Social Media and Media Policy
4 Media policy
4.2 Proactive media
4.3 Reactive media
4.4 Media statements and interviews
4.5 Media relations
4.6 Media spokespeople
4.8 Working in partnership
4.9 VIP visits
4.10 Supporting staff fundraising activity
4.11 Copy and sharing media coverage
4.12 Using and storing images of adults and children
5 Social media policy (personal use)
5.1 Personal use of social media
5.2 Security and privacy
5.4 Accessing social media during core hours
5.5 Monitoring social media use
6 Social media policy (professional use)
6.2 Social media management
6.3 Security and privacy
6.4 Out of hours monitoring
7 Crisis management and business continuity
9 Equality Impact Assessment
- 1. INTRODUCTION
All staff must be aware of how to access this policy either via the staff intranet (today@) or their line manager in the area they work. All staff need to be aware of their responsibilities regarding the media and social media policy.
This summary sheet highlights the key things you need to know:
Social media: personal use - responsibilities and confidentiality
Social media: professional use - responsibilities and confidentiality
Business continuity: management and information sharing
IT Usage Policy
Social media and media escalation processes
Group Business Continuity Plan
This policy adheres to professional best practice. It provides information and guidance to Progress Housing Group (the Group) employees, volunteers, interns, representatives including non-executive directors and agency staff in responding and working with the media and on the use of social media in a business or personal capacity.
This policy applies to the Group including Concert Living Limited, It also applies to volunteers who speak to the media or manage social media channels that directly represent the Group, for example, community pages and groups.
The media and social media policy aims to enable the Group’s staff and its representatives to:
- Understand their role and responsibilities when responding to media interest or using social media
- Convey information about the Group and its work to the media accurately and in the most appropriate way
- Be aware of the potential impact of their actions when using social networking sites or any other new media in a professional or personal capacity
- Achieve fair and balanced media coverage
- Help raise the profile of the Group and the high-quality services it provides
- Promote the positive achievements and successes of the Group
- Put difficult or complex issues in context
- Respond to incidents or emergencies to inform customers, staff, stakeholders and the public and to maintain or restore public confidence in the Group and its services.
- 2. SCOPE OF THE POLICY
This policy applies to the Group’s employees, volunteers, interns, representatives including non-executive directors and agency staff in responding and working with the media and on the use of social media in a business or personal capacity.
- 3. RESPONSIBILITY
All staff, volunteers, agency staff, interns and non-executive directors must adhere to this policy. It is the responsibility of the individual to ensure that they understand it and managers at all levels are responsible for ensuring that the staff for whom they are responsible are aware of and adhere to this policy.
Breach of this policy may result in disciplinary action up to and including dismissal. Any member of staff suspected of violating this policy will be required to co-operate with our investigation, which may involve handing over relevant passwords and login details.
You may be required to remove any social media content that we consider to constitute a breach of this policy. Failure to comply with such a request may in itself result in disciplinary action.
- 4. POLICY
News media is available through digital, broadcast and print platforms. Each channel has the power to influence and offer an opportunity to raise awareness of the organisation, its successes and achievements.
Journalists and editors have to make judgements about what is in the public interest, based on the information available to them, their editorial policy and their target audience. They have the right to make those judgements within the bounds of the law. We should, therefore, consider the media both as a channel to get our information across to the general public and also as an important target audience in their own right.
4.2 Proactive media
The Group is a regulated organisation and is accountable to its tenants and regulators. We are expected to be open and transparent in our dealings with those who use our services. Proactive media relations are part of that openness and transparency.
The Group Marketing and Communications Team maintains relationships with mainstream and specialist media, both local and national. It will seek opportunities to place stories of interest about the Group, its people and the high-quality services it provides. All members of staff are encouraged to contact the team with suggestions for stories or features items.
4.3 Reactive media
The media approaches the Group for comment on a range of topics. Sometimes their interest has been triggered by a tenant who has approached the media directly with a complaint. Other times the media may be seeking a response to a national issue or something that has happened locally – for example, an incident in one of our properties or a response to a change in national housing policy.
All media enquiries are initially dealt with by the Group Marketing and Communications Team. Any member of staff who becomes aware of a situation that might attract media interest must let the Group Marketing and Communications Team know immediately and share all relevant information.
