Social Media Policy for employees of the department
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This policy provides guidance to employees of the department about engaging in social media. All employees are responsible for being aware of the policy and understanding their responsibilities around using social media in their professional and personal capacity.
Overview and principles
Online communication and new media tools are important communication channels that provide the department with the opportunity of engaging with the Victorian public directly. These tools can be used to inform the community about the department’s services; to provide information about programs and to create new channels to open up a two-way conversation and consultation, for example on aspects of policy development.
The objective of this policy is to set the parameters for the use of social media, where it forms part of the employee’s professional responsibilities; inform employees of their responsibilities, when using social media in a personal capacity and to manage risks associated with the department’s use of these tools.
This policy was developed to sit under the framework for the Guidance for the use of social media in the Victorian public sector released by the Public Sector Standards Commissioner.
It is essential that employees understand that comments published via social media platforms are treated the same way as public statements and should be made by an authorised spokesperson in the same way that comments are made in any public forum or to the media.
The intention of this policy is to establish a culture of openness, trust and integrity in activities around web 2.0.
The objectives of this policy are compatible with the Code of Conduct for Victorian Public Sector Employees (No 1) 2007, the Charter of Human Rights and Responsibilities Act 2006 and the Public Sector Standards Commissioner Guidelines for the use of social media in the Victorian public sector.
This policy applies to all employees (see definition) of the department.
General responsibilities as a public sector employee
Employees should be aware of and understand their responsibilities under the Code of Conduct for Victorian Public Sector Employees (No 1) 2007 (VPS Code of Conduct). The following sections of the VPS Code of Conduct are particularly relevant to this policy:
- Section 2.2 Remaining apolitical
- Section 3.2 Using powers at work
- Section 3.4 Official Information
- Section 3.5 Public comment
- Section 3.9 Public trust
- Section 5.3 Work resources
- Section 5.4 Open to scrutiny
- Section 6.1 Fair and objective treatment
- Section 6.2 Privacy and confidentiality
- Section 6.3 Maintaining confidentiality
- Section 6.4 Equity and diversity.
Depending on the circumstances, non-compliance with this policy may constitute a breach of contract of employment or other contractual obligations, misconduct (under the department's relevant discipline policy), sexual harassment, discrimination, or some other contravention of the law.
Failure to comply with the policy may result in disciplinary action and, in more serious cases, may result in termination of employment.
Identifying inappropriate use
Where an employee becomes aware of inappropriate or unlawful online content that relates to the department, or content that may otherwise have been published in breach of this policy the situation and circumstances should be reported immediately to the department’s Media Unit on telephone 9096 7710 or via email to email@example.com.
Privacy breaches can also be reported to the department’s Corporate Integrity Information and Resolutions Unit on telephone 9096 8054 or via email to firstname.lastname@example.org.
Social media is the term used for internet-based tools for sharing and discussing information among people. It refers to user-generated information, opinion and other content shared over open digital networks.
Social media may include (although is not limited to):
- social networking sites (for example Facebook, Myspace, LinkedIn, Bebo, Yammer)
- video and photo sharing websites (for example Flickr, Youtube)
- blogs, including corporate blogs and personal blogs
- blogs hosted by media outlets (for example ‘comments’ or ‘your say’ feature on theage.com.au)
- micro-blogging (for example Twitter)
- wikis and online collaborations (for example Wikipedia)
- forums, discussion boards and groups (for example Google groups, Whirlpool)
- vod and podcasting
- online multiplayer gaming platforms (for example World of Warcraft, Second life)
- instant messaging (including SMS)
- geo-spatial tagging (Foursquare).
Social media also includes all other emerging electronic/digital communication applications.
In this policy, employees include permanent staff and executives, contractors, temporary staff and students on placements.
Statement of policy
Professional use of social media
Becoming authorised to comment
- Before engaging in social media available outside the department as a representative of the department, employees must become authorised to comment.
- Employees may not comment unless authorised to be a representative spokesperson of the department.
- To be authorised to comment or be an authorised spokesperson, employees must have the explicit approval of the Director of Communications.
Rules of engagement
Authorised representatives must:
- disclose that they are an employee/contractor of the department, and use only their own identity, unless authorised to use an approved official account or avatar
- disclose and comment only on information classified as public domain information
- ensure that all content published is accurate and not misleading and complies with all relevant departmental policies and other relevant requirements
- ensure they are not the first to make an announcement (unless specifically given permission to do so)
- comment only on their area of expertise and authority
- ensure comments are respectful of the community in which they are interacting online
Authorised representatives must not:
- post or respond to material that is offensive, obscene, defamatory, threatening, harassing, bullying, discriminatory, hateful, racist, sexist, infringes copyright, constitutes a contempt of court, breaches a court suppression order, or is otherwise unlawful
- use or disclose any confidential or secure information
- comment or post any material that might otherwise cause damage to the department's reputation or bring it into disrepute.
Moderation of department produced social media
The department's site owner or account holder must ensure a clear and unambiguous the moderation policy is in place when inviting public comments to a departmental website or social media platform.
All departmental website activity (including any social media) must be approved by the department’s Communication Committee. For information about the authorisation process contact the Manager, Digital Engagement Unit, Communication Branch on telephone 9096 0779.
Personal use of social media
This policy does not to discourage nor unduly limit employees using social media for personal expression or other on-line activities in their personal life.
Employees should be aware of and understand the potential risks and damage to the department that can occur, either directly or indirectly from their personal use of social media and should comply with this policy to ensure that the risk is minimised.
