Social Media Policy. Author (name and designation) Heather Edwards, Head of Communications

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1 Document type: Version: Social Media Policy Policy Author (name and designation) Heather Edwards, Head of Communications Ratified by: Date ratified: Name of responsible committee/individual: Two Exec Board Exec Board Workforce Committee Name of Executive Lead: Mark Wilkinson, Director of Strategic and Organisational Development Master Document Controller: Caroline Swaby, Online Communications Administrator Date uploaded to intranet: Oct 2015 Review date: September 2018 Equality Impact Bolton NHS Foundation Trust strives to ensure equality of opportunity for all service users, local people and the workforce. As an employer and a provider of healthcare Bolton NHSFT aims to ensure that none are placed at a disadvantage as a result of its policies and procedures. This document has therefore been equality impact assessed by the [insert name of ratifying Committee] to ensure fairness and consistency for all those covered by it regardless of their individuality. The results are shown in the Equality Impact Assessment (EIA) at appendix 8. Version 2 Policy Document Control Policy Date September 2015 Next Review Date September 2018 Page 1 of 13 1

2 Version Control Schedule Version Type of Change Two Wholly revised and with additional appendix Date September 2015 Revisions from previous issues Wholly revised and with additional appendix Version 2 Policy Document Control Policy Date September 2015 Next Review Date September 2018 Page 2 of 13 2

3 Contents 1 Purpose of Policy P6 2 Background P6 3 Appendix 1 Guidance, responsibilities and monitoring P8 4 Appendix 2 Application to set up a work-related social media account 5 Appendix 3 Use of internet and social media by non-trust personnel P11 P14 Version 2 Policy Document Control Policy Date September 2015 Next Review Date September 2018 Page 3 of 13 3

4 Social Media Policy 1. Purpose 2. This policy outlines the way in which the Trust will use social media and gives guidance to the organisation and its staff in order to maximise the benefits of social media, whilst reducing the risks that this may bring. The policy also outlines the Trust s position with regard to use of social media by members of the public whilst on Trust property. 3. This policy should be read in conjunction with others including: 4. Internet and Usage Policy 5. Mobile Communications Policy 6. Information Governance Policy 7. Safeguarding Policy 8. Disciplinary Policy and Procedure 9. Background 10. Social media works via the internet by building virtual communities with shared interests and has many benefits, including interactive and responsive two way communication and engagement, speed of messaging, low or no cost, accessible to many at nearly any location. For organisations it is a powerful marketing tool, attracting customers, building reputations, giving speedy information. For individuals it is a tool for learning and sharing, making and keeping in touch with friends, giving views. 11. There are, however, risks to both organisations and individuals in using social media. There have been numerous instances of breaking the law, damaging reputations, cases of harassment, false claims, breaches of confidentiality therefore it is critical for the Trust to have a clear social media policy in place. 12. Use of social media by the organisation 13. The Trust will use its social media presence in order to: 4

5 14. Build further awareness of the Trust and its services and enhance its reputation 15. Support campaigns such as those for recruitment 16. Build stronger two way communication and engagement with internal and external stakeholders including the public and patients. 17. Provide additional channels to demonstrate good practice 18. Support the marketing of the Trust in an effective and efficient way. 19. Provide channels to enable fast and responsive communication, including at times of urgent need, e.g. major incident, bad weather/industrial action affecting services 20. Demonstrate that we are an up to date organisation, using modern methods of communication. 21. The Trust will have corporate accounts managed by the Communications Department on Twitter, Facebook, LinkedIn, Youtube and other channels as required. Services and members of staff can contact Communications if they wish to highlight a Trust development, news etc. via social media or other channels. 22. Key individuals may be given access to corporate accounts in the interests of the organisation providing they adhere to Trust guidance regarding the use of this account (see appendix 1). 23. Key services may be given permission to open their own social media accounts (e.g. Facebook) provided that they can demonstrate the corporate account is not appropriate and that they adhere to Trust guidance around the use of this account (see appendices 1 and 2 ). 24. Individuals and services must not set up their own social media accounts which are related to work without the express permission of the Communications Department. 25. Use of social media by individual staff 26. There is only limited access to social media from Trust devices due to the lack of bandwidth. However the potential for the new staff intranet to stream the Trust s Twitterfeed and link to other social media will be explored. 27. It is recognised that staff may use their own home or Trust mobile devices to access social media. Use for non-business related reasons should be limited to breaks or for urgent messages whilst at work. 28. Guidance on the use of social media by staff in a private capacity can be found in appendix 1. 5