The information will not be released in its entirety to the media however the Group Marketing and Communications Team must be aware of all the details to ensure that any statement issued is informed by the full details, counteracts further enquiries and clarifies any potential misunderstanding.
Any member of staff approached by the media directly should take contact details, assure the journalist that they will receive a call back within the hour, and alert the Group Marketing and Communications Team immediately. Under no circumstances, should a member of staff make a statement or comment to the media or divulge any details.
4.4 Media statements/interviews/releases/recordings
All media statements and releases are approved by the Group Chief Executive or a member of the Senior Management Team or their nominated deputy.
Only staff requested or authorised by the Group Marketing and Communications Team and/or member of the Senior Management Team are permitted to talk to the media, take part in media interviews, contribute to a media statement, or issue a news release.
All communication with the media should be reviewed by the Group Marketing and Communications Team, who will then coordinate the approval process with the Senior Management Team.
The Group Marketing and Communications Team will control the distribution of any release or statement to media contacts to ensure consistency and to avoid any conflict in messaging.
Any approaches by video production, radio or television companies to film or record in our properties, facilities or film/record staff must be referred to the Group Marketing and Communications Team. The team will escalate to the Group Chief Executive or a member of the Senior Management Team or their nominated deputy for authorisation. The Group Marketing and Communications Team will oversee any recording or filming.
Any recordings must not compromise the safeguarding of all adults and children, the privacy and dignity of customers, tenants, families and staff, or have a detrimental effect on the delivery of services.
Any external production crew or photographer will be accompanied and chaperoned at all times by a member of the Group Marketing and Communications Team. Members of the crew must never be left alone unsupervised with a customer or tenant, whether the customer or tenant is a child or an adult.
4.5 Media relations
All calls from the media must be handled in a professional, consistent and appropriate way. The Group Marketing and Communications Team should be alerted to any media interest and will manage all media enquiries and deadlines.
If a member of staff receives an unplanned call from a journalist, they should:
- Not provide a comment or statement
- Take a note of the journalist’s name and phone number
- Confirm that someone will phone them back promptly
- Contact the Group Marketing and Communications team immediately and share the details.
Occasionally, when responding to media enquiries, there may be times when it is not appropriate for the Group to provide information. Reasons for declining to give a statement or a request for a spokesperson for interview include:
- To maintain tenant, customer or staff confidentiality
- Information is being prepared for publication at a later date (for example a strategic document or the report of an inquiry)
- Taking part will impact adversely on the reputation of the organisation.
4.6 Media spokespeople
The Group aims to be open and transparent, and all communication with the media must be managed so that customers, staff and the Group are protected as much as possible from adverse media attention.
The Group Marketing and Communications Team in consultation with the Chief Executive and Senior Management Team will agree individual spokespeople in response to requests for interview. Only these agreed spokespeople are authorised to speak to the media on behalf of the Group. If other members of staff wish to talk to the media, they must contact the Group Marketing and Communications Team in the first instance.
Any staff member who is considered to have potentially threatened the reputation of the organisation or who provides inaccurate information is in breach of Group guidelines and may be subject to disciplinary proceedings. To ensure this does not happen, the Group Marketing and Communications Team must always be informed and involved before any contact is made with the media.
The Group Marketing and Communications Team will provide clear guidance and support to any staff member authorised to speak to the media.
We recognise that staff have other roles in their private or public life that may require them to provide media statements eg a local councillor or campaigner. However, as an employee or representative of the Group, we would request that you contact the Group Marketing and Communications Team or a member of the Senior Management if there is a potential conflict of interest or the contact or activity might bring the group into disrepute.
Under normal circumstances, there will be no basis for disclosure of confidential and identifiable information to the media. However, there will be occasions when the Group and its staff are asked for information by the media about individual customers, in response to particular circumstances where it is felt that disclosure, with the customer’s’ consent, is justifiable.
There may be some occasions when disclosure without the customer’s consent may be permitted with the authority of the Chief Executive or member of the Senior Management Team who may need to seek legal advice or review with the DPO.
- Requests for updates on the circumstances of particular tenants or customers who are consenting to information being given
- In distressing circumstances, e.g. following a fire or serious crime when the tenant or customer is known to be a customer of the group; their identity is already known to the public and where consent has been obtained
- Circumstances of significant public interest laid down by law, i.e. health and safety
- Vital interest – to protect the life or prevent harm to an individual(s).
