002 Social Media Policy

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1. Introduction

The purpose of this policy and strategy is to provide an overarching framework for the use of social media within the Integrated Care Board for mid and south Essex hereafter referred to as the ICB and the Integrated Care System, hereafter referred to as the ICS.  

2. Purpose / Policy Statement

This policy applies to all Mid and South Essex ICB (known as NHS Mid and South Essex) employees, including apprentices, contractors, volunteers, non-executive directors, and governors, covering personal and organisational accounts.

The purpose of this document is to:

• Provide guidance for using social media, ensuring the ICB, staff and service users are not brought into disrepute because of the inappropriate use of social media.
• Provide a framework for the use of social media accounts operated on behalf of the ICB and wider ICS to ensure they are managed consistently and in line with information governance requirements.
• Support staff using social media for professional development, for example through a personal account that identifies them as an ICB employee and used to discuss professional issues.

3. Scope

The policy will apply across all parts of the organisation as a statutory NHS body and includes all ICB staff and those in the wider ICS as appropriate. It relates to all areas of ICB activities as a commissioner of NHS services and persons engaged in business on behalf of the wider ICS.

4. Definitions

• Social media: internet-based media sites that are used by individuals or groups for two-way interaction and discussion. This could be to express opinion, give advice or share information.
• Social media channels and platforms: This includes but is not limited to: Facebook, Twitter, Instagram, LinkedIn, TikTok, Snapchat and YouTube. There is also Yammer which is an internal social network for ICB staff.
• Social media accounts: Named profiles on a social media platform representing a person or organisation and enabling them to participate in information/opinion sharing and conversation.
• Corporate social media accounts: The named and trusted accounts representing Mid and South Essex ICB and ICS. These are run solely by the corporate communications team.
• Trusted accounts: Social media accounts that have been checked and validated to be authentic. On Twitter this is visually represented by a ‘blue tick’

5. Roles and Responsibilities

All ICB Employees and Board members

All Integrated Care Board Members and staff have a duty to ensure they familiarise themselves with and adhere to the guidelines set out in this policy.

If a member of staff is concerned about something relating to the ICB and ICS that they see on social media, it is their professional responsibility to inform their line manager, the communications team and/or the ICB freedom to speak up lead. Details on freedom to speak up can be found in the Raising Concerns policy.

Contractors and staff working for the ICB and ICS are expected to abide by the contents of this policy.

Integrated Care Board

The Integrated Care Board is responsible for ensuring that the ICB have systems and processes in place for effective use of social media and handling enquiries and comments received via social media.

Executive Director of Strategy and Partnership

The Executive Director of Strategy and Partnership has overall responsibility for this policy.

Director of Communications and Engagement

The Director of Communications and Engagement has responsibility for protecting and promoting the reputation of the ICB and ICS and for dealing with media issues arising from social media.

Senior Communications Manager (Digital) / Policy Author

The Senior Communications Manager (Design and Digital) has responsibility for social media policy monitoring, development and implementation and the strategic development of social media tools for corporate use.

Audit Committee

The Audit Committee is the sponsoring committee for this policy and will seek assurances from the Executive Team that the policy is being adhered to.

6. Policy Detail

Management of corporate social media accounts

Our corporate accounts and what they do

The ICB has corporate accounts on Facebook, Twitter, Instagram, LinkedIn, TikTok and YouTube.

These accounts are owned and managed solely by the communications and engagement team and monitored Monday to Friday 9am-5pm.

We encourage staff to contact the communications team if they want to share news, events or messages relating to their work on our corporate accounts.

Social media management is undertaken by the digital and communications team through a third-party management dashboard called Brandwatch.

Tone of voice and type of post

Our corporate accounts:

• support our corporate objectives.
• promote good news stories about the ICB, ICS and wider partners.
• announce new service developments and examples of innovation and good practice.
• support local, regional and national NHS or government communication and behavioural change campaigns.
• promote key messages about our services.
• give information about changes to services.

We adopt a friendly, first person, tone of voice in line with our corporate values.

