Social Media Policy Solent NHS Trust policies can only be considered to be valid and up-to-date if viewed on the intranet. Please visit the intranet for the latest version. Purpose Document Type Reference Number To provide guidance for staff, volunteers and contractors on the appropriate use of social media. x Policy SOP Guideline Solent NHST/Policy/PR02 Version Version 1 Name of Approving Committees/Groups Assurance Committee Operational Date October 2015 Document Review Date October 2018 Document Sponsor (Name & Job Title) Document Manager (Name & Job Title) Document developed in consultation with Intranet Location Website Location Keywords (for website/intranet uploading) Sarah Austin, Director of Strategy Lauren Riddle, Membership and Marketing Communications Manager Sarah Austin, director of Strategy Sarah Martin, Associate Director or HR Elton Dzikiti, Head of Marketing Communications Mandy Rayani, Chief Nurse Insert the location of the document on the intranet Insert the location of the document on the FOI Publication Scheme Principals of using social media, reputation safeguarding, inappropriate use of social media, conduct expectations. Solent NHS Trust policies can only be considered to be valid and up-to-date if viewed on the intranet. Please visit the intranet for the latest version. 1 of 9 Version 1 Social Media Policy
Contents Page Section Page No 1 Executive summary 3 2 Scope 3 3 Purpose 3 4 Definitions 3 5 Roles & Responsibilities 4 6 Principals 4 7 Associated Risks 5 8 Inappropriate Use 5 9 Naming Solent NHS Trust in one s profile 6 10 Discrimination and Harassment 6 11 Human Rights Act 1998 6 12 Monitoring the Use of Social Media, including Excessive use in Work Hours 6 13 Misuse of Social Media 7 14 Managing Patient Complaints via Social Media 7 15 Policy Review 7 16 Links to other Relevant Policies and Documents 7 Appendix: Equality Impact Assessment 8 2 of 9 Version 1 Social Media Policy
Please see the associated Social Media strategy for the Trust to learn more on how the Trust intends to use social media to benefit services users. The strategy can be found here. 1. EXECUTIVE SUMMARY 1.1 Social media is now the most popular way of communicating and sharing information and advice. It is a very quick way to reach very large numbers and to build trust. It is important that it is given the appropriate resourcing and attention to help it flourish, and that a detailed strategy is in place and continuously updated. Social media is a very simple platform for communicating; the most important thing is the content. Content must be engaging, interactive and either inspire or educate. However, social media platforms when used in a professional capacity should be approached with caution and this policy should be reviewed in full before setting up social media accounts. 1.2 The online elements of Solent s brand plays a large part in the way in which the brand is perceived. Mistakes on any associated websites, information that is not helpful or is incorrect, online booking systems that don t work, not responding to online comments etc are all extremely damaging to Solent s brand image. 1.3 Social media has a vast amount of positive opportunities; however, there are also a number of risks, both when using social media in a professional and personal capacity. Employees are expected to act in the same way on social media as they would in person. 2. SCOPE 2.1 This policy covers all Solent NHS Trust sites and applies to all Trust employees, this includes apprentices, contractors and volunteers. 3. PURPOSE 3.1 The purpose of this policy to ensure that the Trust, staff and service users are not brought in to disrepute, as a result of the inappropriate use of social media. 4. DEFINITIONS 4.1 Social media defines a tool which facilitates two-way interaction online. This includes: social networking channels such as twitter, facebook, google+ social recruitment such as Linkedin video and picture sharing networks such as Instagram and youtube social news discussions such as comments sections on news pages interactive training such as webinars forums hosted on company websites blogs. 4.2 Social media is focussed on building relationships, sharing knowledge and inspiring people to complete an action (click on a link, watch a video, share a post, etc). 3 of 9 Version 1 Social Media Policy
4.3 Social media has a wide range of uses, including: PR Awareness campaigns Patient and customer support Patient and customer communities Research Managing stakeholder relationships Sharing knowledge 5. ROLES AND RESPONSIBILITY 5.1 The Chief Executive has overarching accountability for this policy and delegates the responsibility for ensuring this policy is applied consistently and fairly across the Trust, to the Executive Directors and senior managers of the Trust. 5.2 The Head of Marketing Communications is responsible for ensuring compliance of this policy. 5.3 All employees are responsible for their own actions on social media and must comply fully with this policy at all times. 5.4 Managers should be aware of the use of social media within their team, and are responsible for the compliance of the policy within their team. Managers must be made aware if their team members would like to use social media within working hours for the benefit of the service and service users. 