BRIGHAM AND WOMEN S HOSPITAL HUMAN RESOURCES POLICIES AND PROCEDURES SUBJECT: SOCIAL MEDIA, ELECTRONIC COMMUNICATION and ACCEPTABLE USE POLICY #: HR-503 EFFECTIVE DATE: January 1, 2008 POLICY This policy sets forth guidelines for the proper use of Brigham and Women s Hospital (BWH) computer technology and communication systems including but not limited to hardware, software, e-mail, fax, Internet, social networking sites, text messaging and voice mail systems. These systems are business tools provided by the hospital for use of the hospital s business or work-related matters. As such, all aspects of the hospital s computer technology and communications systems are the property of the hospital. I. PRIVACY Employees should not have any expectation of privacy with respect to e-mail, voice mail, Internet, fax or other electronic communication vehicles. Although the hospital does not intend to routinely monitor such communications, it reserves the right to review or inspect, for legitimate business reasons, the product of any electronic communication vehicle with or without notice. II. PASSWORDS Passwords are intended to keep unauthorized individuals from accessing content inappropriately and should not be shared. III. CAUTIONS A. Employees should use common sense and good judgment when sending messages to each other. B. E-mail messages are electronic communications that do not disappear, and employees should be aware that the delete command doesn t mean that e-mail is irretrievably erased from the computer system. C. E-mail messages can be reproduced in written form and are discoverable in litigation. Revised January 2010 1
IV. PERSONAL USE The hospital allows incidental and necessary personal use of its electronic communication vehicles and devices provided that such use is kept to a minimum and does not interfere with an employee s productivity or the productivity of other employees. V. PROHIBITED ACTIVITIES Prohibited activities may include but are not limited to: A. Transmitting and/or downloading any messages that contain discriminatory, derogatory, inflammatory, offensive or harassing remarks about a person s, or group s sex, race, religion, age, gender, gender identity, national origin, disability, sexual orientation, marital or veteran status. B. Transmitting and/or downloading of sexually explicit materials, including messages, videos, images and cartoons. C. Annoying or harassing other individuals. D. Solicitation on behalf of political, religious or other personal causes or personal business ventures. E. Distributing or storing chain letters. F. Because audio, video and picture files require significant storage space, downloading non-work related material is not permitted. G. Use of Internet access to visit Web sites that contain sexually explicit, racist or other material that management, in its sole judgment, considers offensive, or posting messages on such sites. H. Engaging in illegal, fraudulent or malicious activities. I. Use of personal e-mail accounts (i.e. Gmail, Yahoo, AOL, Hotmail, etc) for business related communications instead of using the BWH-provided e-mail accounts (i.e. partners.org) J. Auto-forwarding of any BWH-provided e-mail to an outside account. K. Use of peer to peer (or P2P ) software (examples include, but are not limited to BitTorrent, Limewire, Napster, and Gnutella). Revised January 2010 2
L. Receipt of, possession of, transmitting and/or downloading, installing, publishing, distributing or copying any copyrighted or trademarked materials, such as software, music or movies without the written consent of the copyright owner. Copyright violations may lead to significant financial penalties in addition to corrective action. M. Attempting to disguise the employee s name or origin of transmission over e- mail, Internet, fax or voice mail. VI. DOWNLOADING FROM INTERNET A. Storage requirements must be met before attempting to download a file from the Internet or upload a file to the network. B. Any download should be considered virus infected until proven to be safe. Do not download material unless you are sure that you have virus protection on your device and that it has the most recent updates installed. C. Files downloaded from a foreign (?) site should be quarantined to the local hard drive and virus-scanning software should be used to disinfect the file. D. Non-work related files should not be downloaded or stored on a BWH system. VII. SOCIAL NETWORKING Due to the emerging nature of social networking (e.g., You Tube, Facebook, itunes, LinkedIn, Twitter etc.; Web feeds such as RSS; blogs and other forums, BWH employees who violate the guidelines relating to revealing patient information or making inappropriate comments will be subject to discipline up to and including discharge under the HR Corrective Action Policy. 1. Institutional representation on online social networking platforms can only be initiated or authorized through the combined efforts of the BWH Marketing and Public Affairs departments. To be clear, there can be no institutional sites or pages on You Tube, Facebook, Twitter, etc., that are presented as official pages of BWH, including use of name and logo, unless these are developed and/or approved by the Marketing and Public Affairs departments. Please see BWH Website Policies. 2. Content owners of pages that have been approved are responsible for posting and using content in accordance with BWH values, the BWH Code of Ethical Conduct, HIPAA, the PHS Conflict of Interest Policy and other relevant policies. Revised January 2010 3
