and malpractice-insurance paperwork | — | — | — | ARSD art. 20:76, rules 20:76:03:05 and 20:76:05:02; read 10 Sep 2026 |
| Tennessee | no client-record period in the sections read; the chapter was not read end to end | — | — | — | Tenn. Comp. R. & Regs. 0870-01; read 10 Sep 2026 |
| US Virgin Islands | no massage chapter or board rules located; the health department's requirements sheet says nothing about client records | — | — | — | V.I. Dept. of Health, Requirements for the Practice of Massage Therapy (2023); read 10 Sep 2026 |
| Utah | no period found. An intake form is required before the first session and must be reviewed before each new one, but no rule says how long to keep it | — | — | the licensee | Utah Admin. Code R156-47b-306, with R156-47b-601(2)(a); read 10 Sep 2026 |
| Virginia | no client-record period in the massage chapter; the five years shown online belongs to home care organizations (12VAC5-381-280) | — | — | — | 18VAC90-50, full chapter; read 10 Sep 2026 |
| United Kingdom (England and Wales) | no statutory period: "no longer than is necessary" (UK GDPR, Art. 5(1)(e)); the insurer's condition: 7 years (Balens) | limitation, not retention: 6 years for a tort claim (s. 2); 3 years for personal injury, from the date of knowledge if later (s. 11) | insurer: 7 years after the age of majority; the limitation clock starts at 18 (s. 28) | anyone holding personal data (ICO); the insurance condition binds the policyholder | ICO, storage limitation guidance (under review, 2026); Limitation Act 1980, ss. 2, 11, 28; Balens, Record Keeping v5 (2019); read 10 Sep 2026 |
| Australia — New South Wales | 7 years | "from the last occasion on which a health service was provided to the individual" | "until the individual has attained the age of 25 years" | health services in the private sector covered by the Act | Health Records and Information Privacy Act 2002 (NSW), s. 25(1), read on AustLII; read 10 Sep 2026 |
| Australia — Victoria | must not delete before 7 years: a ceiling on deletion, not a floor on keeping | "after the last occasion on which a health service was provided to the individual" | not before age 25, "whichever is the later" | health services covered by the Act | Health Records Act 2001 (Vic), Sch. 1, HPP 4.2, read on AustLII; read 10 Sep 2026 |
| Australia — Association of Massage Therapists | "kept for a minimum of 7 years"; association guidance, not law | not stated | not stated | AMT members | AMT blog, 28 September 2023; read 10 Sep 2026 |
What does the clock start from?
Almost never from the day you wrote the note: most rules run from the last session, some from the last entry or the end of the working relationship, several run a minor's clock from a birthday, and a few name no start at all.
Most rules count from the last time you saw the client, not from the date on the page. Washington runs its three years "from the date of last treatment" (WAC 246-830-570, 2021). Delaware, Pennsylvania and Missouri count from the last date services were provided (24 Del. Admin. Code 5300, 2024; 49 Pa. Code § 20.42, 2026; 20 CSR 2197-3.010, 2026).
Louisiana's five calendar years begin "after the last service is performed for that client" (LAC 46:XLIV.4101, 2013). So a note from your first year with a client and one from the last session expire on the same day, the later one.
Other anchors exist, and they can land on different days. New Jersey counts "from the date of the most recent entry" (N.J.A.C. 13:37A-5.2, 2026), so a line added after the client stopped coming restarts the seven years. Alabama, North Carolina and Maryland count from the end of the relationship (Ala. Admin. Code ch. 532-X-3, 2024; 21 NCAC 30 .0505, 2026; COMAR 10.65.03.04, 2026).
Montana says both in two rules: "from the last date of service to the client" in one, "from the termination of the therapeutic relationship" in the other (ARM 24.155.402 and 24.155.902, 2020). Nevada anchors to the record itself, "for 5 years after their receipt or production" (NRS 629.051, 2023). Wisconsin, Kentucky, West Virginia, Texas and Mississippi give a number and no anchor at all. The anchor is yours to pick.
One Wisconsin line travels with its rule online: a client "shall continue to be considered a client for 6 months after the termination of professional services". It sits in the prohibition on sexual conduct, not in the recordkeeping provision (MTBT 5.02(15)(b), 2015), and says nothing about how long the file lives.
