Social Media Policy
Our Thanks to Wessex LMCs for sharing guidance on this subject
The impact of social media on the workplace is increasing and the LMC is receiving a growing number of queries from practices on how to manage social media issues both internally and externally. We have put together a short guide on what to consider, together with links to good practice and further guidance, so that practices can develop their own social media policies.
If you have little or no knowledge of social media, a good overview can be found here:
Social Media & Your Doctors
- The BMA has published guidance for doctors on their use of social media, which can be accessed at: Social Medial Use, practice and eithical guide
- The RCGP has also published the ‘Social Media Highway Code'.
- The GMC has also issued guidance
- NHS Employers Guidance and Toolkit 2017
- HR and social media in the NHS
Social Media & Your Staff
ACAS has some excellent guidance on how employers can develop their own policies and procedures to take into account the impact of social media on:
Social media and managing performance
Social media and recruitment
Social media, discipline and grievances
Social media and bullying
Social media, defamation, data protection and privacy
Social media and how to develop a policy
They also offer a free, confidential helpline and further training and support. The helpline number is 0300 123 1100.
Social Media & Your Patients
The use of social media can have many advantages – it’s a good way to promote your practice, get important health messages across to your patients, engage with those who don’t regularly come into the surgery and get feedback via a private group. However, there are also disadvantages – it is inevitable that you will, at some time, receive complaints/negative comments and you also need to protect the privacy of staff and patients, particularly those who are vulnerable. Top tips for social media in general practice include:
- Have a social media policy and keep it under review
- Make sure it cross references with your complaints policy
- Be careful about which social media platform your choose – it needs to be right for your practice and it must be managed
- Have a staff social media policy
- Publish a code of conduct on your practice website
- Don’t post anything that you are not happy to appear elsewhere and that you would not be prepared to say face to face.
When the Practice is Subject to Criticism or Abuse
You will not be the first, or the last, person/organisation to be the subject of abuse/negative comments. Do not react immediately; consider the most appropriate course of action to take.
1. Decide if you should/can respond. . .
Why is the practice/a member of staff being criticised?
What is the motivation behind the abuse/negative comments?
What would be the value of engaging with a discussion stream? Sometimes the best course of action is to ignore the comments, particularly where responding may simply fuel or reignite the situation.
How can you minimise the harm done?
Do you have a policy for handling this sort of situation?
Save the posts by taking a screenshot or saving the post to a file – comments can be deleted and you may want proof at a later stage. Consider reporting the post to the social media site to see if they will remove any abusive comments – they are likely to only take comments down that name individuals or are extremely inappropriate (racist, pornographic etc.). Also consider blocking the poster (although this won’t stop them from posting about you to others).
If you feel that any practice staff or patients are at risk, report your concerns to the police.
2. Act quickly and go offline.
If you are going to respond, it’s usually best to do so quickly (hours, not days) and with a brief, measured response acknowledging that you have seen the comments. Do not respond in detail – it’s better to ask them to contact you directly to discuss further. Thank them for letting you know there is a concern and you’re looking forward to resolving the issue. Respond in the same comment stream as the original comment was made. Setting a measured, reasonable tone can be very effective in diffusing a situation.
Remember you do not have to respond at all if you don’t think it’s appropriate and be careful not to be provoked into an online spat – remember that all this is being played out publicly. If you can, it may be appropriate to follow up privately but bear in mind that anything you send through may end up in the public domain again. Discuss your response with the LMC if you want a reliable sounding board.
3. Be prepared. . .
Although it may seem tempting, suing for defamation is unlikely to be the best route to take – the damage has already been done and the legal process is too slow to stop it (as well as being very costly).
However, both the Malicious Communications Act 1988 and the Communications Act 2003 have been used against people posting offensive material on social media. The Department of Public Prosecutions subsequently published ‘Interim Guidelines of Prosecuting Cases
Involving communications sent via Social Media’ in December 2012 which set out the offences that are likely to be the most commonly committed.
A criminal offence is only likely to have been committed if the activity amounts to:
- credible threats;
- targeting of an individual or individuals;
- a breach of a court order or;
- Grossly offensive, indecent, obscene or false comments.
However, this is often subject to a high threshold and in many cases a prosecution is unlikely to be considered in the public interest.
Ultimately, you may find that your allies/practice supporters are your best weapon and will defend you when something negative or untrue is posted.
It’s good to be prepared. Consider:
How to monitor what is being said about the Practice in social media, so you can respond quickly
You can set up an alert system via mediums such as Google or monitor Twitter, Facebook etc. on a regular basis.
What have others done?
How have others managed social media attacks (there have been some high profile cases (e.g. Tom Daley on Twitter). What would you do?
Further useful information can be found here:
How can you use social media?
If your Practice has a Facebook or Twitter account, what are you trying to communicate?
Are there other easy ways for patients to contact you to avoid the incentive for them to use social media? How approachable is the Practice?
How do you want to present the organisation? What messages are you trying to get across?
There is helpful guidance on setting up social media to benefit the practice here:
You don’t have to use social media if you don’t feel confident to do so and you don’t have the skills or time to manage it effectively. If you do decide to use it, be aware of the potential pitfalls and enjoy the benefits.