INTERNET AND SOCIAL MEDIA USE POLICY FOR STAFF, PATIENTS AND VISITORS
Available to all staff via the intranet / patients and visitors via our website
- The use of the internet and social media has become an integral part of everyday life. The NHS must embrace this for its opportunities, but also carefully manage its use to ensure appropriate protection for all users.
1.2. Used well, the internet and social media can improve the way we share information, can empower patients and staff and can improve the openness and transparency of NHS organisations. We have an obligation to ensure those using the internet and social media, or in relation to the Practice’s activity, are absolutely clear about our expectations regarding professional behaviour, protecting patient confidentiality and safeguarding.
1.3. The social media ethos is all about engagement, participation and relationship building. 1.4. This policy sets out our expectations for internet and social media use for the Practice’s employees and those visiting our surgery. It outlines the ways in which staff can ensure acceptable use of the internet and social media by patients and visitors.
1.5. Social media is rapidly evolving and expanding, so this policy will focus mainly on the most popular and commonplace social media platforms currently available. This includes Twitter, WordPress, YouTube, Facebook and Reddit.
1.6. New social media channels and platforms will emerge but the underlying principles and expectations of this policy will be the same.
- PURPOSE AND SCOPE
2.1. This policy applies to all personnel of the Practice, including those directly employed via an employment contract, those engaged on a self-employed basis, contractors, volunteers, apprentices and those carrying out business at the Practice, whether paid or unpaid, including the patient Participation Group when they are on our premises. For the purpose of this policy, the term “personnel” will be used to describe all the above groups.
2.2. This policy also applies to patients, carers, families and all those visiting MMC premises, whether in a personal or professional capacity. Its expectations and guidance include any use of Trust or personal devices to access the internet or social media, whether through the WIFI network or through alternative internet access arrangements.
2.3. The scope of this policy includes use of both the Practice and personal resources to access social media, including outside of working hours. All personnel are expected to maintain a professional approach to work, patients and colleagues at all times and must not bring the Practice into disrepute.
2.4. This policy is not intended to account for every situation that may arise. It aims to outline a number of important principles that reflect the standard of behaviour required by Practice personnel.
2.5. All personnel must read and understand this policy to be clear about the general standard of conduct required when using the internet or social media. If any employee of the Practice has any doubt about the meaning of the examples listed, they should speak to their line manager for clarification.
2.6. The Practice communications department will regularly provide communications materials, both internally and externally, to make personnel, patients and visitors aware of this policy and its guidance.
3.1. Social media is the generic term given to any form of internet-based platform that enables online interaction and communication between users. Social media can include text, audio, video, images, podcasts and other multimedia communications.
3.2. Social networking is the use of social media sites, allowing individuals to conduct online interactions that mimic offline interactions between people with similar interests.
3.3. Microblogging is the practice of posting short messages or digital content (essentially this is a form of blogging with a very limited word count). Twitter is an example of a microblogging site and limits messages (or “tweets”) to 280 characters in length.
3.4. Blogging is the use of a public website to write an online diary (known as a blog), sharing thoughts and opinions on various subjects.
3.5. Social sharing is a form of social networking website that allows registered users to create personal profiles, upload photos and videos, send messages and keep in touch.
3.6. Video / picture sharing allows anyone to upload short videos or pictures to a website, either for restricted viewing (to a limited list of friends or viewers) or as a showcase to the wider public.
4.1. All managers are responsible for ensuring that personnel know how to access current Trust policies and, in circumstances when they are not being adhered to, discuss the standards and expectations required with staff concerned. All managers must understand the policy and how to escalate concerns that cannot be resolved locally.
4.2.1. All MMC personnel are required to adhere to this policy.
4.2.2. All personnel have a responsibility to report inappropriate use as outlined in this policy to their line manager in the first instance or to another member of staff (as outlined in 9.0). 4.3. Patients and visitors
4.3.1. All patients and visitors are required to adhere to this policy. It is the responsibility of the Practice to ensure the policy is publicised and available for review by all patients and visitors.
- TRUST USE OF SOCIAL MEDIA
5.1. The Practice maintains its own corporate presence on the following social media channels: • Facebook It may also respond directly to patient feedback on public websites, including but not restricted to NHS Choices and Patient Opinion.