For a client who was a minor, several rules count birthdays instead of sessions. Washington keeps records three years after the client turns eighteen (WAC 246-830-570, 2021). New York's regulator puts it in one line, "six years or until the client turns 22, whichever is longer" (NYS Office of the Professions, 2026). Nevada forbids destroying "the health care records of a person who is less than 23 years of age on the date of the proposed destruction of the records" (NRS 629.051, 2023).
New South Wales and Victoria run to 25 (HRIP Act 2002, s. 25; Health Records Act 2001, HPP 4.2). Massachusetts runs two clocks and takes the longer. For a minor at the last visit, records must be kept "either seven years from the date of the last client encounter or until the client reaches the age of eighteen, whichever is the longer retention period" (269 CMR 6.06, as amended 2025).
A fifteen-year-old's file is governed by the seven years, a six-year-old's by the birthday.
The UK has no records clock, so the arithmetic moves to the claim. The three years for personal injury run from the later of the event and "the date of knowledge (if later) of the person injured" (Limitation Act 1980, s. 11). For someone who was under 18 the period does not begin until they cease to be under a disability (s. 28).
That is why a UK practitioner cannot compute a safe date from the last session alone. It is also why the insurer's "7 years after they reach the age of majority" exists (Balens, 2019). The Limitation Act is a rule about when a claim can be brought, not about what you must keep.
The records you didn't write
Treat your notes and the client's forms as one file, because the rules do. To you they are two different things; to the rules in the table they are one, "client records", and where a rule gives the client a right of access it does not ask who held the pen.
My folder holds two kinds of paper: my notes on each session — what we did, how the person seemed, what I noticed, what I would try next. And the documents I asked clients to write themselves — the consent form at the start, and afterwards a feedback sheet, sometimes a longer written reflection. The note is my working material, a snapshot of sensation, emotion and approach that lets me bring the person back to mind and carry on from there. The consent form is different: of everything in the folder, that part belongs to the client, who wrote it.
The rules do not draw that line: Mississippi's board spells out what "required client documentation" means, and the list runs from intake and release forms through the notes to the appointment book and client evaluations (Mississippi State Board of Massage Therapy, 2025). Delaware keeps intake forms "and any other client records" on the establishment's premises for the same three years as the notes (24 Del. Admin. Code 5300, 2024). The period attaches to the file, whoever wrote each page.
Access is just as blind to authorship. North Carolina assigns ownership of client records to the establishment, or to the licensee working at one, and requires release within 30 days of a written request (21 NCAC 30 .1005, 2019). Minnesota, which does not license massage, still requires a practitioner outside licensing to give every client a written statement covering credentials, complaints, fees, confidentiality and the right of access to records (Minn. Stat. § 146A.11, 2026). In both places the note you wrote and the form they wrote stand on the same footing when the client asks.
Which lands on something I did not do: I do not remember ever telling a client that I was writing things down, and I do not remember one asking. That was a habit, not a position. In Minnesota that written statement is the one duty that reaches a practitioner outside licensing. In the UK the regulator asks that you can justify what you hold (ICO, 2026).
Being open about the records, not a number, is the obligation that follows you out of licensing. What goes into the note is the hub article on session notes; this one stops at how long it stays.
When nobody sets a date: how long should client records be kept?
If no board, insurer or association names one for you, then in the United States no rule in the table names one either, and none puts a ceiling on how long the folder sits there. In the UK a duty reaches you without a number — "no longer than is necessary" — and it names keeping things "just in case" as the wrong answer.
The question of deleting has never come up for me, not once. I have a folder of paper records from clients I no longer see, and it is still there, on the off chance. If one of them comes back, what is in it will still matter: I go back to old notes to refresh how a session went and which approach may have worked. That sense, going into a session, points at where to go, where not to, what burned me last time and what did the job.
Between the two fears I have only ever had one. Keeping too much has never worried me — better to write more than less. Deleting something and then needing it has, and there have been times I did need it.
That is testimony, not advice, and here is where it stops working. In the United States it works because no rule is addressed to me. Minnesota lists massage therapy among the unlicensed complementary and alternative health care practices under chapter 146A (Minnesota Department of Health, 2026). The client bill of rights that chapter requires sets no retention period and does not require records to exist (Minn. Stat. § 146A.11, 2026).