6 Appendix 1 Guidance, Responsibilities and Monitoring Guidance on social media staff and the Trust Staff are encouraged to retweet, favourite or share Trust corporate messages via social media. The more staff that share positive Trust messages the more people will be reached. However, as with a press release, only members of the communications department should make Trust announcements, or give Trust news via social media. Urgent and important out of hours communications that need to be given via social media should be flagged up to Tier One on call manager to consider whether to contact a member of the communications team via switchboard. All social media messages must abide by the law for instance in terms of copyright, data protection, incitement to racial hatred, harassment and NHS specific rules e.g. in protecting patient confidentiality. Social media messages can enhance the reputation of the Trust, but must not bring the Trust into disrepute. Only staff and services that have been given permission from the Communications Department may have social media accounts on behalf of the Trust. Guidance on social media and individual private accounts If you identify yourself via social media as an employee of the Trust you need to be particularly careful not bring the organisation or your profession into disrepute. Staff should use the appropriate channels for raising a work related concern, rather than social media, such as discussing with their immediate line manager, discussing with HR or by reporting an incident using the Safeguard system. You should not discuss work-related matters regarding individual patients, staff or incidents nor post photographs relating to these. Neither should you breach patient confidentiality through social media. Staff should not use private social media accounts to communicate with patients or members of staff about work related matters. 6

7 Social media must not be used for whistleblowing concerns should be raised via the relevant Trust policy. Individuals should take measures to protect their own privacy. Guidance on use of social media can be found from many sources including the NMC and BMA. Responsibilities The organisation will take all reasonable steps to ensure that users of the internet service and social media websites are aware of policies, protocols, procedures and legal obligations relating to the use of the internet. This will be done through training and staff communications at departmental and organisation-wide levels. Please see also the and Internet Usage Policy. The Head of Communications will be responsible for corporate social media accounts and for approving applications for team or service social media accounts. Communications will also produce reports on corporate social media activity, and monitor comments about the Trust as part of the communications strategy. The Chief Informatics Officer will be responsible for technical aspects of social media. Account Editors must abide by the Social Media Policy and sign the declaration on the application form (see appendices). They will be responsible for ensuring their accounts are regularly and frequently updated and that the account adheres to this policy. They must remove offensive or inappropriate material and, if posted by a staff member they must also report it to that person s manager. They must consider measures to ensure confidentiality and safety of patients / service users is not breached particularly if children or vulnerable adults are involved. Once aware, line Managers must take appropriate action in line with the Trust s Disciplinary Policy and Procedure if a member of staff posts offensive or inappropriate material on a social media website. All staff must follow the guidance in this policy and have an understanding of the risks associated with the use of social media. Monitoring Bolton NHS Foundation Trust will maintain appropriate monitoring arrangements in relation to internet and social media related usage from the 7

8 equipment and services it provides, and will also monitor the social media sites and accounts which it gives staff permission to set up in connection with Trust business or services. The Trust will typically investigate inappropriate activity under the following circumstances: A report by a member of staff to their line manager raising concern about the content of social media pages and accounts. A concern raised by a line manager about inappropriate personal use of social media. Routine monitoring by the IT Department identifies potential inappropriate use from Trust equipment. Please note that this list is not exhaustive. Inappropriate use of social media is considered misconduct in line with the Trust s Disciplinary Policy and Procedure. The number and type of social media accounts established under this policy will be reviewed every twelve months, along with the usage of each account and whether there is a continued requirement for it within the service. 8

