Knowsley Council Social Media Protocol: May 2019

Social media is a key channel for the Council to communicate with residents, businesses and other stakeholders.  It is also a highly visible channel which can be seen by anyone, anywhere, and at any time, which means that it must be managed correctly in order to enhance and not harm the Authority’s reputation.

Management of Social Media Accounts

Official Council channels (such as Knowsley Council branded accounts) are managed by the Communications team.  This includes a series of Cabinet Portfolio Twitter accounts which are used to share specific information and news from respective areas of work.

Where there is a clear business case, some specific services within the Council may have their own social media presence (e.g. the Libraries service, or the Children’s Centres service).  This must be with the prior agreement of the Communications Team.  These accounts should be clearly branded with the name of the relevant service or team.  Further guidance on the tone, style and content posted on these channels is available from the Communications team.

Individual members of staff must not use their personal social media accounts to carry out Council business and should not promote their accounts on the basis of their professional positions at Knowsley Council (for example, in profiles or bios).  Council business and promotion should only be conducted using official social media channels which belong to the Council or specific services (in accordance with the circumstances mentioned above).

Appropriate Online Conduct

Staff are advised to read the Officer Code of Conduct and Managing Conduct, Performance & Information Policy when making use of social media.

Staff using social media in a personal capacity should remember that the same standards of behaviour apply online as they do offline. Remember that any opinions expressed may be interpreted as a reflection on your professional role or attitude.

You should never post anything which you would be unhappy to see repeated elsewhere.  In addition, remember that publishing comments or content means that you are making them permanently public (even if you later delete them).  Nothing you post online is ever truly “private” and nothing you delete is ever truly “deleted”.

Ensure that online contact which you have with others is always appropriate.

Use of Social Media during Working Hours

The Council’s intranet, Bertha, provides for social media to be made directly available on to Bertha’s home page, thereby enabling staff to keep up to date on the latest social media posts from the Council.

Staff can of course use their personal accounts to share and participate positively with the Council’s social media accounts.  This can help to spread positive Council messaging to local communities, especially as a large number of staff are also Knowsley residents.

It is permissible for staff to undertake this activity during working hours – within reason.

Staff who monitor some social accounts on behalf of the Council – for example, staff who administrate a Council Facebook page – may also need to log in to their personal accounts during working hours to carry out such functions.

Where staff are using social media accounts in a purely personal capacity, this should be restricted to non-working time, for example during lunch breaks.

Staff are reminded that appropriate action will be taken if social media is being accessed inappropriately or unnecessarily – for guidance in this respect, please refer to the Managing Conduct, Performance & Information Policy.

Moderation of Council Sites and Accounts

  • Administration Responsibilities

Where social media and digital communication are used as part of the communications strategy for priority Council projects, the day-to-day management and administration of related sites and accounts will be the responsibility of the Communications team.

In the case of service-specific accounts, day-to-day administration will be the responsibility of the associated service itself, with support from the Communications team.

The Communications team must always be consulted before social media accounts are set up on behalf of any Council service or team, and this will only be authorised where there is a clear business case to do so.

A generic team/service mailbox should be used when setting up social media accounts on behalf of a Council service, rather than an individual account.  Multiple administrators should be appointed and this should always include the Communications team.  This approach will ensure that the account can be updated/monitored if a member of staff is on leave, on sickness absence, or leaves the Council.

In all cases, log in details and passwords for Council accounts remain the property of the Council.  When a member of staff leaves the employment of the Council, these details must be passed to a line manager.

  • Responding to Social Media Messages

Due to the speed in which information can be published via the internet, a fast response to questions or comments posted on sites may be essential in order to protect the Council’s reputation.  In many cases, the Communications team, or those monitoring an account, will be able to respond instantly, provided that the question is straightforward and not controversial.

In cases where a question requires more research before a response can be given, a holding reply should be given to let the poster know that the question is being considered and that there will be a response soon.  An answer or response should be given the same working day wherever possible.  Difficult or potentially controversial questions should be shared with the Communications team.

It is important to remember that any question and the associated response are public and can be viewed by anyone, at any time.  Such material may also be used by a third party as the basis of a story or conversation elsewhere online or in other media (including newspaper, radio etc.).

Comments posted from official Council social media accounts should be deleted only in exceptional circumstances.  When this does happen, the reasons for doing so should be made clear on the site and, in the case of incorrect information posted in error, an apology should be posted instead.  A screenshot of the comment should be taken for the Council’s own records whenever any comment is removed, and the reasons for this noted.

  • Moderating Comments

Comments on Council-managed accounts should be moderated in line with the Authority’s Social Media Terms and Conditions.

Defamatory or inappropriate comments hosted on Council profiles (e.g. comments on Facebook pages) should be deleted where possible, and the administrator of a site should consider “blocking” persistent offenders in this respect.  Screenshots of comments should be taken before deletion in case of future dispute.  It may be appropriate in such cases to contact a poster directly to explain that he/she has breached the Council’s terms and conditions.  Records of such posts and related correspondence should be retained.

Comments which are negative, but not defamatory or inappropriate, should not be deleted.  Administrators should instead consider replying to offer information, help or advice as appropriate.  A judgement must be made about whether or not responding would help to resolve an issue, or simply create an online disagreement, which could escalate out of control.  Further advice in this respect is available from the Communications team.

Political Considerations

Council-administered accounts must remain apolitical in accordance with local government communications guidelines.

Council accounts must not use social media to endorse a political viewpoint – e.g. they must not re-tweet an Elected Member’s comment if such action could be interpreted as promoting a particular political viewpoint.  A Council account can however share a post by an Elected Member if it relate to apolitical information about a Council service.

Comments of a political nature are not permitted on Knowsley Council’s official social media profiles, as set out in the Social Media Terms and Conditions.  Politically motivated comments from users should be deleted.  This is particularly important during purdah periods in the run-up to elections, during which time Council resources must not be used to further or engage in any political debate.

Legal Considerations

Be mindful of your legal obligations.  As with emails, text messages and other forms of communications, you must comply with the GDPR and other associated legislation and policies.  Remember that social media and other electronic communication sites will retain copies of your posts/messages and that the storage of such information may not be compliant with GDPR.  You should seek advice from the Data Protection Officer if you are unsure.

Where a social media site permits such an approach, a link should be provided to users to the Council’s Social Media Terms and Conditions and to the Authority’s Privacy Policy for information on how private data is handled.

Children and Young People

If you are uploading photographs to support a post and these images include children, you must ensure that you have the appropriate permissions to do so.  Parental consent is required to use children’s images for publicity purposes.  The Communications team will provide a photography permission form which should be used to gain parental consent.  Further guidance on the use of images of children and young people is available from the Data Protection Officer.

Social Media and Covert Surveillance

Social media is a tool which can be used by staff carrying out investigations on behalf of the Council.  This can include matters relating to criminal, regulatory and personnel issues and can involve covert surveillance.

Staff should only carry out investigations of this nature where there is appropriate authorisation in place and after appropriate training has been given concerning the legal framework governing any such investigation.

Where staff are permitted to use social media to assist with investigations into the activities of any individual, they should follow the guidance outlined in the separate Social Media and Covert Surveillance Guidance and ensure that appropriate advice and permissions are sought in advance of any activities taking place.

Further Advice and Guidance

For clarification on anything contained within this Protocol, advice or any other information, contact the Communications Team on (0151)-443 3537 or via communications@knowsley.gov.uk.