We use photographs, graphics, videos, gifs, hashtags and links in line with our and the NHS brand, and adhere to the accessibility guidelines for social media campaigns as set out by the Government Communication Service.

Requests for content to be posted via corporate channels can be made by emailing msepartnership.comms:nhs.net

6.3. Interactions

We respond to direct messages by signposting enquiries to the right department for comment.

We monitor and respond where appropriate to comments on our posts.

We monitor and respond, where appropriate, to posts that tag our accounts.

We escalate to managers within our organisations and to regional, national and/or external partners where they raise concerns about safety, care or inappropriate behaviour.

6.4. Responding to comments

Our social media channels are checked throughout the day between 9am and 5pm and comments and direct messages are usually responded to within two hours on a working day.

Our Facebook account sends an automatic reply to anyone sending a direct message that details working hours and provides a link to our website.

Comments and queries received outside of working hours are responded to the next working day.Comments requiring input from another department are passed onto the right person to provide an answer directly to the enquirer.

If comments are queries posted outside of working hours on any of our corporate social media accounts represent a risk to patient safety or a serious risk to the ICB or ICS’ reputation, they should be flagged to the duty communications manager on call, who will respond as appropriate.

6.5. Medical advice

We do not provide medical advice on social media channels; individuals with medical questions are advised to contact their local GP, NHS111 or to call 999 in a life-threatening emergency.

Photographs and/or personal details provided by individuals are passed onto the relevant department where appropriate and then deleted.

6.6. Internal social media accounts

Our ICB staff intranet Connect Online, includes access to a staff discussion forum which is powered by Yammer, an internal social network. This forum is available to all Mid and South Essex ICB staff.

Staff are asked to follow the rules of engagement when using the platform:

• Be respectful to colleagues.
• Take care not to engage in any conduct that would not be acceptable in the workplace. 
• Be tactful. It is ok to be critical of ideas but remember there are other people involved. Be kind and remember to consider the feelings of those who will be reading your comments. Differences in opinion help us to learn and develop together. Staff are asked to be open-minded to other people’s experiences.
• Any inflammatory or derogatory remarks will not be tolerated and will be removed by the moderators. 

6.7. Staff use of social media

Staff choosing to use social media must be aware that their activity can be traced back to them. The conversations that you take part in and the things that you share about yourself can be enough to identify that you work for the ICB, even if you don’t say that in your profile.

Individuals should take responsibility for protecting their own security online, including but not limited to restricting access to their accounts, blocking unwanted followers and reporting hacked accounts to the platform provider.

We encourage staff who want to have a presence on social media channels which in some way connects them to our organisation – for example, referring to the ICB or ICS in their profile, interacting with or commenting on ICB and ICS content in a way which indicates they are a member of staff, etc – to do so in a way that upholds our values and maintains or amplifies the work we do to deliver our corporate objectives. This means that social media activity should at the very least not undermine our work to promote positive and supportive health messaging, showcasing best practice, innovations and achievements.

A disclaimer like ‘these views are personal and not necessarily those of my employer’ is useful but no guarantee that posts or activity will not have a bearing on the ICB’s or your reputation, either formally or informally.

Comments and content posted by staff on social media channels express the views of the people submitting them. Unless comments are posted by an authorised user of the ICB and ICS’ corporate social media accounts, by an approved departmental account, or are retweeted/reposted by the official accounts, these comments don’t reflect the view of the ICB or ICS.

When using social media, or while online in any capacity, you should not:

• Reveal confidential information about our residents, patients, staff, or the business activities of the ICB or ICS – this includes photographing residents, patients or colleagues without their consent.
• Engage in any activities which might bring the ICB and ICS into disrepute.
• Use the internet in any way to attack or abuse colleagues, patients, or visitors to our sites.
• Post defamatory, derogatory, or offensive comments about colleagues, patients, visitors, your work or NHS Mid and South Essex, the ICB and the ICS.
• Post defamatory, derogatory, discriminatory, or offensive comments that could be perceived as bullying or harassment – please read the ICB Dignity at Work policy.
• Express grievances about your job, your colleagues or the ICB – instead follow the appropriate policy or procedure including the Grievance policy, Dignity at Work policy or the Raising Concerns policy (whistleblowing) policy.
• Respond to requests for interview or opinion by journalists or members of the press – instead follow the guidance set out in the Media policy and direct them to contact the communications team.

