Online Newsletter Subscriber Privacy and Email Use Policy

Organization: Holton Community Hospital
Department Responsible: Marketing & Communications
Effective Date: 06/24/2026
Last Reviewed: 06/24/2026
Review Cycle: Annually, or sooner if legal, technology, vendor, or workflow changes occur.

1. Purpose of the newsletter privacy policy

Holton Community Hospital respects the privacy of individuals who choose to subscribe to our online newsletter. This policy explains how we collect, use, store, protect, and manage the names and email addresses provided through our online newsletter subscription form.

The newsletter is intended to share hospital news, community health education, event information, service updates, provider announcements, and other general information related to Holton Community Hospital and its role in serving the community.

2. Information We Collect

For the online newsletter subscription, Holton Community Hospital will collect only the information needed to manage the subscription:

• First and/or last name

• Email address

• Subscription status, such as active, unsubscribed, or bounced

• Basic email delivery information, such as whether an email was delivered, opened, or clicked, if provided by the email platform

Holton Community Hospital will not request, collect, or store medical record information, diagnosis information, insurance information, Social Security numbers, financial information, or other sensitive personal information through the newsletter signup form.

3. Voluntary Subscription

Subscribing to the Holton Community Hospital online newsletter is voluntary. Individuals may subscribe through the online signup form or another approved opt-in process managed by Holton Community Hospital.

Holton Community Hospital will not add individuals to the newsletter list based on patient status, appointment history, service-line use, diagnosis, billing records, medical records, or other protected health information.

4. How Subscriber Information Is Used

Subscriber names and email addresses may be used only for the following purposes:

• Sending the Holton Community Hospital online newsletter

• Sharing hospital news, events, health education, and community updates

• Managing subscriptions, preferences, bounced emails, and unsubscribe requests

• Reviewing general newsletter performance, such as open rates and click activity

• Improving the clarity, accessibility, and usefulness of newsletter content

Subscriber information will not be used to make medical decisions, provide clinical care, determine eligibility for services, or target individuals based on private health information.

5. Healthcare Privacy and Protected Health Information

The newsletter subscription list is not intended to collect or use protected health information. Holton Community Hospital will keep newsletter subscriber information separate from patient medical records and will not use patient records to create or segment the newsletter audience.

Newsletter content should remain general in nature. Staff must not send newsletter content that identifies a patient, reveals a patient relationship with Holton Community Hospital, references a person’s diagnosis or treatment, or includes a patient story, image, testimonial, or other identifiable information unless all required written permissions and HIPAA authorizations have been obtained and reviewed through the appropriate approval process.

6. Email Consent and Unsubscribe Rights

Every newsletter email will include a clear way for recipients to unsubscribe or opt out of future newsletter emails.

Unsubscribe requests will be honored promptly and in accordance with applicable law. Once a person unsubscribes, Holton Community Hospital will not continue sending newsletter emails to that address unless the individual later chooses to resubscribe.

Newsletter emails will include accurate sender information, a truthful subject line, and Holton Community Hospital’s valid physical mailing address.

7. Sharing and Selling of Subscriber Information

Holton Community Hospital will not sell, rent, trade, or share newsletter subscriber names or email addresses with outside organizations for their independent marketing purposes.

Subscriber information may be shared only with approved service providers that help Holton Community Hospital manage email delivery, subscription preferences, analytics, security, or related newsletter operations. These service providers must be reviewed and approved according to Holton Community Hospital’s vendor, privacy, security, and compliance processes.

8. Email Platform and Vendor Requirements

Any third-party email platform used to manage newsletter subscriptions must be reviewed before use. At minimum, the platform should provide appropriate administrative access controls, unsubscribe management, data export and deletion options, security safeguards, and reasonable privacy protections.

If the newsletter process, email platform, website form, tracking technology, or any related workflow may collect, receive, maintain, transmit, or disclose protected health information, the arrangement must be reviewed by the appropriate privacy, security, compliance, and/or legal personnel before implementation. A Business Associate Agreement may be required depending on the nature of the information involved and the services provided.

9. Access Controls

Access to newsletter subscriber information will be limited to workforce members and approved vendors who need access to perform assigned duties.

Staff with access to the subscriber list must use the information only for approved newsletter-related purposes. Subscriber lists must not be downloaded, copied, emailed, exported, stored on personal devices, or shared outside approved systems unless specifically authorized for a legitimate business purpose.

10. Data Retention

Holton Community Hospital will retain newsletter subscriber information only as long as needed to manage the newsletter, document subscription status, honor unsubscribe requests, comply with applicable requirements, and support legitimate business needs.

Unsubscribed email addresses may be retained in a suppression or unsubscribe list to help ensure the individual does not receive future newsletter emails unless they choose to resubscribe.

Subscriber information that is no longer needed will be securely deleted or deidentified when appropriate.

11. Security Safeguards

Holton Community Hospital will use reasonable administrative, technical, and physical safeguards to protect newsletter subscriber information from unauthorized access, loss, misuse, alteration, or disclosure.

These safeguards may include access controls, password protections, multi-factor authentication where available, staff training, vendor review, secure data handling practices, and periodic review of user access.

12. Tracking, Analytics, and Cookies

Newsletter emails and signup pages may use limited analytics to understand general engagement, such as email opens, clicks, delivery status, and subscription activity.

Holton Community Hospital will not use newsletter analytics to identify, infer, or target individuals based on medical conditions, treatment history, patient status, or protected health information.

Any website tracking technology connected to newsletter signup forms must be reviewed to ensure it does not improperly collect or disclose protected health information or other sensitive information.

13. Individual Requests

Subscribers may unsubscribe from the newsletter at any time by using the unsubscribe link in the email or by contacting Holton Community Hospital.

Subscribers may also request that their name or email address be corrected or removed from the active newsletter list by contacting:

Holton Community Hospital
Roger Stockman, Director of Marketing & Recruitment

1110 Colombine Dr. Holton, Kansas 66436

roger.stockman@rhrjc.org

785-364-9660

14. Staff Responsibilities

Staff involved in newsletter creation, subscriber management, website forms, email distribution, analytics, or vendor management are responsible for following this policy.

Staff must report any suspected unauthorized access, improper disclosure, accidental sharing, or misuse of newsletter subscriber information according to Holton Community Hospital’s privacy, security, and incident response procedures.

15. Public Signup Form Privacy Notice

The following notice should appear near the newsletter signup form:

“By subscribing, you agree to receive email updates from Holton Community Hospital. We will use your name and email address only to send hospital news, health education, event information, and related community updates. We do not sell or rent newsletter subscriber information. You may unsubscribe at any time using the link included in our emails. Please do not submit medical questions, personal health information, or urgent health concerns through this form. For medical questions, contact your healthcare provider. For emergencies, call 911.”

16. Policy Review

This policy will be reviewed at least annually and whenever there are material changes to newsletter practices, email platforms, website tracking tools, privacy laws, security requirements, or Holton Community Hospital’s internal procedures.