Social media employee usage policy

1 Introduction

For the purposes of this policy, social media is interactive online media that allows parties to communicate instantly with one another or to share data in a public forum. This includes online social networking, messaging and blogging sites such as Facebook, X, WhatsApp, Keek, LinkedIn and Tumblr, as well as YouTube, Flickr, Instagram, Snapchat, TikTok, and other image and video-sharing sites. This list is not intended to be exhaustive as this is a constantly evolving area. Employees should adhere to this policy in relation to any social media they use. For the purposes of this policy, the terms “social media” and “social networking” are used interchangeably.

The trust recognises that in recent years there has been a significant rise in the use of social networking sites. While it is recognised that all employees are entitled to privacy in their personal life, the trust is committed to maintaining confidentiality and safety at all times whilst also maintaining the reputation of the trust and that of the relevant profession by exhibiting acceptable behaviour at all times.

All colleagues need to be aware that, even if they believe that they are using these sites with enhanced privacy settings applied, this does not exempt them from the guidelines that are outlined in this policy.

If a colleague has concerns about the online conduct of any other colleague, if the colleague feels comfortable in doing so they can raise this directly with the colleague, or alternatively this should be raised with an appropriate manager in line with the freedom to speak up, raising concerns (whistleblowing) policy for the NHS, the respect, civility and resolution policy or the grievance and dispute procedure, depending upon the issue raised.

It is also acknowledged that in the NHS, the use of social media has evolved and provides a powerful way of engaging and communicating with target audiences, peers, professional bodies and key influences and trust employees may utilise social media to promote our services. This is not included in the scope of this policy and additional guidance is available from ‘How to use social media for promoting your service’ which can be found on the trust intranet site.

2 Purpose

The purpose of this policy is to set out the clear expectation that, if a colleague identifies an association with the trust, discusses their work and, or colleagues, or comes into contact, or is likely to, with patients, service users or clients on any social media sites, they will behave appropriately and in a way which is consistent with the trust’s values and where relevant, with their professional code of conduct. The duty to act in a manner that is in line with the conditions set out herein does not only apply when a colleague is at work, but at all times when a connection to the trust, the NHS or their profession has been made, either explicitly or inadvertently.

This policy aims also:

to outline to colleagues what is acceptable use of social media linked to their employment
to make a clear distinction between acceptable usage of social media at work and in colleagues’ personal lives
to encourage colleagues to be mindful of what content they share on the internet
to ensure appropriate standards of confidentiality are maintained
to ensure that professional boundaries with patients, service users or clients are maintained and protected
to ensure there is support available for employees should they be named on social media
to maintain and protect the reputation of the trust

This policy sets out the principles which colleagues are expected to follow when using social media both in their personal lives and professionally. The internet involves fast moving technologies and it is therefore impossible to cover all circumstances.

The intent of this policy is not to stop colleagues from conducting legitimate activities on the internet, nor to stifle constructive criticism, but serves to highlight those areas in which problems can arise for both individual colleagues and the trust. There have been several cases where staff have been dismissed or issued with a disciplinary caution for inappropriate use of a social website or other media.

3 Scope

This policy applies to all employees who are directly employed by the trust. The policy also applies to any agency workers, students, seconded staff and volunteers whilst on placement at the trust.

The policy should be read in conjunction with the information technology (IT) security policy and also with reference to any relevant professional or union code of conduct such as the GMC, NMC’s and HCPC’s guidelines on social media usage which can be found at:

4 Responsibilities, accountabilities and duties

4.1 Managers

It is every manager’s responsibility to ensure that colleagues are aware of this policy and the parameters that are outlined and to react in an appropriate manner when informed of instances where behaviour is not in accordance with the procedure that is set out herein.

Managers are also advised to ensure that a hard copy of this policy is available and accessible for colleagues to read who do not have intranet access at work.

The voluntary services manager will need to ensure that all volunteers are aware of the policy.

