Communications and media policy (including social
media policy and guidelines for officers).
September 2014
Version two
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Scope
This policy applies to all council employees (including third party agents, temporary
staff and anyone who has access to the council’s network). It gives guidelines to staff
and managers on external communications, contact with the media and use of social
media.
The policy also sets out how we can effectively manage social media usage and
indicates how any risks or pitfalls can be minimised or mitigated.
Introduction
Council employees are governed by strict rules on impartiality and publicity and are
not allowed to enter into any form of communication that supports or promotes, or
may be interpreted as supporting or promoting, the political views of any councillor or
group of councillors. Any communications either through public statements or the
media (including social media) must only support and promote council policy and not
politicians or political parties.
External communications and working with the news media
To safeguard individual officers and protect the integrity and impartiality of the
council as a whole all media enquiries should be referred to the council’s
communications team before any comment is given.
In line with the Employee Code of Conduct no member of staff is permitted to make
any statement to the media, or any other public statement, which concerns the
business of the council, unless authorised to do so.
In support of the above no employee should ever, either during the course of their
employment or in their private life:
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Publicise confidential information gained in the course of their employment.
Maliciously undermine the council and its decisions by adverse or negative
comments.
Take personal issues concerning their employment to the media.
Bring the council into disrepute by the extremity of their views.
Any evidence of the above will not be tolerated by the council and this applies
whether it takes place during or outside of working hours and may result in
disciplinary action (please see the ‘breaches of this policy’ section for further
information).
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The council may also be liable for the actions of officers whose comments or content
on social media in a private capacity are closely connected to the work environment.
If you are a trade union representative, local resident or member of a local action
group, you should take care to ensure that any statements you make in such a
capacity do not breach this policy or the employee code of conduct. The council
recognises your right to take part in lawful trade union activity; however this does not
extend to a right to make statements that are malicious, untruthful or irrelevant.
Social media
Social media is the term used for online tools, websites and interactive media that
enable users to interact with each other by sharing information, opinions, knowledge
and interests. This policy and guidelines cover social media issues over the internet
and by email, smart phones, social networking sites, blogging, and tweeting that are
directly work related or through personal use that can be directly or indirectly linked
to work.
Social media increases our access to audiences and improves the accessibility of
our communication. It enables us to be more active in our relationships with citizens,
partners and stakeholders and encourages people to be involved in local decision
making, enabling better engagement and feedback, ultimately helping to improve the
services we provide.
For the purposes of this policy, the term ‘social media’ covers sites and applications
including but not restricted to Facebook, Twitter, MySpace, Flickr, YouTube,
LinkedIn, blogs, discussion forums, wikis and any sites which may emerge after the
creation of this policy where Salford City Council could be represented via employee
participation.
Salford City Council acknowledges social media as a useful tool however, clear
guidelines are needed for the use of social media sites to ensure they are used
effectively as part of a wider communications mix and that their use does not expose
the council to security risks, reputational damage or breach the Data Protection Act.
Risks
The following risks have been identified with social media use (this is not an
exhaustive list):
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Virus or other malware (malicious software) infection from infected sites.
Disclosure of confidential information.
Damage to the council’s reputation.
Social engineering attacks (also known as ‘phishing’).
Bullying or witch-hunting.
Civil or criminal action relating to breaches of legislation.
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Breach of safeguarding through the use of images or personal details leading
to the exploitation of vulnerable individuals.
In light of these risks, the use of social media sites should be regulated to ensure
that such use does not damage the council, its employees, councillors, partners and
the people it serves. As such this policy aims to ensure:
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A consistent and corporate approach is adopted and maintained in the use of
social media.
Council information remains secure and is not compromised through the use
of social media.
Users operate within existing policies, guidelines and relevant legislation.
The council’s reputation is not damaged or adversely affected.
Policy framework
This policy provides a structured approach to using social media and will ensure that
it is effective, lawful and does not compromise council information or computer
systems/networks.
Users must ensure that they use social media sensibly and responsibly, in line with
corporate policy. It must be ensured that their use will not adversely affect the
council or its business, nor be damaging to the council’s reputation and credibility or
otherwise violate any council policies.
Users must not set up accounts, groups, pages or profiles, or take part in any
social media activity on behalf of their service area without first consulting the
web team and the relevant head of service. As part of this process a moderator
must be agreed for each account, group, page or profile.
