Social media policy

Policy Number IND-I-187 Effective Date 12/4/2016 Review Date 31 December 2017

Policy Statement

Social media gives NSW Department of Industry, Skills and Regional Development (the department) the opportunity to engage in ongoing 'conversations' with its diverse customer base. Social media, as a direct public engagement channel, can be used by the community to access the department and vice versa. The department encourages the use of social media to enhance service delivery, communications, collaboration and information exchange in support of its objectives.

Scope

The policy applies to all divisions and authorities within the department. It applies to all ongoing/term/casual/ temporary/seconded employees and private contractors/consultants.

It applies to these uses of social media:

Creating a social media presence as an official representative of the department
Publishing messages, responding to comments and uploading content including data to official, public facing departmental social media channels and/or third party social media channels
Making reference to the department in a private capacity on a social media channel
Participating in discussion that relates directly or indirectly to the field in which a staff member is employed by the department.

It does not apply:

to staff in their private use of social media where the staff member makes no reference to the department, its services, its people, Ministers, the government and/or other related business and organisations.

This policy is consistent with the NSW Government's Social Media Policy.

Requirements

Principles of conduct
1. In using social media staff should be:
  1. Open - using social media to share and promote access to information and services and being transparent and accountable
  2. Collaborative - creating opportunities to listen to and engage customers in policy design, implementation and service delivery
  3. Responsive - responding quickly to customers and emerging issues
  4. Reliable - providing a consistent and quality experience
  5. Appropriate - using social media in a manner that is consistent with public sector values, legal requirements, related policies, and the department's Codes of Conduct.
2. Whether using social media for official use, or in a private capacity, staff must not do anything that may adversely affect their standing as a public official or which could bring themselves, the department or the public sector into disrepute.
3. Any actions or comments that could bring the department into disrepute, even if using social media in a private capacity, may be subject to disciplinary action
4. All staff must exercise caution and adopt a risk minimisation approach when using social media channels, given that all content posted on social media sites immediately becomes:
  1. public information, freely available to those who access it and potentially permanent, difficult to erase, remove or retract.
  2. possible source material for journalists and other interested parties
  3. the property of the networking host if a third party site.
5. Any media interest generated through the use of social media must be referred to the relevant media contact and managed using the department's media policy.
Establishing an official social media presence

An official social media presence must:
1. Be part of a documented communications strategy which specifies the business objective and identifies resources and responsibility for content planning, promotion, management, moderation, evaluation, decommissioning of the channel and/or account and risk mitigation strategies. The communications strategy must be approved by the Executive Director, Communications & Engagement (or delegate) prior to approval by head of division (or delegate).
2. Have publicly available 'Terms and Conditions of Use' such as information on privacy, content moderation, monitoring, complaints handling, and record keeping which comply with relevant legislation and regulations..
3. Be established by a delegated officer nominated by Executive Director, Communications & Engagement.
4. Be established using a departmental email address.
5. Be branded with a NSW Government logo or a suitable alternative.
6. Describe the NSW Government entity administering the presence.
7. Be recorded in the department's social media register.
8. Be used for official departmental business only.
Official use of social media

Staff participating on third-party or department hosted social media platforms in an official capacity must:
1. Participate in training which covers operational and strategic aspects of social media management.
2. Use the social media resources available on the intranet to support account management.
3. Use an official social media account or profile established with the approval of the Executive Director, Communications & Engagement (or delegate).
4. Have prior approval from a delegated officer to act as an authorised social media user.
5. Only discuss or post information that is publicly available or within a 'content framework' approved by a nominated media contact and that falls within their area of expertise within the department. This is to minimise the risk of inadvertently posting and releasing inappropriate and/or unauthorised including confidential, misleading or sensitive material.
6. Disclose in a manner suitable to the platform that they are an employee of the department and specify their role and responsibilities within the department.
7. Not mix personal views with official comments
8. Inform the nominated media officers of any media involvement or interest by journalists.
9. Ensure that if advertising is associated with free social media accounts, it is appropriate or else consider budgeting for an account upgrade to exclude advertising.
10. Follow and comply with the requirements of the departmental and whole of government privacy, copyright, advertising, media, record keeping and publishing policies and procedures and any other relevant legal requirements such as defamation, intellectual property, and anti-discrimination legislation and regulations.
11. Ensure there is no conflict of interest for the department in complying with the platform owner's terms and conditions of use.
Private use of social media

Staff participating in social media in a private capacity are expected to:
1. Exercise sound judgement and commonsense and behave in accordance with the department's Code of Conduct. This includes the responsibility to discuss any potential conflicts of interest with their manager/supervisor.
2. Clearly separate private opinions from the department's official position. A disclaimer should be used when expressing private views related to your work, and there can be no implication that the department endorses any private opinions.
3. Comply with the department's acceptable use of communications devices policy when at work.
4. Not allow the use of social media to undermine their effectiveness at work.
5. Use a private social media account, established with a private email address. (Staff must not use a departmental social media account or a departmental email address for private use of social media).
6. Not disclose confidential information obtained through work. This includes information relating to employment, departmental email addresses, contact lists, work duties or photographs of departmental business activities or staff at work.
7. Understand the risks, benefits and implications that may arise from making private contributions to discussions that relate to their work. Note that even positive and supportive comments can become contentious if it becomes publicly known that the person making the comment is a departmental officer.
8. Seek advice from nominated communications and media contacts to address any issues or concerns.

Procedures

Procedures outlining how to establish and manage an official social media presence from planning through to decommissioning are available on the intranet.