6. PRINCIPALS 6.1 If a member of staff decides that social media would benefit their service users and the Trust, please review this policy in full first and seek advice from the Marketing Communications Team before creating social media profiles and pages. The team can provide support and advice to maximise efforts. When developing social media content it is important to follow the guidelines below: Content must be interesting, useful or helpful and provide the audience with an opportunity to learn or be inspired Content should never be published just for the sake of it. If you have nothing to say, don t say anything. Content is always engaging and invites two-way interaction eg sharing, likes, retweets, comments. Content should never be solely about selling a product or service. 6.2 Any information posted online is in the public domain and can be freely viewed by anyone at any time, even if it has been deleted. 6.3 If an employee identifies themselves as working for the Trust and discusses their work on social networking sites, they must behave professionally and in a way that is consistent with this policy and the Trust s values. 4 of 9 Version 1 Social Media Policy
6.4 Solent NHS Trust values: 7. ASSOCIATED RISKS 7.1 There are a number a number of risks associated with using social media and it is important that these points are adhered to, to ensure the Trust s reputation is not brought in to disrepute: unauthorised disclosure of Trust information and breaches of confidentiality or protectively marked information legal liabilities from offensive postings personal Data being disclosed without consent - breach of Data Protection Act damage to the Reputation of Solent NHS Trust identity theft breach of safeguarding virus or other malicious software infection publication of inappropriate content including, but not limited to operational material civil or criminal action relating to breaches of legislation. 8. INAPPROPRIATE USE 8.1 Any communication via social media in a personal and professional capacity must adhere to the following: staff may not discuss patients or other staff. The only exception to this is when promoting positive patient stories via the Solent accounts ONLY. Full written consent must be obtained from the marketing communications team, the service involved and the patient or member of staff involved. The patient/staff and service must be made aware of exactly how it will be used staff may not discuss confidential organisational information staff may not send direct messages to patients unless it is to signpost to relevant services for more information staff may not discuss any situations which may lead to a patient or member(s) of staff being identified staff must not make comments that would bring the Trust, staff or services in to disrepute staff may not post anything that they would not openly say to a journalist. Once it is published, it cannot be taken away. Even if a comment is deleted, it can still be found. Staff may not comment on negative issues and incidents relating to the Trust in a professional capacity. Staff must not knowingly make friends with a relative or friend of a patient. 5 of 9 Version 1 Social Media Policy
9. NAMING SOLENT NHS TRUST IN ONE S PROFILE 9.1 It is acceptable for employees to say they work for the trust when using any social media networks, but it is advised that the following disclaimer is added to their profile The postings on this site are my own personal opinion and do not represent Solent NHS Trust policy or opinion. This can be done by going to account settings within a profile. 9.2 Employees should use a personal email address and not a Solent address or NHS.net when setting up a personal account. This is to protect the email servers from viruses. 10. DISCRIMINATION AND HARASSMENT 10.1 All employees are advised that they must refrain from any online behaviour which could be considered to be discriminatory or which may constitute bullying or harassment of colleagues or service users. This includes, for example, making offensive comments relating to gender, gender reassignment, race (including nationality), disability, sexual orientation, religion/belief or age; using social media to bully another individual ( cyberbullying ) and posting images that are discriminatory or offensive or links to such images. 10.2 Harassment is defined under the Equality Act (2010) as violating dignity or, creating an intimidating, hostile, degrading, humiliating or offensive environment. 10.3 Incidents of discrimination bullying or harassment which take place via social media will be managed in-line with the following policies, where appropriate - Dignity at work policy, Grievance policy and the Disciplinary policy. 10.4 If members of staff have any concerns, they are encouraged to contact their manager, Human Resources, their trade union representative or staff advisor for an informal discussion and advice. 11. HUMAN RIGHT ACTS 1998 11.1 The Human Rights Act 1998 states that everyone has the right to privacy and the right to freedom of expression. However, these rights come with responsibilities and neither provide immunity if the manner in which a person chooses. to exercise these rights offends or upsets another person. 12. MONITORING THE USE OF SOCIAL MEDIA 12.1 Monitoring is only carried out to the extent permitted or as required by law and as necessary and justifiable for business purposes. 12.2 Managers reserve the right to restrict or prevent access to social media and other websites if they consider personal use to be excessive/ inappropriate during working hours. 12.3 If there are any concerns that any points within this policy have been breached, the manager involved and the communications team have the right to request access to view the account in question. 6 of 9 Version 1 Social Media Policy