Responsibilities of officers
Officers, who in the course of their employment place content on behalf of Salford
City Council, are personally responsible for any content published on any form of
social media. Publishing or allowing to be published (in the form of a comment) an
untrue statement about a person which is damaging to their reputation may incur a
libel action. The council could also potentially be liable for the actions of our
employees in these circumstances.
Social media sites are in the public domain and officers must ensure the reliability
and be confident of the nature of the information published. Once published, content
is almost impossible to control and may be manipulated without consent, used in
different contexts, or further distributed.
Officers must not disclose anyone’s personal details such as home addresses and
telephone numbers. Officers must ensure that any personal or sensitive information
is handled in line with the council’s Data protection policy.
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Safeguarding issues are paramount because social media sites are often misused
by offenders. Safeguarding is everyone’s business – all officers have a responsibility
to report any concerns about other site users. For children and young people contact
the Referral and Initial Assessment team on 0161 603 4500 or email
worriedaboutachild@salford.gov.uk. For any concerns relating to adults the reporting
line is 0161 909 6517 (Monday to Friday 8.30am to 4.30pm) or 0161 794 8888
outside these hours, or email worriedaboutanadult@salford.gov.uk. For more
information about adult abuse go to www.salford.gov.uk/adultabuse.htm
Officers must not publish or report on meetings which are private or internal (where
no members of the public are present or it is of a confidential nature) or are Part 2
reports (which contain confidential information or matters which are exempt under
the provision of the Local Government (Access to Information) Act 1985). Use of
social media in meetings must comply with the guidance for using electronic devices
during council meetings.
Copyright laws still apply online. Placing images or text from a copyrighted source
(e.g. extracts from publications or photos) without permission is likely to breach
copyright. If officers are unsure about publishing anything they must seek permission
from the copyright holder in advance.
Council social media must not be used for party political purposes or specific party
political campaigning purposes as the council is not permitted to publish material
which ‘in whole or part appears to affect public support for a political party’ (Local
Government Act 1986). Officers must not seek to promote councillors’ social media
accounts during the pre-election period.
All council officers must not post via social media any inappropriate, abusive,
bullying, racist or defamatory messages to members of the public, councillors or
colleagues either in or outside the work environment.
Officers using social media must be aware of and comply with the council’s Code of
conduct for employees, Disciplinary rules for local government services employees.
Officers should also be aware that misconduct arising from the misuse of social
media will be treated in the same way as any other form of misconduct and in line
with the council’s Local disciplinary procedure. For more information in relation to
disciplinary action please see the ‘breaches of this policy’ section.
Council officers must be aware of their own safety when placing information on the
internet and must not publish information which could leave them vulnerable.
If an officer receives any threats, abuse or harassment from members of the public
through their use of social media as part of their work they must report such
incidents immediately to their line manager. Officers should also refer to the Violence
to staff policy.
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This policy and guidelines is in addition to any professional standards that govern
officers’ area of work, and in addition to all other Salford City Council policies which
officers are expected to comply with.
Personal use of social media
Officers must be aware that, where they are identified directly or indirectly as a
council employee, when using social media in a personal capacity it is expected they
behave appropriately and in line with council values and policies. Any inappropriate
online activity will not be tolerated by the council and this applies whether the
inappropriate online activity takes place during or outside of working hours and may
result in disciplinary action (please see the ‘breaches of this policy’ section for further
information).
The council may also be liable for the actions of officers who post comments or
content on social media in a private capacity which are closely connected to the work
environment.
Officers using social media in a personal or work capacity must be mindful of their
professional working role and maintain professional boundaries with children and
vulnerable adults at all times.
It’s your own personal choice whether or not you choose to participate in any kind of
social media activity in your own time – the views and opinions that you express are
your own. However, as a council officer you should be aware that any information
which you post about Salford City Council cannot be kept entirely separate from your
working life. This is in line with the Code of conduct for employees, it is
recommended that you familiarise yourself with the full document. Any information
published online can be accessed around the world in seconds and will be publicly
available for all to see. Other helpful tips are:
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Add a disclaimer to your social media profile to make it clearer that your
personal accounts are personal – for example: ‘These views are my own’.
Check your online privacy settings so that you can understand who can see
the information you publish and who can view your personal information.
A work e-mail address should not be used when registering on social media
sites for personal use.
Mature discretion should be exercised in all personal communications in a
social media environment.
Officers’ obligations must be complied with in respect of other council policies
when using social media, particularly confidentiality issues and proprietary
information policies.