Managers are also required to ensure that any issues or concerns reported to them that involve social media use should be acted upon appropriately and a record kept of the matter that has been raised and what action has been taken. Managers are advised to contact the People Experience team in HR if they require any advice or guidance.

Manager’s must support employees who may have been named on social media and must contact both the Communication team and the People Experience team for advice.

4.2 Employees and colleagues

Employees must ensure that they are complying with the expectations of this policy to support the reputation of the trust and, where relevant, of their profession. Employees must make sure that they conduct themselves online in the same manner that would be expected of them in any other situation, to uphold the reputation of the trust and, where relevant, the reputation of their profession. Employees who use social media will be responsible for ensuring that they are aware of this policy and understand the content and principles of the policy.

Employees who are named on social media, for example within a review of the trust or service, should seek advice from their manager who will raise with the Communication and People Experience teams. If an employee notices that another employee is named on social media they must report this to their line manager for exploration and support. Employees should not respond to comments made about themselves or other colleagues and instead should seek support from the trust.

4.3 Communication team

If an employee is named on social media, such as in a review, the Communication team will, wherever possible, contact social media company to request removal of the post.

5 Procedure and implementation

5.1 Summary of principles

When any employee has identified their association with the trust when using any social media site it is expected that they behave in a manner which acknowledges the duty of care that they owe to their colleagues and the organisation.

Once information has been published on the internet it is no longer considered to be private and thus the employee will be held accountable for any information posted which is challenged on the basis that it compromises themselves, their colleagues or the trust.

Employees should be aware that some social media sites have been known to make changes to user’s privacy settings without warning and the knowledge of the user concerned.

It is also important to be aware that any other employees or members of the public may, where appropriate, raise concerns with the trust about content that they have viewed on social media to which they had access to. They may also be able to share that data with others who would not otherwise be able to see it, without the original user’s knowledge or permission, for example by taking a screen shot.

Employees should also be mindful that connections could be made by members of the public between their making personal use of one site (such as Facebook) and identifying themselves as an employee of the trust or NHS on another (such as LinkedIn for example), particularly if both sites identify them by a photograph or some other unique personal data.

It is important to note that messaging services such as WhatsApp and Facebook Messenger also fall in the realms of social media and are therefore covered by this policy.

It should therefore never be assumed that something being posted on a social media site is private and cannot be viewed by others.

If an employee has a device which has a camera or video facility, this must not be used in the workplace, other than for work purposes, to then load images onto social media sites.

Within social media sites, individuals can choose to post comments, pictures or phrases to which other individuals can indicate their support or agreement to by clicking the ‘like’ button or by “sharing” on Facebook or “retweeting” on Twitter for example. This action is seen to be attaching the employee’s name and implied support to the material. This can be seen as being equivalent to posting the comment originally and therefore this action may also bring the employee’s conduct into question.

5.2 Use at work

Employees are allowed to access social media sites from any trust devices in connection with work related activities, such as posting about the service, upcoming events or publicising the service or trust. Employees are reminded that they must comply with all aspects of this policy.

Given the increasing use of social media to promote our services and engage with clients the trust permits employees to access some sites for work purposes. Employees are able to use these sites during their normal working hours for official trust business. This use should not be excessive however and should not interfere with employees’ other duties, or give rise to personal use of social media during work time.

Where the use of social media sites for work purposes has been approved, this should not give rise to using trust accounts on social media sites for purposes that may be considered personal, such as posting links to, or information about, non-trust related issues or events.

For personal use. The trust understands that employees may wish to use their own devices such as mobile phones, to access social media websites while they are at work, but employees must limit their use of their own devices so not to interfere with their working day and this must be limited to their allocated break times.