All social media activity by any member of staff must adhere to the ICB policies on confidentiality and information governance, internet usage, and declarations of interests, gifts, sponsorship, and hospitality. Staff are individually responsible for content they post or publish online and should use discretion and common sense in all social media activity.

This includes any individually identifiable information about residents, patients, or people, including those featured in the background of photos/video footage or other content. Any activity by staff which brings the ICB into disrepute – including posting, re-posting, commenting on or otherwise endorsing inappropriate content – could result in the ICB’s disciplinary procedures being invoked.

Individuals using social media in any professional capacity should follow the principles set out below:

• Be transparent.
  • In your profile, be honest and clear about who you work for, what your role is, what you’re interested in and reflect some of your personality.If you do enter conversations in a professional capacity, identify yourself as working for our organisation and make clear that you are speaking in your own capacity and not on behalf of the ICB or ICS.
  • If you enter conversations using a departmental account, you are speaking on behalf of the ICB or ICS.
• Be friendly and approachable.
  • Try to make your messages friendly; be professional but human, use the first person (‘I’) and get involved in conversations. It’s fine to express your personal opinions, as long as it’s obvious that’s what they are, but only say things that you would in a crowded room.
    
• Be accurate and honest and mindful of spelling and grammar.
  • It’s fine to say ‘I do not know’ if something is not your area of expertise. You can always tag someone in who may know and can help or offer to put the person in touch with the right person/department using other channels like phone or email. That way you’re opening the conversation to others. It’s far better to be clear and check with an expert than to share wrong information.
  • While everyone can make an occasional mistake, correct spelling, and grammar (including correct use of apostrophes) will positively influence how your account is perceived. Minimise your use of abbreviations where possible and don’t assume everyone will understand jargon.
    
• Participate, do not dictate
  • Social media is about having conversations to build relationships. The most important thing is that you are part of those conversations. So, you can really help by trying to add something useful, valuable, or helpful to every interaction.
    
• Do not name our ICB or ICS in your personal account handle
  • Using MSE, Mid and South Essex or any other variation of our ICS name in your handle, for example, @JoeBloggsMSEICS will give the wrong impression that you are acting on behalf of the organisation.
    
• Do name our ICB or ICS in departmental account handles
  • If you’ve received authorisation to set up and run a departmental account, you should include our ICB or ICS name in your handle. See Appendix B for our house rules.
    
• Do not say anything you would not say in a crowded room
  • Do not swear, use aggressive, abusive, discriminatory, or antagonistic language or get political. Use common sense and do not post anything that could be seen as damaging to your or our reputation.
    
• Do not discuss patients or patient care
  • If you’re approached online by a patient or relative, be clear that social media is not the right way to discuss care or raised concerns, and direct them to contact the ICB through the right channels.
  • Never comment on anything related to legal matters or complaints. If you’re not sure if something’s about a legal issue, it’s best not to comment at all. This applies to statements coming from our corporate accounts, and to comments on our corporate channel posts – the communications team will handle public comments in line with our processes.  Any legal matters must be referred to the governance team/Chief of Staff.
    
• Do not get involved during a crisis
  • In the event of a major incident, staff must not film or show on social media anything relating to an ongoing incident or its response. This is to ensure integrity of policy and other emergency responses. For further information, please refer to the ICB Emergency preparedness, resilience and response Team and associated policies/plans.
  • During major incidents it’s better to have just one, official source of news and information, and this could be an external agency such as the police force, fire service or regional NHS organisation. Be mindful of what you say externally on any social networking sites as it can easily be picked up by the media. Look to internal channels such as the intranet or all staff emails for guidance during major incidents.
    
