City of Knoxville – SMS/Chat Privacy Policy
Applies to: City of Knoxville Innovation & Technology, 311 City Services and 211 Social Services via SMS text messaging, web chat, and in app chat.
Effective date: April 1, 2026
Contact: 311 or 211;
[email protected],
EastTN211.org
1) What this policy covers
This policy explains how we collect, use, share, and protect information when you contact 311 or 211 by
text message or chat. It covers message content, phone numbers, opt in/opt out records, delivery/interaction logs, and limited device/network data associated with Messaging Services.
It does
not change how other City departments handle information gathered by phone, in person, or other websites/apps. For general 311/211 website or app privacy, refer to those pages separately.
2) Why we collect data (lawful purposes)
We collect only what’s reasonably necessary to:
•
Receive and process your requests for
city services, service status, and notifications (311). Provide
information & referrals to community and social services (211).
•
Operate, secure, troubleshoot, and improve the Messaging Services; monitor delivery, abuse, and spam filtering; and fulfill our reporting and quality assurance obligations Satisfy legal, safety, and records management requirements.
(See “Disclosures & safety exceptions.”)
3) What we collect
Depending on how you engage with us, we may collect:
• Identifiers: mobile number, first/last name (if you provide it), address or intersection for service issues, email (if provided).
• Message content & metadata: your messages, photos you send, system timestamps, delivery/response logs, and opt in/opt out confirmations required by carriers
• Service details: request type (e.g., pothole, missed pickup), case ID/status; for 211, non commercial intake notes and referral outcomes consistent with 211 practices.
• Technical data: carrier, device type, and network info necessary to deliver texts and prevent fraud/abuse
We do
not collect precise location from your device unless you choose to share an address, intersection, or map pin. Photos you send are stored with your request record; we don’t access your camera roll.
4) How we obtain consent for SMS (TCPA/CTIA/10DLC)
•
You must
opt in before receiving ongoing SMS from us
(e.g., texting a keyword, signing up on a City page, or checking an SMS box on a form).
•
Opt in language includes our name, message frequency
(or “msgs may vary”), “Msg & data rates may apply,” and
STOP/HELP instructions.
•
Every campaign maintains records of opt ins/opt outs per U.S. carrier and CTIA guidance; 10DLC campaigns are registered with The Campaign Registry where applicable.
Opt out anytime: Reply
STOP to end. Reply
HELP for help. Standard
message and data rates may apply.
5) How we use your information
• Provide services: route and respond to your requests; send confirmations, updates, reminders, and follow ups (e.g., service completion, appointment windows, weather impacts).
• Information & referral (211): determine needs, identify appropriate resources, and—with your permission—share limited info with a referral partner to connect you to services.
• Operations & security: deliver/retry messages, prevent spam and abuse, analyze usage trends to improve service access
• Reporting: produce aggregate, de identified statistics about requests and services
(never for commercial advertising). 211 programs commonly publish aggregate metrics while protecting client privacy. We
do not sell your mobile number or message content, and we don’t share SMS opt in data with third parties for marketing.
6) Disclosures & safety exceptions
We share your information
only as needed to operate the Programs, comply with law, or protect safety:
• City operations & vendors: with City staff and contracted service providers (e.g., messaging platforms/contact center software) under agreements that restrict use to our instructions and require safeguards. Examples of 211 vendor disclosures are public
(NICE/inContact; iCarol).
• Referrals you request (211): with your permission, we may share limited details with partner agencies to obtain services for you
• Required by law/safety: we may disclose information to emergency responders or authorities if there is an imminent threat to life/safety, suspected abuse/neglect, or as otherwise legally required. 211 programs document these limited confidentiality exceptions.
• About HIPAA: 311/211 are
not health care providers and are generally
not HIPAA covered entities. If you share health details, we handle them confidentially and apply reasonable safeguards, but HIPAA rules usually apply only to health plans, health care providers, or clearinghouses and their business associates.
7) Tennessee privacy law context (TIPA)
The
Tennessee Information Protection Act (TIPA) (effective July 1, 2025) applies to certain for profit businesses and
does not apply to
state/local government entities like the City of Knoxville. Even so, we align to its principles where feasible (transparency, data minimization, security, and rights to access/correction through existing City processes.
8) Data retention
• 311 requests: kept per the City’s records schedule to manage service delivery, audits, and legal obligations.
• 211 contacts: retained per 211 program standards to document referrals and outcomes; reports are typically aggregate/de identified.
• SMS/Chat logs & consent records: retained to meet federal/carrier requirements
(e.g., opt in/opt out proof) and to troubleshoot delivery.
We purge or de identify data when no longer needed for the purposes above or required by law.
9) Children & vulnerable individuals
The Messaging Services are intended for adults. If you are a parent/guardian contacting us for a child, you may do so. For
211, disclosures may occur if staff believe there is abuse, neglect, or an immediate threat, consistent with mandated reporting laws and 211 confidentiality policies.
10) Your choices & rights
• Opt out of SMS: Reply STOP at any time. You may still receive critical one to one replies relating to an open request you initiated.
• Update information: If a service request contains incorrect contact details or location, reply in the same thread or call 311/211.
• Access copies: You may request copies of your own request history consistent with City records procedures.
• Anonymity: Where possible
(e.g., reporting a pothole), you may report without providing your name.
11) Security
We use administrative, technical, and physical safeguards appropriate to City operations and vendor platforms—e.g., encryption in transit, role based access, audit logging, and staff training—to protect your information against unauthorized access, alteration, or disclosure.
(211 national guidance and municipal 311 policies emphasize similar safeguards.)
12) Message practices required by carriers
•
Each campaign clearly identifies “City of Knoxville 311” or “Knoxville 211.”
•
Initial and recurring messages include
STOP and
HELP instructions (or provide them on request), and “Msg & data rates may apply.”
•
Campaigns are registered for
10DLC where applicable to ensure delivery and reduce spam filtering
13) Third party links & platforms
If we connect you to non City websites/apps
(e.g., partner agencies, 211 resource platforms), their privacy practices apply. Review those policies before sharing information. 211 programs publicly list key vendors for transparency.
14) Changes to this policy
We may update this policy to reflect law, technology, or service changes. We’ll post the
effective date and, when changes are material, provide a notice
(e.g., a link in SMS or on our websites). Other cities publish effective dates and updates in similar fashion
15) How to contact us
• 311 City Services: Dial 311 or visit
KnoxvilleTN.gov/311
• 211 Social Services: Dial 211 or visit
EastTN211.org
• Privacy questions: [email protected]
• SMS help (automated): Reply HELP
• Stop texts: Reply STOP
Appendix A – Reference Standards we follow
• CTIA Short Code Monitoring Handbook (v1.9, 2024): opt in/opt out, HELP, identification, content guidelines
• TCPA & carrier practices: prior express consent for promotional messaging; recordkeeping for consent/opt out; message identification.
•
10DLC registration & blocking risk: brand/campaign registration via The Campaign Registry; carriers block unregistered A2P traffic.
• 211 confidentiality norms & data sharing for referrals: limited disclosures with client permission; safety exceptions for abuse/self harm/violence; aggregate reporting.
•
Tennessee Information Protection Act (TIPA): not applicable to local government, but principles inform our transparency and security practices.