1.1 This policy sets out the approach of NHS Portsmouth Clinical Commissioning Group (“the CCG”) towards the news media, and explains how such interactions will be viewed, and managed. It also accepts that large amounts of public and private discourse increasingly takes place on platforms other than the traditional news media, and thus sets out how the CCG approaches the opportunities and challenges of social media, and how staff should conduct their social media activity both in a professional and a personal capacity.
1.2 The aim of this policy is to support staff so that CCG public communications activities are conducted in a way which is consistent with the values and objectives of the CCG, and which support the CCG to achieve its objectives. It should also ensure that all staff understand both the opportunities, and the risks, which are inherent in public facing communications, know what is expected of them, and how and when to seek support.
1.3 In terms of the title of this document, the term “Media Policy” includes both ‘traditional’ print and broadcast media, and also social media – including platforms such as Facebook, Twitter, Instagram, but also platforms such as WhatsApp which might sometimes be considered to host more ‘closed’ conversations. Where appropriate, this policy will seek to differentiate between traditional news media, and social media.
9.0 Social media: principles
9.1 As set out in Section 5 regarding the principles of dealing with news media, it is CCG policy to be as open, honest and transparent as possible. Social media should no longer be considered as ‘new media’ – it has now become an integral part (indeed often the integral part) of public debate, and so those overarching principles continue to apply.
9.2 Unlike traditional media, social media provides the ready possibility of both professional, and personal, activity. This diversification, and the ability for individuals to simultaneously have several voices, roles and identities, offers a wealth of opportunities but also the risk of the professional and the personal becoming intertwined in a way which may negatively impact the standing of the individual, or the CCG, or both.
9.3 This policy will address the use of both corporate and personal accounts. In the case of the former, policy is relatively clear and easily applied. In the case of the latter it is less so, and so greater attention and consideration is required.
9.4 Social media accounts which are used – either wholly, or in part – for professional purposes (whether corporate accounts, or accounts run by individuals) offer the opportunity to:
9.5 CCG employees who operate personal social media accounts are entirely at liberty to use those accounts for the purposes outlined in Section 9.4, above – promoting the work of the CCG and its partners through such channels is entirely legitimate, but should absolutely not be thought of as a necessary part of their employment.
9.6 All staff members posting, or responding to, activity on online articles, blogs, message boards, tweets, Facebook posts or content on any other digital forum must take care to ensure that:
9.7 Staff should ensure they use social media responsibly and consider the following:
9.8 Staff are permitted to use social media on NHS equipment, at work, but this is on condition that the use:
9.9 The growing popularity of (often encrypted) direct messaging platforms such as WhatsApp or Facebook Messenger poses new questions for organisations regarding governance and behaviour. Given the apparently closed and private nature of the format, there is a risk that CCG employees may consider activity on such platforms to be secure – it isn’t. All employees must be mindful that any activity which is shared with anyone – regardless of how apparently private the platform may be – is automatically beyond their control and can be subsequently shared with others, without their permission or knowledge. Anything which is written or shared on direct messaging services such as WhatsApp has the potential to subsequently become public, and so the considerations set out in section 9.6 of this policy continue to apply.
10.0 Social media: practical guidelines
10.1 Staff access to official CCG social media accounts will be limited to authorised marketing, communications and engagement team members.
10.2 The CCG social media accounts will be routinely monitored Monday to Friday during office hours.
10.3 Social media will be used not only to promote our work and corporate messages, but also to support our partners, staff and appropriate local enterprises through likes, mentions and retweets.
10.4 Events and projects will, where possible, be branded with an appropriate hash-tag and used throughout the promotion and event itself.
10.5 When staff are using personal social media accounts in a professional capacity, they are reminded that they represent the CCG and should conduct themselves in the same professional manner in which they would in the workplace. It is also suggested that they state on their profile that their ‘views are their own’, but do not assume that such an action is, in itself, sufficient to enable comments or activity which may be detrimental to the reputation of the CCG.
10.6 When staff are using personal social media accounts in a professional capacity they should make the marketing, communications and engagement team aware of such activity. This will allow the team to offer support from corporate accounts, monitor impact, and to advise on content and approach.
11.0 Major incidents and emergencies
11.1 In the event of a major incident or a threat to business continuity, there may be news media and / or social media interest which need to be managed. In such circumstances staff should respond to any approaches in the same way as is outlined in Section 6 of this policy.
11.2 During major incidents and emergencies the marketing, communications and engagement team will be required to work closely with partner agencies, as will other CCG colleagues. This will be done through the Hampshire and Isle of Wight Local Resilience Forum Media Cell – normally the police service will lead such a co-ordinated response. As part of this collective response to a crisis, CCG staff may be required to support the communications activity of other statutory agencies.
11.3 Should a major incident, or threat to business continuity, take place, staff should be aware that the potential for them to play a positive role through the use of social media is heightened at this time. Assisting with the dissemination of important information can help both members of the public and the emergency services respond to a situation. Staff must be aware:
11.4 During a major incident, it is essential that information released by the CCG does not contradict statements made by partner agencies.
11.5 The responsibility for internal communications sits with each partner organisation. However, each organisation must ensure that key messages are being used which are consistent with those being issued by the Media Cell or the lead agency where appropriate.
11.6 During a major incident, as at any other time, it is the responsibility of line managers to ensure that their colleagues are able to receive information in a timely way.
12.0 Training
12.1 Senior CCG staff – including members of the Governing Board, and clinical leads – should expect that their role may require them to be available for media interviews, either to proactively promote good news, or to reactively respond to questions about policy or practice. The marketing, communications and engagement team should arrange appropriate media training for this group, as required.
12.2 On some occasions there may an opportunity, or a requirement, for other members of staff, especially those senior managers who are responsible for particular areas of work, to work with the media or to participate in the response to journalists. In such cases, the marketing, communications and engagement team will either provide, or facilitate, targeted support and preparation to enable the individual to respond confidently and appropriately.
13.0 Equality analysis
13.1 See Equality Impact Assessment at Appendix One.
14.0 Review
14.1 This policy will be reviewed every two years.
14.2 Minor changes, which do not impact on the substance of the policy, may be made outside the formal review process, with the approval of the marketing manager leading the integrated marketing, communications and engagement team.
Version Number: 1.1
Operative date: July 2020
Review date: August 2022
This page was updated on 03 Jun 2021 and is due for review by 03 Jun 2022
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