5.3 Personal use

While using social networking sites in a personal capacity and not acting on behalf of the trust it should still be recognised that employees’ actions can damage the trust’s reputation. All communications that are made, even in a personal capacity must not:

behave in a manner that would not be acceptable in any other situation
bring the trust into disrepute
breach confidentiality
make comments that could be considered to be bullying, harassment or discriminatory against any individual
use offensive or intimidating language
pursue personal relationships with current patients or service users or clients (pursuing personal relationships with current patients, services users or clients is not acceptable under any circumstances, for further information refer to the relationships at work policy. These actions will bring about possible disciplinary proceedings, which could result in the employee’s dismissal)
use social networking sites in any way which is unlawful
post inappropriate comments about colleagues or patients, service users or clients
post remarks which may unwittingly cause offence and constitute unlawful discrimination in the form of harassment
comment on work related issues

Employees are reminded that information may be classified as cyberbullying. Cyberbullying is bullying that takes place using electronic technology. Electronic technology includes devices and equipment such as mobile phones, computers, and tablets as well as communication tools including social media sites, text messages, chat, and websites. This also includes use of the trust’s clinical IT systems and instant messaging facilities.

Examples of cyberbullying include offensive or derogatory text messages or emails, rumours sent by email or posted on social networking sites, and embarrassing pictures, videos.

Bullying through this platform can include:

posting negative comments on pictures
posting abusive posts on a user’s Facebook wall
using pictures or videos to make fun of another user
sending intimidating or derogatory messages through a messaging service

Many of the acts of bullying on social media are similar to what they would be in a real-life situation, only in digital form.

Professionally qualified staff may place their registration at risk if they fail to adhere to the above guidelines.

All employees should be mindful of the personal information they disclose on social networking sites, especially in regard to identity theft. Making information such as date of birth, place of work and other personal information publicly available can be high risk in terms of identity theft.

Where employees associate themselves with the trust (through providing work details or joining a trust or NHS network) they should also act in a manner which does not bring the trust, the NHS, or their profession into disrepute. This applies to both open and private sections of a site if an employee has identified themselves as an employee of the trust or has connections to work colleagues (for example, as “friends” or “followers”, for instance) within the trust or other NHS and NHS-related organisations.

Employees should also be mindful that their usernames on social media sites should not demonstrate a connection to the trust, the NHS or their profession.

Where an employee chooses to associate themselves with the trust or the NHS on a social media site, they must add a disclaimer statement in a prominent position which clearly states that whatever is posted represents their personal views only and not necessarily the views of the trust, the NHS or their profession.

Where an employee is unsure about whether to post something on a social networking site then the most prudent action should be taken in line with their professional judgement.

5.4 Professional use

The trust encourages that some staff members may wish to have a professional presence on social media to promote the trust and their services. In doing so, employees must ensure that their online conduct meets the expectations and standards set out in this policy and that it does not in any way conflict with their obligations to the trust.

Employees should also ensure that any commercial interests that arise from professional social media use are declared to the trust, in accordance with the conflicts of interest policy (declarations of interest and hospitality).

Employees must also ensure that they declare any potential conflicts of interest when writing about professional matters online, taking full account of the fact that members of the public, including other staff and patients, service users or clients, may place a high value on their opinions as a clinician or NHS professional. Conflicts of interest may include financial interests in other organisations or any secondary employment undertaken, such as in private practice. As stated in the conflicts of interest policy, employees must also ensure that any such interests are declared to the trust.

5.5 Interactions involving different affected groups

5.5.1 Patients, service users or clients

Confidentiality must be upheld at all times and no information that could lead to a service user or their carer being identified should be disclosed through this media. Employees should not accept or make contact with any patients, service users or clients and carers through social media so that professional boundaries can be maintained; this is in line with other professional guidelines.

If an employee is contacted online by a service user, in order to protect both themselves and the service user from any risk, they should politely decline to engage in any contact and report the matter immediately to their line manager.

5.5.2 Work colleagues

When interacting with colleagues online, employees should be mindful of their responsibilities to be professional and courteous and never use these sites to attack or abuse any colleagues or to act in any way that may damage working relationships. When there is content that is being uploaded that includes other employees, for example pictures from a social event, then permission should be sought from their colleagues before they post such items and they should not post any items that they have been asked not to. Any item that a colleague has asked to be removed that includes them should be removed immediately.

