Social Media Policy and Employee Guidance
I know everyone is working on this. What is management’s response to the sudden and enormous popularity of social media sites? How do we manage its effects on employee productivity (and perceived productivity)? How do we provide employees guidance so they don’t post something that violates a patient’s rivacy rights or otherwise embarrases the organization?
Ministry and Affinity have been tackling this too. Because I have been writing a blog for several years a lot of people have asked me about this hoping we were further ahead in figuring this out. So, I thought I would post what we have done so far (with the blessing of my fellow social media council members). I am hoping this is a good crowdsourcing excercise and that your comments will improve this draft. I plan to post updates to the documents.
My big concern when tackling this is that management would try to set the clock back to a time when people didn’t check Facebook before their morning coffee. I am concerned that they only sell see this as a problem to be mitigated. I bbelieve we have a huge opportunity for employers to turn all of their employees into uber-effective marketers that promote every new and worthy aspect of our services with far more credibility than corporate voice advertising. Focusing only on the negative aspects of social media, and not the opportunity, is a risk.
There are two documents below. The first is the DRAFT policy. It is very legalese, but it is intended to provide employees unambiguous direction. The second is an employee guidance which is intended to be an easier read in plain English. Once the spirit and content of the employe guidance is finalized we intend to make that available to all employees, perhaps as content in our Learning Management System. I am also thinking of doing a YouTube video.
TITLE: SOCIAL MEDIA Policy
Defined terms are “Capitalized.” Definitions are imbedded in or included at the end of the Policy.
- Ministry Health Care and its wholly owned subsidiaries identified in the “Scope” section above (“Organization”) recognizes the value of on-line Social Media sites and Blogs as vital resources to positively promote the organization’s mission and values, operational goals, marketing and recruitment activities, as well as a forum for exchange of information by its 12,000 Workforce members.
- The Organization supports access to Social Media and Blogs by workforce members through the provision of Internet access. Internet access and use is a privilege and must be carried out in a manner that is consistent with job responsibilities and Human Resources policies addressing appropriate use of scheduled work time and resources. Access to the Internet by workforce members is supported at the enterprise level and is provided through IT to all workforce members through available devices. An organization and/or business unit may choose to establish local work rules for Internet access, including Social Media and Blogs, by policy. Due to the need for workforce members to have Internet access, IT will not provide resources to block access by geographic sites, individual devices, or websites (certain websites will continue to be blocked at the enterprise level (e.g., illegal sites).
- The Organization shall establish and maintain an organizational presence on popular Social Media sites and through Blogs. This presence will facilitate expanding communication opportunities for patients, employees, and other stakeholders in the communities served by Ministry.
- The Organization has established the Social Media Steering Committee as an enterprise level oversight structure to develop and manage the organization’s Social Media and Blog communication strategy, as well as respond to issues and concerns related to the use of Social Media and Blogs. This Committee will function under the oversight of the IT Customer Advisory Board (CAB). Participants shall include representatives from Marketing, Human Resources, Information Technology, Corporate Integrity, and Education.
- The use of Social Media and Blogs for Ministry official business operations shall be under the guidance of the responsible business unit leader as noted below:
- Marketing/Business Development – VP of Marketing & Business Development.
- Human Resource Recruitment – VP of Human Resources.
- Information Technology Operations – Chief Information Officer.
- Corporate Integrity – Director of Privacy.
- Education – Director of Education and Development.
- Others – To be defined as developed.
- All uses and disclosures of patient identifying health information shall be carried out in a manner compliant with applicable patient privacy policies, regulations, and standards. Prior to sharing patient identifying health information or images through Ministry sponsored Social Media and Blogs, the individual responsible for the project involving the sharing of that information shall obtain a written authorization for the use and disclosure of the information from the patient/patient’s legal representative.
- The Organization supports its Workforce members’ use of Social Media and Blogs for personal and professional use, recognizing that Workforce members have a strong voice in representing the organization. Workforce members engaged in personal or professional Social Media and Blog communications that reference Ministry-related content shall do so in a manner consistent with the organization’s mission and values, enterprise administrative policies and procedures, and safeguards to ensure the privacy and security of patient health information, as well as proprietary business information. Ministry has developed guidelines for Workforce members on communicating Ministry-related content through Social Media and Blogs (see attachment).
- At no time shall Ministry Workforce members utilizing personal or professional Social Media and Blogs share confidential patient or proprietary business information.
