{{org_field_logo}}

{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Handling Media Inquiries and Communication Policy

1. Purpose

The purpose of this policy is to ensure that all media inquiries and external communications relating to {{org_field_name}} are handled professionally, consistently, and in a manner that protects the privacy, dignity, and rights of the people we support. This policy aims to minimise reputational risk, ensure legal compliance, and uphold the values of transparency, integrity, and confidentiality. This policy supports compliance with the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, including Regulation 10 (Dignity and respect), Regulation 16 (Receiving and acting on complaints), Regulation 17 (Good governance) and, where applicable, Regulation 20 (Duty of candour), together with the Care Quality Commission (Registration) Regulations 2009 relating to notifications and changes to registration details. It also supports compliance with UK GDPR, the Data Protection Act 2018, confidentiality requirements, and relevant safeguarding, equality and human rights duties.

2. Scope

This policy applies to all employees, directors, the Nominated Individual, the Registered Manager, agency staff, bank staff, contractors, consultants, students and volunteers. It applies to any communication made in the course of employment or engagement, or where an individual could reasonably be identified as connected with {{org_field_name}}, including verbal statements, telephone calls, emails, letters, website content, review-site responses, social media activity, messaging applications, photography, video, public speaking, interviews, press statements and contact with influencers, bloggers or other content creators. This policy applies both during and outside working hours where the communication relates to the service, the people using the service, their relatives, staff, incidents, complaints, safeguarding matters, inspections, enforcement action or the reputation of the organisation.

3. Related Policies

• CH04 – Good Governance Policy
• CH13 – Safeguarding Adults from Abuse and Improper Treatment Policy
• CH20 – Fire Safety and Evacuation Procedures (for media during incidents)
• CH28 – Staff Conduct and Code of Ethics Policy
• CH34 – Confidentiality and Data Protection (GDPR) – Service User Policy
• CH35 – Duty of Candour Policy

4. Policy Statement and Responsibilities

Media Communication Objectives

{{org_field_name}} is committed to open and honest communication while safeguarding the confidentiality and dignity of the people we support and our workforce. All media communication will:

• be coordinated only through authorised roles and in line with approved internal escalation processes;
• be accurate, factual, proportionate and limited to information that can lawfully be shared;
• protect the dignity, privacy, safety and rights of people using the service, relatives, visitors and staff;
• avoid confirming whether any named person does or does not use the service unless disclosure is lawful and expressly authorised;
• support lawful safeguarding, regulatory and statutory reporting without disclosing more information than is necessary;
• ensure that records are kept of significant media contacts, decisions, approvals, statements issued and follow-up actions taken; and
• support learning, oversight and assurance under the organisation’s good governance framework.

Authorised Spokespersons

Only the following roles are authorised to make statements to the media or approve external communications on behalf of {{org_field_name}}:

• support learning, oversight and assurance under the organisation’s good governance.
• Company Director
• Registered Manager
• Nominated Individual
• any person expressly delegated in writing by one of the above for a specific matter.

Authorisation attaches to the role rather than only to the named post-holder. Where a named authorised person is absent, unavailable or conflicted, the most senior available authorised role holder must appoint a deputy and record that decision.

No other employee, worker, volunteer or contractor may give interviews, issue statements, confirm facts, respond to allegations, provide photographs or footage, or comment ‘off the record’ on behalf of the organisation. Staff must not assume that a casual, informal or background conversation with a journalist, photographer, blogger or content creator is private or non-reportable.

Handling Media Inquiries

If any member of staff is approached by a journalist, broadcaster, photographer, blogger, influencer, content creator or other external party seeking comment, they must:

1. remain polite and professional;
2. state that they are not authorised to comment;
3. not confirm or deny whether any named person uses the service, has lived at the service, works at the service or has been involved in any incident;
4. avoid discussing any incident, complaint, safeguarding matter, staffing issue, inspection activity or operational concern;
5. take the enquirer’s name, organisation, contact details, deadline and the nature of the request;
6. make an immediate written record of the contact in the Media Contact Log;
7. inform the Registered Manager, or if unavailable the next authorised spokesperson, without delay; and
8. forward any email, message, letter or recording request promptly and unaltered.

The same requirements apply to approaches made by telephone, in person, by email, through social media, via messaging applications, through relatives or visitors, or by persons seeking to enter the premises for filming, photography or comment.

Media During Incidents

In the event of a serious incident, complaint, safeguarding concern, unexpected death, police attendance, service disruption, emergency or other event likely to attract external attention, the priority of {{org_field_name}} is the immediate safety, welfare, dignity and lawful rights of people using the service and others affected.

No unauthorised person may make any public statement. An authorised spokesperson may issue a brief holding statement where necessary. Any holding statement must be factual, minimal, avoid speculation, avoid attributing blame, avoid disclosing personal data, and avoid confirming the identity of any person receiving care unless lawful authority to do so has been confirmed.

Media access to the premises, grounds, residents, relatives, visitors, records, images, CCTV, staff work areas or incident scenes is not permitted unless formally authorised by senior management and lawful in the circumstances. Where police, the local authority, the coroner, safeguarding partners or other public authorities are involved, {{org_field_name}} will coordinate external communications so as not to prejudice investigations or place any person at risk.

The issue of a media statement must not delay, replace or be confused with safeguarding action, complaint handling, statutory notifications, duty of candour obligations, family communication, police liaison or reporting to insurers, commissioners or the Care Quality Commission.