9 Appendix 2 Application to Set Up a Work Related Social Media Account Please complete this form if you wish to apply for permission to set up a social media account and send it to: Heather Edwards, Head of Communications, Trust HQ. Full name: Job title:.... address:.... Telephone number Department/service/campaign that the account will be used for: Has the division/department agreed to this application? Yes Type of account to be set up: (eg Facebook, Twitter etc) Name and web address of new social media account/group: Who will be the account editor?... Job title of account editor: Contact no. for account editor:. What is the purpose of the account?... 9

10 .... Who is your primary audience?.... What measures will you take to ensure confidentiality and safety of patients / service users is not breached particularly if children or vulnerable adults are involved... Why is it not appropriate to use the Trust s corporate account?. How long is the account intended to be used for? Long-term 0-3 months 3-6 months Other (please state).... Will the account editor have sufficient time Yes to monitor and regularly update the account? What other methods of communication do you use/intend to use?... 10

11 Does the account editor know the procedure for reporting Yes the misuse of social media if it is by a member of staff? Declaration I acknowledge that I have read and understand the terms and conditions applicable to the use of social media accounts and agree to abide by the guidelines set out by the Social Media Policy. Signed:. Date:... 11

12 Appendix 3 Use of internet and social media by non-trust personnel Only those people who have signed up to the Trust s Internet and Usage Policy may use Trust devices to access the web and social media or indeed for any reason whatsoever. Staff must never give another person including volunteers and subcontractors - access via their own Trust account or allow them to view confidential information on shared Trust devices. There is currently no access to the internet from bedside television sets. Policy will need to be reviewed should this change. The Trust will not permit non-trust personnel to take photographs or post comments on social media of other patients, visitors or staff members unless informed consent has been given and is appropriate. Examples of where this may be appropriate with consent include photos taken by family members with a new baby. Staff should challenge anyone who appears to be using a mobile device inappropriately to take photos or comment on social media about other patients, visitors or staff. This is important in the maintenance of privacy, dignity and confidentiality. It is particularly important in the case of children or vulnerable adults. Staff should challenge anyone who appears to be sharing inappropriate sites for instance pornography -- with others. If this is with children or vulnerable adults it could be a safeguarding issue and must be reported as such, even if the person sharing the material is a guardian, carer or parent. Similarly staff should challenge anyone who attempts to make inappropriate arrangements to contact a child or vulnerable adult via social media. It is recognised that it will be difficult to manage these aspects of the social media policy. The organisation will help by: Producing advisory posters for wards and departments. Including information in the inpatient bedside booklets. Producing advisory leaflets for parents, children, young people and carers of vulnerable adults. Including information in the relevant patient sections of the Trust website. Ensuring staff are aware of this guidance and can access the policy via the intranet. 12

13 EQUALITY IMPACT ASSESSMENT TOOL To be completed and attached to any procedural document when submitted to the appropriate committee for consideration and approval. Yes/ Comments 1. Does the document/guidance affect one group less or more favourably than another on the basis of: Race Ethnic origins (including gypsies and travellers) Nationality Gender (including gender reassignment) Culture Religion or belief Sexual orientation Age Disability - learning disabilities, physical disability, sensory impairment and mental health problems 2. Is there any evidence that some groups are affected differently? 3. If you have identified potential discrimination, are there any valid exceptions, legal and/or justifiable? 4. Is the impact of the document/guidance likely to be negative? 5. If so, can the impact be avoided? 6. What alternative is there to achieving the document/guidance without the impact? 7. Can we reduce the impact by taking different action? If you have identified a potential discriminatory impact of this procedural document, please refer it to your divisional E and D lead together with any suggestions as to the action required to avoid/reduce this impact. For advice in respect of answering the above questions, please contact Lenny StJean. 13