- Prior to discussing work-related activities on Social Media and Blogs, the individual should consider:
- Does the discussion positively promote the individual’s role as a Ministry healthcare Workforce member?
- Does the discussion reflect positively on individual’s co-workers/colleagues? The individual’s work unit? The organization?
- Does the discussion conflict with Ministry’s mission, culture, and/or values?
- Does the discussion reveal confidential patient or proprietary business information?
- Does the discussion include any information that could directly (e.g., name, Social Security number, address, etc.) or indirectly (e.g., provider name, date of birth, diagnosis, images, etc.) identify a patient under the care of the individual/organization?
- The Social Media Steering Committee shall serve as a resource for questions and concerns regarding the appropriate use of Social Media and Blogs by Workforce Members. The Committee can be notified of a concern by contacting the Corporate Integrity Department (Director of Privacy).
- The inappropriate use of Social Media and Blogs by Workforce members that conflicts with the Organization’s mission and values, violates enterprise administrative policies and procedures, and/or compromises the privacy and security of confidential patient health or propriety business information shall be subject to corrective action, up to and including termination. In addition, breach of confidential patient health information may also be subject to legal proceedings and/or criminal charges.
Attachment: Guidelines for Ministry Workforce Members Communicating Ministry-Related Content through Social Media and Blogs (Pending)
Related Policies/Position Statements /Other Documents
- HR-5709: Corrective Action
- HR-5723: Internet Use by Workforce Members
- PV-15: Media Access To and Disclosure of Patient Protected Health Information
- PV-19: Disclosure of Patient Health Information
- SE-5: Workstation Use and Security
- Corporate Communications Policies (Under Development)
- Confidentiality/Computer User Agreements
Blog: A blog is a website maintained by an individual or organization with regular entries of commentary, descriptions of events, or other materials such as graphics or video. Blogs may provide commentary or news on a particular subject; others function as more personal on-line diaries.
Social Media: For the purposes of this policy social media is an on-line social structure made up of individuals or organizations that are tied by one or more specific types of interdependency, such as values, visions, ideas, financial exchange, friendship, business operations, professional exchange, etc. Social media sites operate on many levels, from families up to the level of nations, and play a critical role in determining the way information is exchanged, problems are solved, organizations are run, and the degree to which individuals succeed in achieving their goals.
Workforce: Under HIPAA, the workforce is defined to include employees, medical staff members, volunteers, trainees, and other persons whose conduct, in the performance of work for a covered entity, is under the direct control of such entity, whether or not they are paid by the covered entity.
The healthcare industry, like many other industries, has embraced the use of Social Media and Blogs. Social Media sites and Blogs facilitate communication, education, collaboration with others, research, business travel, remote work, etc. For many, the Internet is a tool to aid in daily business practices that improves work quality and job satisfaction. The Internet provides a wide array of resources, services, and interconnectivity to Ministry Health Care and Workforce members. However, there are also risks associated with inappropriate Internet access and use which must be addressed through appropriate safeguards, policies and practices, education and training, and appropriate corrective action when necessary. Monitoring appropriate use of the Internet by Workforce members is a joint responsibility of the organization’s leadership, information technology (IT) support staff, and human resources leaders.
Distribution: Ministry Health Care and all wholly owned Ministry organizations, except Agape. Agape Community Center will be provided notification of and access to all Ministry Administrative Guidance and will determine applicability and the need to implement.
Values: This Policy has been reviewed for support of the Ministry Health Care Values.
Key Words: Facebook, Linked-In, MySpace, Social Media, Social Networking/Networks, Twitter, Yammer
For More Information Contact: Vice President, Marketing and Business Development, Chief Information Officer, Director of Privacy
This information is an accurate statement of published Ministry Health Care Policy as of the time of publication. Permission is granted to electronically copy and to print in hard copy for internal use only. No part of this information may be reproduced, modified, or redistributed in any form or by any means, for any purposes other than those noted above without permission of the Responsible System Leader. Ministry adopts the Policy and recommends that the user always check for the latest version on Our Ministry, the Ministry Intranet site before any subsequent use. Ministry may make changes to the Policy without notice and may deviate from the Policy as determined in its discretion.
Social Media Guidelines for Ministry Workforce Members
Today, virtually every workforce member of Ministry Health Care has an email account and the capacity to access “Our Ministry” and surf the Internet. Large companies, including Ministry Health Care, often have a love-hate relationship with Facebook and other Social Media websites
Progressive organizations recognize that encouraging employees to use Facebook and other Social Media tools can have much greater benefit that drawback. Ministry strategically supports leveraging Social Media tools to establish the organization at the leading age of optimizing presence in the on-line environment.
