SMS Text Messaging to Service Users Policy Reference No: Version: 2 Ratified by: P_IG_24 LCHS Trust Board Date ratified: 29 th July 2014 Name of originator/author: Name of responsible committee/individual: Date issued: February 2011 Review date: July 2015 Target audience: Distributed via: Kaz Scott, Information Governance Manager Information Governance Sub Committee LCHS Website / Intranet 1
Version Lincolnshire Community Health Services NHS Trust SMS Text Messaging to Service Users Policy Section/Para/Appendix Version Control Sheet Version/Description of Amendments Date Author/ Amended by 1 New Policy Feb 2011 Kaz Scott 2 Minor amendments throughout. Amendments to mirror organisational changes, links updated. Updated EIA Referenced to align to IG policies. July 2014 Kaz Scott 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 2
Lincolnshire Community Health Services NHS Trust SMS Text Messaging to Service Users Policy Contents i) Version Control Sheet ii) Policy Statement 4 Introduction 5 Purpose of the Policy 5 Use of SMS 5 Key Points of the Policy 6 Consent 6 Risks 7 Equality Impact Assessment 7 Audit and NHSLA Monitoring 7 Appendix 1 Consent Form Appendix 2 Equality Impact Assessment 8 9 References 10 3
Lincolnshire Community Health Services NHS Trust SMS Text Messaging to Service Users Policy Policy Statement Background Short Message Service (SMS) is an easy to use, standardised, mobile communications service for the exchange of short alphanumeric text messages, usually between mobile telephone devices and can also be sent from, but not to, NHSmail accounts (*.nhs.net). This policy conforms to current legislation and other Organisational policies: Clinical Records Management Policy Data Protection and Confidentiality Policy Risk Management Strategy Information Risk & Privacy Impact Assessment Policy E-Mail Policy and Procedure Incident Reporting Policy Statement Responsibilities Training Staff working for the Trust will ensure that they comply with the requirements of the Data Protection Act and safeguard the confidentiality of any personal information which is held. All staff have a responsibility for maintaining confidentiality and handling information appropriately in accordance with this policy. All staff are responsible for their own actions and must maintain an up-todate awareness of legal and ethical issues concerning the subject. Dissemination This policy will be published on the Trust website Resource implication None. 4
1 Introduction The Organisation supports the use of Text Messaging (or SMS - Short Message Service) as a means of communication, subject to compliance with this policy. A user in this policy is an NHS employee or any other person working for or on behalf of the organisation. Although the basic principles of SMS have been available for a number of years, it is recognised that it is an ever-growing technology. Accordingly, this policy will be reviewed at least annually and users should ensure they follow the most recent version of the policy, which will available on the Organisation s Website. 2 Purpose of the policy This Policy sets out the circumstances in which service users may be contacted by SMS / Text Messaging and the procedures that must be followed when using this method of communication. Services must individually agree the need/benefit of using SMS and formally approve and document the implementation of the service. Individual users must not use SMS for healthrelated purposes without formal documented approval. Local/departmental procedures for the use of SMS, which comply with this policy, must be documented and cover the following topics Identification of the need or justification for the use of SMS Identification of the service or facility to be provided The agreement to the use of the service by its intended beneficiaries/recipients Clear identification of the associated risks and of the means by which these risks are managed Storage and retention procedures (in particular, patient messages or important Organisation messages 3 Use of SMS SMS can be used for a number of purposes to send individual clients/patients appointment reminders to broadcast messages to a wide-ranging audience, for example, as a health promotion exercise to support a lone worker messages to Staff and Team Members to assist staff movements/shifts Advantages of using SMS to communicate with service users are: Quick and easy communication without delays Reduced postage costs Reduced possibility of communications going astray through incorrect postal addresses, changing addresses of service users etc Ability to send appointment reminders to reduce DNAs 5
4 Key points of the policy SMS or text messaging is an attractive technology for quick communication of short messages and is a widely accepted form of communication. Service users therefore increasingly expect the Organisation to communicate with them in this way for simple transactions such as appointment reminders. The Organisation endorses the use of SMS to communicate with service users provided this is for simple communications such as appointment reminders, and provided strict Organisation protocol (outlined below) is followed when sending messages. Only = mail accounts must be used when sending out appointments or reminders. This means that teams / services must either set up a generic (team account) or individual nhs.net email account prior to sending SMS messages to service users A generic email account is one that refers to a service or function rather than an individual e.g. LHNT.reminders@nhs.net Explicit informed consent should be gained from service users prior to any SMS messaging taking place SMS messaging must not be used for sensitive personal information such as test results or discharge summaries. It must be used only for appointments and other nonsensitive information Under NO circumstances whatsoever should any type of person identifiable patient or staff data be transmitted via SMS Confidential business information should not be transmitted via SMS 5 Consent Where patients or members of the public are the intended recipients/beneficiaries of a healthrelated service, they must consent to this. Informed Consent is gained from the service user