Communications 01: Social Media Policy: To communicate the Network s mission publicly, to inform and engage the community regarding the Network s activities, and to establish appropriate and professional use of Social Media by Staff Members and Affiliates. I. Applicable Definitions: 1. Social Media: any form of electronic communication or media through which users share and/or communicate information, ideas, personal messages, and other content. Examples of electronic media include, but are not limited to, websites for social networks, microblogging, and video such as Facebook, Twitter, LinkedIn, Instagram, Wikipedia, Flickr, and YouTube. For purposes of this Communications 01, public comments on media websites (such as comments on a WRAL-TV online story) also constitute Social Media. 2. Official Representation: having authorization to communicate on behalf of the Network or a department within the Network. Examples of Official Representation include, but are not limited to: The Network s Twitter account; The Network s Facebook account; Responding to or directing any statements, whether verbal, written, or electronic, to the media; and Making or presenting statements to the general public. 3. Unofficial Representation: is defined as: Any use of Social Media in which a Staff Member and Affiliate identifies his/her affiliation with NCCN. Any use of Social Media in which the subject matter being discussed is related to the Staff Member or Affiliate s affiliation with the Network. Examples of Unofficial Representation include, but are not limited to: Identifying the Network as a Staff Member s or Affiliate s employer ; Personal blogging, or other electronic communications, which identify, refer to, or otherwise, discuss the Network and/or the patient population it manages; and Participation in electronic discussions about the Network and/or the patient population it manages. 4. Personal Use: a Staff Member or Affiliate s use of Social Media that is personal in nature and which does not reference, identify, or otherwise discuss the Network. II. Network Expectations:
The following expectations apply to Staff Members and Affiliates use of Social Media and his/her public communications related to the Network and/or its patient population. Nothing in this Policy is intended to interfere with the rights afforded by the National Labor Relations Act or other applicable laws. A. Protecting Confidentiality Electronic communications via Social Media are held to the same laws and policies as verbal and written communications. Staff Members and Affiliates shall not communicate, post, or tweet any Confidential Information, as that term is defined by the Network s Privacy & Security Policies and Procedures. Staff Members and Affiliates may not post pictures or videos that include patients, without appropriate written and signed consent and/or authorization from all individuals visible in the picture and/or video. Any potential violation of the Network s Privacy & Security Policies and Procedures in relation to Social Media should be directed to the Communications Manager and Compliance Officer for further investigation and potential recommended disciplinary action. B. Respecting Copyright Laws Staff Members and Affiliates shall abide by copyright laws by ensuring that they have permission to use or reproduce any copyrighted text, photos, graphics, video, or other material owned by others. Use of the Network s logo, CCNC s logo, or other trademarked material to imply Official Representation without permission from the Communications Manager, who will consult the CCNC Logo Specification Reference Guide as appropriate, is prohibited. C. Posting with Caution All online activities, even those that seem private, may be intentionally or unintentionally public, particularly if copied, forwarded, or printed. Staff Members and Affiliates should be mindful that all text, images, and video can remain on the Internet indefinitely even after efforts have been made to remove them. Therefore, good judgment should be used in posting content on the Internet. D. Transparency Staff Members and Affiliates must identify themselves and their employer when communicating on behalf of NCCN regarding a subject matter that relates to their area of expertise or professional role with the Network. NCCN will not pay for comments or planting statements anonymously or under false names that make the statement appear to be from an objective outsider. E. Reporting Negative Posts/Non-Compliance with this Policy Nothing in this Communications 01 is intended to or will be applied in a manner that limits Staff Members and Affiliates rights to engage in protected concerted activity as prescribed by the National Labor Relations Act.
