COMMUNICATIONS POLICY
Updated 3.16.2021

Purpose & Definition

    1. The Brain Injury Network of Dallas strives to advance its mission by communicating openly and honestly using consistent messages with its constituents, the general public, and the media. It is important for all BIND staff, volunteers and Board Members to reinforce these messages by referring all calls/inquiries from any source to the appropriate staff.  Communication policies are established to ensure consistency of message and establishes the chain of command for handling inquiries and clarifies the communication process.
    2. In regards to use of social media, BIND employees and volunteers are encouraged to interact and be a part of social media communities where BIND is present. As one is participating in these social networks, you represent BIND.  Technology increases the opportunities for better communications but introduces a new set of risks related to electronic media.
    3. In every organization there is the possibility of crisis, internal or external. The nature of that crisis, its origin, and its potential impact will determine how the organization responds.  Potential crises should be identified before they happen, with overall processes to set in motion when necessary.  A crisis communication policy is intended to help the Board, volunteers and staff act swiftly and consistently under stressful circumstances.  Having a plan and following it is essential in minimizing or avoiding negative effects.
    4. “Copyright” refers to the legal right of the owner of intellectual property. “Intellectual property” is a work or invention that is the result of creativity, such as a manuscript or a design, to which one has rights and for which one may apply for a patent, copyright, trademark, etc. As related to the Brain Injury Network of Dallas, the logo and any BIND-created alteration and production of logo elements are the property of the organization and must be used consistently across all platforms that intersect with the general public.
    5. A BIND website will be established and maintained to provide access to member services and information to the general public. The website will be updated on a regular basis. Information and updates will be posted by the Executive Director or by designated employees or volunteers after training and/or approval from the Executive Director.

Scope

Without expiration, all employees, volunteers, student interns and Board Members across all locations and situations will be required to follow communication policies and procedures.

Policy and Procedure Related to Intellectual Property and the BIND Privacy Policy:

        1. Intellectual Property
          1. Use or alteration of any BIND-created image, logo, artwork or photography must be discussed with and granted as permissible by the Executive Director or the Development Director. Any such resulting image or product using the BIND logo, whether in whole or in part, must be formally approved by either the Executive Director or Development Director prior to distribution or publication on any printed, electronic, or tangible item or if used or shared on any social media platform whether owned and managed by BIND or otherwise. If either the Executive Director or Development Director are not available and the approval is time-sensitive, the Board of Directors must provide permission.
        2. The BIND Website
          1. The contents of all materials contained on the BIND website are owned by the organization (unless otherwise indicated) and are protected by copyright laws. All rights are reserved by BIND, and visitors may not copy, reproduce, download, upload, republish, disseminate, post, distribute, or transmit by any means the contents of the website, except with the expressed permission of BIND.
          2. The information contained on BIND’s website is provided by the organization for general information purposes. None of the information on the website is intended or should be construed to be legal or medical advice or a legal or medical opinion unless the content is produced by a licensed professional providing such services who is an approved partner of the Brain Injury Network of Dallas. While every effort has been made to ensure that the information contained on the website is as accurate as possible, omissions and errors may occur. BIND and its contributing authors expressly disclaim all liability to any person with respect to the consequences of any act or omission committed based upon reliance, in whole or in part, on any of the contents of the website.
          3. At certain places on the website, live links to other Internet addresses/third-party sites can be accessed. Such third-party sites contain information created, published, maintained, or otherwise posted by institutions or organizations independent of BIND. BIND does not endorse, approve, certify or control these third-party sites and therefore cannot guarantee the accuracy, completeness, efficacy, timeliness, or correct sequencing of information located at such addresses. Reference therein to any specific product, process, or service by trade name, trademark, service mark, manufacturer, or otherwise to partners of BIND is made in good faith. However, use of the BIND website and further use of third-party sites is at the risk of the website visitor and the website visitor assumes full responsibility for all consequences that arise out of use.
          4. BIND respects the privacy of each visitor to the BIND website. BIND reserves the right to use cookies or other tools for the purpose of de-identified analytics. Any personal contact information or protected health information provided to BIND through the website will be used solely by BIND for internal purposes. Further, personal contact information and protected health information is securely stored by BIND through numerous password-protected layers accessible only to fully trained BIND employees, a designee the Board of Directors, or other fully trained designees named by the Executive Director.
          5. Personal information provided via the BIND website will be shared only with third-party service providers who perform functions on our behalf, including processing credit card payments, event registration or other customer services (i.e. PayPal, Event Brite, Race Roster, Bid Pal). Personal information will not be sold to any entity by BIND.

3. Contact Information Including E-Mail, Phone, Fax and Physical Addresses

            1. Through engagement with BIND, individuals (donors, volunteers, employees, program members, community members, family caregivers) are establishing a business relationship with BIND and are authorizing the use of e-mail addresses, physical addresses & phone numbers as they are provided to the organization by its employees or fully trained volunteer designees.
            2. BIND may use contact information for communication and promotion of BIND events, meetings, programs, products and services, unless specifically instructed otherwise by an individual.
            3. BIND will provide recipients of all mass e-mail or phone/text communications the opportunity to unsubscribe from distribution lists.
            4. Any personal contact information provided to BIND will be used solely by BIND for internal purposes, and, where appropriate, to contact individuals directly. Personal information will not be sold. Personal information will be shared only with third-party service providers who perform functions on our behalf, including processing credit card payments, event registration or other customer services (ie PayPal, Event Brite, Race Roster, Bid Pal).