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Principles for using social media in your work
You should follow these five guiding principles for any social media activities that
form part of your work:
Be respectful – set the tone for online conversations by being polite, open and
respectful. Use familiar language, be cordial, honest and professional at all times.
Make sure that you respect people’s confidentiality – do not disclose non-public
information or the personal information of others.
Be credible and consistent – be accurate, fair, thorough and transparent.
Encourage constructive criticism and deliberation. Make sure that what you say
online is consistent with your other communications.
Be honest about who you are – remember that you are an ambassador for your
organisation. It’s important that any accounts or profiles that you set up on behalf of
Salford City Council are clearly and easily identifiable as corporate profiles. Be clear
about your own personal role and the service that you represent.
Be responsive – make an effort to share what you know. Offer insights where
appropriate and put people in touch with someone who can help if you can’t.
Respond to questions and comments in a timely manner (make sure you manage
user expectations for the type of social media that you’re using – e.g. the council
publishes its social media rules).
Be confident – don’t be scared of participating. Follow these rules and seek further
guidance if you need it. If you’re about to publish something that makes you even the
slightest bit uncomfortable, pause to think about it. Feel confident in what you say
before you say it – and say it as clearly as you can.
Help when moderating
If you are moderating any kind of online space that is managed by Salford City
Council, we have some basic rules about what kind of content is acceptable. We
agree to publish all contributions from our users (whether or not we agree with what
the user is saying), providing that they don’t break these rules.
In addition to our rules for users’ content a handy step by step flowchart has been
created to guide you through a range of scenarios you will encounter as a
moderator.
Guidance on capturing social media posts
Posts made using third party sites such as Facebook or Twitter are not held or within
the control of the council - posts can be deleted by site administrators without
knowledge or consent of the council. In exceptional circumstances, copies of posts
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may be made and retained by the council, (e.g. as evidence of inappropriate posts)
in line with relevant council procedures, (depending on the nature of the allegation)
and the Monitoring of Communications Policy. These copies will be held for a period
dependent on the type of investigation they are subject to, (e.g. disciplinary, audit,
criminal, etc).
Where inappropriate use is suspected, in addition to reporting the incident using the
relevant reporting procedure (see ‘Responsibilities for officers’), it is suggested that
staff should also pro-actively attempt to capture any inappropriate posts (before they
might be deleted). This can be done in one of the following ways:
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For Facebook or Twitter pages where staff are acting in a professional
capacity on behalf of the council as site moderators. Copies should be
made as part of any potential investigation (press, 'alt+Prt Scrn,' and copy into
MS Word) and reported to both the relevant authority within the council, (e.g.
line manager, human resources, the contact for safeguarding children or
adults as detailed under ‘Responsibilities for officers’), and relevant council
site moderator. Any inappropriate content should where possible be initially
hidden so that it is no longer visible, (not deleted) by the moderator, pending
any further investigation. This means that the post in question would still be
accessible to moderators should evidence of it be required. Once the
investigation and any potential appeal is concluded - this post can be deleted
by the moderator.
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For Facebook or Twitter or other pages where the council is not a
moderator, (e.g. employees personal Facebook pages). Copies should be
made as part of any potential investigation (press, 'alt+Prt Scrn,' and copy into
MS Word) and reported to both the relevant authority within the council, (e.g.
line manager, human resources, the contact for safeguarding children or
adults as detailed under ‘Responsibilities for officers’), as well as following the
social media sites own reporting procedures where appropriate.
Please note that this is just one means of gathering evidence of inappropriate use; it
does not preclude the gathering of other types of evidence, e.g. witness statements.
Guidance for managers
It is every manager’s responsibility to ensure that this policy is adhered to by
employees and they may at any time monitor, review and investigate the use of
social media used for council purposes by officers.
Managers may also be required to review and investigate the personal use of social
media that takes place in or outside of working hours where concerns are raised or
identified (please refer to the ‘Personal use of social media’ section of this policy for
more information). Managers must only review and investigate personal use of social
media where a complaint or concern is raised or identified and must not as a matter
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of course monitor employees social media pages. It is likely that this information will
already be in the public domain therefore permission to access personal accounts
will not be required.
Officers using social networks, and in particular those who are authorised to use
them for work purposes, may have concerns or queries about impartiality,
confidentiality, conflicts of interest or commercial sensitivity and managers should
provide advice and support when requested.