5.2. Maintaining an active presence on social media sites allows the Practice to effectively manage its corporate brand and communication to stakeholders online. This is overseen by the Practice Manager, with support from members of the practice team.
5.3. Content deemed suitable for corporate social media includes: news, events and activities that are related to the Practice’s business, content that provides a direct link back to the Practice’s external website, engagement with people who have an interest in the Practice, information that enhances the Practice’s reputation and new developments, awards or achievements in the Practice.
5.4. Any member of staff may submit information to be considered for inclusion on social media sites by contacting the Deputy Practice Manager
5.5. All social media accounts associated with the Practice’s business and activities are expected to adhere to the principles and expectations of this policy. The Practice will take all steps available to close down any linked social media account found to be acting outside of this policy.
- KEY PRINCIPLES FOR USE OF SOCIAL MEDIA
6.1. These key principles apply to all Mayflower Medical Centre (MMC) personnel or contractors who make use of any form of social media, whether personal or professional, using Trust or personal equipment, inside or outside working hours.
6.2. The intention of these principles is not to prevent MMC personnel from conducting legitimate activities on the internet in their personal time, nor to stifle constructive feedback. It serves to highlight those areas in which problems are most likely to arise, both for individual personnel and the Practice as a whole.
6.3. Maintain confidentiality at all times
6.3.1. All personnel have a responsibility to maintain and protect service user, colleague and organisational confidentiality. Under no circumstances should you identify service users, post information that may lead to the identification of the individual or post information that is stigmatising or derogatory to any patient group or condition. This includes never disclosing information which may be: • Sensitive, • Confidential, or •
6.3.2. By disclosing any such information, you interfere with privacy and breach the law on confidentiality, your employment contract and your professional Code of Practice. 6.3.3. When creating a new social media account, a privacy impact assessment should be completed to ensure that the Practice’s information governance standards are adhered to.
6.4. You are an ambassador for the Practice and your profession
6.4.1. Never post a comment, photo or video online that you would not be willing to share with people in “real” life in a face-to-face setting.
6.4.2. Your online behaviour not only reflects on you but also on the Practice and your profession. While there is often a focus on the negative impact of social media on an organisation and its reputation, remember that you have the potential to act as a positive and respected brand ambassador for the Practice. Everything you post online, including photographs, is public, even with the strictest privacy settings. Once something is online, it can be copied and redistributed and it is easy to lose control of it. Presume that everything you post online will be permanent and will be shared. You should refrain from any action or activity that may bring you, your colleagues, your profession, the Practice or the NHS into disrepute. This may include posting on any social media (whether text, images, video or audio) that expresses defamatory, derogatory or offensive comments or attitudes (whether explicit or implied) towards any of the following: - Service users or their relatives, carers or visitors - Your colleagues, direct reports or managers - The Practice or its contractors Union representatives are at liberty to use social media to publicise views and campaign on behalf of their members. Even though these may on occasion be critical of the Practice, this would not be deemed to be bringing the Practice into disrepute.
6.5. Be mindful of professional boundaries
6.5.1. Do not use social media to build or pursue relationships with service users, their families or carers even if they are no longer in your care. If you receive a friend request from a current or former patient or their relative, some sites like Facebook allow you to ignore this request without the person being informed, avoiding unnecessary offence. Please refer to the Policy and Procedure Regarding Staff Relationships with Service Users for further guidance on this.
6.6. Protect your own privacy
6.6.1. Think carefully about what kind of information you want to share and with whom, and adjust your privacy settings accordingly. For example, Facebook allows you to adjust your privacy settings at group level to share different levels of information with different kinds of friends.
- EMPLOYEE PERSONAL USE OF SOCIAL MEDIA
7.1. Personal use of social media should be restricted to agreed rest/lunch breaks and should comply with the principles in this policy. The principles exist to protect everyone using the internet and social media. Professional use via a personal account, such as at a conference or other work related event, is acceptable during working hours.
7.2. The Practice acknowledges that social media provides a number of benefits in which personnel may wish to participate. Whether or not an employee explicitly declares their association with MMC on social media, they are expected to behave appropriately and professionally at all times and in a manner that is consistent with the Practice’s values and policies and relevant professional codes of conduct.