Roles and responsibilities

Communications & Engagement Branch

Provide social media guidelines and tools
Identify and promote social media training opportunities

Business & Technology Services

Provide operational assistance to support the use of social media as required, e.g. establishing generic email addresses.
Provide technical 'how to' account establishment guidance
Maintain a register of official social media accounts and channels
Register the approved site/presence on the NSW Government portal (www.nsw.gov.au)

Executive Director, Communication & Engagement (or delegate)

Provide authority for establishing a social media channel as part of a communication strategy
Ensure approval processes are followed when using social media
Authorise staff to represent the department/division/branch in approved social media channels
Ensure that social media strategies are adequately resourced and maintained, are regularly monitored, and have an exit strategy
Maintain internal processes to ensure quality, technical accuracy and currency of content posted to social media sites and risks are managed

Nominated media contacts

Conduct all media management
Advise on and approve social media content where the information is not already publicly available and is more than a routine operational issue
Track and monitor discussions and respond to emerging issues
Outline relevant 'escalation plans' for staff engaging with the public on department owned or approved social media channels

Authorised social media user

Undertake social media training/awareness as available
Assess the risk of publishing content to social media sites and refer high risk / contentious content to the relevant media/communications contact
Ensure information is authorised for public release
Monitor and track discussion and alert media contacts to emerging issues
Ensure that approved content is well written, accurate, and up-to-date and complies with department and NSW Government standards
Ensure all required approvals are received before establishing a social media channel or posting content.
Maintain official records
Ensure personal information is not disclosed in social media sites and that content complies with the department's privacy policy

Safety considerations

Businesses, industry, the community and staff rely on current and accurate information published by the department to help inform and guide the healthy and safe conduct of activities.

Delegations


Activity or function	Policy reference	Delegated officer
Approve, or delegate authority to approve, communication strategy (which may include use of social media)	2a	Executive Director, Communication & Engagement Deputy Secretary, Executive Director, CEO or General Manager
Approve, or delegate authority to approve, establishment of an official social media account or profile	3c	Executive Director, Communication & Engagement
Approve,or delegate authority to approve, appropriate staff to act as social media users for official purposes	3d	Executive Director, Communication & Engagement
Approve, or delegate authority to approve, of a 'content framework' as a source for social media content	3e	Executive Director, Communication & Engagement

Definitions

Conflict of interest - exists when a staff member comments in a private capacity in an area that relates to their work or employment. This is particularly important when a staff member wishes to expresses a private opinion that differs from or could undermine the official position of the department on a topical or controversial issue.
Content framework - a list of topics or messages which an authorised social media user intends to post on social media sites to start a conversation.
Departmental email address - an email address within a domain managed by the department or one of its constituent authorities. For example, any address ending with '.nsw.gov.au' is a departmental email address.
Escalation plan - media procedures staff use to alert relevant nominated media/communications contacts to any contentious or significant issue relevant to the department.
Generic email address - an email address that is not assigned to an individual and may be directed to one or more staff for attention. For example, webmaster@industry.nsw.gov.au is a generic email address.
Nominated Communications Officers - the relevant communications branch/unit within the division, department, office or authority.
Nominated media contacts - the relevant media branch/unit within the division, department, office or authority.
Official use - when fulfilling your capacity as an employee or acting in relation to your employment. Comments made using an official social media account, using a departmental email address or a social media account established using a departmental email address would be considered official use.
Operational issue - routine, non contentious matters that do not involve comment on government policy.
Private use - when participating in social media in your capacity as a private individual. For example, discussing the performance of your favourite football team using your personal profile established with your private email address.
Significant issue - any local, state, or national issue that can be expected to generate substantial media interest.
Social media - umbrella term that describes the various activities that use technology, primarily internet, web and mobile based tools, for social interaction and content creation and sharing. In the interests of simplicity, this policy is focussed on those social media activities that are used for discussions and information sharing such as social networks, blogs, wikis and forums. Technologies that relate more specifically to the development, publishing and distribution of information content are covered under the Publications and Websites Policies. (See the Social media resources and guidelines for explanations of social media terms).
Social media account - a user name, logon name, profile name, avatar or other identity used to participate in social media. A social media account may be established at an individual level i.e. a real person, or at a generic level, such as a unit within the department. It is also possible that a generic social media account could be established as a fictitious individual.
Social media channel - a presence on a social media platform. Examples include a Facebook page, a wiki page, a YouTube channel or a Twitter account. In some cases, a social media channel and social media user are the same, but in other cases, several users could share a single channel.
Social media platform - software or technology that enables users to build, integrate or facilitate community and social interactions and user-generated content. Examples include blogs, wikis (such as Wikipedia), forums/discussion boards, social networks (such as Facebook and myspace), social bookmarking (such as delicious), and video and photo sharing websites (such as YouTube and Flickr).
Social media presence - can be an official social media account, platform or channel.
Social media user - an individual staff member who directly participates in social media.

Legislation

Copyright Act 1968 (Cth)
Government Sector Employment Act 2013
Spam Act 2003 (Cth)
Privacy and Personal Information Protection Act 1998 (NSW)
State Records Act 1998 (NSW)
Anti-Discrimination Act 1977 (NSW)
Defamation Act 2005 (NSW)
Government Information (Public Access) Act 2009 (NSW)

Related policies

IND-I-177 Records management
TI-A-130 Code of conduct
TI-G-135 Enterprise risk management
A-032 Use of employer communication devices
TI-G-144 Publishing
TI-A-137 Media policy
TI-A-134 Complaints handling
TI-G-155 Privacy management plan
TI-G-148 Copyright policy

Revision history


Version	Date issued	Notes	By
1	12/04/2016	Administrative updates. Allocation of NSW Dept of Industry policy number. Legislation updated.	Project Officer, Corporate Governance

Review date

31/12/2017

Contact

Communication & Engagement Branch