Login

DC94-Using Social Media Platforms Policy

{{org_field_logo}}

{{org_field_name}}

Registration Number: {{org_field_registration_no}}

Using Social Media Platforms Policy

1. Purpose and Commitment

The purpose of this policy is to outline how {{org_field_name}} manages the use of social media platforms efficiently, ensuring that staff, service users, and the organisation are protected from potential risks while embracing the benefits of digital communication. Our commitment is to promote responsible social media usage that aligns with our core values, safeguarding principles, and professional standards.

Social media platforms, including Facebook, Instagram, Twitter, LinkedIn, and TikTok, provide opportunities for communication, marketing, and community engagement. However, they also pose potential risks, such as breaches of confidentiality, reputational damage, and safeguarding concerns. This policy ensures that staff understand their responsibilities when using social media in both personal and professional capacities.

2. Scope

This policy applies to all employees, volunteers, contractors, and stakeholders associated with {{org_field_name}}. It covers:

The policy applies to all types of social media, including blogs, discussion forums, video-sharing sites, and professional networking platforms.

3. Policy Statement

{{org_field_name}} recognises the value of social media as a communication tool while acknowledging its potential risks. We are committed to promoting safe, respectful, and responsible social media use by:

We expect all staff to uphold the highest standards of professionalism and integrity when engaging with social media platforms, both within and outside work hours.

4. Personal Use of Social Media

4.1 Responsible Personal Use

Employees may use personal social media accounts outside working hours. However, they must:

4.2 Privacy Settings

Staff are encouraged to review their social media privacy settings regularly to control who can view their posts. This helps protect personal information and reduces the risk of unintended exposure.

4.3 Avoiding Association with the Company

Unless authorised, employees should not present themselves as company representatives when posting personal content. Social media bios should clarify that views expressed are personal and do not reflect the company’s stance.

5. Professional Use of Social Media

5.1 Company Social Media Accounts

{{org_field_name}} maintains official social media accounts to:

Only authorised staff can manage official social media accounts. Content posted must be accurate, respectful, and aligned with company values.

5.2 Professional Conduct

When using social media for professional purposes, employees must:

5.3 Social Media Monitoring

The company reserves the right to monitor its official social media accounts. Any inappropriate or harmful content will be removed, and further action may be taken if necessary.

6. Interactions with Service Users on Social Media

6.1 Maintaining Professional Boundaries

To protect both staff and service users, employees must:

6.2 Protecting Confidentiality, Privacy and Personal Information

{{org_field_name}} will protect the confidentiality, privacy, dignity and personal information of every service user when social media is used.

Employees, volunteers, contractors and other persons acting on behalf of {{org_field_name}} must not post, upload, transmit, share, forward or otherwise disclose any identifiable information about a service user through social media unless the disclosure has been specifically authorised by {{org_field_name}} and complies with applicable confidentiality and data protection requirements.

This includes, but is not limited to:

Where {{org_field_name}} intends to use a service user’s photograph, video, testimonial or other personal information for publicity, marketing, recruitment, fundraising or social media purposes, the organisation must identify and document an appropriate lawful basis for processing under the UK GDPR before the information is used. Where special category personal data is involved, an appropriate condition under Article 9 of the UK GDPR must also be identified and documented.

Where {{org_field_name}} relies upon consent as the lawful basis, the consent must be freely given, specific, informed and unambiguous and must be recorded. Where explicit consent is required, it must be expressly confirmed. The person must be informed that consent can be withdrawn and withdrawal must be acted upon appropriately in relation to future processing.

A service user’s agreement to receive care from {{org_field_name}} must never be treated as agreement to the use of their image, personal information or care information on social media.

Where there is reason to doubt whether a service user has capacity to make the particular decision about the proposed use or publication of their information, staff must not proceed solely on the basis of a relative’s, friend’s or informal carer’s permission. The matter must be referred to the appropriate manager and dealt with in accordance with the Mental Capacity Act 2005, including establishing whether another person has lawful authority to make the relevant decision where applicable.

Staff must not take photographs, videos or audio recordings of service users on personal devices for social media or promotional purposes.

Any authorised image, recording or information must only be used for the approved purpose and through communication channels approved by {{org_field_name}}.

7. Safeguarding, Confidentiality and Information Security

7.1 Safeguarding Concerns Arising Through Social Media

Social media must never be used to abuse, exploit, intimidate, discriminate against, harass, humiliate, threaten, groom or otherwise improperly treat a service user.

Any employee, volunteer or contractor who becomes aware of information on social media that indicates or may indicate abuse, neglect, exploitation, improper treatment or another safeguarding risk involving a service user must report the concern immediately in accordance with {{org_field_name}}’s Safeguarding Adults Policy and Procedure.

This requirement includes concerns arising from:

Staff must not attempt to investigate a safeguarding allegation independently through social media, confront the alleged perpetrator online or delete potentially relevant information unless necessary to prevent an immediate and serious risk.

The Registered Manager or designated safeguarding lead must ensure that safeguarding information received through social media is acted upon without delay, recorded appropriately and dealt with in accordance with the organisation’s safeguarding procedures.

Where required by the circumstances, this may include referral or notification to:

Where there is an immediate danger to a person, emergency services must be contacted without delay.

7.2 Confidentiality

Employees, volunteers and contractors must not disclose confidential information obtained through their work with {{org_field_name}} on social media or through social-media messaging services.

This includes:

Confidential information must only be accessed, used or disclosed where there is a lawful and legitimate reason to do so and through systems and processes authorised by {{org_field_name}}.

Information relating to service users must not be transferred to personal social-media accounts, personal cloud-storage accounts or other unauthorised systems.