CONFIDENTIALITY POLICY
Updated 4.16.2020

Purpose & Definition

Confidentiality is defined as “the preservation of privileged medical, financial, demographic, situational or other personal information.” Employees, volunteers, student interns and Board Members of BIND: Brain Injury Network of Dallas may be exposed to information that is confidential or privileged and proprietary in nature. Respecting the privacy of our members, employees, donors, student interns, volunteers and members of the Board of Directors at BIND: Brain Injury Network of Dallas itself is a basic value of the organization.

Scope

Without expiration, all employees, volunteers, student interns and Board Members across all locations and situations will be required to follow confidentiality policies and procedures.

  1. Policy
    1. Personal, medical, demographic, situational and financial information is confidential and should not be disclosed or discussed with anyone without permission or authorization from the person in question. Volunteer, employee, donor, student intern and member information must be kept confidential both during and after service or relationship with the organization.
    2. Confidential information may be shared with authorized persons, agencies or other care providers with the permission of the person in question and/or in the event of emergency medical situations in which the person in question is unable to grant such permission.
    3. Confidential information may be shared with a member’s designated emergency contact by the Executive Director or by a trained designee of the Executive Director for the purpose of providing pertinent information about a member’s physical, emotional, behavioral, employment or cognitive status. Every attempt possible will be made to store written documentation of such communication at the BIND location.
    4. Unauthorized disclosure of confidential or privileged information is a serious violation and will subject the person(s) who made the unauthorized disclosure to appropriate discipline, including an immediate warning or termination. Providing confidential information to an unauthorized person could result in the agency’s refusal to support you in the event of legal action. Violation of the state statutes regarding confidentiality of records is punishable upon conviction by fines or by imprisonment or by both.
    5. Any actual or suspected breach of confidential information, including but not limited to Texas Workforce Solutions, Texas Workforce Commission, Texas Health and Human Services, any local or county municipality or protected governmental agency information will be reported to the appropriate agency/regulatory authority in accordance with respective applicable laws or contracts.
    6. Training will be provided annually, at minimum, to BIND employees (and any applicable volunteers) and training completion will be subsequently documented in regards to confidentiality/privacy/security practices, data usage, ethics, lobbying, compliance, and reporting. Training will be provided in advance of accessing or using any protected government information/systems, or, within 30 days of hiring a new employee who will handle Texas Health and Human Services confidential information. Texas HHS training must include:
      1. Privacy and security policies, procedures, plans and applicable requirements of handling Texas HHS confident information
      2. A requirement of complete training before access is given to Texas HHS confidential information and
      3. Written proof of training and a procedure for monitoring timely completion of training.
  1. Procedure:
    1. Forms containing privileged and private employee, volunteer, donor, student intern, or member information will be reviewed, processed and maintained by the Executive Director or by a properly trained designee of the Executive Director.
    2. Employee, student intern and volunteer forms will be stored in private, individual files in the office of the Executive Director, Program Director or other designated BIND representative and access to such files will be limited to a properly trained designee of the Executive Director. An employee, student intern or volunteer is able to review their own file at any time requested.
    3. Any and all electronic copies of all or a portion of employee, volunteer, student intern, or member form will be maintained by the Executive Director or by a properly trained designee of the Executive Director and stored under password protection.
    4. Care shall be taken to ensure that unauthorized individuals do not overhear any discussion of confidential information regarding employees, student interns, volunteers, donors or members and that documents containing confidential information are not left in the open or inadvertently shared.
    5. In public BIND facility spaces (i.e. member mailboxes, daily work assignment boards, sign-in sheets), in print media, educational, training or other similar marketing venues, employees, student interns, volunteers and members will be identified by their first name only unless consent to use a person’s last name is provided.
    6. In the event of a medical emergency, privileged employee, student intern, volunteer or member information will be provided to emergency medical technicians at their request or at the time of necessary hand-off to an emergency technician.
    7. Care will be taken to completely conceal any written documentation of an employee, student intern, volunteer or member’s social security number on forms maintained at the Clubhouse premises. BIND members are not encouraged to provide their social security number on any written forms unless required by a government agency with a contractual relationship with BIND.
    8. Employees, student interns, volunteers and board members will return or destroy materials containing privileged or confidential information at the time of separation from employment/service or at any time requested by the Executive Director, Program Director or other designated BIND representative.
    9. Any assumed or verified violation of this policy will be fully documented and will be stored by the organization permanently. Further, any assumed or verified violation of this policy will be fully described and reported to any applicable government agency with whom BIND has a contractual relationship.
    10. BIND employees will be required to change user passwords at least every 90 calendar days and are further prohibited from creating weak passwords for any computer systems that access or store Texas Health and Human Services or related government agency confidential information. In this case, passwords must have 8 characters with a combination of upper case letters, lower case letters, special characters, and numerals, where possible.
    11. BIND employees who remotely access Texas Health and Human Services or any related government agency confidential information must secure, manage, and encrypt systems or devices used and must be granted valid access to perform work duties remotely by the Executive Director, Program Director, or designated BIND representative.
    12. Encryption is required for all Texas Health and Human Services confidential information, HIPPA data, criminal justice information services data, IRS federal tax information data and Centers for Medicare and Medicaid services data. Encryption is required for any information transmitted over a public network such as wifi/internet.
    13. Refer to BIND Policy and Procedures for Financial Management for confidential, storage and privacy issues specifically related to donor information.