SMS Communication, Data Privacy and Protection

Cedar Valley Psychiatry (Cedar Valley or CVP) is committed to safeguarding personal and patient data collected through our SMS communications. The purpose of the SMS Communication, Data Privacy and Protection policy is to establish processes and procedures for managing data obtained through SMS activities. This policy covers all SMS based interactions that involve the collection, storage, and processing of personal and or patient data. It serves to assure compliance with data protection laws such as HIPAA, and other applicable regulations.

SMS Opt-In Procedures

Cedar Valley is dedicated to protecting your privacy and ensuring that all communications sent via SMS comply with applicable laws and regulations regarding user consent.

Subscribing to SMS messages: Individuals can subscribe to receive SMS messages from Cedar Valley by:

• Texting a specific keyword to our designated number
• When filling out health care communication forms
• Opting in via our physical locations (e.g. Office Location)

Sample Opt-In SMS texts

• Hello! Text YES to confirm Cedar Valley can send recurring text messages.
• You are confirmed. Messages are recurring and frequency varies. Text STOP to cancel. HELP for help. Read full terms and privacy policy here: https://cedarvp.com/policies/sms Message and data rates may apply.
• Hello [name], this is [name] from Cedar Valley. You filled out an online form and said we could text you at this number. To confirm please reply Yes? ”

Confirmation of subscription: After opting in, subscribers will receive a confirmation SMS acknowledging their subscription and detailing the nature of the communications they will receive.

Consent verification: We ensure that all individuals on our subscriber list have explicitly agreed to receive messages. Regular checks are conducted to maintain compliance with legal standards.

SMS Opt-out Procedures

Cedar Valley is committed to protecting your privacy and ensuring that all communications sent via SMS comply with applicable laws and regulations concerning user consent.

Unsubscribing from SMS messages: Subscribers can opt out of receiving SMS messages at any time by:

• Replying with the word “STOP” to any of our SMS communications
• Adjusting their subscription preferences via “contact us” form on our website
• Contacting front desk receptionist to request removal from the SMS list

Confirmation of unsubscription: Once an opt-out request is received, the subscriber will be removed from future communications and will receive a final SMS confirmation.

Managing subscriber lists

Consent verification: We regularly verify the consent of all individuals on our subscriber list to ensure compliance with legal standards and that only those who have explicitly agreed to receive messages are contacted.

Data accuracy: We maintain the accuracy of our subscriber lists by updating them regularly to remove opt-outs and correct any errors in subscriber information.

Privacy protection: All subscriber data is securely stored and protected against unauthorized access, use, or disclosure.

Data Collection via SMS

Types of data collected: This includes mobile phone numbers, text message content, and, depending on the context, may include other personal identifiers.

Consent: Prior explicit consent will be obtained before collecting data via SMS, detailing what data is collected and how it will be used.

Data Use and Protection
Usage: Personal data collected via SMS will only be used for the purposes stated at the time of collection such as

Protection measures: Strong security measures, including encryption and secure data storage, are implemented to protect data from unauthorized access or breaches.

User Rights

Data subjects have the right to:

• Access, correct, and request the deletion of their personal data.
• Withdraw consent at any time by opting out of SMS communications.

HIPAA-compliant confirmations Sample SMS Texts

• “You have indicated your interest in receiving important messages from Cedar Valley. As a HIPAA compliant organization, we must inform you SMS is not a fully secure channel. To opt into messaging, reply YES. Msg/data rates may apply. Read full terms and privacy policy here: https://cedarvp.com/policies/sms
• Appointment confirmation template
  Hi [CUSTOMER NAME], Your appointment on [DATE] at [TIME] is confirmed.
• Appointment reminder template – Day of
  Hi [CUSTOMER NAME], Your appointment is today, [DATE], at [TIME].

References

• Twilio – Sample Appointment confirmations – https://www.twilio.com/en-us/blog/12-sms-templates-examples-to-get-you-started
• Klaviyo – SMS privacy policy best practices –https://help.klaviyo.com/hc/en-us/articles/4404199571867
• Textmagic – 5 SMS compliance policy templates every business should use – https://www.textmagic.com/blog/sms-policy-templates/