Electronic Communication Policy (ECP)

The use of various types of electronic communications is increasingly common and many individuals prefer electronic methods of communication over other forms of communication, both in their personal and professional lives. However, many of these common modes of communication put your privacy at risk and the law and standards of the counselling profession require the protection of your privacy. This electronic communications policy (ECP) has been prepared to assure the security and confidentiality of your treatment, and to assure that it is consistent with professional ethics and the law.

This document is intended to clarify our use of electronic communication during your therapy. Please also see my Social Media Policy. Reviewing these policies (ECP and SMP) ill help you understand how your counselor will conduct themselves online as a mental health professional. It will also help you understand how you can expect them to respond to various interactions that may occur online. Providing you with this information helps you understand the benefits and limitations of electronic communication and helps ensure that you can give informed consent to such communication.

As new technology develops there may be a need to update this policy. Clients will be notified in writing of any policy changes, and a copy of the updated electronic communications policy will be provided upon request. It is important that as we communicate, we also protect the confidentiality that is vital to therapy.

NON-SECURE ELECTRONIC COMMUNICATION OVERVIEW

Email, text and other forms of electronic messages provide convenient methods of communication. Please be advised that these methods, in their typical form, are not confidential means of communication. Therefore, FCC prefers to use email communication and text messaging only with your permission, and only for administrative purposes unless we have made another arrangement. If you use these methods to communicate with your counselor or with the
practice, there is a reasonable chance that a third party may be able to gain access to those messages. The types of parties that may intercept these messages include, but are not limited to:

● Those who have access to your phone, computer, or other devices that you use to read and write messages
● Your employer, if you use your work email to communicate with us
● Internet server administrators and others who monitor Internet traffic

If there are people in your life that you do not want accessing these communications, please talk with your counselor about ways to keep your communications safe and confidential. Let your counselor know if you have any questions, comments, or concerns about this.

EMAIL

Email is not a confidential form of communication. Therefore, FCC chooses to not conduct counseling by email, and discourages the use of email communication between clients and counseling staff, except for administrative purposes, such as arranging or changing appointments and for forwarding links to articles, meditations, books and other resources to enhance your therapy.

There is still a possibility that your privacy may be compromised when appointment times and resources are sent electronically. Please read below for more information:

1. No form of encryption is used by the practice for outgoing emails.
2. The Family Counseling Center sends appointment reminders via email. If you do not wish to receive reminders via email, please inform your counselor of that preference.
3. Emails will generally be responded to within two business days (unless your counselor is unavailable and then the response time may be longer), and if a response has not been received within that time, you can call 931-723-0380 to leave a message for your counselor.
4. Emails are intended to be used for booking, rescheduling, or cancelling appointments and for links to resources to be made accessible to you for enhancing your therapeutic process. Should they be used inappropriately (for example to “chat” or to “access counselling support”), the emails will not be responded to and this may be discussed for clarification in your next session.
5. Please identify the purpose of emails, and their urgency, in the subject line (for example: “Question, Non-urgent”, or “Cancellation, request to Rebook- Urgent”)
6. Email messages become part of your counseling records and may be shared along with your record should the documents be subpoenaed by the courts or other governing agencies. If at any time emails contain information in which the counselor feels you or those in your care may be in danger, the counselor will be required to make a report as per the TN Mandated Reporter Statute.
7. You may revoke your consent for email communication at any time. You may discuss any questions or concerns with your counselor further in your next session.

ADDITIONAL STEPS TO KEEP EMAIL SECURE AND PRIVATE

If you use a secure email service that offers end-to-end encryption, your messages are difficult to get. There are still more precautions you can take:

1. Beware of keylogging software that captures what you type right from your keyboard – before the secure email encryption can protect it.
2. Safeguard your mobile devices and make sure they are protected with strong passwords and have no guest accounts or similarly unprotected access allowed.
3. Be vigilant of social engineering. Phishing attempts can be very cleverly designed to trick you into handing out personal details, information or even passwords.
4. Do not write down or share any passwords. Never make a note of the password that lets you decrypt secure emails you receive. Guard passwords to other email accounts or social networking accounts.

TEXT MESSAGING

The Family Counseling Center sends appointment reminders via text message. If you do not wish to receive reminders via text message, please inform your counselor of that preference. While this is an easy and convenient way to send communication, it is also not secure and you may want to consider the risks to your confidentiality surrounding your access to counseling services. Below is a list of potential risks associated with the use of text messaging:

1. Communication issues can arise when communicating in text due to the lack of access to visual or voice cues, as well as the possibility of limited space, and the chance of misunderstanding when using “shorthand” words or characters to represent meaning.
2. A lost or misplaced cell phone, or a phone simply left in an insecure location, can inadvertently communicate to others that you are in counseling.
3. Your identifying information will NOT be stored in your counselor’s phone. If you are texting your counselor please identify yourself in a way that your counselor will know who is sending the message.
4. Text messages are intended to be used for booking, rescheduling, or cancelling appointments and for links to resources to be made accessible to you for enhancing your therapeutic process. Should they be used inappropriately (for example to “chat” or to “access counselling support”), the messages will not be responded to and this may be discussed for clarification in your next session.
5. Typically, text messages will be responded to within two business days, unless your counselor is unavailable and then response time may be longer. If you are in a crisis do not text your counselor as they may not respond if out of the office, please go to the ER, call 911 or a local crisis line.
6. All text messages become part of your counseling records and as such may be subject to being shared along with your record should the documents be subpoenaed by the courts or other governing agencies. If at any time text messages contain information in which the counselor feels you or those in your care may be in danger, the counselor will be required to make a report as per the TN Mandated Reporter Statute.
7. You may revoke your consent for text message communication at any time. You are also welcome to discuss any questions or concerns with your counselor further in your next session.

THIRD-PARTY ACCESS TO COMMUNICATIONS

When you use electronic communications methods, such as email, texting, online video, etc., there are various technicians and administrators who maintain these services, and who could conceivably have access to the content of those communications.

If you use your work email to communicate electronically, your employer may access those communications. There may be similar issues involved in school email or other email accounts associated with organizations that you are affiliated with.

Furthermore, people with access to your computer, mobile phone, or other devices may gain access to your email or text messages. It is important to contemplate the risks involved if any of these persons were to access the messages exchanged with your counselor.

SHARING ELECTRONIC COMMUNICATION WITH OTHERS

If you wish to publicly reveal information related to your therapy through electronic communication with your counselor, it is requested that you consult with your counselor before doing so.

BETWEEN SESSION CONTACT

Between session contact with your counselor is normally limited to short messages regarding scheduling sessions. Longer contact is possible, by arrangement, and the charge will be prorated per your session fees. Phone calls lasting longer than 5 minutes or emails (or multiple emails) requiring more than 5 minutes to read will be considered as additional counseling services and billed accordingly.

COLLECTION AND STORAGE OF PERSONAL INFORMATION

Storage and collection of client information is in accordance with the Personal Information Protection Act (PIPA) and in accordance with professional guidelines.

EMERGENCIES

The Family Counseling Center is not nor do they provide emergency services. Please do not contact The Family Counseling Center as an emergency resource. If you are in crisis or require emergency mental health assistance please call 911, go to the emergency department of your nearest hospital, or contact a crisis line in your area.