Statutory Duty of Candour, Complaints and Regulatory Notifications

Where an incident meets the threshold for a notifiable safety incident, the registered person must comply with Regulation 20 Duty of Candour by being open and transparent with the relevant person as soon as reasonably practicable. This duty is owed to the relevant person in connection with the care and treatment provided and must not be treated as a duty to inform the media or the general public.

Where required, the service must also make timely notifications to the Care Quality Commission and any other relevant body in accordance with the Care Quality Commission (Registration) Regulations 2009, safeguarding procedures, contractual requirements and other applicable law.

If a media approach includes an expression of dissatisfaction, allegation, or concern about care or treatment, the matter must also be considered under the Complaints Policy and Incident Reporting procedures. All complaints must be recorded, investigated and responded to through the service’s formal systems, irrespective of any media interest.

Protecting Confidentiality and Dignity

{{org_field_name}} will protect confidential information and personal data relating to people using the service, relatives, visitors, staff and others. No information will be shared externally unless there is a lawful basis to do so, the disclosure is necessary and proportionate, and only the minimum necessary information is disclosed.

Photographs, video, audio recordings, names, room numbers, care needs, diagnoses, incidents, safeguarding concerns, shift details, employment matters and any other identifying or potentially identifying details must not be disclosed to the media or the public without proper authority. A person may be identifiable from a combination of details even where their name is not used.

Where the proposed use of images, recordings or personal stories for publicity relies on consent, that consent must be explicit, informed, specific, documented and capable of being withdrawn. Where a person lacks capacity to consent, staff must not rely on informal family agreement alone; the proposed use must be considered under the Mental Capacity Act 2005, best interests principles, the person’s rights, and any applicable legal authority before any image or identifying information is used.

Staff must take all reasonable steps to preserve privacy and dignity, including ensuring that conversations cannot be overheard unnecessarily, records are secure, screens and devices are protected, and people are not exposed to unnecessary attention, intrusion or publicity. Any suspected breach of confidentiality or personal data security must be reported immediately through the organisation’s incident reporting and data breach procedures.

Social Media and Public Comments

Staff must not post, share, upload, livestream, comment on or otherwise disclose information relating to {{org_field_name}}, people using the service, relatives, visitors, colleagues, incidents, complaints, investigations, inspections or internal matters on social media or other online platforms unless expressly authorised in writing and acting within their role. This includes personal accounts, anonymous accounts, closed groups, community forums, messaging applications, review websites and content shared from personal devices.

Staff must not publish workplace photographs, audio or video, refer to identifiable incidents, discuss staff shortages or operational issues in a way that could identify the service or individuals, respond to criticism online on behalf of the organisation, or engage in arguments with members of the public, relatives or journalists.

Any online concern, complaint, threatening post, inaccurate allegation or reputational issue involving the service must be escalated to the Registered Manager promptly and managed through the appropriate internal policy route.

Photography, Filming and Publicity Content

No photography, filming, audio recording or testimonial involving people using the service, relatives, visitors or staff may be arranged for publicity or media purposes unless it has been risk assessed, approved by management, checked for confidentiality and privacy implications, and supported by the appropriate lawful basis under data protection law.

Consent forms must clearly state what material will be used, where it may appear, how long it may be retained, who may have access to it, and how consent can be withdrawn. Refusal to participate must never affect the care, support, opportunities or relationships offered to a person.

Publicity activity must not take place where a person appears distressed, lacks understanding of what is proposed, may feel pressured to agree, or where the content could undermine their dignity, safety or future privacy.

Proactive Media and Public Relations

Positive publicity, marketing and community engagement may be undertaken where it is consistent with the organisation’s values, truthful, respectful and lawful. All campaigns, stories, photographs, videos, interviews, award submissions, case studies and recruitment publicity must be approved in advance by the Registered Manager and an authorised spokesperson.

Before any publicity is issued, management must confirm:

• the accuracy of the content;
• the lawful basis for using any personal data;
• whether consent is required and has been properly obtained;
• whether the person has capacity to consent or whether additional legal and best interests consideration is required;
• that the material does not reveal unnecessary confidential or special category data; and
• that publication does not create avoidable risks to the safety, dignity or privacy of any person.

Publicity must never exaggerate, misrepresent inspection findings, imply endorsement by CQC, or place any person using the service under real or perceived pressure to participate.

Training and Staff Awareness

All staff, workers and volunteers must receive induction and refresher training on confidentiality, data protection, social media conduct, media handling, record keeping, complaints escalation, safeguarding escalation and the distinction between media communication, statutory duty of candour and regulatory notifications. Role-specific guidance must be provided to managers and authorised spokespersons. Training records must be maintained and monitored through the organisation’s governance systems.

Audit and Compliance

The Registered Manager will ensure that the service maintains oversight of:

• all significant media contacts and requests;
• statements issued and approvals given;
• consent records relating to publicity materials;
• online and social media incidents escalated under this policy;
• complaints or concerns received through media or public channels;
• any safeguarding, candour, data breach or regulatory notification issues arising in connection with external communications; and
• lessons learned, actions taken and policy improvements.

Compliance with this policy must be reviewed through governance audits, incident reviews, complaints analysis and supervision processes. Findings must be reported within the organisation’s good governance framework, including oversight at provider or board level where applicable.

5. Policy Review

This policy will be reviewed at least annually and sooner where required by legislative change, updated CQC guidance, inspection feedback, a serious incident, a complaint trend, a data protection breach, a safeguarding event, significant media involvement or organisational learning. The review must include confirmation that related policies, role allocations, contact details, consent arrangements, escalation routes and notification procedures remain current.

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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.