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9.MEP.3 |
Client's (Past or Present) Participation in Fundraising or Public Relations Communications Activities
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Type: Procedure
Category: Risk Management and Safety
Level: Community Care
Parties: Community Care employees and contractees
Printer Friendly Version: http://apps.comcareme.org/policymanual/default.aspx?code=9.MEP.3&nonav=yes
Supporting References: COA standard G1.5.07; Rights of Recipients page 16 Confidentiality; Community Care's Confidentiality policy and procedure; HIPAA Privacy Rule Standard 164.514(f)1, (f)2
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Parent |
Effective Date |
Approval Level |
Revision Dates |
Last Reviewed |
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N/A |
1-1-2004
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Management Team
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None
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N/A |
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Related Document Code |
Related Document Name |
Type |
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1.ME.65 |
Fundraising Materials Sent to Clients |
Policy |
Procedure: 1. Any time fundraising or public relations activity requires the sharing of any client information, Community Care employees and contractees are limited in the scope of protected health information they may use. This scope is limited to demographic information relating to individuals served and the dates of health related services provided.
2. Should a client's participation be sought or recommended for fundraising events or public relations activities, Community Care employees and/or contractees will engage in the process of determining if it is possible for the client to be involved.
3. Community Care employees and/or contractees will communicate all aspects of the fundraising event or public relations activity to the client and/or legal guardian, the client's other team members (as appropriate), and document this conversation in the case record.
4. Any client, past or present, has the right to opt out of participation, including the choice to opt out of receiving any future notices or communications regarding fundraising or public relations activities. When such a request is made, Community Care must make reasonable efforts to accommodate this request.
5. Should a client wish to be involved in a fundraising or public relations activity, the Community Care employee and/or contractee will get the client's and/or their legal guardian's informed and written consent.
6. Should a client make a statement expressing gratitude to Community Care, and the agency wishes to use this statement for public purposes, the client's and/or legal guardian's informed and written consent will be sought. Community Care staff will explain to the client/legal guardian how and where the statement is going to be used and document the conversation in the case record.
7. Should a client voluntarily make statements to the public when engaged in fundraising or public relations activities, Community Care will make every attempt to protect the client's rights including, but not limited to, informing the client that they are giving information to the public and may be violating their own right to confidentiality. This action must be documented and entered into a client's record.
8. Any time Community Care wishes to use photographs, videotapes, audio-taped interviews, artwork or writings of or about clients served, the client's and/or their legal guardian's informed and written consent will be obtained. Community Care staff will explain how and where the above will be used and document this conversation in the case record.
9. Copies of the written consents will be given to the client and/or legal guardian and the original placed in the case record.
10. Without the written consent of a client and/or their legal guardian, Community Care will not publish, print, or share any document that would disclose confidential information regarding that client to the public for the purpose of raising funds or in building public relations. Without consent, only demographic information relating to individuals and the dates of services provided to individuals may be shared.