Disclosing Special Category information or criminal conviction information needs to be of significant public interest, including public health, vital interest (protection of life) or explicit consent.
Only the Group Marketing and Communications Team are permitted to respond to such requests from journalists, and this will be done in agreement with the Chief Executive or a member of the Senior Management Team.
The explicit consent of the individual tenant or customer(s) concerned should be sought before disclosing any information about their circumstances, including their relationship to the Group. Where a customer or tenant is not competent to make a decision about disclosure, the views of family members should be sought and decisions made in the customer or tenant's best interests.
In circumstances where a customer or a customer’s relatives are complaining publicly and unfairly about the services provided and if they have put confidential information in the public domain, and thus it has lost the element of confidentiality, then a response from the organisation might be justified. For example, to correct wrong information and to ensure that the Group is not unfairly and publicly maligned.
However, disclosures need to be justified on a case by case basis. Disclosure should be legal, fair and proportionate and information should only be permitted to be disclosed by an authorising manager after discussion with the Chief Executive or appropriate member of the Senior Management Team who may need to seek legal advice.
4.8 Working in partnership
The Group Marketing and Communications Team works in partnership with other service providers and with other organisations eg charities to provide content and comment for news releases and media enquiries.
No member of staff should agree to liaise with the media or provide quotes, comments or endorsements through another organisation that will be used in a media statement or media campaign without first contacting the Group Marketing and Communications Team.
The Group will work with partner organisations to develop a shared, corporate and cohesive approach and response to media enquiries to ensure responses are consistent and unified to ensure public confidence in its services and the wider sector. For long-term or commercial partnerships, appropriate contractual terms should be agreed to define relationship scope.
The Group will not make public statements that might undermine public confidence in itself or, by implication, in partner organisations or the sector as a whole.
The Group’s and its subsidiary brands (including logos/testimonials) should not be used to endorse another organisation or business without first contacting the Group Marketing and Communications Team.
4.9 VIP visits
Occasionally, the Group will be asked if a high‐profile representative can visit our services and meet customers and tenants. Although rare, these visits can play a significant role in enhancing the customer experience and motivating our staff.
Although we will aim to accommodate these visits wherever possible, it must not compromise the safeguarding of all adults and children, the privacy and dignity of customers, tenants, families and staff, or have a detrimental effect on the delivery of services.
All requests for visits to Group properties, schemes or individual customers must be made through the Group Marketing and Communications Team. If an individual or team is approached privately by a VIP, the visit must be approved by and organised through, the Group Marketing and Communications Team in coordination with the Senior Management Team.
The Group Marketing and Communications Team will oversee visits and, if appropriate, enable the media to attend. This could include TV, radio and print media.
All visitors will be accompanied and chaperoned at all times by a member of the Group Marketing and Communications Team, a member of the Senior Management Team and a Head of Service or their deputy. Visitors must never be left alone unsupervised with a customer or tenant, whether the customer or tenant is a child or an adult.
A non-disclosure agreement must be completed in advance of the visit to ensure security of data.
All efforts should be made to ensure data is protected such as clear desks, computer screen access, confidential conversations and visibility.
All scheduled visitors will be met at the main reception or an agreed location and escorted to the pre-arranged venue where the visit will take place.
4.10 Fundraising – using Group social channels to promote events/tagging businesses
The Group supports and encourages fundraising and voluntary efforts by staff and will support them where appropriate with media, social media activity, internal communications, and where applicable, promotional items.
Staff can apply for donations and sponsorship through the charity fund. Refer to the Group’s Volunteering and Fundraising policies for guidance.
Donation pages and endorsed content
Unless the Group is formally sponsoring, organising or otherwise supporting an event in a corporate capacity, the promotion of links on Group-owned digital platforms to personal donation pages or the creation of content (including promotional items) that implies Group endorsement is prohibited. Staff are welcome to use the intranet boards, newsfeed and notice boards to promote any charitable activity.
Where several colleagues undertake a fundraising activity, it must be explicit in any communications that the Group is not the organiser.
In the event a partnering organisation or supplier offers sponsorship or a donation, the Group Marketing and Communications should be contacted in the first instance for guidance. This is to ensure there is no conflict of interest or endorsement of commercial activity.
