TITLE: Personal Cell Phones & Other Personal Electronic Devices
REVISED: January 1, 2018

Using a personal cell phone or any other personal electronic device during work hours is not permitted. For purposes of this policy, “electronic device” refers to any device used to create, view, or send any electronic communications or other electronic information, including but not limited to: computers, laptops, tablets, digital cameras, video recorders, scanners, smartphones, cell phones, and pagers.

During non-paid lunch breaks the employee may use a personal cell phone or other personal electronic device only in a designated area determined by their supervisor.

The use of a cell phone or other personal electronic device will not be done in the view of residents, families, visitors or other employees during their working time.

Personal cell phones or other personal electronic devices are prohibited from being connected to the facilities’ Wi-Fi.

Personal cell phones or other personal electronic devices must either be turned off or placed on silent when not in use.

Employees who have access to their work e-mail from their cell phone are required to protect this information by using a security lock to prevent others from accessing this information. Swipe to open a cell phone is not considered a security lock.

Employees are absolutely prohibited from using personal cell phone or any other personal electronic devices in any way that would result in a family member, visitor or employee to be displayed in a negative manner.

Employees are absolutely prohibited from using personal cell phones or any other personal electronic device in any way that would violate HIPAA or otherwise disclose or compromise residents’ Protected Health Information (“PHI”). This includes but is not limited to the following:

• DO NOT use your personal cell phone or any other personal electronic device to post, upload, send, or otherwise share or disclose a photo or video of any resident without prior written permission of the resident or the resident’s authorized agent as required by applicable law. You must use Evergreen Estates’ authorization form to obtain such prior written authorization. This prohibition includes photos and videos where the resident is not easily identifiable (e.g., a photo of the resident’s hand, a close-up photo of any part of a resident’s body, or a photo of the back of a resident in the far background of the photo). It also includes photos or videos where the resident is easily identifiable, whether in the photo video itself or through a caption. This prohibition also includes photos and videos of residents participating in company-sponsored activities or events. When in doubt, assume that you do not have permission to share a photo or video of the resident. Keep in mind that the resident or the resident’s authorized agency may revoke the permission at any time, which could require you to destroy all such photos or videos, including where posted.

• DO NOT use your personal cell phone or any other personal electronic device to post, upload, send, or otherwise share or disclose the name of any resident (even if just the first name or a nickname) without prior written permission of the resident or the resident’s authorized agent as required by applicable law. You must use Evergreen Estates’ authorization form to obtain such prior written permission. When in doubt, assume you do not have permission to share the resident’s name. Keep in mind that the resident or the resident’s authorized agency may revoke the permission at any time, which could require you to destroy all such photos or videos, including where posted.

• DO NOT use your personal cell phone or any other personal electronic device to post, upload, send, or otherwise share or disclose any information about a specific resident, even without a photo, video, or name, that could allow any individual to identify the resident without prior written permission of the resident or the resident’s authorized agent as required by applicable law. You must use Evergreen Estates’ authorization form to obtain such prior written permission. This prohibition includes any resident’s age, biographical background information, unique medical condition, treatment or payment information, or other personal or identifiable information about a resident, whether alone or in concert with other information about the resident. This prohibition also includes any photos, videos, or other identifying information about the family members of any resident. When in doubt, assume you do not have permission to share the resident’s name. Keep in mind that the resident or the resident’s authorized agency may revoke the permission at any time, which could require you to destroy all such photos or videos, including where posted.