Procedures - Use and Disclosure of Protected Health Information on Social Media Platforms

	LOS ANGELES COUNTY DEPARTMENT OF MENTAL HEALTH
	Policy 500.09 Use and Disclosure of Protected Health Information on Social Media Platforms
	PROCEDURES

A. Safeguards and Privacy Practices

1. All content posted on official department social media accounts must be reviewed and approved prior to publication.

a. Posting client PHI/PII is prohibited unless:

i. Privacy Officer has reviewed both the content that references client PHI/PII and a valid Authorization for Use and Disclosure of Protected Health Information is signed by the client and specifying the content to be posted and on which social media channels (DMH-602)

ii. Only the Public Information Officer or designee may post content on DMH social media accounts.

iii. The MH602 must include the following information (HIPAA §164.508):

• Description of the information to be used or disclosed.

• Description of the purpose of the use or disclosure.

• Client signature and expires once the content has been posted on social media.

B. Workforce members must ensure all privacy practices and safeguards are adhered to when posting PHI/PII and that it is reviewed and approved. Workforce members shall:

1. Verify that content does not contain PHI/PII or confidential organizational information.

2. Do not post images, videos, or screenshots from the workplace that reveal client PHI/PII, confidential information and client's person without signed documentation.

3. Ensure content is professional, appropriate, and non-discriminatory and aligns with the Department's Code of Conduct.

4. Submit all proposed social media content, including signed authorization to the Supervisor/Program Manager for review and approval. The Supervisor/Program Manager forwards approved content to the Public Information Office for posting to DMH social media accounts.

5. Do not post DMH-related content to personal or program-level social media accounts, including the Public Information Office (PIO) social media account and, the Director of DMH's official account (if applicable).

6. Retain documentation verifying posting approval to include:

a. Date and time of posting.

b. Name and title of approver.

c. Social media platform used.