POLICY 3.44: SOCIAL MEDIA POLICY
Recognizing the risks facing Carobell due to the various forms of technology
available, Carobell has the following policy regarding employee use of
technology.
Computer hardware and software, computer files, the E-mail system, the Internet,
voice mail, pagers, cellular telephones, copy machines and other equipment or
service are furnished for business use and are property of Carobell. Employees
are not permitted to use a password, access a file, or retrieve any stored
communication without authorization. Carobell licenses the use of copies of
computer software from a variety of companies and shall use the software only in
accordance with the license agreements. To ensure compliance with this policy,
computer, E-mail, voice mail, Internet, cellular phone and copy machine usage
may be intercepted and monitored at any time. Employees are not permitted to
violate the privacy of the residents by reproducing any information or images of
them through electronic means and distributing through any form of Social
Networking.
PROCEDURES:
1. Use of the Internet: Access to the Internet through the Carobell network is a
privilege and carries responsibilities reflecting responsible and ethical use.
Internet access must be approved through the Chief Financial Officer (CFO)
and granted through the Systems Administrator. Use of the Internet through
the Carobell network constitutes the individual’s acceptance of this policy.
2. Authentication Process: Employees must first be authenticated through a
Carobell assigned network username and password. The username and
password are the responsibility of the individual to whom it is assigned.
Violations of Carobell’s Internet use policy and any other policy through the
authorized use of the username and password subjects the individual to whom
it is assigned to disciplinary action, up to and including termination.
3. Personal Use: Limited personal use of the Internet is allowed by Carobell.
However, employees are reminded that use of any and all Carobell property is
primarily for the purpose of Carobell’s business. Any personal use of the
Internet, social networking or any electronic communication is expected to be
on the user’s own time and is not to interfere with the person’s job
responsibilities. No personal computers, flash drives or software should be
taken out of the facility without authorization from the CFO or Systems
Administrator.
4. Ethical Use of the Internet: At any time and without prior notice, Carobell
management reserves the right to examine e-mail, personal file directories,
and other information stored on Carobell’s computers. This examination
helps to ensure compliance with internal policies, supports the performance of
internal investigations and assists the management of information systems.
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5. As such, the Systems Administrator and/or the CFO may monitor access to
the Internet. Use of the Internet constitutes acceptance of such monitoring.
a. This policy should be read and interpreted in conjunction with all other
Carobell policies including but not limited to policies prohibiting
harassment, discrimination, offensive conduct or inappropriate
behavior.
b. Employees are prohibited from accessing and using electronic
communication, social networking and the Internet for any unethical
purposes, including pornography, violence, gambling, racism,
harassment, or any illegal activity.
c. Employees are forbidden from using profanity or vulgarity when
posting electronic mail via the Internet.
d. Employees must abide by all federal and state laws with regard to
information sent through the Internet. The Carobell Code of Ethics
strictly prohibits unauthorized release or disclosure of any information
through the Internet or through any other means. Company trade
secrets and confidential information should not be transmitted over the
Internet.
e. Employees are also prohibited from using Internet access through
Carobell systems for any other business or profit-making activities.
6. Social Media Websites, Web Logs and Blogs: Carobell recognizes that the
company’s positive reputation is critical to supporting the mission and
strategic objectives. As such, all employees have an obligation to uphold the
corporate image and not bring the company into disrepute.
a. This duty encompasses employee Internet postings to social media
websites, to internal and external web logs (e.g., blogs) and other
electronic forums in the public domain, including communications
prepared and submitted by employees when off-duty.
b. Employees are expected to exercise sound judgment and discretion on
their personal sites to ensure a distinct separation between personal
and organizational views.
c. Employee use of websites during work hours shall be limited to
business purposes only.
d. As with all other communications, employees shall conduct
themselves in a professional manner when using such forums and
posting comments about Carobell.
e. Public criticism of the company, its employees, residents and/or
customers, whether by name, implication or dissemination of material
contrary to the company’s interest is not permitted.
f. Disclosure of trade secrets and other proprietary information is
prohibited.
g. Public expression of a negative opinion in conflict with the company’s
formal equal employment policy may be conducive or contribute to a
hostile work environment, and is thus prohibited.
h. Carobell may, at its option, monitor internal and external sources to
identify inappropriate use.