13. MISUSE OF SOCIAL MEDIA 13.1 Employees should note that there have been a number of cases in which NHS staff have been disciplined for inappropriate use of social media.. Staff can by subject to criminal police investigations if serious misuse of social media is suspected. 13.2 If employees notice any use of social media by other members of staff in breach of this policy they should report it to their manager immediately. 13.3 In particular uploading, posting forwarding or posting a link on any of the following types of material on a social media website that brings the Trust into disrepute, which may be in a professional or personal capacity, could amount to gross misconduct (this list is not exhaustive): pornographic material (that is, writing, pictures, films and video clips of sexually explicit or arousing nature); a false and defamatory statement about any person or organization; material which is offensive, obscene, criminal, discriminatory, derogatory or may cause embarrassment to Solent, our patients, or our staff; confidential information about Solent or any of our staff or patients (which you do not have express authority to disseminate); disclosing personal data without consent - intentional breach of the Data Protection Act; any other statement which is likely to create any liability (whether criminal or civil, and whether for you or us); materials in breach of copyright or intellectual property rights, or which invades the privacy of any person; bullying, harassing or discriminating against any other employee in any way whilst online complaining about any customers, staff or patients in any way whilst online 14. MANAGING PATIENT COMPLAINTS VIA SOCIAL MEDIA 14.1 Patients often prefer to use social media as a way of complaining, venting their frustrations and endorsing services. It is important that patient complaints via social media are responded to quickly and are given the Patient Experience Services contact details. 14.2 We advise all staff to contact the Marketing Communications Team for support with how to manage patient complaints online as this is potentially a serious reputation management issue. 15. POLICY REVIEW 15.1 The policy will be reviewed three years from the date it has been approved. 16. LINKS TO OTHER RELEVANT POLICIES AND DOCUMENTS Disciplinary policy Media policy 7 of 9 Version 1 Social Media Policy
APPENDIX EQUALITY IMPACT ASSESSMENT Step 1 Scoping; identify the policies aims Answer 1. What are the main aims and objectives of the document? To provide guidance to staff volunteers and contractors on the appropriate use of social media 2. Who will be affected by it? All staff, volunteers and contractors. 3. What are the existing performance indicators/measures for this? What are the outcomes you want to achieve? 4. What information do you already have on the equality impact of this document? 5. Are there demographic changes or trends locally to be considered? This is a new policy and there has not been one like it before. The outcomes expended are for staff to be educated and to fully understand what is appropriate use of social media and what is not. None. No. 6. What other information do you need? None. Step 2 - Assessing the Impact; consider the data and research Yes No Answer (Evidence) 1. Could the document unlawfully against any group? N 2. Can any group benefit or be excluded? N 3. Can any group be denied fair & equal access to or treatment as a result of this document? 4. Can this actively promote good relations with and between different groups? 5. Have you carried out any consultation internally/externally with relevant individual groups? 6. Have you used a variety of different methods of consultation/involvement N Yes N N The use of social media could potentially benefit harder to reach groups and communities. 8 of 9 Version 1 Social Media Policy
Mental Capacity Act implications 7. Will this document require a decision to be made by or about a service user? (Refer to the Mental Capacity Act document for further information) N If there is no negative impact end the Impact Assessment here. Step 3 - Recommendations and Action Plans Answer 1. Is the impact low, medium or high? Low 2. What action/modification needs to be taken to minimise or eliminate the negative impact? 3. Are there likely to be different outcomes with any modifications? Explain these? None No. Step 4- Implementation, Monitoring and Review 1. What are the implementation and monitoring arrangements, including timescales? 2. Who within the Department/Team will be responsible for monitoring and regular review of the document? Step 5 - Publishing the Results Answer To be communicated with all staff, managers to monitor and the policy will be reviewed in 3 years. Lauren Riddle Answer 9 of 9 Version 1 Social Media Policy