Breaches of this policy
Salford City Council will act quickly in cases of unauthorised external
communications and/or social media misuse. Any clip or comment that breaches the
rules set out in this policy must be removed from the website concerned in order to
limit any potential damage. Once instructed, the officer concerned must remove the
information or post immediately. Any refusal or failure to remove the content from the
social media site may, in itself, amount to an act of gross misconduct for failing to
follow a reasonable instruction.
Any breaches of this policy including unauthorised external communications, public
statements, contact with the news media or inappropriate online activity may lead to
access being withdrawn and disciplinary action being taken. Serious or repeated
breaches of this policy by council employees may constitute gross misconduct and
may result in dismissal. Breaches of the policy and/or cases of misconduct will be
dealt with in line with the Local disciplinary procedure.
The following are some examples of inappropriate activity that may constitute gross
misconduct (this is not an exhaustive list):
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Defamatory comments relating to the council or damaging its reputation or
that of its partners.
Breaching confidentiality.
Any offensive, defamatory, discriminatory, threatening, harassing, bullying,
hateful, racist, sexist or other inappropriate comments released in a public
statement or posted on any social network site or blog relating, directly or
indirectly, to your employment.
Posting material which is in any way unlawful, and which does not comply
with the equality laws contained within the Equality Act 2010 and associated
legislation.
Gross misconduct may also include conduct that takes place inside or outside work
which impacts upon an employee’s suitability to do their job or damages the council’s
reputation.
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Other violations of this policy, such as breaching the Data Protection Act, could lead
to fines being issued and possible criminal or civil action being taken against the
council or the individual(s) involved.
Where inappropriate social media activity raises concerns in relation to safeguarding
children this would be managed through the procedures for managing allegations
against workers, carers and volunteers who have contact with children.
Relationship with other council policies
This social media policy should be read in conjunction with:
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The guidance for using electronic devices during council meetings.
The Code of conduct for employees which provides a framework for all
employees with regards official conduct.
The Disciplinary rules for local government services employees which sets
standards of conduct at work, provides procedures to ensure these standards
are adhered to and provides a fair method of dealing with alleged failures to
observe them.
The Internet and electronic communications usage policy which details the
acceptable use of the council’s internet and electronic communications.
The Monitoring of communications policy which outlines the requirements and
procedures to be followed when the monitoring of communications is
undertaken.
The Acceptable usage policy for council information technology systems
which defines the principles that govern the use of information and information
holding assets by all users.
The Smartphone and tablet usage policy which defines usage of council
provided and personally owned devices.
The Corporate information security policy which details the council’s legal and
statutory obligations to protect its information assets.
The Data protection policy which outlines the council’s adherence to the eight
principles of the Data Protection Act 1998 with regards the collection, storage
and use of personal data.
The Salford standards across adult and children safeguarding. This document
represents the minimum standards of safeguarding practice expected by the
Salford Safeguarding Children Board and the Salford Adult Safeguarding
Board across Salford.
The E-safety practice guidance published by the Salford Safeguarding
Children Board. This guidance includes best practice and safe practice on the
use social media for anyone working or volunteering with children and young
people.
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The Violence to staff policy which offers advice to assist in reducing the
potential for violence, or handling situations should they occur as well as
outlining the procedures for reporting incidents.
You should also read: the Code of Recommended Practice on Local Authority
Publicity. This code applies in relation to all decisions by local authorities relating to a
range of publicity and includes ‘the maintenance of websites – including the hosting
of material which is created by third parties’; Open and accountable local
government a guide for the press and public on attending and reporting local
government meetings.
Complaints
If an employee has any concern about anything posted on a social media site which
the council has responsibility for, they should contact their manager in the first
instance and provide any supporting evidence to enable appropriate action to be
taken (see ‘Guidance on capturing social media posts’). A social media platform will
not, of itself, raise concerns, and not all may be monitored continuously. Further
information can be found on the website.
Useful contacts
All external communications with the media or public must be cleared with the
communications team - public.relations@salford.gov.uk or 0161 793 3410
If you need advice about using social media in your work, please get in touch with
others who can help you.
Web team – webmaster@salford.gov.uk or 0161 793 2958
Human Resources – Ask HR or 0161 793 2000
Safeguarding children – worriedaboutachild@salford.gov.uk or 0161 603 4500
Safeguarding adults – worriedaboutanadult@salford.gov.uk or 0161 909 6517
(Monday to Friday 8.30am to 4.30pm) or 0161 794 8888
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