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7. Resident Rights to Privacy: Carobell strictly prohibits the unauthorized use of
any electronic or photographic equipment that will photograph, video or in
any way reproduce and record any information regarding the residents or
images of the residents.
a. All employees have the obligation to protect resident privacy rights at
all times.
b. The unauthorized sharing and transmission of images or information
through the use of any Public Computer Sites or Social Networks
(such as My Space, Facebook, Twitter, etc.) regarding the residents is
forbidden and subject to corrective action up to and including
termination of employment for the first offense.
c. Employees are not permitted to provide any information through
Public Computer Sites or Social Networks that may directly or
indirectly identify a Carobell resident and the resident’s privacy and
protected health information. Example: Carobell employees using
Facebook who identify Carobell as their place of employment in their
Facebook profile, and post comments on their wall about a resident,
may lead to the identification of the resident while not mentioning the
resident by name.
VIOLATIONS of this policy may be grounds for disciplinary action up to and
including termination of employment.
8. Privacy Rights and the Use of Public Computer Sites and Cell Phones:
Carobell strictly prohibits the unauthorized use of any electronic or
photographic equipment that will photograph, video or in any way reproduce
and record any information regarding the residents or images of the residents.
The unauthorized sharing and transmission of images or information through
the use of any Public Computer Sites or Social Networks (such as My Space,
Facebook, Twitter, etc.) regarding the residents is forbidden and subject to
corrective action up to and including termination of employment for the first
offense.
All employees have the obligation to protect resident privacy rights at all
times. Employees are not permitted to provide any information through
Public Computer Sites or Social Networks that may directly or indirectly
identify a Carobell resident and the resident’s privacy and protected health
information.
9. Downloading Software:
Employees are prohibited from downloading
software from the Internet. Employees may not install other on-line services
to access the Internet on Carobell owned computers. Employees are not
permitted to install their own copies of any software onto Carobell’s
machines, nor are employees permitted to copy software from Carobell
computers and install it on home or any other computers.
10. Software Licenses: Any employee who knowingly makes, acquires, or uses
unauthorized copies of computer software licensed to Carobell or who places
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or uses unauthorized software on company premises or equipment shall be
subject to disciplinary action which could include termination for the first
offense. Unauthorized reproduction of software is a federal offense and
offenders can be subject to civil damages, criminal penalties, and
imprisonment.
11. Ethical Standards: The use of computers, the Internet, voice mail, E-mail,
pagers, cellular telephones or copiers in ways that are disruptive, or offensive
to others, or harmful to morale is prohibited. This includes, but is not limited
to, the display or transmission of sexually explicit images, messages, and
cartoons, ethnic slurs, racial comments, or anything that may be construed as
harassment or showing disrespect for others.
12. The Federal CAN-SPAM Act: Carobell follows the CAN-SPAM Act in
broadcast e-mails or those with a commercial promotion of a service or
product. The CAN-SPAM law requires that a commercial e-mail message,
referred to below simply as “e-mail,” include the following three items:
a. Message Identification. The e-mail must include a “clear and
conspicuous identification that the message is an advertisement or
solicitation.” The Act does not require the identification to appear in
the subject line. The message identification requirement is not
applicable if the recipient has given previous permission to send such
messages.
b. Opt-out Requirements. Recipients must be given an opportunity to
“opt-out” of further solicitations. This must be achieved by including
either a functioning return e-mail address or a link to another Internetbased mechanism that may be used for opting out. The opt-out
mechanism must remain available to the recipient for thirty days after
the e-mail transmission. The sender must honor the opt-out request
within ten days from receipt of the request. Even if a recipient has
given prior consent to receipt of e-mail, the message must contain an
opt-out provision.
i. A sender may include an option for a recipient to opt out of
some but not all messages.
ii. If an entity has “separate lines of business or divisions,” an optout by an e-mail recipient will be treated as an opt-out only for
that line or division, provided that the e-mail has identified the
sender as a line or division within the entity.
iii. A vendor who sends messages on behalf of Carobell must also
include the opt-out provisions.
c. Sender Identification. Senders must include a valid physical address.
13. Policy Violations: Employees should notify the Chief Financial Officer upon
learning of violations of this policy. Employees who violate this policy will
be subject to disciplinary action, up to and including termination
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