SMS Privacy Policy

1. What this policy covers

This SMS Privacy Policy applies only to the text-message program operated by Empowered Services, Inc. (“we,” “us,” or “our”) and to people who have opted in to receive our SMS messages. Our general Privacy Policy & HIPAA Notice of Privacy Practices applies to all other personal information and protected health information (PHI) we handle.

2. Information we collect

• Mobile phone number — provided when you opt in.
• Consent record — the date, time, method, and exact wording shown when you opted in (web form, paper form during intake, keyword reply, or recorded verbal consent).
• Message interaction data — delivery status (sent, delivered, failed), responses (e.g., HELP, STOP), engagement counts, and program identifier.
• Aggregate analytics — non-identifying counts used to improve service.

We do not collect any other information solely through the SMS program.

3. How we use the information

• Send the messages you opted in to receive (appointment reminders, service updates, safety/care notifications, schedule changes, urgent alerts).
• Maintain TCPA, FCC, and CTIA compliance — including proof of consent and proof of opt-out.
• Operate, secure, and improve the SMS service through aggregate metrics.

We do not use SMS data for marketing or advertising, do not sell your number, and do not let any vendor use your number for their own purposes.

4. Consent & one-program rule

Consistent with the Telephone Consumer Protection Act (TCPA), FCC rules, and CTIA Messaging Principles, we obtain prior express written consent before sending any non-emergency SMS. Your consent applies only to communications from Empowered Services and is not shared with any third party. Consent is not a condition of receiving Empowered Services care, services, employment, or any other benefit.

5. SMS & protected health information

By opting in to SMS, you acknowledge the limitations above. We will use the minimum necessary information in any text. We will not send full PHI by SMS without a separate written authorization. Our SMS gateway operates under a Business Associate Agreement that meets 45 CFR 164.504(e).

6. Message frequency & carrier rates

Routine messages will not exceed five (5) per day. Frequency may temporarily increase for urgent care, safety issues, severe weather, or required regulatory notices. Standard message and data rates may apply depending on your mobile plan; Empowered Services is not responsible for those carrier charges. Mobile carriers can also block or filter messages — Empowered Services is not responsible for non-delivery caused by carrier filtering.

7. Opt-out, HELP, and STOP

8. Data sharing & vendors

We never sell or rent SMS data. We share information only with:

• Telecommunications carriers and our SMS gateway, solely to deliver messages and only under a Business Associate Agreement;
• Internal Empowered Services staff with a need-to-know;
• Government regulators or courts when required by valid legal process or by law (mandatory reporting, subpoena, audit).

If you are listed on the National Do Not Call Registry, we will not send you promotional SMS unless you have given us prior express written consent.

9. Security

We use industry-standard administrative, physical, and technical safeguards to protect SMS-related data, consistent with the HIPAA Security Rule (45 CFR 164.302–318). However, no system is perfectly secure; we cannot guarantee absolute security of data during transmission, particularly across mobile carrier networks.

10. Records, consent logs, and retention

Consistent with TCPA recordkeeping standards and CTIA Messaging Principles, we retain proof-of-consent and proof-of-opt-out for at least four (4) years. We retain message-interaction logs for twelve (12) months for compliance and troubleshooting, after which they are aggregated or destroyed.

11. Oregon Consumer Privacy Act rights

If you are an Oregon resident, you may exercise your OCPA rights — including access, correction, deletion, portability, and opt-out of sale or targeted advertising — with respect to SMS data by emailing info@empowered-services.org. Effective January 1, 2026, we honor universal opt-out preference signals where applicable. We will not sell SMS data of any consumer we know to be under 16.

12. Accessibility & language access

If text messaging is not accessible to you, we will use a voice call, large-print mail, or Oregon Relay (711) at no cost. Free interpreters and translated materials are available — call (503) 855-3581 or email info@empowered-services.org. We will not require you to bring your own interpreter and will not use minor children as interpreters.

13. Minors

We do not knowingly enroll a person we know to be under 13 in SMS without verifiable parental consent. For consumers known to be under 16, effective January 1, 2026, we will not sell SMS-program data and will not use it for targeted advertising.

14. Changes to this policy

If we materially change this policy we will text current subscribers and post the updated version with a new effective date at empowered-services.org/sms-privacy-policy/. Continued participation after a material change indicates acceptance.

15. Contact us