Employees are personally responsible for content published in their personal capacity on any form of social media platform. When in doubt, employees can seek guidance from the department on how to comply with the following obligations.
To avoid breaching this policy employees must:
- only disclose and discuss publicly available information
- ensure that all content published is accurate and not misleading and complies with all relevant departmental policies and other government requirements
- expressly state that stated views are personal and are not representative of the department or the government
- behave politely and respectfully
Employees must not:
- post material that is offensive, obscene, defamatory, threatening, harassing, bullying, discriminatory, hateful, racist, sexist, infringes copyright, constitutes a contempt of court, breaches a Court suppression order, or is otherwise unlawful
- imply that they are authorised to speak as a representative of the department or the government, nor give the impression that the views expressed are those of the department or the government
- use the identity or likeness of another employee, contractor or other member of the department
- use their department email address or any department or Victorian Government logos or insignia that may give the impression of official support or endorsement of their personal comment
- use or disclose any confidential information or personal information obtained in their capacity as an employee or contractor of the department
- post material that is, or might be construed as, threatening, harassing, bullying or discriminatory towards another employee or contractor of the department
- comment or post any material that might otherwise cause damage to the department's reputation or bring it into disrepute.
Reasonable and unreasonable personal use
- When accessing social media via the department's Internet, intranet and extranet systems, employees must do so in accordance with the department’s Acceptable Use of Computer Services Policy, which requires employees to use these resources ‘reasonably’, in a manner that does not interfere with work, and is not inappropriate or excessively accessed.
Examples of reasonable use include:
- re-tweeting content from the VicGovDHS account on a personal Twitter account
- accessing and posting comments on the Human Services network within Yammer (microblog service)
- participating in working groups on the VPS Hub (whole of Victorian government intranet)
- updating Facebook status and posting messages during a lunch break.
- Departmental resources should not be used to access or post any material that is fraudulent, harassing, threatening, bullying, embarrassing, sexually explicit, profane, obscene, racist, sexist, intimidating, defamatory or otherwise inappropriate or unlawful.
- Employees should not use the department’s Internet and computer resources to provide comments to journalists, politicians and lobby groups other than as authorised in the course of their official duties.
- It is not acceptable to spend time using social media that is not related to your work unless it occurs in your own time (for example during meal breaks) or at times acceptable to your line manager.
Guidance for navigating legal issues
The following is offered as general guidance to assist employees in complying with the obligations set out in this policy. When in doubt, employees should seek further guidance from the department.
Privacy, confidentiality and information security
- Users should not publish or report on conversations or information that is deemed confidential or classified or deals with matters that are internal in nature.
- Client personal information should not be made available on social media unless express consent has been obtained from the client in relation to the use and disclosure of their personal information.
- For more information on posting material online (in the 'public domain'), refer to the Information Security Classification – Policy and Standards section on Information Security Classifications.
- Employees must respect copyright laws and fair use of copyrighted material.
- All employees are expected to attribute work to the original author or source wherever possible.
Harassment and bullying
- The department’s Anti Bullying and Workplace Conflict Policy applies both online and in the physical workplace.
- Workplace bullying and harassment includes any bullying or harassing comments employees make on-line, even on their own private social networks or out of office hours.
- Abusive, harassing, threatening or defaming postings are in breach of the Positive and Fair Workplaces - Working Well Together Package, and may result in disciplinary action being taken.
- All employees are expected to treat their colleagues with respect and dignity and must ensure their behaviour does not constitute bullying and/or harassment.
Employees are to refrain from publishing material that may cause injury to another person, organisation, association or company's reputation, and should seek further legal guidance if publication of such material is thought to be necessary.
Offensive or obscene material
Material may be offensive or obscene and may infringe relevant online classification laws if it is pornographic, sexually suggestive, harassing, hateful, racist, sexist, abusive or discriminatory.
Contempt of court
All employees must exercise care if referring to pending court proceedings to avoid publishing material that may have a tendency to prejudice those proceedings, in particular, material that will not be part of the evidence in those proceedings.
It is recommended that all employees make enquiries as to any applicable court suppression orders prior to commenting on any court proceeding (whether past or pending).
- Code of Conduct for Victorian Public Sector Employees
- Guidance for the use of social media in the Victorian public sector
- Information Security Classification – Policy and Standards
- Positive and fair workplaces: working well together package
- DHS Records Management Policy
- Acceptable Use of Computer Services Policy
- Health Records Act 2001
- Procedure for responding to web breaches of employee and client privacy.
- Charter of Human Rights and Responsibilities Act 2006 (Vic)
- Information Privacy Act 2000 (Vic)
- Public Administration Act 2004 (Vic)
- Equal Opportunity Act 2010 (Vic)
- This policy was endorsed on 9 August 2011.
- This policy is effective from 9 August 2011.
This policy is endorsed by: The department's Communication Committee.
Modification and Review
- The date the policy is due for review no greater than two years from the date of endorsement.
- The department's Communications Branch is responsible for reviewing this policy.
Contact the Manager, Digital Engagement Unit, Communications Branch, telephone 9096 0779 for further information about this policy.
This document has been reproduced and adapted from the Department of Justice - Social Media Policy 2011.
This work is licensed under a Creative Commons Attribution – Non-commercial – Share Alike 2.5 Australia Licence. www.creativecommons.org/licenses/by-nc-sa/2.5/au