South Carolina licenses massage and still writes a conditional: "If client treatment records are kept, they shall be maintained in a manner to safeguard the confidentiality of the records" (S.C. Code Regs. 77-141, 2023). Idaho's whole massage chapter runs three pages with no records provision at all (IDAPA 24.27.01, 2024). In those states no rule tells you to keep the folder, and none tells you when to empty it.
In the UK it does not work, and the regulator has the folder's exact words. The principle is one clause: personal data "kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed" (UK GDPR, Art. 5(1)(e), as reproduced by the ICO, 2026). The ICO's gloss is shorter: "You must not keep personal data for longer than you need it", you should not keep data indefinitely "just in case", and you need to "be able to justify" how long you keep it (ICO, 2026).
A small practice doing occasional low-risk processing may not need a written retention policy, the same page says, but "must still regularly review the data you hold, and delete or anonymise anything you no longer need". The duty attaches to holding the data, not to holding a licence.
The licensing states sit between the two: their rules set a floor, and where they mention a ceiling it is a permission. Washington says records may be disposed of once the period has run (WAC 246-830-570, 2021). Louisiana says that after five years "client records may be disposed of in an appropriate and confidential manner" (LAC 46:XLIV.4101, 2013). Victoria drafts it the other way round, a ban on deleting before seven years or age 25 and nothing about after (Health Records Act 2001 (Vic), HPP 4.2).
So keeping forever is not a rule anywhere in the table; it is what happens when no one asks. What happens when a practice closes, or its owner dies, is the question a reader asks on a pause, and none of these texts answers it.
Getting rid of them
Where a rule says how, it says shred, delete, erase, or make the medium unreadable; most only say "securely"; two Australian states ask you to write down what you destroyed and when. Scanning is not disposal.
Most rules stop at the adverb. Alabama, North Carolina, West Virginia and the District of Columbia each tell the licensee to dispose of client files "in a secure manner" and leave the method to you (Ala. Admin. Code ch. 532-X-3, 2024; 21 NCAC 30 .0505, 2026; W. Va. Code R. § 194-1-4.1, 2026; DC Health, 2019).
Washington names methods: once the period has run, records may be disposed of "by shredding, deleting or erasing electronic media, or otherwise rendering the media unusable and unreadable" (WAC 246-830-570, 2021). That covers a filing cabinet and a hard drive in one sentence, and it is the method to borrow when your rule only says "securely".
Australia adds a step none of the US rules in the table asks for: a record of the destruction. In New South Wales a practice that deletes health information "must keep a record of the name of the individual to whom the health information related, the period covered by it and the date on which it was deleted or disposed of" (HRIP Act 2002 (NSW), s. 25); Victoria's HPP 4.3 asks for the same note (Health Records Act 2001 (Vic), Sch. 1). The file goes; a line saying it went stays.
My own plan for the folder, when I next find it, is either to destroy it or to scan it, pack it up with a password and burn the paper. The second half deserves a plain word: a scan is not disposal. The rules above say "records" and "files", not "paper", and Washington puts electronic media in the same breath as shredding. A password-protected archive is still a record with the same clock on it — safer storage, not an ending.
Where do the records live while the clock runs?
Whatever you keep them in, it should show the last session date for every client, keep each history in one place, and let you take all of it with you when you leave.
Every anchor in the table — last session, last entry, end of the relationship, a birthday — is a date you have to find for one client, years later. HoldSpace is practice management for holistic practitioners — voice-first session notes, online booking, and client history in one place, built for people who hold space, not for hospitals.
Notes belong to the client rather than to a session, so a whole history reads as one timeline with its dates on it. Deleting a client is an archive step: the whole tree is kept for 30 days before it is removed for good. You can export your clients, sessions, notes, forms and logs as one file at any time, which is what leaving looks like when a practice closes.
Neither the tool nor this article tells you your period: the table shows what each document says, and nothing here, and nothing in the product, decides which one governs you. How the screens look is in the article on why we built it; the plans are on the pricing page.
So, the folder, this week. Find your row in the table and write its number and its starting point inside the cover; if the row says none, write that too, because it is the answer. Then go through the folder once and note the last session date for each client: almost every clock in the table starts there. What is past its period can go the way your rule says, shredded or erased; what has no period is yours to decide, and deciding again next year beats keeping it forever because nobody asked.