3. Content owners are responsible for monitoring and maintaining web content: a. Content must be current and accurate. b. Content owners will not engage in any communications that would be unacceptable in the BWH workplace, including sharing information about patients, their families, employees, donors or anyone who has a connection with BWH, without permission from that person and Marketing or Public Affairs, or in the case of donors, the Development office. c. Content owners will respect copyrights and disclosures and will not reveal proprietary financial information, intellectual property or similar sensitive or private content about BWH. d. Content owners are responsible for constantly monitoring postings to social media sites and deleting postings that do not adhere to our policies. Social Computing Guidelines for BWH Employees: Online social media enable BWH employees to engage in professional and personal conversations. These guidelines apply to employees who identify themselves with BWH in social media venues such as professional society blogs, Linked In, Facebook, etc. Activities which do not identify employees with BWH, do not discuss BWH and are purely about personal matters would normally fall outside these guidelines. 1. BWH employees may not have personal blogs in their work-related capacity. 2. Employees must follow the same Code of Ethical Conduct, Conflict of Interest Policy, HIPAA and general civil behavior guidelines cited previously in these policies. 3. BWH employees may list BWH as their place of work on personal profiles such as those on Linked In. However, if an employee identifies him- or herself as a member of the BWH community in any online forum, it must be made clear that that person is not speaking for BWH. The following disclaimer should appear in the post: The comments I am expressing are my own and do not represent the views or opinions of Brigham and Women s Hospital or its administration. 4. BWH employees who participate in off-duty misconduct, communications or activities, and such conduct, communication, or activity have the potential of jeopardizing the reputation or standing of BWH in the community or place the organization in a bad light will be subject to discipline up to and including discharge. In addition, if BWH s name, brand, logo or the work with which an employee is associated is mentioned in an online forum; and the content is unflattering or raises concerns or questions, the employee should contact BWH Public Affairs before responding. The goal is to avoid a public airing of concerns or issues without consultation with and authorization from Public Affairs. Revised January 2010 4
VIII. CONFIDENTIAL INFORMATION A. Employees are expected to use electronic communications in a way that respects the confidential information of BWH, its employees and its patients. Employees must use discretion in transmitting patient identifying information by electronic communication when necessary to perform one s job. Transmission must occur in a way that guarantees it will be seen only by a recipient who has a need to know the information. Please refer to the Breach of Confidentiality-Sanctions for Employees and Medical Staff Policy# HR- 501for additional information. B. When faxing confidential information, employees should use caution. Employees must use a fax cover sheet with that includes the name of the hospital, the correct fax number, the sender s phone number and must ensure that the receiving fax machine is in a secure location and/or the intended receiver is available to immediately receive the fax. C. If an employee is an unintended recipient of either an e-mail or fax, the employee should contact the originator of the message without reading the content. If the message contains patient information, the employee should take steps to destroy the information, i.e., shredding, and should contact the originator of the fax or e-mail to correct IX. TELEPHONE USAGE A. Unauthorized use of hospital telephones and inappropriate and excessive usage of personal telecommunication devices during work hours may result in corrective action. B. Employees may be required to reimburse the cost of unauthorized telephone calls. X. CORRECTIVE ACTION A. Managers in conjunction with the Human Resources Consultant will determine violations of this policy. B. An employee who has been found to be in violation of this policy will be subject to the hospital s corrective process as outlined in the Corrective Action, HR-303. Certain violations may subject the violators to civil and criminal penalties under federal and state law and additional liabilities of copyright holders for infringement. Revised January 2010 5
APPROVED BY: Vice President Human Resources Chief Operating Officer This policy is intended as a guideline to assist in the consistent application of Brigham and Women s Hospital policies and programs for employees. The policy does not create a contract implied or expressed, with any hospital employees who are employees at will. The hospital reserves the right to modify this policy in whole or in part, at any time, at its sole discretion. Revised January 2010 6