Employees should be aware of the consequences of using any social media site to post content of any kind that conflicts with information that they have already provided to the trust, for example in relation to their health and fitness for work or any secondary employment that they undertake.

These actions will bring about possible disciplinary proceedings and, or referral to the trust’s counter fraud specialist which could result in the employee’s dismissal and criminal proceedings.

5.5.3 The trust

In any instances where there are any comments or questions which the employee wishes to raise in connection with their employment with the trust, either positive or negative, these should be raised through the appropriate channels internally rather than these views being expressed on social networking sites. Additional guidance and support is available through the trust policies and procedures, line managers or the People Experience team. Employees should be mindful that this may also apply to “private messages” being exchanged between work colleagues, as although they may not necessarily be seen by a wider audience, they may still be brought to the attention of the trust.

5.6 Breaches of the policy

If there is an instance where the guidelines set out in this policy appear to have been breached and the breach is bought to the attention of the trust then the matter should be investigated to ascertain the nature and the extent of the concerns that have been raised. The investigation should be carried out in accordance with the trust’s personal responsibility framework, disciplinary policy and maintaining high professional standards for doctors. Complaints about the use of social networking sites or other online activity will be taken as seriously as ‘real-world’ events by the trust. Consideration should be given to any professional boundaries that have been crossed; any breach of confidentiality; whether an association to the trust has been identified and, or whether any of the material is offensive to colleagues or patients, service users and clients or potentially damaging to the reputation of any party to whom the member of staff owes a duty of care as an employee of the trust.

If an employee is concerned about another employee’s behaviour online then they should report this to their line manager along with any supporting evidence of their claim, so that the appropriate action can be taken in accordance with trust policy.

Failure to follow this policy may result in the instigation of the disciplinary policy and may constitute a breach of professional code of conduct. In serious cases, a breach may be regarded as gross misconduct and may result in the employee’s dismissal.

5.6.1 Use of social media data in investigations

The trust reserves the right to monitor employees’ internet use on any trust device, in line with the information technology (IT) security policy. Any data obtained about an employee’s internet use may therefore form part of an employment investigation under the trust’s disciplinary policy and counter fraud, bribery and corruption policy.

If concerns are raised with the trust by another employee or member of the public about the online behaviour of any employee, the trust will be required to investigate this. The trust may therefore obtain copies of data posted on social media, and these may be kept electronically or in hard copy. This data will be retained by the trust in line with the trust’s policies on records management.

5.7 Support for employees named on social media

There may be times when patients, service users or clients or members of the public make comments about the trust online such as reviews on social media sites or a Google review. Unfortunately, there are times that these name colleagues within the trust.

The trust is committed to supporting colleagues if named publicly. Employees should report this to their line manager at their earliest convenience for the manager to explore support. The manager is able to contact the People Experience team and programme coordinator, staff health and wellbeing. Support may include increased supervision, counselling, access to other health and wellbeing support and safeguarding referrals if appropriate.

If the employee does not feel comfortable raising the issue with their line manager, they are able to do so with a freedom to speak up champion or guardian who can offer support and advice. Further information of how to raise a concern via this route can be found in the freedom to speak up, raising concerns (whistleblowing) policy.

The line manager (or freedom to speak up champion or guardian) must report the review or comment to the Communication team who will, wherever possible, contact the social media company to request for removal.

If an employee notices a review or comment naming a colleague of the trust they must report this to their line manager, so support can be offered to the relevant party.

6 Training implications

6.1 Employee usage of social media policy

Staff groups requiring training: Managers.
How often should this be undertaken: Introduction of the policy document and on revision of the policy or new appointment or promotion.
Delivery method: Team meetings.
Training delivered by whom: HR department through the communications department and via managers for promotions and newly appointed employees.

