Bulletin Boards and Patient Photos/Notes
If you have bulletin boards in your area that you use to display notes from and photos of
patients and their families, please be reminded of the following:
- A photo sent by a patient may not be PHI, but once the photo is displayed -- in a cancer clinic or communicable disease clinic, for example -- it says to those who see the photo that the patient was likely treated for cancer or a sensitive condition. The more limited your clinic practice is, the more likely it is that posting a patient photo is disclosing PHI by making it possible for others to determine the general nature of the patientís treatment. This is also true if you post signed notes or cards from patients. (Remove PHI from notes by redacting the patientís name and other identifying information.)*
- Not all patients who send pictures and notes expect that you will post them where other patients will see them. Some are intended to be personal messages of thanks or greeting to particular staff members or clinics. You cannot legally assume that because a patient mails a photo or note, they want other patients to see it.
- The only way to be sure whether the patient intends for you to post a photo or note in a place where other patients will see it is to ask. The better your documentation, the lower the chance for any misunderstanding or complaint. This documentation should be made by having the patient complete our Authorization form.*
- If the purpose of your bulletin board is for staff morale, consider putting the bulletin board in a break room or other employee-only area that is not open to other patients.*
We are proud of our patients and like to share our successes. We need to be certain that our desire to share, however, doesnít infringe on any patientís desire for privacy. Patients will appreciate being asked, and we can be sure we have done the right thing.
*It is up to each HCC to have its own procedures, consistent with these guidelines and HIPAA, for posting patient photos and notes. Please consult with your clinic manager if you are unsure of your areaís procedures. Clinic managers who have questions about establishing procedures should contact their supervisors or may call Jill Raines.