There are some simple guidelines to keep in mind when using Social Media sites. These guidelines are really based on existing policies, but it is worth the exercise of translating those policies for applicability in the online world. There is a detailed policy on social media, but here are the highlights in broad terms:
Don’t betray our patient’s trust (and don’t get arrested)
Remember, disclosing confidential patient Protected Health Information (PHI) in an inappropriate manner is a federal offense. The penalties include significant fines and/or arrest. Ministry employees should never publicly make comments about the care of a specific patient, especially online. Even acknowledging the care of a patient is an unacceptable disclosure of PHI.
Don’t get fired
Your employment at Ministry is based upon the premise that your value is a least equivalent to your salary. If you are using Social Media (or any other medium) to harm the reputation of Ministry Health Care then your value to the organization has diminished greatly, regardless of your job performance. This is not to say that everything you say in the public domain about your employer has to be flattering. But there is a significant difference between occasional constructive criticism and statements that are harmful to the organization’s reputation. Don’t:
- Post work-related information that may compromise Ministry’s business practices or patient privacy and security.
- Engage in any form of harassment, including derogatory or inflammatory remarks about an individual’s race, age, disability, relation, national origin, physical attributes, sexual preference, or health condition.
- Violate copyrighted or trademarked information.
Don’t Cheat Your Employer
It has been Ministry’s policy to only block web sites that are clearly inconsistent with our values. We do not consider Facebook or other Social Media as such sites. However, many find Social Media sites addictive in nature. While Ministry policy does not ban access to Social Media sites at work, employees should not be checking their Facebook updates when they are supposed to be doing their job.
Don’t Think Your Facebook Posts are Private
Even though there are privacy controls on sites such as Facebook and other Social Media sites, you should assume that anything posted on a website that has not been examined by the IT department will be seen by the general public, as well as your employer. Remember:
- “Friends: can copy your posts and make them available in public.
- Your friends are likely our patients
- It is easy to for your privacy settings to be set to something other than what you had planned
Don’t Jeopardize Your Reputation and/or Future Employment Opportunities
You should consider that everything you post online begins to build a lifetime record of you. Increasingly, employers will search this online history using Google or web sites like pipl.com:
Don’t Alienate Your Co-workers
Remember, you have to work these people. Use common sense. Remember what your mother told you about gossip.
Ministry loves the Internet
At Ministry we believe in the power of the Internet and Social Medial sites. We encourage our employees to appropriately use and participate in Social Media activities.
We need a Tech Savvy Workforce
The skills you develop using the Internet and Social Media improve the IT skills that we need Ministry employees to possess to compete in the future. Furthermore….
The Best Advertising Used to be Word-of-Mouth – Now it is – Word-of-Keyboard
In the near future, Ministry’s best advertising will come from employee’s sharing with their communities how we are living the promise every day. A well written Facebook post about a new service or the care that we provide to our patients will have far greater effect than a paid TV commercial. While that post may not have the same reach, the fact that it is coming from a person that is trusted in their community will mean the message has more weight. People listen to people. Corporate voices are discounted to a large degree, no matter how glossy the pictures are well-written the copy.
We are encouraging employees to talk about work online. But in a responsible, legal manner avoiding the pitfalls we have outlined above. We hope employees will write about positive experiences you have working with your co-workers. We hope employees will write about thank-you notes they receive from appreciative patients. We are hoping employees educate their communities about the services we provide that can benefit their family and friends (online and physical).
Share Your Knowledge
Everyone that works at Ministry has knowledge, talent, and special skills. Ministry employees are encouraged to share this information on Social Media sites. There is a halo effect to doing so. If you share information with someone they will remember you and your organization when it comes time to get those services. People at Ministry are doing that today. Many are using Social Media sites to share their knowledge, talents, and skills with others. This reflects positively on them and on Ministry.
These individuals are routinely contacted by others, including the media, through the Social Media tools they used based on the contributions they have made. As they are cited by the media as experts in their fields, that has a positive reflection on Ministry. If you are contacted by the media as a result of your Social Media activities, you are encouraged to contact Marketing. Marketing not only wants to track these experiences, they can also assist in providing you guidance in responding in knowledgeable and articulate manner.
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