prior to the commencement of SMS messaging taking place and potential benefits and risks should be explained before deciding on whether or not to participate. This could be achieved at the time of recording a mobile phone number. Retrospectively, this must be done by making contact with the intended recipient before initiating the service for that person. Consent should be recorded electronically within the clinical system used e.g. SystmOne (S1) and templates exist where an option can be selected to confirm patient has consented to receive SMS Text Messages. Where it is not possible to record within the system, a consent form (Appendix 1) must be signed and where possible, scanned into the record or stored securely onsite ensuring there is a file note relating to the patient s consent. Service Users may withdraw their consent to receive SMS messages at any time by informing their Health Professional. Disciplinary action may be taken against individuals who: Send messages from any email account other than an nhs.net account specifically approved for this purpose. 6
6 Risks The risks associated with this technology will vary according to the outcome the user is seeking to achieve. A Privacy Impact Assessment (PIA) should be completed prior to the implementation of the service. In areas where it is felt that risks are unacceptable, the service must not be implemented. The following risks must always be taken into account - Confidentiality risks can be mitigated to a large extent by only sending non-sensitive messages and by never sending sensitive data such as - your next ante-natal appointment is... With particular regard to patients/clients, this must be the primary concern of users. The following points must be addressed Ensuring delivery to the correct recipient (i.e. the safe haven principle; the sender must be sure that the phone number being used is that of the intended recipient being aware that phones are regularly changed, exchanged or sold) Theft of the recipient s phone If a service wishes to contract with an external provider of SMS Text Messaging, it must seek approval from Information Governance and ensure all contractual and security measures are in place before any agreement takes place. 7 Equality Assessment Text messaging can undoubtedly be of benefit to recipients, for example, those with hearing impairment or those who would benefit from appointment reminders. However, this policy cannot address every issue that may arise from the use of SMS and an Equality Impact Assessment has been completed. 8 Audit & NHSLA Monitoring Auditing procedures will be established by Information Governance, in collaboration with the Information Governance Sub Committee (IGSC), to ensure; The service does not create problems or difficulties for the Organisation or for patients An Owner or Local Organisation Administrator (LOA) of the NHSmail account should monitor activity, assess risks and audit the effectiveness of the service Risks are identified, regularly re-assessed and adequately addressed The service is providing good value to the Organisation and to users Confidentiality is not put at risk Policy will be reviewed at least annually Minimum requirement to be monitored Process for monitorin g e.g. audit Responsible individuals/ group/ committee Frequency of monitorin g/audit Responsible individuals/ group/ committee (multidisciplinary) for review of results Responsible individuals/ group/ committee for development of action plan Responsible individuals/ group/ committee for monitoring of action plan IG Toolkit Standards Review / Audit / Reports IG Manager Annual IG Manager / IGSC IG Manager / IGSC IG Manager / IGSC 7
APPENDI 1 CONSENT FORM FOR USE OF SMS TETING Consent to receive appointment reminders by SMS text message APPOINTMENT REMINDER BY TET (Example) We will get in touch with you approximately 2 weeks before your appointment is due. The text will not identify the sender and will read as follows: Appointment reminder: Date and time Please let us know if your phone is lost, stolen or you have changed your number Thank you The health practitioner may wish to contact you by SMS Texting to remind you about a forthcoming appointment. I agree to the service communicating with me by Short Messaging Service (SMS or Text). I confirm that the mobile number the service holds on my record is correct and I will notify them of any changes. I agree to receive a reminder of my appointment by SMS. I am aware that I can withdraw consent at any time by informing the Health Professional either verbally or in writing. NHS Number:.. DOB:.. (To be completed by Health Professional) (Name)... Signature:... Consent obtained by: (Name):... Specialty;... Signature:... 8
APPENDI 2 Equality Analysis A. B. C. D. Briefly give an outline of the key objectives of the policy; what it s intended outcome is and who the intended beneficiaries are expected to be Does the policy have an impact on patients, carers or staff, or the wider community that we have links with? Please give details Is there is any evidence that the policy\service relates to an area with known inequalities? Please give details Will/Does the implementation of the policy\service result in different impacts for protected characteristics? To provide a framework for SMS Text Messaging for Service Users. To provide clear and effective management and accountability structures, governance processes, documented policies and procedures. All Staff and Service Users No No Disability Sexual Orientation Sex Gender Reassignment Race Marriage/Civil Partnership Maternity/Pregnancy Age Religion or Belief Carers Yes If you have answered Yes to any of the questions then you are required to carry out a full Equality Analysis which should be approved by the Equality and Human Rights Lead please go to section 2 The above named policy has been considered and does not require a full equality analysis Equality Analysis Carried out by: Kaz Scott Date: 14th July 2014 No 9
References Use of SMS text messaging to improve outpatient attendance http://www.ncbi.nlm.nih.gov/pubmed/16201955 RCN Use of Text Messaging Services http://www.rcn.org.uk/ data/assets/pdf_file/0003/450246/004_230_using_text_messaging_v2. pdf 10