Our Third-Party Content Policy
We value the significant role third-party content can play in real patients’ journeys. Providing patients with relevant health information supports conversations with their care teams. This knowledge helps individuals play an active role in healthcare decision-making.
Phreesia always follows the laws and regulations regarding third-party content. This policy provides more clarity about additional standards we set for third-party content and outlines how third-party content works on the Phreesia platform. As we build and serve all third-party content ourselves, we ensure third-party materials align with this policy, so our products and services meet the standards outlined below.
Basis of our policy stances
All third parties must adhere to all regulatory and legal standards for information shared with users via Phreesia. In addition, they must comply with expectations and standards outlined in contracts with Phreesia. (Please note: there may be third party links embedded in the content on our platform. This policy does not apply to the content off our platform that one can access via those links.)
We also rely on data, best practices, and recommendations from expert sources to inform certain policy items. Some of the expert sources we look to include:
- Regulatory bodies
- Research institutions
- Internal Review Boards
- Academic institutions
- Peer-reviewed journals
- Centers of excellence in healthcare
- Leading patient advocacy organizations
Phreesia has tried to outline as many stances as possible in this content policy; however, there will always be unique or new situations. In these instances, we look to experts for clarity and direction.
User choice to view third-party content
Phreesia’s software is designed to automate workflows before, during, and after a user’s visit with a healthcare provider. These workflows could include, but are not limited to:
- Scheduling an appointment
- Capturing relevant intake information from the user and sharing it with the provider
- Notifying the user via email or text that they have an upcoming appointment or preventive health screening due
Third-party content may appear after these workflows. Prior to displaying third-party content, users are presented with an Authorization Form. If accepted, Phreesia uses the information provided in these workflows to deliver relevant, personalized content. The Authorization Form requires the user to click an “Accept” or “Decline” button. Declining has no impact on a user’s healthcare treatment. Users who decline are not presented with third-party content.
When check-in has been completed and users have chosen to receive messages, they can interact with content as they choose. Users can leave third-party content at any time. If any outbound links are present in third-party content, a pop-up modal appears. The modal informs users they are leaving the content environment and are no longer subject to Phreesia’s policy protections.
Third parties receive engagement metrics for campaigns they sponsor in aggregate. No engagement data is ever shared with third-party sponsors at the individual level.
Participation in third-party research surveys
All research surveys for third parties fielded on the Phreesia platform begin with consent language. Consent language clearly indicates:
- The topic of the survey
- How much time is estimated to complete the questions
- If the user will be paid for participating
- That questions are not being asked by their Provider
- That responses will not be shared with their Provider
- How survey responses may be used
- That all surveys are entirely voluntary and can be declined
If a user agrees to participate, all questions within surveys present users with the option to “decline to answer.” This allows users to complete surveys without providing information for all questions.
Users can also leave surveys at any time, from any screen. Some surveys offer users additional information or research opportunities. If interested, they can provide their contact information for follow-up. Alternatively, users can decline such additional engagement. As mentioned previously, third-party sponsors do not receive survey answers at the individual level; however, they may receive individual contact information if the individual requests that such information be shared with the sponsor.
Follow-up information and communications
Third-party content often allows users to opt in for additional information or communications. Users can decline to receive additional information or communications from any content. Unless users have specifically and affirmatively consented, they do not receive any additional information from third parties. We do not believe in the use of dark patterns or intentionally deceptive design practices. We want users to understand their choices and be free to choose to receive additional information if they want it. That is why we require a user to take multiple actions at different points to request more information.
To receive any additional information, users must first add their contact information. This is done either by typing it in or selecting to use an auto-fill feature and confirming the information. They must then provide an additional consent and submit their contact information.
Users must provide additional consent to receive any ongoing correspondence from third parties. This consent specifies that third-party privacy rules will take effect for such ongoing communications from the third party.
There may be third-party links within the content on our platform. In these situations, a clear disclaimer informs users that the link’s destination is not covered by or subject to Phreesia policies. If any outbound links are present, a pop-up modal appears that informs users they are leaving the content environment and are no longer subject to Phreesia’s policy protections.
Matching audiences to content
We support the autonomy, agency, and privacy of individuals using our platform. We also believe users should have access to personalized information that is clinically relevant to them. We recognize that personalization needs to be treated with respect and diligence. When done thoughtfully, we believe it supports better health outcomes.
Users must always agree to the authorization described above before they can see any third-party content. After that, there are two ways users who consent can access third-party content:
- Individual users may select messages themselves from a menu screen that shows multiple content options
- Phreesia may match relevant messages to individual users
There are certain ways Phreesia does not match a user to third-party content, including:
- Content is not delivered to audiences younger than 18 years old. Content can be designed to be shown to a parent or caregiver of a minor.
