Social Media and Confidentiality Policy

Policy Statement

Social media allows people to communicate instantly with each other or to share information in a public forum. Social media tools and platforms include email, online social forums, Facebook, Twitter, TikTok, blogs, wikis, podcasts, message services, video- and image-sharing websites and similar facilities.

This policy is intended to help staff make appropriate decisions about the use of social media in connection with their work, to outline the standards expected in its use, to explain the organisation’s approach to achieving standards and to describe what will happen in cases of non-compliance with the policy.

Aims of the Policy

This policy on the acceptable and unacceptable use of social media from the perspective of {{org_field_name}} specifically aims to:

give clear guidelines to all staff on what they can and cannot say on social medial platforms about {{org_field_name}} and organisation
help managers to manage the conduct of their staff effectively
help staff work out the boundaries between their private and work lives
comply with the laws on discrimination, data protection and online safety for people receiving care and staff
be clear about sensitive issues like monitoring and explain how disciplinary rules and sanctions apply to any social media misuse
help protect it against potential liability for the possible actions of its staff.

Scope of Policy

This policy covers the use of social media by staff employed by {{org_field_name}} as it might impact on their work, on the people who use the service, including their informal carers, relatives and friends, and on others who come into contact with the service, eg other agencies and professionals.

It extends to the use of social media both in the work setting and in the course of a person’s work.

It relates to the personal and private use of social media, where references may be made to the work situation and to a person’s work experiences, which can be accessed publicly, whether intended or not. It applies to whichever social media devices are used, ie those owned by the organisation and staff members’ personal devices since both can be used for identical purposes and contain the same information.

It does not include private and confidential social media and electronic communications, which — like letter writing and conversation — do not normally enter the public arena. At the same time it is seen to be the individual’s responsibility to exercise the relevant privacy controls over their social media platforms so that material implicating {{org_field_name}} or its users does not appear in the public arena unintentionally. Any relevant material that does so is covered by this policy.

The policy applies to the use of {{org_field_name}}’s own social media accounts and to the private accounts of all of its staff, where the content falls within the scope of the policy as explained in the previous paragraphs.

Specific Aspects

Use of the service’s social media platforms (where applicable)

Applicants for posts with the service are reassured that the service does not normally attempt to examine their social media accounts when they apply for a job, which is considered to be a breach of their privacy. It might seek to do so if it was alerted to or provided with evidence that would affect their suitability for the position for which they have applied, but only with their permission.

The service uses certain social media platforms [specify, eg service’s own website, Facebook page] to promote and explain its values, aims and work. Staff are encouraged to contribute and share their ideas about and within these means as they would on any other aspect of the service.

When contributing to any forum launched by the service to obtain people’s views, staff are expected to contribute as they would to any conventional staff meeting in line with established ground rules.

Staff must be authorised by the service management/medium administrator to contribute to the content/make any changes to any feature of the relevant platform. Any attempt to hack the service’s own media platforms is a serious offence that will result in the staff member(s) facing disciplinary proceedings, almost inevitable immediate dismissal and possible criminal proceedings.

In using the service’s own devices for social media use staff must observe the guidelines set out below. They must be aware that they have no right to privacy to any information or data acquired for personal use that is stored on the service’s devices. Personal use of the service’s devices will be regularly monitored and reviewed to make sure that it is following the guidelines.

Use of personal social media platforms

It is accepted that staff members might use on occasions the service’s and/or their own devices (computers, smartphones, tablets, etc) to make use of their personal social media platforms in the course of or away from their work.

The personal use of social media in work time, eg for messaging purposes, must not interfere in any way with their work.

Where they make any reference to their work situation or work in general on their personal platforms, eg in a blog or diary, they should make sure that they are expressing their views in a personal capacity and not as a representative of their organisation by providing a suitable disclaimer, eg “The views I express here are mine alone and do not necessarily reflect the views of my organisation/employer.”

Guidelines

However and whenever staff make use of social media that makes reference to or has implications for the service, it is essential that they comply with the following rules.

In general they should use social media that contains any reference to their work situation responsibly, respectfully and constructively. They should also co-operate within the law governing communications offences. Any breach of the law resulting from non-work-related social media use could also have an impact on their fitness to be employed in a care service and to be addressed accordingly.

Staff are advised to discuss any possible areas of confusion with their manager. They should obtain consent to access and/or post any significant work-related material and information, particularly where there are possible breaches of data protection and confidentiality.

Staff members must not:

breach confidentiality by referring directly to people or their care or revealing personal details about them
post images, photographs or videos of people receiving care or colleagues without their knowledge or consent
give away confidential information that they have obtained about any individual, colleague or person with whom they have met in the course of their work
discuss the business of the service or information about it that they know should be treated as confidential information
do anything that could be considered discriminatory against, or bullying or harassment of, any individual associated with their work
make offensive or derogatory comments relating to the sex, gender reassignment, race (including nationality), disability, sexual orientation, religion or belief or age of anyone connected to the work situation, user or colleague
use social media to bully a colleague or people receiving care or anyone connected to either
bring their employer into disrepute, eg by making derogatory or malicious comments or defamatory remarks about the service owners or management
use the service’s devices to post images that are inappropriate or that make links to inappropriate content, eg pornographic websites
disclose confidential intellectual property or information owned by {{org_field_name}}/company or breach copyright where the latter is related to the work of the service.

Social Media Monitoring

To assist its information governance generally, and specifically, if it is suspected that the above guidelines are being breached or there is unauthorised use of the service’s technology, the service reserves the right to monitor and check staff’s use of its social media platforms. It will exercise this right only where it has grounds, as stated, for doing this. It will always keep staff suitably involved and informed of any monitoring being carried out. In making any checks, the service will not seek access to personal or private data content, and it would never disclose or share it without the person’s consent, except in extreme circumstances where, for example, there is evidence of criminal activity.

Public Interest Disclosure (Whistleblowing)

Where a staff member releases information through social media that might be considered a Public Interest Disclosure, eg to disclose abuse of vulnerable people receiving care, the organisation’s whistleblowing policy will be followed before further action is taken.

Non-compliance

Any breaches of this policy will be dealt with through the service’s disciplinary procedures. Serious cases will be treated as gross misconduct and result in dismissal.

Possible breaches of the law will be referred to the police for investigation and possible criminal proceedings.

Where people using services are harmed or put at risk of harm as a result of social media misuse, matters will addressed under safeguarding procedures and referred to the local safeguarding authority.

Staff engaged in regulated activity who have caused harm to people receiving care or put them at risk of harm through social media misuse will be deemed to have committed gross professional misconduct, dismissed and referred to the Disclosure and Barring Service for possible inclusion on its barring lists.

Training

The policy is explained to all new staff as part of their induction. All staff are regularly reminded of the policy and of their responsibilities to use all forms of social media within these guidelines while remaining employees of {{org_field_name}}.

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}}

DS191. Social Media and Confidentiality