UCH SMS/Text Messaging Policy and Procedures

UCH is committed to protecting our patients’ privacy and confidential Protected Health Information (PHI), and to providing our patients excellent customer service. HIPAA regulations permit patients to request and receive confidential communications of their PHI by alternative means (45 CFR §164.522 (b)(1)(i)). To improve customer service for UCH patients requesting their medical records, patients may opt-in to receive a Short Message Service (SMS) text message link (from UCH medical records contractor Datavant) to request and receive medical records electronically and securely. Patients must authorize SMS/text messaging if they choose to utilize this service. This policy explains how UCH collects and uses information about our patients if/when a patient opts-in to receive SMS/text messages from UCH.  

Procedures:  

1.     When a patient opts in to receive SMS/text messages from UCH, UCH collects the following information from the patient:

a.     Name, Phone number; email address, basic contact information;

b.     Consent for the patient to receive SMS/text messages from UCH and/or Datavant; and

c.     Other relevant information, such as the time/date of the medical records text, and the number to where the text is sent.

2.     UCH also may collect the following information from the patient:

a.     Messaging interaction data, such as delivery status, responses, and opt-in methods;

3.     UCH Collects patient information in the following ways:

a.     Directly from the patient, such as when the patient completes a form;

b.     When a patient contacts UCH; and/or

c.     Automatically, such as when a patient interacts with UCH’s website.

4.     UCH may use patient information in the following ways:

a.     To send the patient the SMS/text messages the patient has opted to receive; specifically, the Datavant link that will allow patients to electronically request their medical records and the UCH SMS Terms & Conditions and the UCH SMS Text Messaging Policy & Procedures;

b.     To provide updates to the patient, including but not limited to any relevant content based on the patient’s preferences. At this time, the only information that will be texted to patients will be the link that will allow the patient to electronically request medical records, and the UCH SMS Terms & Conditions and the UCH SMS Text Messaging Policy & Procedures;

c.     To provide options/choices to users to manage their personal data and privacy settings such as: opting out of certain data collection, adjusting privacy settings, or deleting personal information to enable patients to control how their information is collected, used, and disclosed, and to enable patients to make informed decisions about their data privacy.

d.     To monitor and improve our text messaging services;

e.     If necessary for the operation of UCH’s business; and

f.      To keep a record of the patient phone number and caller ID for auditing/quality assurance purposes.

g.     Patients’ mobile opt-in information will not be shared.

5.     Patients may opt-out of receiving UCH or Datavant SMS/text messages at any time by replying “STOP” to any UCH/Datavant message the patient receives. The attached Terms and Conditions include additional information regarding the opt-out process.

6.     UCH may disclose patient information to the following:

a.     Trusted third party service providers who help us deliver text messaging services, business advisors or consultants who provide services to UCH; in the event of a corporate transaction (such as merger or sale); when required by law or administrative order; to assert claims or rights or to defend against claims or agency investigations; or to ensure safety and security/to prevent harm or respond to emergencies.

b.     UCH will take all necessary steps to protect patient information against unauthorized use or disclosure.

7.     UCH will not share patients’ personal/confidential information, including phone number or SMS/text consent opt-in data with any third parties or affiliates for marketing or promotional purposes.

8.     UCH takes reasonable precautions to safeguard patient information from unauthorized access, disclosure or misuse. While we strive to protect patient data, we cannot guarantee the security of information during transmission or storage. The delivery of medical records will be via an encrypted transmission.    

9.     UCH periodically may update this privacy policy. If UCH makes material changes that have a substantive and adverse impact on patient privacy, UCH will provide notice on the UCH website prior to the change becoming effective. UCH encourages patients to periodically review the UCH website for the most recent information about UCH’s privacy practices. If any part of this policy conflicts with UCH’s Notice of Privacy Practices, the Notice of Privacy Practices will govern, if applicable.

10.  How to contact Datavant or UCH regarding text message requests for medical records:

a.     To get technical support, please call Datavant at 1-800-367-1500.

b.     If you have any questions about this SMS/text messaging policy or wish to update your text preferences, you may email Datavant at: UCH-RecordsRequests@Datavant.com or email UCH at UCH.compliance@uthsc.edu