A confidentiality breach may also constitute a personal data breach and must therefore be reported immediately in accordance with Section 7.3.

7.3 Personal Data Breaches Involving Social Media

Any accidental or unauthorised disclosure, loss, alteration, publication, transmission or access involving personal information through social media must be treated as a potential personal data breach.

Staff must immediately report a suspected or actual personal data breach to the person responsible for data protection within {{org_field_name}} and must follow the organisation’s Data Protection and Personal Data Breach procedures.

Staff must not attempt to conceal a breach or delay reporting it while attempting to resolve the matter themselves.

{{org_field_name}} will assess each personal data breach and determine whether notification to the Information Commissioner’s Office is required.

Where a personal data breach is likely to result in a risk to the rights and freedoms of individuals, {{org_field_name}} must notify the Information Commissioner’s Office without undue delay and, where feasible, not later than 72 hours after becoming aware of the breach.

Where the personal data breach is likely to result in a high risk to the rights and freedoms of an affected individual, {{org_field_name}} must also communicate the breach to that individual without undue delay, unless an applicable legal exception applies.

{{org_field_name}} will maintain records of personal data breaches in accordance with applicable data protection legislation.

8. Social Media Training and Support

8.1 Staff Training

{{org_field_name}} will ensure that staff receive appropriate information, instruction, training and support relevant to their role concerning the safe and lawful use of social media.

Training and guidance relevant to this policy will include, as appropriate to the person’s role:

Training needs will be considered during induction and reviewed at appropriate intervals and when there is a relevant change in legislation, regulatory requirements, technology, systems, role or identified risk.

Staff must receive additional instruction or training before they are authorised to manage official social-media accounts or publish information on behalf of {{org_field_name}} where this is necessary for them to perform that responsibility safely and lawfully.

8.2 Ongoing Support

The company will provide resources, workshops, and regular updates to ensure staff remain informed about best practices and emerging risks related to social media.

9. Reporting Concerns, Breaches and Complaints

9.1 Internal Reporting by Staff

Staff who become aware of inappropriate, unlawful or potentially harmful social-media activity connected with {{org_field_name}}, its staff or its service users must report the matter promptly to their line manager, the Registered Manager or another person identified by the organisation’s reporting procedures.

Matters requiring reporting include:

Where the concern relates to safeguarding or a personal data breach, the specific procedures in Section 7 must also be followed.

9.2 Reporting to External Bodies

{{org_field_name}} will determine whether a social-media incident must be referred or reported to an external organisation.

Depending upon the circumstances, this may include:

Staff must not make regulatory notifications on behalf of {{org_field_name}} unless authorised to do so.

Nothing in this policy prevents a person from contacting the police, emergency services, a safeguarding authority, the Care Quality Commission, the Information Commissioner’s Office or another appropriate statutory body directly where they are legally entitled to do so.

9.3 Data Protection Complaints

A concern or complaint about the collection, use, disclosure, publication, retention, security or other processing of personal information through social media must be treated as a potential data protection complaint.

{{org_field_name}} will provide an accessible means by which individuals can submit data protection complaints.

When a data protection complaint is received, {{org_field_name}} must:

Data protection complaints must be handled in accordance with {{org_field_name}}’s applicable data protection complaints procedure.

10. Disciplinary Action

Failure to comply with this policy may be addressed under {{org_field_name}}’s disciplinary procedure.

Depending upon the circumstances and seriousness of the matter, disciplinary action may include:

Serious breaches may constitute gross misconduct. Examples may include deliberate unauthorised disclosure of confidential service-user information, serious breaches of professional boundaries, abusive or discriminatory conduct, deliberate misuse of photographs or recordings of service users, or conduct that places a service user at risk of harm.

Any disciplinary action will be considered on the individual facts of the case and dealt with in accordance with {{org_field_name}}’s disciplinary procedure and applicable employment law.

Where appropriate, the matter may also require separate safeguarding, data protection, regulatory or criminal investigation or referral.

11. Monitoring and Continuous Improvement

11.1 Regular Audits

The company will conduct regular audits of official social media accounts to ensure compliance with this policy. Any issues identified will be addressed promptly.

11.2 Policy Review

This policy will be reviewed at least annually and sooner where necessary.

An earlier review must be undertaken where there is:

Where a review identifies that this policy, associated procedures or organisational practices no longer comply with applicable requirements, corrective action must be taken without undue delay.

12. Compliance and Legal Considerations

12.1 Legal and Regulatory Framework

{{org_field_name}} will manage social-media use in accordance with applicable legislation and regulatory requirements.

Relevant legislation and requirements include, where applicable:

In particular, social-media activity must be managed consistently with applicable CQC requirements concerning dignity and respect, consent, safeguarding from abuse and improper treatment, staffing and good governance.

12.2 Data Protection and Confidentiality

Personal information must only be collected, accessed, recorded, used, shared, stored, published, retained or otherwise processed where {{org_field_name}} has an appropriate lawful basis and complies with applicable data protection legislation.

Where information is special category personal data, {{org_field_name}} must also identify an appropriate condition permitting the processing of that information.

Personal information must be:

Confidential information obtained through the provision of care must not be disclosed through social media unless the disclosure is lawful, authorised and consistent with the person’s rights and the organisation’s confidentiality obligations.

12.3 Organisational Responsibility

Only staff who have been specifically authorised may publish material through an official {{org_field_name}} social-media account.

Authorised staff must ensure that information published on behalf of {{org_field_name}}:

The Registered Manager or another appropriately authorised person will ensure that significant social-media incidents affecting service users, confidentiality, safeguarding or data protection are reviewed and that any required corrective, safeguarding or regulatory action is taken.

Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.

Leave a Reply

Your email address will not be published. Required fields are marked *