• When sharing content, make sure you credit the original source
  • It’s fine to link to external content, especially if it’s of value to the conversation but make sure you credit the correct source. If you’re not sure of the original source, at least tag the person you received it from.
    
• Admit your mistakes
  • Mistakes happen and that’s OK. The best thing to do when these occur is to admit it, apologise and correct it. Don’t delete the content in the hope it will go away or pretend you’re in the right, and if you’re not sure, contact the communications department for help.
    
• Pause
  • We all sometimes get into uncomfortable conversations. Before responding, it’s always a good idea to take a moment to consider your response. Show it to a colleague or contact the communications department for advice.
    
• Talk amongst your team
  • Be aware of our key corporate messages and try not to contradict these.
    
• Quality over quantity
  • You don’t need to post every day to add a valuable voice to our messaging – it’s a conversation, not an obligation. However, if you want to engage with your peers or other audience, you should aim for regular high-quality posts.
    
• Don’t make big announcements
  • If you have a big announcement, such as innovation or service development, award nomination, or any good new story, let the communications team know first. We can work with you to amplify your message through all our communications channels to ensure you get maximum coverage. We understand the temptation to post big news quickly but sharing too soon can undermine other communications plans that you might not be aware of and may sometimes conflict with national guidance such as the pre-election period when restrictions are placed on public sector communications activity.

6.8. Departmental accounts

Departments should not set up social media accounts without prior approval from the communications team.

All new requests for departmental social media accounts must come through the digital and marketing communications team to assess the need for the account and establish clear and measurable objectives for success.

In many cases departmental accounts are not appropriate, and better reach and coverage can be gained by channelling content through the ICB and ICS’ corporate accounts another communications channels, or by setting up an individual professional account.It is essential that staff members running an approved departmental account have clear objectives and aims to help determine how they will run their account.

Staff wishing to set up a social media account for their department are required to submit an initial request to the communications team inbox ([email protected]), who will arrange a conversation about the request.

6.9. Training

If staff would like social media training they should contact the communications and engagement team.

6.10. Unauthorised accounts

If any account is set up without prior approval, the communications team will make contact via messaging or a comment, requesting that the account owner gets in contact so we can provide support and gain the username and password for the account in case of hacking or malicious use. The communications team will then work with the account owner to establish objectives for success.

If the communications team is unable to contact account owners after repeated requests, or if posts originating from an authorised or unauthorised account breach this policy, the account will be reported through the relevant platform’s processes for impersonating a verified account or for posting false content, with a view to having the account permanently removed.

7. Monitoring Compliance

It is the responsibility of all staff to ensure that the Social Media Policy is adhered to and is being embedded within the ICB and wider ICS as appropriate. The Director of Communications and Engagement will ultimately be accountable to the Integrated Care Board via the Audit Committee for ensuring that the social media management process delivers as expected and that the process remains robust and operates effectively and reviewed as necessary.

8.Staff Training

See section 6.9.

9. Arrangements for Review

This policy will be reviewed no less frequently than every two years.  An earlier review will be carried out in the event of any relevant changes in legislation, national or local policy/guidance, organisational change or other circumstances which mean the policy needs to be reviewed.

If only minor changes are required, the sponsoring committee has authority to make these changes without referral to the Integrated Care Board. If more significant or substantial changes are required, the policy will need to be ratified by the relevant committee before final approval by the Integrated Care Board.

10. Associated Policies, Guidance and Documents

Associated Policies

• Media policy
• Disciplinary policy
• Grievance policy
• Dignity at work policy
• Raising concerns (whistleblowing) policy
• Managing violence and aggression policy

11. References

• Government Communication Service (GCS) Digital communication guidance
  
• Government Communication Service (GCS) Accessible communication
  
• Government Communication Service (GCS) Planning, creating and publishing accessible information

If you would like to download a full copy of the policy in a Microsoft Word format please click the link below.

002 Social Media Policy (doc, 264kb)