A subject line can be considered protected health information (PHI) if it contains any information that can identify a patient or relates to their health status, treatment, or diagnosis. For example, a subject line like "Results of your recent lab test" could reveal sensitive information about a patient’s health, thus making it PHI under HIPAA regulations.
While subject lines are usually short, they can sometimes inadvertently disclose information that should be kept confidential. This is particularly true when dealing with healthcare-related email communications.
Related: HIPAA compliant email: the definitive guide
Understanding protected health information
The HHS defines PHI as "all "individually identifiable health information" held or transmitted by a covered entity or its business associate, in any form or media, whether electronic, paper, or oral." HIPAA mandates robust protection for PHI to ensure patient confidentiality and prevent unauthorized access or breaches.
Related: What is protected health information (PHI)?
Email marketing in the healthcare context
Email marketing can be used to disseminate health-related information, share appointment reminders, and promote wellness initiatives. However, when engaging in email marketing, healthcare organizations must balance effective communication and the ethical obligation to safeguard patient privacy, navigate regulations, and maintain compliance concerning PHI.
Related: HIPAA compliant email marketing: what you need to know
How to encrypt subject lines for HIPAA compliance
When incorporating PHI into subject lines, the safest process is encrypting all emails by default. Paubox provides a seamless solution by automatically encrypting all emails, including the subject line. That means that all components of the email, from subject lines to the body content and even attachments containing PHI, are secured to meet HIPAA standards.
A recent study, titled Human Factors in Electronic Health Records Cybersecurity Breach: An Exploratory Analysis, found that most data breaches in healthcare are caused by human error. This automatic process mitigates the risk of human error and simplifies the experience for recipients, who can access the information without needing special software or taking additional steps.
Why subject lines matter
Subject lines are the gateway to an email's content. They often determine whether an email is promptly opened or relegated to digital obscurity. In healthcare email marketing, crafting the subject line becomes an art of precision - capturing attention while upholding confidentiality.
Crafting effective subject lines in healthcare email marketing
- Avoid specific medical details: Steer clear of overt references to medical conditions, treatments, or procedures in subject lines.
- Emphasize general health and wellness: Opt for subject lines that pivot around broader health and well-being themes, maintaining a comfortable distance from divulging specific medical aspects.
- Highlight benefits and value: Subject lines should be structured to underscore the benefits recipients can derive from opening the email. This could encompass insights into maintaining a healthy lifestyle, managing stress, or even updates on preventive care measures.
- Maintain clarity and honesty: They should provide a truthful glimpse into the email's content without employing sensationalism or misleading language.
Compliance and ethical considerations
The realm of healthcare mandates compliance with regulations such as HIPAA. While the subject line might not overtly include PHI, the potential for inadvertent disclosure underscores the necessity for meticulousness in crafting it.
In healthcare email marketing, subject lines are the threshold between engagement and privacy. While not overtly containing PHI, they can reveal, even unintentionally, sensitive information. Healthcare organizations must carefully craft their subject lines when engaging in email marketing.
FAQs
What are the risks of not encrypting subject lines in healthcare emails?
Unencrypted subject lines can expose sensitive patient information to unauthorized parties, increasing the risk of breaches and non-compliance with HIPAA.
Are there any specific guidelines for crafting subject lines for appointment reminders?
Yes, appointment reminders should use general language and avoid mentioning specific medical details, while ensuring the reminder is clear and actionable.
Can subject lines be used to communicate general health tips without violating HIPAA?
Subject lines can include general health tips or wellness information as long as they do not include personal health details or identifiers that could be considered PHI.
Liyanda Tembani