Suppliers and partners of the Group
Staff should not approach suppliers and partners of the Group to support personal fundraising activities.
Donations to, or sponsorship of, the Group or its activities by suppliers and partners are permitted but must be discussed in advance with the Governance Team to avoid a conflict of interest or endorsement of commercial products and services.
4.11 Copying and sharing media content
Under no circumstances should you make copies, digitally or otherwise, of media coverage including headlines, body text and images. To do so is a breach of copyright and could lead the Group to being fined. To be explicit, this includes photocopying, photographing, scanning, copying and pasting any coverage published on media websites, social media or print publications. Further guidance is available on the intranet. Search: NLA guidelines.
4.12 Using and storing images of adults and children
Using images or footage of ‘real’ staff or customers help us to create an authentic brand and tell our story effectively. However, in order to meet our data protection obligations, you must ensure that you have the explicit and demonstrable consent of the subject of the image or footage before using it in any external communication whether this be printed or digital communications, on social media, case studies, tender documents or on the website.
Safeguarding measures should be maintained when using images of customers and staff and in particularly, there are stringent guidelines around photographing or filming children and vulnerable adults. This also applies to storing images and footage.
There are best practice guidelines available on the intranet.
The Group encourages teams to enter industry-recognised awards. The Group’s awards schedule is planned a year in advance with the agreement of the Senior Management Team to ensure adequate resource and budget is in place. It is requested that you advise the Group Marketing and Communications Team at budget setting if you intend to enter an award.
You must gain prior approval from a member of the Senior Management Team prior to writing and submitting an entry.
Completed entries should be reviewed and submitted to the awards body by the Group Marketing and Communications Team and not by individual teams.
- 5. Social media – personal use
Social media is a powerful tool and is an important way for people to share opinions, information and knowledge. It also offers everyone the opportunity to be a ‘journalist’, and say anything to a public audience. Often these authors are offering only their personal views without any research or right to reply.
This policy covers all current and future social media platforms, including review and blogging sites.
This policy aims to make sure that we are all using social media to enhance and protect the reputation of the Group online, and to make sure we are adopting a best-practice approach to social media. It is also to protect you from any consequences of social media activity that may inadvertently bring the Group into disrepute.
5.1. Personal use of social media – supporting the Group’s social media activity
Social media is an essential way we spread the word about our work – and we value every retweet, like and share in support of our activities. We know many of our staff are on social media and often get behind our posts, and we appreciate it. If you have an event or news item that you would like to share on the Group’s channels, contact the Group Marketing and Communications Team.
The Group’s social accounts are:
- Google Business
Other prominent teams/services and subsidiaries also have their own social media channels.
A full list of our social media accounts is available on the intranet.
5.2 Security and privacy
It is essential that the potential impact of posting content on social media, both in a personal and professional capacity, is always taken into consideration. Information shared on social media is in the public domain, and this activity may result in your comments being permanently available to customers, colleagues, the Group, future employers and/or open to being republished in other media.
Staff and representatives of the Group are encouraged to:
- Check their security/privacy settings on personal social networking sites to ensure that information is only visible to the people who they want to see it
- Not allow customers or colleagues to post any photographs or videos of them at work without their prior consent
- Avoid ‘friending or following’ customers and maintain a professional distance
- Understand the difference in public and private posting, and direct messaging.
5.3 Responsibilities when using social media in a personal capacity
The Group recognises that many staff members make use of social media in a personal capacity. While they are not acting on behalf of the organisation, staff must be aware that they can damage the organisation if they are recognised as being one
Staff should follow the same behavioural standards online as they would in their everyday roles and abide by their legal and ethical duties to protect customer and colleague confidentiality.
Staff who post comments or information online regarding the Group are personally responsible for their actions and the online content they have created.
No social media sites or pages relating to the Group or that might be considered and viewed as official Group corporate social media accounts should be set up by staff, volunteers or anyone working for the Group without prior discussion and agreement from the Group Marketing and Communications Team.