6.2 Employees

How often should this be undertaken: Introduction of the policy document and on revision of the policy or new appointment or promotion.
Delivery method: Local induction and team meetings.
Training delivered by whom: Managers.

6.3 Staff side

How often should this be undertaken: Introduction of the policy document and on revision of the policy or new appointment or promotion
Delivery method: Through policy forum and trust staff council
Training delivered by whom: HR department

7 Monitoring arrangements

7.1 Number of grievances or complaints regarding the application of the policy

How: Review of HR data.
Who by: HR.
Reported to: POD and organisation learning forum.
Frequency: Annually.

7.2 Number of disciplinaries regarding social media usage

How: Review of HR data.
Who by: HR.
Reported to: POD and organisation learning forum.
Frequency: Annually.

8 Equality impact assessment screening

To access the equality impact assessment for this policy, please see the overarching equality impact assessment.

8.1 Privacy, dignity and respect

The NHS Constitution states that all patients should feel that their privacy and dignity are respected while they are in hospital. High Quality Care for All (2008), Lord Darzi’s review of the NHS, identifies the need to organise care around the individual, “not just clinically but in terms of dignity and respect”.

As a consequence the trust is required to articulate its intent to deliver care with privacy and dignity that treats all service users with respect. Therefore, all procedural documents will be considered, if relevant, to reflect the requirement to treat everyone with privacy, dignity and respect, (when appropriate this should also include how same sex accommodation is provided).

8.1.1 How this will be met

No issues have been identified in relation to this policy.

8.2 Mental Capacity Act (2005)

Central to any aspect of care delivered to adults and young people aged 16 years or over will be the consideration of the individuals’ capacity to participate in the decision-making process. Consequently, no intervention should be carried out without either the individuals informed consent, or the powers included in a legal framework, or by order of the court.

Therefore, the trust is required to make sure that all employees working with individuals who use our service are familiar with the provisions within the Mental Capacity Act (2005). For this reason all procedural documents will be considered, if relevant to reflect the provisions of the Mental Capacity Act (2005) to ensure that the interests of an individual whose capacity is in question can continue to make as many decisions for themselves as possible.

8.2.1 How this will be met

All individuals involved in the implementation of this policy should do so in accordance with the guiding principles of the Mental Capacity Act (2005) (section 1).

9 Associated documents

Disciplinary policy
Grievance and dispute policy
Respect, civility and resolution policy
Freedom to speak up, raising concerns (whistleblowing) policy for the NHS
Relationships at work policy
Maintaining high professional standards for doctors
How to use social media for promoting your service’ (RDaSH staff intranet)
Counter fraud, bribery and corruption policy
Information technology (IT) security policy
Information governance policy and management framework (including data protection)
Personal responsibility framework
Conflict of interest policy

10 References

Arbitration, Conciliation and Arbitration Service, social networking and how to develop a policy.
British Medical Association, using social media: practical and ethical guidance for doctors and students.
GMC, doctors’ use of social media (2013).
Nursing and Midwifery Council, guidance on using social media responsibly (2015).
Health Care Professionals Council, focus on standards, social networking sites.
Xperthr (opens in new window), policy on use of social media and policy on use of social networking websites.
Professional codes of conduct as detailed in section 3.
NHS information governance, information risk.
Management guidance, blogging and social networking, connecting for health.
Game retail ltd v laws EAT/0188/14.
NHS employers, HR and social media in the NHS, November 2013.

Document control

Version: 6.1.
Unique reference number: 251.
Date ratified: 11 January 2024.
Ratified by: Corporate policy approval group.
Name of originator or author: Head of People Experience team.
Name of responsible individual: Director of people experience and organisational development.
Date issued: 16 January 2024.
Review date: November 2025.
Target audience: All staff, volunteers, seconded staff and agency staff.

Page last reviewed: November 14, 2024
Next review due: November 14, 2025

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