Social media is part of nearly every profession these days, and healthcare is no exception to this. Healthcare providers and entities alike may use social media for everything from posting pictures of their office decorations to communicating with patients regarding service updates or vaccine availability.
However, not everything should be shared on social media. It’s important to think twice before sharing anything that could potentially identify a patient without their explicit written consent. Here are a few things to consider.
HIPAA privacy or security breaches
Sharing photos of patients or family members on social media is not something to take lightly. Even the most well-intentioned or endearing photos could violate HIPAA privacy or security policies. Pay close attention to anything that contains personally identifiable information, per HIPAA’s privacy rules. Personally identifiable information contains direct or “facial” identifiers of either the patient or their relatives. These include:
- Name, address and date of birth
- Voice prints
- Images showing the entire face of an individual
- Comparable images
This information applies to the entire photo shared on social media, including individuals who may be out of focus or in the background of an image.
To avoid any privacy breaches, providers should obtain a signed HIPAA authorization form from patients or their personal representatives. This form should permit you to publish the photo in question.
Implementing a clear social media policy
While clearing individual photos is important, it is also important to establish a clear policy regarding business social media use in general. Consider the following questions in developing the policy for your firm:
- Who has the authorization to add content?
- What kind of information are you posting – and is it accurate, trustworthy and up to date?
- Do you have a review process in place before anything new is posted?
- Are any disclaimers necessary?
- How is your practice ensuring you are in compliance with HIPAA privacy rules?
Depending on your practice and the type of content you are looking to share, as well as the frequency of your posts, you may have more important questions to consider as well.
Aside from getting a policy in place, simply checking your social media presence regularly is a good practice to get into. This can help you stay active with any inquiries or requests that come in from social media and help you remain aware of the content published on your platforms. A healthcare law attorney can help you stay cognizant of social media do’s and don’ts.