7.3. Personnel holding professional registration should be aware of their responsibility to uphold the reputation of their profession, and that their online conduct could jeopardise their registration if their fitness to practice is called into question.
7.5. The absence of affiliation or registration with a professional body (e.g. where registration is not required for employment) does not exempt personnel from appropriate and responsible use of social media.
7.6. Personnel who are found to breach the Internet and Social Media Use Policy or the Practice’s Acceptable Use Policy may be subject to disciplinary action in line with the Practice’s Disciplinary and Capability Policy.
- PATIENT / VISITOR USE OF INTERNET AND SOCIAL MEDIA
8.1. Patients and visitors to our premises will be able to access WIFI where installed. The appropriateness of accessible content will be automatically managed by the NHS IT team using existing security protocols.
8.2. Patients and visitors may be able to access social media and internet sites via their mobile phone networks whilst at the surgery.
8.3. Where staff suspect inappropriate use of social media or internet content by patients or visitors, they should alert their line manager in the first instance.
8.4. The Practice requires all users of mobile devices to use them in a courteous, considerate and non-intrusive manner to help maintain a caring environment for patients and effective working environment for staff. Patients must not use mobile devices during consultations with MMC staff.
8.5. Mobile devices must not be used to photograph MMC staff, patients or facilities without the explicit permission of the individual and the ward/department manager.
8.6. Patients may take photos of themselves and / or their relatives for personal reasons and for their own personal use. Patients and visitors must ensure that other patients are not visible in any part of such photography to ensure confidentiality and to protect privacy and dignity.
8.7. Express permission is needed for photographs to be taken of the inside of MMC premises, particularly reception and clinical areas. This includes photographs of MMC staff. Permission should be obtained from the Practice Manager in the first instance. Taking photographs on our site of other patients, staff or visitors without their informed consent is not permitted.
8.8. We understand that our patients will want to stay in touch with their friends and family. We also have a duty to protect patient confidentiality and a responsibility to safeguard vulnerable patients in our care. The following guidelines apply to all our patients: • You may overhear conversations about other patients while on our premises. Please respect the confidential nature of these conversations by not sharing details about others in our care without their prior consent. If we obtain evidence of internet or social media activity that shares such confidential information, we will ask you to remove that content. • Defamatory comments about members of our staff should not be shared in any public forum. Legal advice will be sought and action taken where necessary. The Partners at MMC believe that complaints that take the form of a scurrilous personal attack on members of the Practice or contain allegations which are clearly unfounded usually indicate a serious breakdown in the patient-doctor relationship.
It is a breakdown of the relationship rather than a complaint per se which must form the basis of any decision to remove a patient from the list; it may then be in the patient’s best interest to seek care at another practice.
- RAISING A CONCERN
9.1. Personnel who become aware of a breach of this policy have a duty to report it to their line manager. If they are unable to or are uncomfortable doing so, they may report their concerns to the next in line, another senior manager or via mechanisms outlined in the Practice’s Whistleblowing Policy.
9.2. Personnel or patients who become aware of inappropriate use of the internet or social media by patients or visitors on Trust sites should report it to their line manager.
9.3. Line managers who are made aware of a breach of the policy should seek Human Resources (HR) advice and where possible resolve the matter informally and locally. Where it concerns patients or visitors, line managers should seek advice from the Safeguarding Team/Caldicott Guardian if required and where possible resolve the matter informally and locally.
9.4. Directly employed personnel in breach of the policy will be managed via the Practice’s Disciplinary and Capability Policy and sanctions taken could include dismissal.
9.5. If you feel that you are the target of complaints or abuse on social media sites, you can remove someone from your friends or followers list and block them from interacting with you. Most sites will include mechanisms to report abusive activity and provide support for users who are subject to abuse by others. If you have reason to believe that the activity is originating from a colleague or service user, you should alert your line manager or the next in line.
9.6. Any grievance with the Practice should be channelled through procedures and policies already in place and dealt with in the work environment, and not displayed or discussed via social media.
The policy has been made available to visitors, patients, and carers on the Practice’s website and will be publicised on facebook, our intranet (one set up) and CQC policies section