Members of staff and representatives of the Group should not disclose information, make commitments or engage in activities on behalf of the Group without the knowledge of the Group Marketing and Communications Manager and will require permission to do so
Staff and representatives of the Group using social media are reminded to:
- Comply with the law regarding libel; defamation; copyright; data protection and equality
- Not bring the organisation into disrepute and risk legal action against them and the Group, for example by criticising or arguing with customers, colleagues or rivals or making defamatory comments about individuals or other organisations or groups
- Not to post or share any personal identifiable information about customers or colleagues without their prior consent
- Not to post, tag or share images or videos of yourself or colleagues in situ at work or in your work uniform unless for legitimate group messages and with the consent from others featured in the image or video
- Give consideration to your surroundings and the prospect of any other visible people or data and in the circumstance of video, audible conversations. Due to the high quality of images, video and audio, it may inadvertently lead to the breach of personal, sensitive or corporate information
- Avoid making any social media activity that could damage the Group’s interests or reputation, even indirectly. You must not use social media to defame or disparage the Group, staff or any third party; to harass, bully or unlawfully discriminate against staff or third parties; to make false or misleading statements, or to impersonate colleagues or third parties
- Be mindful that the Group may be made aware of any views and opinions expressed online that are in conflict with the Group’s values or ways of working
- Not to express opinions or post on behalf of the Group or as a representative of the Group via social media, unless expressly authorised to do so by your line manager. You may be required to undergo training to obtain such authorisation.
- Not post comments about sensitive business-related topics, such as our performance, or do anything to jeopardise our trade secrets, confidential information and intellectual property. For the avoidance of doubt, confidential information includes (but is not limited to) information relating to the business, products, affairs and/or finances of the Group or any of its associated companies, clients, customers, agents, distributors or suppliers which is confidential to it or them or treated by it or them as being confidential (including, without limitation, market intelligence, processes, pricing policies, methods, inventions, technical data, software, password and security information and know-how)
- Not include the Group’s or subsidiary logos or other trademarks in any social media posting or in your profile on any social media
- Report any misuse of social media in a public arena which specifically mentions the Group or a colleague to your line manager
Please notify the Group Marketing and Communications Team if you become aware of any defamatory or potentially damaging content on social media or the wider internet. There is a social media and media escalation process available on the intranet.
Staff members should note that any breaches of this policy may lead to disciplinary action. Serious breaches of this policy, for example incidents of bullying of colleagues or social media activity that might cause serious damage to the organisation, may constitute gross misconduct and lead to summary dismissal.
5.4 Accessing social media during core hours
Unless agreed as part of your role or supported by your manager in relation to specific work related activities, use of social media on work and personal devices is discouraged during core working hours, and use should never interfere with employees' responsibilities. The Group's equipment and internet access are provided primarily for business purposes. Excessive use of social media in core hours on the Group's devices, computers or personal devices which impacts negatively on individual or team productivity may result in disciplinary action.
5.5 Monitoring personal social media use
As per the Group’s IT policy, we reserve the right to monitor, intercept and review, without further notice, staff activities using our IT resources and communications systems. This includes but is not limited to social media postings and activities, to ensure that the Group’s rules are being complied with and for legitimate business purposes and you consent to such monitoring by your use of such resources and systems.
- 6. Social media – representing the Group in a professional capacity
Although Heads of Service for our subsidiary brands manage the day-to-day social presence of their service area, the Group Marketing and Communications Team has overall responsibility for the strategy, programme, content, and tone of the Group’s corporate and subsidiary social media channels with the exception of private or direct messaging via social media, which is managed by trained staff in the relevant teams.
6.2 Social media management
Staff using or who intend to use the Group and its subsidiary social media accounts should, in the first instance approach the Group Marketing and Communications Team. The team will advise on the Group's social media guidelines and provide support and training if required. Social media activity for all the Group and its subsidiaries is managed centrally through the Group’s social media management platform to ensure governance, avoid conflicts in messaging, and brand compliance.
The Group’s brand guidelines and accessibility guidelines should be adhered to as the general code of conduct detailed in this policy when using social media. Guidelines are available on the intranet.
All approved accounts for Facebook must be managed through Facebook manager using an individual work email account. Personal or generic email addresses are prohibited as is using a personal email account to manage an approved Progress Housing Group page.
Twitter, LinkedIn, Google Business and YouTube
The Group’s main Twitter, LinkedIn, Google Business and YouTube accounts are managed by the Group Marketing and Communications Team; subsidiary Twitter, LinkedIn, Google Business and YouTube accounts are managed by Heads of Service or a nominated deputy under guidance from the Group Marketing and Communications Team.