In an effort to protect the good reputation of the Network, however, Staff Members and Affiliates who encounter negative communications related to NCCN are encouraged but not required to forward the posts to info@nwcommunitycare.org. F. Medical Advice Electronic communications via Social Media on behalf of the Network should be for, and should state that they are for general information or for educational purposes only. Content should not be written in a way that could be interpreted as professional medical advice. Staff Members and Affiliates shall not address individual medical conditions through Social Media. III. Official Representation The following applies to Staff Members and Affiliates permitted by the Network to provide Official Representation. A. Authorization to Represent NCCN Any communication (verbal, written, or electronic) appearing on social media or other electronic web-based sites, appearing to be an Official Representation of the Network that is created or exists without prior approval from the Communications Manager or the Network Director is subject to review and may be amended or removed. B. Maintaining a Professional Presence All communications made by Staff Members and Affiliates related to the Network, its Staff Members, Affiliates, and/or its patient population shall not be obscene, defamatory, profane, proprietary, libelous, or harassing. When communicating publicly, Staff Members and Affiliates should use good, professional judgment. Those who are unsure about whether material could be interpreted as inappropriate should contact the Communications Manager before making a public communication via Social Media or otherwise. C. Monitoring and Managing of Accounts The Communications Manager is responsible for monitoring all Official Representation in Social Media. The Communications Manager may amend and/or remove any posts that are inaccurate, inappropriate, or unrelated to the work of the Network. The Communications Manager may delete an account that has become inactive, has been hacked, used for spam, or has violated this Communications 01. The Communications Manager will serve as the Network s Social Media Administrator and in that role will: o Manage account operations including, content, community interaction, passwords, and account settings in compliance with all other policies and procedures;
o Maintain Social Media accounts by utilizing desktop/laptop computers, smartphones, and/or other devices, as needed; o Designate a Backup Administrator who is knowledgeable about the role of the Social Media Administrator and who will have administrative rights to access and set account settings and passwords; and o Notify the Backup Administrator when back-up support is required. The Backup Administrator will assume Social Media responsibilities at the direction of the Communications Manager. IV. Personal Use and Unofficial Representation A. Separation of professional and personal online presences Staff Members and Affiliates must make a clear distinction between their personal and professional online presences. When personal conduct and opinions are linked to the Network in any way, Staff Members and Affiliates may be acting as Unofficial Representatives of the Network. NCCN email (nwcommunitycare.org) should not be used on personal profiles or blogs. For non-business related Social Media, Staff Members and Affiliates must use a personal email address and must not attribute to or imply that personal opinions or statements are endorsed or supported by the Network. Staff Members and Affiliates who in any way indicate that they are affiliated with the Network are encouraged to include a disclaimer, such as the one below, to be clear that they are not officially representing the Network: o The views and opinions expressed here are my personal views and opinions and do not represent those of Northwest Community Care Network. Staff Members and Affiliates must not use Social Media to defame the Network, any other Staff Member or Affiliate of the Network, any member of the Network s patient population, the Network s competitors, its community partners, and/or its vendors. Staff Members and Affiliates shall comply with all applicable state and federal laws, including, but not limited to, HIPAA, 42 CFR Part 2, Title VII, trademark, trade secret, copyright, and other intellectual property laws. Staff Members and Affiliates shall not use Social Media to discriminate or harass any individual based on race, color, gender, religion, national origin, disability, age, veteran status, genetic information or any other characteristic protected by state or federal law. Staff Members and Affiliates must not use social media to harass, bully or intimidate other Staff Members and Affiliates or otherwise engage in conduct that is prohibited by NCCN policies. B. Executive Leadership Executive Leadership (the Network Director, Deputy Network Director, and Clinical Director) should consider whether their personal views could be interpreted as Official or Unofficial Representations, even with a disclaimer present. Executives have a special responsibility when it comes to online communications and should think before posting and act according to how they would like to be perceived in a professional capacity.
C. Use of Social Media at Work Staff Members and Affiliates are required to follow and adhere to their respective employers policies and procedures regarding access to Social Media at their place of employment. NCCN staff members may access social media for professional use while on working time, whether on Network computers or personal electronic devices. V. Enforcement Failure to comply with the provisions of this Communications 01 may result in corrective action up to and including termination. If a Staff Member or Affiliate observes, learns of, or otherwise has knowledge about a potential violation of this Communications 01, he/she shall notify the Communications Manager or his/her supervisor as soon as practical. Depending on the nature of the potential violation, the Communications Manager will notify the Network s Management Team as soon as practical. After a review of the matter, the Network s Management Team will take appropriate steps to notify the Staff Member s or Affiliate s employer and will request discipline as determined by the Management Team. If the matter involves potentially identifiable patient information, the Communications Manager will notify the Compliance Officer as well. If matter is confirmed to involve identifiable patient information (IIHI/PHI), the Compliance Officer will address the matter in accordance with the Network s Privacy & Security Policies and Procedures. The Communications Manager will work with the Staff Member or Affiliate, the Communications Team, the appropriate employer, including the employer's IT, as appropriate, to investigate the Communication. Approval Date: September 8, 2014 Effective Date: September 8, 2014 Revision Date: None Review Date: None
Jim Graham, Network Director Written by: Michael D. Cottingham, Communications Manager