Social Media Policy for Healthcare
Developing a Social Media Policy for your healthcare, senior living, home care, hospice, LTC company, or medical practice does not have to be as complicated as you think. As my good friends at SocialFish point out, the Mayo Clinic’s Center for Social Media recommends starting with twelve simple words:
- Don’t Lie, Don’t Pry
- Don’t Cheat, Can’t Delete
- Don’t Steal, Don’t Reveal
Having a Social Media Policy in place is an important step to developing your Online Presence and every healthcare organization should have one. In addition to Mayo Clinic’s 12 words, here are some important elements and language to consider including. Most of these were collected from a variety of highly reputable sources from around the web, including the SocialFish White Paper, Social Media, Risk, and Policies for Associations and the Mayo Clinic Social Media Policy.
Follow all applicable Company policies. You must not share confidential or proprietary information about the Company and you must maintain patient/resident privacy. Among the policies most pertinent to this discussion are those concerning Protected Health Information, HIPAA, Confidentiality, Computer, E-mail & Internet Use, Photography and Video Use.
- Be yourself. You are responsible for the content you post. Never impersonate someone else, or purposely obscure your identity as a Company employee. Write in the first person. Build your own reputation. Care about what you are talking about. Be transparent and state that you work at the Company, and be clear about your role. Your honesty will be noted and appreciated on the social web. In public social media spaces, where your connection to the Company is apparent, make it clear that you are speaking for yourself and not on behalf of the Company. In those circumstances, you may want to include this disclaimer: “The views expressed here are my own and do not reflect the views of my employer.” Consider adding this language in an “About me” section of your blog or social networking profile. Avoid using unprofessional online personas, photos, or avatars.
- Be transparent. If you communicate in the public internet about the Company or Company-related matters, disclose your connection with the Company and your role at the Company. Use good judgment and strive for accuracy in your communications; errors and omissions reflect poorly on the Company, and may result in liability for you or the Company. If you have a vested interest in what you are discussing, be the first to say so.
- Be honest. Never represent yourself or the Company in a false or misleading way. All statements must be true and not misleading; all claims must be substantiated.
- Write what you know. Stick to your area of expertise and provide unique, individual perspectives on what’s going on at the Company and in the world.
- Don’t tell secrets. Respect proprietary information and content, confidentiality, brand, trademark, copyright, and fair use. Know the laws and don’t break them. Don’t discuss patient/resident protected health information ever. The nature of your position may provide access to confidential protected health information or proprietary information. Remember to respect and maintain the confidentiality entrusted to you. Do not divulge or discuss protected health information, proprietary information, internal documents, personal details about other people or other confidential material.
- Add value. Be helpful to our residents/patients, families, employees and associates by answering questions, posting interesting content, or adding tips or advice. Don’t spam, ever. You can link to other Company blog posts or information about services but do it subtly and only if the link provides value to the conversation. Always provide content that builds a positive sense of community.
- Be smart. Or, put another way, don’t be stupid. Use common sense and common courtesy. If what you are posting gives you pause or is something you wouldn’t want to say in front of your manager, your mother, or a judge, don’t post it. If your postings on public sites related to the Company are inconsistent with, or would negatively impact the Company’s reputation or brand, you should not refer to the Company, or identify your connection to the Company.
- Be polite and respectful. Be respectful and professional to fellow employees, business partners, competitors and patients/residents. Never use ethnic slurs, personal insults, obscenity, or engage in any other conduct that would not be acceptable in the Company’s workplaces. If you want to write about the competition, make sure you behave diplomatically, have the facts straight and that you have the appropriate permissions. When disagreeing with others’ opinions, keep it appropriate and polite. If you find yourself in a situation online that looks as if it’s becoming antagonistic, do not get overly defensive and do not disengage from the conversation abruptly: feel free to ask the a manager for advice and/or to disengage from the dialogue in a polite manner that reflects well on the Company.
- Be a leader. There can be a fine line between healthy debate and incendiary reaction. Don’t denigrate anyone. Nor do you need to respond to every criticism or barb. Try to frame what you write to invite differing points of view without inflaming others. Some topics – like religion and politics – often slide into sensitive territory. Show leadership by being careful and considerate with your words.
- Avoid litigation issues. Please never comment on anything related to legal matters, litigation, or any parties the Company may be in litigation with.
- Ask for help in a crisis. Never participate in Social Media when the topic being discussed may be considered a crisis situation. Even anonymous comments may be traced back to your or the Company’s IP address. Refer all Social Media activity around crisis topics to a manager.
- Consult your manager. Don’t hesitate to ask a supervisor if you have any questions about what is appropriate to include in your blog or social networking profile. Remember that if you wouldn’t want your manager or others at Liberty HRS to see your comments, it is unwise to post them to the Internet.
- Represent responsibly. Some Liberty HRS staff may be asked by supervisors or leadership to participate, in support of the Company’s organizational objectives. Such engagement on behalf of the Company, including establishment of official external sites representing the Company or any Company organization, must be approved and coordinated through your supervisor or manager. the Company’s Social Media Team provides oversight and assistance to guide development of new social media platforms, sharing knowledge and instituting best practices for successful implementation. Use of external Web sites for work-related purposes (e.g. photo sharing through Flickr.com) must be first approved by your manager and/or the social media team.
- Fix mistakes fast. Mistakes happen. If you make a mistake, admit it and be quick with your correction. Tell your supervisor. Most of the time, you can then move on. If not, let the team help you fix your mistakes; explain the situation and the team can come together to find a solution to any problem. Your participation in social media on behalf of the Company is not a right but a privilege that needs to be taken seriously and with respect. What you write, post or contribute is ultimately your responsibility. Failure to abide by these guidelines and the Company Code of Conduct, Code of Ethics, or other personnel and corporate policies could put your participation at risk.
We trust that you will live and breathe these guidelines on the social web. If, for any reason an incident occurs that violates the guidelines, we expect you to bring the issue to our attention immediately so that we can work together toward a resolution. We’ll work through each issue on a case-by-case basis, and we’ll listen to every side of the story. We promise that any consequences will be commensurate with the violation. The consequences for violating these policies can range from a helpful discussion to a warning to withdrawal of social media participation to possible termination.
There are many additional resources on the web that can help you develop your own policy here are some of my favorites:
- Healthcare Social Media Policies List
- Inc. Magazine’s How to Write a Social Media Policy
- KevinMD’s post on AMA’s Social Media Policy Guidelines
- Social Media and HIPAA: What You Need To Know