- Content is not delivered to audiences with cognitive impairments. Content can be designed to be shown to a care partner or caregiver.
- We will only allow for the segmentation of content in ways that align with our values, as determined by Phreesia in its sole discretion at any point in a campaign’s development process.
- We do not support geolocation-based audience parameters or geofencing, or audience parameters that rely on pixels, cookies, or similar technologies. We do not permit practices that allow third parties to identify patients in our network without appropriate safeguards in place.
- We do not match content to audiences based on individuals’ income or credit worthiness.
- We do not match content to audiences using social security numbers or equivalent identifiers.
- We exclude pregnant women, when possible, from being matched to several types of content (e.g., weight loss content).
- We never support messaging to audiences based on historical or potential future abortions or miscarriages.
- We do not match content to audiences based on the contents of psychotherapy notes, or based on records of child abuse or neglect, or intimate partner violence.
Standards for third-party content shared on our platform
There are some types of content that are incompatible with our goals. We do not present users with content:
- That promotes the use of substances, products, or supplements that contribute to harming the health and safety of the public. These are determined by Phreesia in its sole discretion and based on its review of clinical guidelines, as well as publicly available safety and efficacy data. We do not show third-party content about:
- Opioids for acute or chronic pain conditions
- Tobacco products and related paraphernalia. This includes electronic cigarettes, vaporizers, or any other products that simulate smoking.
- Weapons and related items. This includes ammunition, explosives, and weapon modification accessories.
- Other unsafe substances, products, or supplements that contribute to harming the health and safety of the public.
- That discourages vaccination or advocates against vaccines.
- That advocates against any reproductive healthcare choices.
- That promotes eating disorders. Content about recovery from, or research about, disordered eating always features an interstitial disclaimer. This allows users to opt out of viewing it. It also includes national helpline information with instructions for use for any users who may need it.
- That presents solicitations for financial contributions from users of any kind. This includes requests for credit card or other payment information.
- Partisan advertisements for or from political candidates.
- That requests a social security number or equivalent identifier.
- Nonpartisan civic engagement content is allowed if it is health-focused (e.g., “You can vote on this healthcare item on this date.”)
- That presents out-of-date or inaccurate medical information. This extends to information that contains deceptive, false, or misleading claims.
- Resources to increase health, media, and digital literacy are available. These can help users better identify inaccurate information they may encounter on other channels.
- That promotes a non-existent or fake product or service offering.
- That contains unsubstantiated claims about a competitive product, service, or offering.
- That contains assertions or implications of a user’s personal attributes. This includes direct or indirect assertions or implications about a person’s race, ethnicity, religion, beliefs, age, sexual orientation or practices, gender identity, disability, physical or mental health (including medical condition), vulnerable social needs, family structure, etc.
- That promotes suicide or self-injury.
- Content about recovery, or research about suicide or self-injury, always features an interstitial disclaimer. This allows a user to opt out of viewing it. It also includes national helpline information with instructions for use for any users who may need it.
- That implies support or recommendation from providers in our networks or any groups other than the third party. This extends to the use of other copyrighted logos or brand names without consent. In addition, all third-party content must clearly display the supporter of the content.
- That contains profanity or bad grammar and punctuation.
- Colloquial language may be used in accordance with health literacy best practices.
- That contains content that is disparaging of any race, ethnic group, religion, creed, sex, gender, sexual orientation, or other class of person.
- That contains depictions of people in sexually explicit or suggestive positions. This includes activities that are overly suggestive or sexually provocative. Nudity is occasionally allowed for the purposes of medical clarity and accuracy at Phreesia’s sole discretion.
- That otherwise would be likely to be offensive to a reasonable person in the context of a healthcare engagement.
- For non-therapeutic cosmetic procedures. It is Phreesia’s sole discretion as to whether content is allowed.
It is the responsibility of third-party content sponsors to understand and comply with all relevant laws and regulations. Failure to comply may result in the cancellation of agreements. Phreesia will not knowingly disseminate content that does not comply with the third party’s own legal obligations. Please consult the institutions noted above for more information about content considerations.
Feedback on content
We carefully consider feedback on content from users and providers. If content is found to be offensive by what Phreesia deems too many users or providers in the Phreesia network, we will:
(a) modify audience parameters and associated guarantees, or
(b) provide free creative services to update campaigns.
About this policy & future updates
Interpretations of this policy and how specific content does or does not align with this policy are at the sole discretion of Phreesia. This policy is subject to change at any time without prior notice. Changes to this policy will be posted to Phreesia’s webpage.
LAST UPDATED: 11/21/23