Keep every client's history in one timeline — free30 minutes of voice, 10 structurings and 5 clients.
FAQ
How long do therapists have to keep client records?
As long as the body that regulates your own profession says, and a neighbouring profession's number is not yours. In the table it runs from two years (Texas, and only for the dates, types and billing — 16 TAC § 117.90, 2026) to seven (Massachusetts, 269 CMR 6.06, 2017). The seven years shown online for Minnesota belongs to the Board of Behavioral Health and Therapy, which does not license massage (Minn. R. 2150.7535, 2026).
How long does a massage therapist have to keep client records in the UK?
No law names a number. The UK GDPR "does not set specific time limits for different types of data" (ICO, 2026); the seven years practitioners quote is an insurance condition (Balens, 2019); the Limitation Act 1980 sets six years for a tort claim and three for personal injury (ss. 2 and 11). Your number lives in your own policy wording.
How long does a massage therapist have to keep client records in Australia?
Seven years from the last service in New South Wales (Health Records and Information Privacy Act 2002 (NSW), s. 25). In Victoria, a ban on deleting before seven years or age 25, whichever is later (Health Records Act 2001 (Vic), HPP 4.2). Both come from the state health-records acts, not from Ahpra, whose 15 National Boards do not include massage (Ahpra, 2024).
Does HIPAA require keeping client records for seven years?
No. "The Privacy Rule does not include medical record retention requirements and covered entities may destroy such records at the time permitted by State or other applicable law" (HHS, 2023). HIPAA's six years is in the Security Rule: a covered entity must "Retain the documentation required by paragraph (b)(1) of this section for 6 years from the date of its creation or the date when it last was in effect, whichever is later" (45 CFR § 164.316, 2023). That paragraph (b)(1) is its own policies, procedures and the record of its own assessments, not anyone's session notes. Whether HIPAA reaches your practice is a separate question for a legal professional who knows your state; our position is in the Terms — this is not a HIPAA-covered tool, and if HIPAA applies to your practice, read them first.
Sources
- Federation of State Massage Therapy Boards (2026). Regulated States. Retrieved 10 September 2026. fsmtb.org/regulated-states/
- Washington State Department of Health, Board of Massage (2021). WAC 246-830-570, Washington Administrative Code. Filed 24 December 2020, effective 1 September 2021 (WSR 21-02-012). Retrieved 10 September 2026. app.leg.wa.gov/WAC/default.aspx?cite=246-830-570
- Massachusetts Board of Registration of Massage Therapy (2017). 269 CMR 6.06, within 269 CMR 6.00, Facility Licensure. Mass. Register Issue 1330, effective 13 January 2017. Read on Cornell LII, 9 September 2026 (mass.gov blocks automated retrieval; to be confirmed against mass.gov). law.cornell.edu/regulations/massachusetts/269-CMR-6-06
- Wisconsin Massage Therapy and Bodywork Therapy Affiliated Credentialing Board (2015). Wis. Admin. Code MTBT 5.02. Register June 2015 No. 714, effective 1 July 2015. Retrieved 10 September 2026. docs.legis.wisconsin.gov/code/admin_code/mtbt/5/02
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- Texas Department of Licensing and Regulation (2026). 16 Texas Administrative Code § 117.90(f). Read on Cornell LII, 9 September 2026; corroborated by TDLR, Massage Therapy Administrative Sanctions. law.cornell.edu/regulations/texas/16-Tex-Admin-Code-SS-117-90; tdlr.texas.gov/enforcement/mtsanctions.htm
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- Montana Board of Massage Therapy, Department of Labor and Industry (2020). ARM 24.155.402(3) and 24.155.902(3)(d). 24.155.402 new, 2020 MAR p. 1327, effective 25 July 2020. Retrieved 10 September 2026. boards.bsd.dli.mt.gov/_docs/arm/CH-155-LMT-as-of-06-30-2021.pdf
- West Virginia Massage Therapy Licensure Board (2026). W. Va. Code R. § 194-1-4.1.r. Retrieved 10 September 2026. apps.sos.wv.gov/adlaw/csr/readfile.aspx?DocId=55216
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