Endorsed PHG Twitter accounts
Endorsed accounts for individuals and teams on Twitter are encouraged as they help us to grow our social profile, reach specialist areas, and create a human face for the organisation. Staff using or who intend to create an endorsed Twitter account should, in the first instance approach the Group Marketing and Communications Team.
Any endorsed accounts should clearly state that the account holder’s views are personal and not necessarily the views of Progress Housing Group.
New social media accounts
No social media channels, groups or pages on established or emerging social platforms relating to the Group or that might be considered and viewed as official the Group corporate or subsidiary social media accounts should be set up by staff, volunteers or anyone working for the Group without prior discussion and agreement from the Group Marketing and Communications Team. Please note, that there are specific issues relating to professional use of WhatsApp (business to customer) Contact the Group Marketing and Communications Team for further guidance.
Staff who are approved to manage a Group and/or subsidiary accounts must ensure that login credentials are not shared and are stored securely. Line managers have a responsibility to notify the Group Marketing and Communications Team if a member of staff leaves so that access can be removed and/or accounts linked to a work email are closed before the member of staff departs. Under no circumstances should credentials be shared with any individuals who are not directly employed by the Group.
6.4 Out of hours monitoring
The Group’s social media accounts are only monitored during office hours. In the event of a negative social media post, this will be responded to as a priority on the next working day.
For an out of hours crisis or incident which could bring the Group into disrepute or creates a serious safeguarding or safety issue, please refer to point 7.
7 Crisis management, reputational risk and business continuity
Almost any major incident will usually generate media interest and comment on social media.
Comment and details about a major incident may be shared on social media often within just a few minutes of a situation happening although the details shared will be unverified it may initially be the only source of information for the media, customers and tenants.
Digital and broadcast media are sometimes the only source of information for the public in an emergency; it is vital to ensure they have accurate, timely information.
Media liaison will be co-ordinated through the Group’s Incident Management Team as part of the Business Continuity Plan. Usually, in a major incident, statements and interviews will be given by the Chief Executive and members of the Senior Management Team supported by senior colleagues and advised by the Group Marketing and Communications Team. This process is to protect the brand, limit reputational damage and the spread of misinformation and ensure that the media has access to accurate and safe content.
The Group Marketing and Communications Team will manage messaging on social media and websites. In the event of a major out of hour’s incident, the Group’s IT service desk will update and manage digital channels under the direction of the Group’s Incident Management Team and/or Senior Management Team.
During such times the Group will be as open and helpful as is possible and is practical in the circumstances. We will seek to explain the situation, describe the impact (if any) on services, customers and staff and set out what action is being taken to resolve any outstanding issues.
Each critical service area must have a crisis communications plan in place as part of their overall Business Continuity Plan. These should be developed with, and approved by, the Group Marketing and Communications Team and Incident Management Team.
Out of hours, the Group’s Incident Management Team can be reached by contacting the Control Centre on 03333 204555.
The Group’s social media and media escalation process is available on the intranet.
This policy and guidance is available on the intranet and training sessions are available on request.
The Operations Director for Digital Services is responsible for infrastructure, implementation, monitoring and review of this document.
The Operations Director for Digital Services is responsible for ensuring that the policy is approved, that it is in line with the Group Policies and includes amendments and strict document control.
Contacting the Group Marketing and Communications Team
The Group Marketing and Communications Team can be contacted during office hours Monday – Friday on 03333 204555 or firstname.lastname@example.org
Outside these times, please contact the Control Centre on 03333 204555 who will, in turn, contact a member of the Senior Management Team, the Group’s Incident Management Team or Group Marketing and Communications Team as required.
11 EQUALITY IMPACT ASSESSMENT
This document demonstrates commitment to create a positive culture of respect for all individuals, including staff, customers, as well as community partners. The intention is, as required by the Equality Act 2010, to identify, remove or minimise discriminatory practice in the nine named protected characteristics of age, disability, sex, gender reassignment, pregnancy and maternity; race; sexual orientation; religion or belief; marriage and civil partnership.
It is also intended to use the Human Rights Act 1998 to promote positive practice and value the diversity of all individuals and communities. This document is available in different languages and formats upon request.
An Equality and Impact Assessment has been undertaken as part of the general Media Relations Policy.